1. Introduction

holdpay ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our peer-to-peer payment platform. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us, including:

Name and email address
Phone number (optional)
Payment information (processed securely through Stripe)
Bank account details for payouts (stored securely with Stripe)

2.2 Transaction Information

We collect details about the transactions you make through our platform:

Hold details (amount, title, description)
Transaction status and timeline
Ratings and reviews

2.3 Automatically Collected Information

Device information and IP address
Browser type and version
Usage data and analytics

2.4 Agent API Data

When interacting with our Agent API, we collect:

Agent identifiers (ERC-8004 token IDs)
API request logs and IP addresses
Webhook delivery logs
On-chain wallet addresses associated with agents
Trust tier and reputation data fetched from on-chain sources

3. How We Use Your Information

We use the information we collect to:

Provide, maintain, and improve our payment services
Process transactions and send related notifications
Verify your identity and prevent fraud
Respond to your requests and provide customer support
Send you technical notices and security alerts
Comply with legal obligations and enforce our terms

4. Information Sharing

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

4.1 Service Providers

Stripe: Payment processing and payout services
Hosting providers: Application and database hosting
Email services: Transaction notifications

4.2 Transaction Parties

Limited information is shared between buyers and sellers to facilitate transactions:

Name and user ID
Transaction details
Ratings (after transaction completion)

4.3 Legal Requirements

We may disclose your information if required by law or to protect our rights and safety.

5. Data Security

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

Encryption in transit (TLS) and at rest
Secure authentication protocols
PCI DSS-compliant payment processing through Stripe
Regular security reviews

No method of electronic transmission or storage is completely secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security against all threats.

6. Your Rights

You have the right to:

Access and receive a copy of your personal data
Correct inaccurate or incomplete information
Request deletion of your account and data
Object to or restrict certain processing activities
Data portability

To exercise these rights, please contact us at privacy@holdpay.me

7. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations. Transaction records are kept for 7 years for financial compliance purposes.

8. International Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers.

9. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date.

11. Australian Privacy Law

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). If you believe we have breached your privacy rights, you may lodge a complaint with us. If you are unsatisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

12. Contact Us

If you have questions about this Privacy Policy, please contact us:

Email: privacy@holdpay.me
Address: Perth, Australia