Privacy Policy

Last updated: March 12, 2025

You must be at least 18 years old to use exchangeflo.io (the “Site,” “ExchangeFlo,” “Us,” and/or “We”). ExchangeFlo LLC, its parent, subsidiary, and affiliated companies, and each of their respective officers, directors, members, owners, employees, agents, and representatives are incorporated into and included in any reference to the Site, “ExchangeFlo”, “Us”, “Our”, and/or “We” herein.

We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why We collect, store, use, and share your personal information when you use the Site and/or the ExchangeFlo portal platform on the Site (the “ExchangeFlo Portal”) and/or the services made available through the ExchangeFlo Portal (collectively, the “ExchangeFlo Services”). This Privacy Policy also explains your rights in relation to your personal information and how to contact Us.

Your use of the Site is governed by Our Terms. By accessing, using, and/or submitting information to the Site, you agree to this Privacy Policy and to Our Terms. Your use of the ExchangeFlo Portal and the ExchangeFlo Services are further governed by the Terms of Service.

1. Contact Information

If you have any questions or concerns regarding your privacy rights or Our Privacy Policy or practices, you may contact Us at info@exchangeflo.io.

2. Personal Information We Collect About You

We collect the personal information directly from you via the Site and/or the ExchangeFlo Portal (and/or in connection with the ExchangeFlo Services), and from your interactions with the Site and/or the ExchangeFlo Portal (and/or in connection with the ExchangeFlo Services), including any personal information which you provide to Us directly or indirectly.

  • Directly from you; We collect any personal information which you submit directly to the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services.
    • To the extent that you register for an account on the ExchangeFlo Portal, We collect information the following personal information which you provide on Our registration form: your email address.
    • To the extent that you contact Us or request customer support, We collect the personal information that you submit, including your name and email address.
    • To the extent that you provide your details to receive payments earned through the ExchangeFlo Services, We collect your payment account information.
    • If you choose to sign in to our application using Google OAuth, we collect certain information from your Google account as permitted by your Google account settings.

3. How We Use Collected Personal Information

Providing the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services: We use the personal information We gather on the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services to allow individuals to access and interact with the Site and/or the ExchangeFlo Portal and/or to use the ExchangeFlo Services. We permit third party advertisers/buyers to submit content, and create and manage their advertising campaigns on the ExchangeFlo Portal. We make these such advertising campaigns accessible to publishers through the ExchangeFlo Portal. We use the information collected through the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services to track your access and interaction with the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services. We also use the information collected through the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services to track and report the performance of the third party advertising campaigns made available through the ExchangeFlo Portal and/or the ExchangeFlo Services, including leads, clicks, and calls. As noted below, tracking performance of third party advertising campaigns requires the sharing of personal information with our third party advertisers/buyers and publishers, including leads, clicks, and calls generated from the performance of the third party advertising campaigns. Personal information is used to calculate payments earned through the third party advertising campaigns and to process and initiate payments earned through the ExchangeFlo Services. We also use information collected through the Site to fulfill any requests which you submit to Us; to personalize and improve the Site and/or ExchangeFlo Portal and/or the ExchangeFlo Services and functionality of the same; for advertising/marketing purposes; to supplement Our internal database; to perform analytic and statistically analyze and monitor use of the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services; to improve the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services; to provide customer support; and to detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity; and to debug, to identify, perform diagnostics, and repair errors that affect functionality of the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services; and to process and make payments to Our users.

We may share the personal information collected through your use of the Site with Our third party advertisers/buyers and publishers. We and Our third party advertisers/buyers and publishers may collect and use personal information about you obtained through cookies and tracking pixels to track the performance of a particular advertising campaign made available through the ExchangeFlo Services. As noted above, in the event that your web browser requests that We do not track you or store a cookie, unless otherwise required by law to do so, We do not guarantee that We will honor such requests.

Information Collected From Third Parties: In addition to collecting personal information through the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services, We also collect personal information through third party advertisers/buyers and publishers. We may receive compensation from third party advertisers/buyers based on the performance of their advertising campaigns. Third party cookies and tracking pixels may also be used to track the performance (leads, clicks, calls) of such advertising campaigns. We and Our third party advertisers/buyers automatically collect information on an individual’s interaction with advertising campaigns. To the extent that an individual clicks on an exit listing or other advertising campaign made available through the ExchangeFlo Services, We and the applicable third party advertiser/buyer collects information on which link was clicked and whether any leads, clicks, and/or calls were generated.

4. With Whom Do We Share Your Information

We may share personal information in all of the above categories internally with any subsidiary and affiliated companies. We may also share personal information with Our third party advertisers/buyers, publishers, and third party service providers, including Our payment processor service provider. Sharing of personal information with Our third party advertisers/buyers and publishers is for the purpose of tracking the performance of the advertising campaigns offers made available through the ExchangeFlo Services (counting leads, clicks, and/or calls), and calculating payments earned through the ExchangeFlo Services.

Also, on occasion, We may be required by law enforcement or judicial authorities to provide personal information to the appropriate governmental authorities. In the event of a merger, acquisition, or sale of Our business, your personal information may also be transferred. In the event We become the subject of an insolvency proceeding, whether voluntary or involuntary, We or Our liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of, such personal information in a transaction approved by the court.

5. Transfer, Processing, and Storage of Information

Your personal information may be transferred to, processed, and stored outside of your state, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States, please note that the personal information We collect through the Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services may be processed in and outside of the United States. We will take all the steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and that no transfer takes place to an organization or a country unless there are adequate controls in place including the security of your data. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6. Security

The security of your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, We cannot guarantee its absolute security. As a result, you acknowledge that there are security and privacy limitations of the Internet which are beyond Our control; the security, integrity, and privacy of any and all information and data exchanged between you and Us through this Site and/or the ExchangeFlo Portal and/or the ExchangeFlo Services cannot be guaranteed; and any such information and data may be viewed or tampered with in transit by a third party. We make no warranty, express, implied, or otherwise, regarding the security of the Site, ExchangeFlo Portal, and/or the ExchangeFlo Services and your personal information.

7. Third Party Links and Offers

The Site, ExchangeFlo Portal, and the ExchangeFlo Services contain links to third party promotional offers and to their corresponding websites. We are not responsible for the privacy practices or the content of any such third parties. This Privacy Policy only addresses Our use and disclosure of information which We collect from you. Any third party websites which are accessible through Our Site, ExchangeFlo Portal, and the ExchangeFlo Services and the companies to whom your information is transferred, have their own privacy policies and data collection, use and disclosure practices. Please consult each third party website’s privacy policy. We are not responsible for the policies or practices of third parties or their sites. Additionally, third party advertisers and advertising network(s) may collect personal information about you when you share featured promotional offers, or when individual recipients interact with the shared promotional offers, through the use of cookies and tracking pixels. We cannot control this collection of such personal information. You should contact these third parties directly if you have any questions about their use of the personal information that they collect. Any sharing of offers through third party platforms shall be in compliance with such third party platforms’ terms of service.

8. Children

You must be an adult of 18 years or older to use the Site. We do not target the Site to children. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), We will never knowingly collect personal information from anyone under the age of 13 without requesting parental consent. If you are aware that your minor child under the age of 13 has provided Us with personal information, please contact Us.

9. Google User Data Retention and Deletion

When you sign in to our application using Google OAuth, we collect and store certain information from your Google account as described in the “Information We Collect” section of this privacy policy. This section outlines how we handle the retention and deletion of Google user data.

Data Retention:

  • Active Accounts: For users with active accounts, we retain Google user data for the duration that your account remains active on our platform.
  • Inactive Accounts: For accounts that have been inactive for more than 12 consecutive months, we may delete the associated Google user data or convert it to an anonymized form.

Data Deletion: You have the following options to request deletion of your Google user data:

  • Account Settings: You can remove Google account access and delete associated data through your account settings on our platform.
  • Direct Request: You can submit a request for deletion of your Google user data by contacting us at info@exchangeflo.io.
  • Account Deletion: If you choose to delete your entire account with us, all Google user data will be deleted within 30 days of account termination.

Data Deletion Process: Upon receiving a deletion request, we will:

  1. Verify your identity to ensure the security of the deletion process.
  2. Delete your Google user data from our active systems within 30 days.
  3. Remove your Google user data from our backups within 90 days after deletion from active systems.
  4. Provide confirmation once the deletion process is complete.

Note that certain information may be retained as required by law or for legitimate business purposes, such as fraud prevention, as outlined in the general data retention section of this privacy policy.

Google API Services User Data Policy: Our application adheres to the Google API Services User Data Policy, including the Limited Use requirements.

10. Changes

This Privacy Policy was published and last updated as of the date noted above. We may update this Privacy Policy from time to time by updating this posting. Changes to this Privacy Policy are effective when they are posted. You acknowledge and agree that it is your responsibility to review this Site and this Privacy Policy periodically and to be aware of any modifications. Your use of the Site after such modifications will constitute your acknowledgment of the modified Privacy Policy; and agreement to abide and be bound by the modified Privacy Policy.

11. Do You Need Extra Help?

If you have a disability which interferes with your ability to access this Privacy Policy, We can make accommodations to present the policy in an alternative format to assist you. If you would like to receive this Privacy Policy in another format that is accessible to your needs (for example: audio, large print, etc.) please contact Us.