TulayPay

Privacy Policy

Effective date: [to be set at launch] — DRAFT

Pre-launch notice: TulayPay is not yet available to the public. This policy describes, in advance, the privacy practices the TulayPay service will follow when it launches. Until launch, this website does not offer accounts or process transactions.

1. Who we are

TulayPay is a service of TULAYPAY LLC, a Michigan limited liability company based in Kalamazoo, Michigan, United States. We are building a service that will let people in the United States send money to recipients in the Philippines. In this policy, "TulayPay," "we," and "us" refer to TULAYPAY LLC.

2. Information we will collect

When the service launches, we expect to collect only the information needed to operate it:

3. Our partners hold and move the funds

TulayPay will operate a partner-led model. Licensed financial partners will hold customer funds, perform money transmission, carry out identity verification and anti-money-laundering checks, and complete payouts in the Philippines. To do this, we will share the information a transaction requires with the partner performing it. TulayPay itself is not a bank and will not hold customer funds.

4. How we will use information

5. We do not sell personal data

We will not sell your personal information. We will share information only with licensed partners as needed to process your transactions, with service providers who support our operations under contract, or where required by law, regulation, or legal process.

6. Cookies

This website may use cookies and similar technologies for basic functionality, security, and understanding how the site is used. You can control cookies through your browser settings. We do not use cookies to sell personal information.

7. Data security and retention

We will use reasonable administrative, technical, and physical safeguards designed to protect personal information. No system is completely secure, and we cannot guarantee absolute security. We will retain information only for as long as needed to provide the service and to meet legal and regulatory requirements, after which it will be deleted or anonymized.

8. Your rights and choices

You may contact us to request access to, correction of, or deletion of your personal information, subject to legal and regulatory retention requirements that may require us to keep certain records. We will respond to verified requests within a reasonable time. You may also opt out of marketing communications at any time.

9. Children

The service will be intended for adults. You must be at least 18 years old to use TulayPay. We will not knowingly collect information from anyone under 18.

10. Changes to this policy

We may update this policy before or after launch. Material changes will be posted on this page with a revised effective date.

11. Contact us

Questions about this policy, or requests about your information (including deletion), can be sent to andre@tulaypay.com or to the mailing address in the footer below.