Privacy Policy

1. Introduction

Trebanx ("we," "us," or "our") operates a technology platform that enables member-to-member lending through group savings circles. This Privacy Policy applies to all users of our Platform.

By using the Platform, you consent to the collection and use of your information as described in this Policy. If you do not agree, please do not use the Platform.

2. Information We Collect

Information You Provide

• Account Information: Name, email address, phone number, date of birth, and password
• Identity Verification: Government-issued ID, Social Security Number (last 4 digits or full), address, and selfie photos for KYC compliance
• Financial Information: Bank account details, transaction history within the Platform
• Circle Information: Circle membership, contributions, loans, and repayments
• Communications: Messages you send to us or other users through the Platform

Information Collected Automatically

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, time spent, click patterns
• Location Data: General location based on IP address (we do not collect precise GPS data)
• Cookies: Session data, preferences, and analytics (see Section 8)

Information from Third Parties

• Identity verification services (for KYC/AML compliance)
• Banking partners and payment processors (Stripe)
• Credit reporting agencies (if applicable)
• Public databases and government records

3. How We Use Your Information

We use your information to:

• Provide, maintain, and improve the Platform
• Verify your identity and prevent fraud
• Process transactions and manage Circle activities
• Communicate with you about your account and services
• Comply with legal and regulatory requirements (KYC, AML, tax reporting)
• Enforce our Terms of Service and protect users
• Analyze usage patterns to improve user experience
• Send promotional communications (with your consent)
• Respond to your inquiries and support requests

4. Information Sharing

We do not sell your personal information. We may share your information with:

• Circle Members: Limited information necessary for Circle operations (name, contribution status, loan details)
• Service Providers: Companies that help us operate the Platform (payment processing, hosting, analytics, identity verification)
• Banking Partners: Regulated financial institutions that provide banking services
• Legal Requirements: When required by law, court order, or government request
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you explicitly authorize us to share

All service providers are contractually obligated to protect your information and use it only for the services they provide to us.

5. Data Security

We implement industry-standard security measures to protect your information:

• 256-bit TLS encryption for data in transit
• AES-256 encryption for data at rest
• PCI DSS Level 1 compliant payment processing (via Stripe)
• Multi-factor authentication options
• Regular security audits and penetration testing
• Employee access controls and training
• Real-time transaction monitoring

While we strive to protect your information, no method of transmission or storage is 100% secure. You are responsible for maintaining the security of your account credentials.

6. Data Retention

We retain your information for as long as necessary to:

• Provide services to you
• Comply with legal obligations (tax records, AML requirements)
• Resolve disputes and enforce agreements

After account closure, we may retain certain information for up to 7 years as required by law. Anonymous or aggregated data may be retained indefinitely for analytics purposes.

7. Your Rights & Choices

You have the right to:

• Access: Request a copy of your personal information
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Portability: Receive your data in a structured, machine-readable format
• Opt-out: Unsubscribe from marketing communications
• Restrict Processing: Limit how we use your information in certain circumstances

To exercise these rights, contact us at privacy@trebanx.com. We will respond within 30 days.

8. Cookies & Tracking

We use cookies and similar technologies for:

• Essential Cookies: Required for Platform functionality (session management, authentication)
• Analytics Cookies: Help us understand how users interact with the Platform
• Preference Cookies: Remember your settings and preferences

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality.

9. Third-Party Services

Our Platform integrates with third-party services that have their own privacy policies:

• Stripe: Payment processing (stripe.com/privacy)
• Banking Partners: See individual institution privacy policies
• Identity Verification: KYC service provider privacy policies apply

10. Children's Privacy

The Platform is not intended for users under 18 years of age. We do not knowingly collect information from children. If we learn that we have collected information from a child under 18, we will delete it promptly. If you believe a child has provided us with personal information, please contact us at privacy@trebanx.com.

11. International Transfers

Your information may be transferred to and processed in the United States, where data protection laws may differ from your country. By using the Platform, you consent to this transfer. We implement appropriate safeguards to protect your information in compliance with applicable laws.

12. California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, and shared
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising privacy rights

To exercise these rights, contact us at privacy@trebanx.com or call our privacy line.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through the Platform. The "Last Updated" date at the top indicates when the Policy was last revised. Your continued use of the Platform after changes become effective constitutes acceptance of the revised Policy.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us: