Effective Date: April 11, 2025

This Privacy Policy (the “Privacy Policy”) describes how and why CargoBill Inc. (“CargoBill,” “Provider,” “we,” “us,” or “our”) might collect, store, use, and/or share ("process") your (the “Customer,” “User,” “you,” “your”) information when you use our Services, including when you visit our Site at [cargobill.co], access and use our service/application for stablecoin payments and banking services located at our Site or via our APIs (the “Service”), or when you engage with us in other related ways, including sales, marketing, or support.

This Privacy Policy is incorporated by reference into the CargoBill Terms of Service (the "Agreement"). Please read this Privacy Policy and the Agreement carefully before accessing or using our Services. Capitalized terms not defined in the Privacy Policy shall have the meaning set forth in the Agreement.

We revise this Privacy Policy from time to time to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by emailing your User Account, or by posting notice of the change on our Site or Service, otherwise the revised Privacy Policy will be effective as of the published effective date.

OVERVIEW

CargoBill may collect your information when you access or use our Services. This information which may include Personal Information or Personal Data as defined under the applicable data protection laws, statistical data such as Aggregated and Anonymized Information, and in some jurisdictions Personal Data that is considered Sensitive information.

For our Services, we typically act as a “data controller” or “business” (the entity that determines the purposes and means of processing). In limited circumstances involving specific integrations or partner services, we might act as a “data processor” or “service provider” processing data on behalf of another entity.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

DEFINITIONS

• Personal Information or Personal Data: Defined by applicable data protection law, but generally means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular person or business entity. Personal Information does not include Aggregated or Anonymized Data.
• Aggregated and Anonymized Data: Information viewable only in summaries or groups, or information that can no longer reasonably be linked to a particular person, household, or entity. This is not Personal Information.
• Sensitive Information: A specific subset of Personal Information defined by jurisdiction. For CargoBill, this may include government-issued IDs, beneficial ownership information provided for compliance, financial information linked via partners, or account access credentials.

CATEGORIES OF PERSONAL DATA WE COLLECT

We may collect the following categories of Personal Information from you, including, but not limited to, from your interactions with us and use of the Site, Service or Services:

• Individual and Business Identifiers and Demographic Information: Name (personal and business), Business Address, Phone Number, Email, IP address, Device Information, Information collected from cookies or other tracking technologies, Cryptocurrency Wallet Addresses (yours and counterparties'), other information necessary to establish a User Account.
• Records and Financial Information: Bank account details (primarily accessed via On-Ramp/Off-Ramp partners), payment card info (if used for CargoBill fees), transaction details facilitated through our Services (instructions, linked identifiers like invoice numbers, transaction amounts, timestamps), publicly recorded blockchain transaction data (including TxIDs, sending/receiving addresses, amounts, gas fees, timestamps).
• Internet or Network Activity: Interactions with our Services (features used, pages viewed, clicks), response times, error data, usage session details, IP Address, Location data (general region/country), Browser Type/Version, Operating System, Referring Site/Search Engine, Device Type, Language preferences, information collected through Cookies.
• Sensory Information, such as Audio, Visual or other similar information: User Account profile pictures (if feature enabled); audio recordings of Customer Support calls for quality assurance/training purposes (with notice/consent where required).
• Professional or Employment Information: Job title, company name, contact emails/phones, Taxpayer ID numbers (business), Business Verification Data (e.g., company registration documents, articles of incorporation, beneficial ownership information).
• Information you provide when you contact us: Responses to surveys, recorded conversations/chat logs with support (with notice/consent where required), email correspondence, feedback provided.