REFERRAL PRO — PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy describes how Referral Pro LLC (“Referral Pro,” “we,” “our,” or “us”) collects, uses, discloses, and protects your personal information when you access or use our website, mobile application, and referral platform (collectively, the “Service”).

By using the Service, you consent to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Service.

This Privacy Policy is incorporated into and subject to our Terms and Conditions.

2. INFORMATION WE COLLECT

2.1 Personal Information You Provide

When you create an account or use the Service, we may collect:

• Name
• Email address
• Phone number
• Date of birth
• Username and password
• Profile information

2.2 Business Information

If you register as a Business User, we may collect:

• Legal business name
• Business address
• Business contact information
• Tax identification number (if required)
• Business licenses or documentation
• Business profile details

2.3 Referral and Transaction Data

• Referral submissions and history
• Referral confirmations and outcomes
• Points earned, redeemed, and balances
• Transaction and redemption records
• Dashboard analytics and metrics

2.4 Payment Information

• Referral Pro does not directly collect or store payment card numbers, bank account numbers, or other sensitive financial information.
• Payment data is collected and processed solely by our third-party payment processors (Stripe and PayPal).
• We may receive limited transaction confirmations (e.g., successful payment, last four digits of card) from processors.
• Tax information you provide to redeem rewards, such as an IRS Form W-9 or W-8 and your taxpayer identification number, and tax forms we issue to you (such as Form 1099) as described in our Terms and Conditions.

2.5 Technical and Device Information

We automatically collect:

• IP address
• Device type, model, and operating system
• Browser type and version
• Unique device identifiers
• Mobile network information
• Time zone and language settings

2.6 Usage Data

• Pages and features accessed
• Clickstream data and navigation paths
• Time spent on the Service
• Search queries within the Service
• Error logs and performance data

2.7 Cookies and Tracking Technologies

We use cookies, pixels, web beacons, and similar technologies to:

• Authenticate users and maintain sessions
• Remember preferences and settings
• Analyze Service performance and usage
• Deliver relevant content

See Section 10 (Cookies and Tracking Technologies) for more details.

2.8 Information from Third Parties

We may receive information from:

• Payment processors (transaction status)
• Analytics providers
• Business partners
• Publicly available sources

3. HOW WE COLLECT INFORMATION

We collect information through:

• Account registration and profile updates
• Your use of the Service
• Referral submissions and tracking
• Communications with Referral Pro (support requests, emails)
• Automatic collection via cookies and similar technologies
• Third-party integrations

4. HOW WE USE INFORMATION

We use the information we collect to:

4.1 Provide and Operate the Service

• Create and manage your account
• Process and track referrals
• Award and manage Points
• Process redemptions and payments
• Provide customer support

4.2 Improve and Develop the Service

• Analyze usage patterns and trends
• Identify and fix technical issues
• Develop new features and functionality
• Conduct research and analytics

4.3 Communications

• Send transactional notifications (referral confirmations, payments)
• Provide customer support responses
• Send service updates and announcements
• Send marketing communications (with your consent or as permitted by law)

4.4 Safety and Security

• Detect and prevent fraud, abuse, and policy violations
• Verify user identity
• Protect the security and integrity of the Service
• Enforce our Terms and Conditions

4.5 Legal Compliance

• Comply with applicable laws and regulations
• Respond to legal process and government requests
• Establish, exercise, or defend legal claims

5. HOW WE SHARE INFORMATION

Referral Pro does not sell your personal information. We may share your information with:

5.1 Businesses Receiving Referrals

• When you submit a referral, we share necessary information with the receiving business to facilitate the referral.

5.2 Payment Processors

• Stripe and PayPal process payments on our behalf and receive information necessary for payment processing.

5.3 Service Providers

• We engage third-party vendors to provide services such as:
  • Cloud hosting and data storage
  • Analytics and performance monitoring
  • Customer support tools
  • Email and communication services
• Service providers are contractually obligated to protect your information and use it only for the services they provide to us.

5.4 Legal and Safety Disclosures

We may disclose information if we believe it is necessary to:

• Comply with applicable laws, regulations, or legal process
• Respond to government or regulatory requests
• Protect the rights, property, or safety of Referral Pro, our Users, or others
• Detect, prevent, or address fraud, security, or technical issues
• Enforce our Terms and Conditions

5.5 Business Transfers

If Referral Pro is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

5.6 With Your Consent

We may share information with third parties when you direct us to do so or provide consent.

5.7 Aggregated or De-Identified Data

We may share aggregated or de-identified data that cannot reasonably be used to identify you for any purpose.

6. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

6.1 Right to Know

You have the right to request information about:

• The categories of personal information we collected
• The sources from which we collected it
• Our business purposes for collecting or sharing it
• The categories of third parties with whom we share it
• The specific pieces of personal information we collected about you

6.2 Right to Delete

You may request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, ongoing transactions).

6.3 Right to Correct

You may request correction of inaccurate personal information.

6.4 Right to Opt-Out of Sale/Sharing

Referral Pro does not sell personal information. Referral Pro does not share personal information for cross-context behavioral advertising.

6.5 Right to Limit Sensitive Personal Information

You may request that we limit the use of sensitive personal information to purposes necessary to provide the Service.

6.6 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

6.7 Exercising Your Rights

To exercise your rights, contact us at: info@thereferralpro.com

We will verify your identity before processing your request. You may designate an authorized agent to make requests on your behalf.

6.8 Categories of Information Collected

In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers (name, email, phone, IP address)
• Commercial information (referral history, transactions)
• Internet/electronic activity (usage data, device information)
• Geolocation data (derived from IP address)
• Professional/employment information (for Business Users)

6.9 Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law.

6.10 Shine the Light

California residents may request information about disclosures of personal information to third parties for direct marketing purposes. Contact us at info@thereferralpro.com.

7. OTHER STATE PRIVACY RIGHTS

7.1 Virginia, Colorado, Connecticut, Utah, and Other States

Residents of states with comprehensive privacy laws (such as Virginia's VCDPA, Colorado's CPA, Connecticut's CTDPA) may have similar rights to access, delete, correct, and opt-out. Contact us to exercise these rights.

7.2 Appeals of Denied Requests

If we decline to take action on a request you submit under Section 6 or this Section 7, you have the right to appeal our decision where the privacy law of your state provides an appeal right. To appeal, contact us at info@thereferralpro.com within a reasonable period after you receive our decision, and reference your original request and the reason you disagree with our decision. Within sixty (60) days of receiving your appeal, we will inform you in writing of any action taken or not taken in response, together with a written explanation of the reasons for our decision. If we deny your appeal, we will provide you with a method to submit a complaint to your state Attorney General where your state’s law provides for such a mechanism.

8. INTERNATIONAL DATA TRANSFERS

8.1 United States Processing

Referral Pro is based in the United States and processes data primarily in the United States. If you access the Service from outside the United States, your information will be transferred to, stored, and processed in the United States.

8.2 EU/UK Users

The Service is not directed to users in the European Union, European Economic Area, or United Kingdom. If you access the Service from these regions:

• You do so at your own risk
• You consent to the transfer of your data to the United States
• U.S. data protection laws may differ from those in your jurisdiction
• Referral Pro makes no representation regarding GDPR compliance

9. SECURITY MEASURES

We implement reasonable administrative, technical, and physical safeguards to protect your information, including:

• Secure access controls and authentication
• Encryption of data in transit (TLS/SSL)
• Encryption provided by payment processors for financial data
• Regular security assessments
• Employee training and access limitations
• Incident response procedures

No method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.

10. COOKIES AND TRACKING TECHNOLOGIES

10.1 Types of Cookies We Use

Cookie TypePurposeEssentialRequired for Service functionality, authentication, securityPerformanceAnalyze usage, identify errors, improve performanceFunctionalRemember preferences and settingsAnalyticsUnderstand how users interact with the Service

10.2 Third-Party Analytics

We use analytics tools such as Google Analytics to understand Service usage. These tools may collect information about your use of the Service and other websites.

10.3 Cookie Consent and Consent Manager

Essential cookies are strictly necessary to operate the Service (for example, authentication, security, and session management) and are always active; they do not require consent and cannot be disabled through the Service. Performance, functional, and analytics cookies, including Google Analytics, are optional and are placed only with your consent or, where applicable law permits an opt-out rather than opt-in, until you opt out.

When you first access the Service, and at any time afterward, you can manage these optional cookies through our cookie banner and “Cookie Preferences” (or “Cookie Settings”) control, which lets you accept all cookies, reject all non-essential cookies, or choose by category. You may change or withdraw your choices at any time using the same control; withdrawing consent does not affect the lawfulness of any processing carried out before withdrawal. Where required by applicable law, we honor opt-out preference signals such as the Global Privacy Control (GPC).

We do not currently use cookies or similar technologies for cross-context behavioral advertising or targeted advertising. If we introduce advertising cookies in the future, we will update this Policy and obtain consent or provide an opt-out where required by law.

10.4 Your Cookie Choices

• Most browsers allow you to control cookies through settings
• You may delete or disable cookies, but this may affect Service functionality
• Some browsers offer “Do Not Track” signals (see Section 10.5)

10.5 Do Not Track Disclosure

Some browsers have a “Do Not Track” (DNT) feature. Currently, we do not respond to DNT signals because there is no industry-wide standard for DNT. We will update this policy if a standard is established.

11. USER RIGHTS AND CHOICES

11.1 Access and Update

You may access and update your account information through your dashboard or by contacting us.

11.2 Deletion

You may request deletion of your account and personal information by contacting us. We will process your request within thirty (30) days, subject to legal exceptions.

11.3 Marketing Opt-Out

You may opt out of marketing communications by:

• Clicking “unsubscribe” in marketing emails
• Adjusting notification settings in your account
• Contacting us at info@thereferralpro.com

We will continue to send transactional communications (e.g., referral confirmations, payment notices).

11.4 Response Time

We aim to respond to privacy requests within thirty (30) days. Complex requests may require an additional thirty (30) days, in which case we will notify you.

12. DATA RETENTION

We retain personal information for as long as necessary to:

• Provide the Service and maintain your account
• Process and verify transactions
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Support business operations (analytics, security)

Specific retention periods:

• Account information: Duration of account plus two (2) years
• Transaction records: Three (3) years (or as required by tax/legal obligations)
• Marketing data: Until opt-out plus two (2) years
• Security logs: 12 months

We may retain de-identified or aggregated data indefinitely.

13. CHILDREN'S PRIVACY

The Service is not intended for children under the age of eighteen (18). We do not knowingly collect personal information from children under 18.

If we learn that we have collected personal information from a child under 18, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us at info@thereferralpro.com.

14. THIRD-PARTY LINKS AND SERVICES

The Service may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the “Last Updated” date at the top
• Post the revised policy on the Service
• Notify you via email or in-app notification for significant changes

Your continued use of the Service after the effective date of changes constitutes your acceptance of the updated Privacy Policy.

16. CONTACT US

For privacy-related questions, requests, or concerns, contact:

Referral Pro LLC
Attn: Privacy Team
Email: info@thereferralpro.com

For data subject requests, please include:

• Your name and email associated with your account
• Description of your request
• Any relevant details to help us locate your information

BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.