1. Introduction and Scope

This Privacy Policy describes how Ernesto Pay LLC ("Ernesto Pay," "we," "us") collects, uses, shares, and protects the information of Workers and Clients who use the Platform. By using Ernesto Pay, you agree to the practices described in this document, together with our Terms of Service.

This policy applies to the ernestopay.com website, public Worker profiles, and any interaction with our services. It does not apply to third-party sites or services linked from the Platform, including Stripe, whose own privacy policy governs the data it processes directly.

2. What Information We Collect

2.1 Information Ernesto Pay Collects Directly

Category	Specific Data	From Whom
Identity and profile	Name, photo, occupation, city, workplace (optional)	Worker
Professional profile (optional)	Biography, specialties, years of experience, languages spoken, certifications (name and year)	Worker
Public contact details (optional)	Phone and contact email, only if the Worker expressly turns on their publication	Worker
Account	Email, password (or authentication credentials), preferred language	Worker
Platform usage	Public profile visit history, QR/link interactions, device and browser metadata	Worker and Client
Website usage analytics	Recording of browsing on the public website (pages viewed, clicks, scrolling), IP address, and device and browser metadata, collected through Microsoft Clarity. Does not apply to the Worker app	Any visitor to the public website
Communications	Support messages, contact emails, survey responses	Worker and Client
Transactions (metadata, non-financial)	Recognition amount, date, Client's name (if voluntarily provided)	Client, visible on Worker dashboard
Ratings	A 1-to-5 star rating tied to a confirmed Recognition. No free-text comments	Client, anonymously
Consent records	Type and version of the document accepted, date and time, language, IP address, session identifier	Worker

The professional profile and the public contact details are entirely optional: a Worker can use the Platform and receive Recognitions without providing them. Phone and contact email are not published by default; they are shown only if the Worker turns that option on, and it can be turned off at any time.

2.2 Information We Do NOT Collect — Processed Exclusively by Stripe

Ernesto Pay never receives, sees, or stores: Social Security Numbers (SSN) or EINs, full bank account or card numbers, identity verification (KYC) information, or any other sensitive financial data. All of this is collected and held directly by Stripe, Inc. during the Stripe Connect onboarding process, under Stripe's own Privacy Policy (available at stripe.com/privacy).

3. How We Use the Information

Operate and maintain the Worker's public profile and the Recognition flow.
Display to Clients who open the Worker's link or QR code the information on their profile, including any professional profile they have completed and the contact details they have chosen to publish.
Facilitate communication with Stripe for payment processing, identity verification, and tax compliance.
Send transactional notifications (confirmation of a Recognition received, notices relating to your account and to the legal documents you accepted).
Enable future search and discovery features. Ernesto Pay intends to develop features allowing Clients and businesses to search for and find Workers by criteria such as occupation, specialty, location, or language, using the professional profile information described in Section 2.1. This functionality is not currently available. We collect that information now so that we do not have to request it again later. When the functionality exists, you will be notified, and your profile appearing in search results will require you to expressly turn it on: it will not be enabled automatically.
Respond to support requests and resolve disputes or content reports.
Analyze aggregate Platform usage to improve the product (internal analytics, without sale to third parties).
Verify that the phone number the Worker chooses to publish belongs to them, by sending a code via SMS.
Process any subscription or paid plans Ernesto Pay may offer in the future, if the Worker chooses to purchase them.
Comply with legal obligations, including valid requests from competent authorities, and retain consent records as evidence of compliance.

4. Who We Share Information With

Recipient	What Ernesto Pay Shares	Purpose
Stripe, Inc.	Name, email, and the data the Worker enters directly in the Stripe Connect flow	Payment processing, identity verification, tax compliance
Infrastructure providers (hosting, database)	All data stored on the Platform, under confidentiality agreement	Technical operation of the service
Microsoft Corporation (Clarity)	Browsing recordings and usage metrics for the public website. Never data from the Worker app or from pages behind a login	Product analytics and heatmaps
Twilio Inc.	The Worker's phone number and the IP address from which they request verification. Only when the Worker asks to verify their number	Sending the verification code by SMS
Legal authorities	Specific information under valid legal request (subpoena, court order)	Legal compliance
Clients visiting the public profile	Worker's photo, name, occupation, city and workplace; any professional profile they have completed; their average rating and number of Recognitions received; and their phone or email only if the Worker turned on publication	Core function of the Platform

The public profile is accessible without creating an account: anyone with the Worker's link or QR code can view it. This is intentional — it is what allows Recognitions to be received without friction — and it is why phone and email remain off unless expressly turned on.

Ernesto Pay does not sell personal information to third parties for advertising purposes.

With one exception worth stating plainly: Microsoft, the provider of the Clarity analytics tool, may use the data it collects on our public website for its own purposes, under its terms of service. Under the CPRA, that processing may constitute "sharing." It is limited to the public website; the Worker app sends no data to Microsoft. See Section 7.

5. Data Retention

We retain Worker information for as long as their account remains active, and for a reasonable additional period after deactivation to comply with legal, tax, and dispute-resolution obligations (generally up to 7 years for transaction-related records, consistent with standard tax retention practices). Workers may request early deletion of data not subject to mandatory legal retention.

Exception — consent records. The record of accepted legal consents (document type, version, date, language, and technical identifiers of the acceptance) is retained indefinitely, including after account deletion, as it is the evidence that the Worker accepted each document at the time. If account deletion is requested, that record may be anonymized, but it is not deleted.

6. Your Rights Over Your Data

Depending on your state of residence, you may have the right to:

Access the personal information we hold about you.
Request correction of inaccurate information.
Request deletion of your personal information, subject to legal retention obligations.
Opt out of the "sale" or "sharing" of personal information (Ernesto Pay does not sell data, so this right does not currently apply in practice).
Request a portable copy of your information in a structured format.

In addition, you may at any time turn off publication of your phone number and contact email, and delete your professional profile information, from your account settings.

To exercise any of these rights, contact legal@ernestopay.com

7. Specific Notice for California Residents (CCPA/CPRA)

If you reside in California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you additional rights over your personal information, including the right to know what categories of information we collect (detailed in Section 2), the right to request deletion, and the right not to face discrimination for exercising your privacy rights.

Categories of information collected from California residents in the past 12 months:

Identifiers: name, email, phone number (if the Worker provides one).
Commercial information: history of Recognitions received.
Approximate geographic information: city and workplace.
Professional or employment-related information: occupation, specialties, years of experience, languages, certifications.
Internet activity information: public profile visits, QR or link interactions, device and browser metadata, and recordings of browsing on the public website collected through Microsoft Clarity.
Inferences: Ernesto Pay does not build inferred profiles about identified individuals. The public website analytics tool analyzes browsing behavior in aggregate and not linked to an identity.

Ernesto Pay does not sell personal information.

⚠️ It does use a third-party analytics tool (Microsoft Clarity) on its public website. Because the provider may use that data for its own purposes, this processing may constitute "sharing" under the CPRA definition. It is limited to the public website and does not reach the Worker app or any page behind a login.

You may opt out by writing to legal@ernestopay.com, and also by enabling the Global Privacy Control (GPC) signal in your browser, which we honor.

8. Information Security

We implement reasonable technical and organizational measures to protect personal information against unauthorized access, loss, or alteration, including encryption in transit and access controls. However, no system is completely secure, and Ernesto Pay cannot guarantee the absolute security of information transmitted over the internet.

9. Children's Privacy

The Platform is not directed to individuals under 18 years of age, and we do not knowingly collect personal information from minors. If we become aware that a minor has provided personal information, we will remove it from our systems.

10. Cookies and Similar Technologies

Ernesto Pay may use cookies and similar technologies to maintain the user's session, remember language preferences, and analyze aggregate Platform usage. Users may configure their browser to reject cookies, although this may affect Platform functionality.

The public website additionally uses Microsoft Clarity, which sets Microsoft’s own cookies to distinguish sessions and generate heatmaps and browsing recordings. The Worker app does not use these cookies and sends no data to Microsoft.

11. Consent to Electronic Communications (E-SIGN Act)

By accepting this Privacy Policy and the Terms of Service, the Worker expressly consents to receive disclosures, notifications, and documents (including payment confirmations and related tax documents) electronically, rather than on paper, in accordance with the Electronic Signatures in Global and National Commerce Act (E-SIGN Act).

12. International Transfers

Information is processed and stored primarily on servers located in the United States. If you access the Platform from outside the U.S., your information will be transferred to the United States for processing in accordance with this policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified at least 15 days in advance by email or via an in-Platform notification. Continued use after the effective date constitutes acceptance of the updated policy.

14. Contact

For questions about this Privacy Policy or to exercise your data rights, contact: legal@ernestopay.com