Privacy Policy

Privacy Policy - JRNY Flex (United States)

Effective Date: DD Month 2026

Last Updated: DD Month 2026

(Company Name) (“Company”, “we”, “us”, or “our”) provides its website and related services and is committed to protecting your privacy.

This Privacy Policy describes how we collect, use, disclose, and protect personal information of individuals located in the United States when they access JRNY Flex services or website.

This Policy is intended to comply with applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other applicable state privacy laws.

We collect personal information for the business purposes described in this Policy and retain it only as long as reasonably necessary to fulfil those purposes.

At or before the time of collection, we inform individuals of the categories of personal information we collect and the purposes for which such information will be used. We do not sell personal information. We do not share personal information for cross-context behavioural advertising unless explicitly stated in this Privacy Policy.

1. Who Operates JRNY Flex

(Company Legal Name)

(Company Address)

For purposes of applicable U.S. state privacy laws, [Company Name] acts as the “business” under applicable U.S. state privacy laws and determines the purposes and means of processing personal information.

Contact:

(Contact Email)

2. Categories of Personal Information We Collect

We may collect the following categories of personal information:

Identifiers

• Name

• Email address

• Postal address

• Telephone number

• IP address

Government Identification Information (Sensitive Personal Information)

• Passport details

• Driver’s licence information

• Other government-issued identification details

• Identity verification status and related metadata

Identity documents are securely transmitted to third-party identity verification providers. We do not retain full copies of identity documents unless required by law.

Commercial Information

• Records of services requested or purchased

• Transaction information

Financial Information

• Payment-related information processed through secure third-party payment processors

We do not store complete credit card numbers.

Internet or Network Activity

• Browser type

• Device information

• Usage data

• Interaction data

We do not knowingly collect personal information from children under 13.

The categories listed above reflect personal information collected in the preceding 12 months.

3. Sources of Personal Information

We collect personal information:

• Directly from you

• Through identity verification processes

• From payment processing providers

• Through cookies and similar technologies

• From publicly available sources where appropriate

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our services, including analytics and functionality purposes. You can control cookies through your browser settings.

5. How We Use Personal Information

We use personal information to:

• Provide and manage services

• Verify identity and prevent fraud

• Process payments

• Communicate with you

• Improve our website and services

• Comply with legal obligations

We use sensitive personal information only for purposes permitted under applicable state law and do not use it to infer characteristics about individuals.

6. Disclosure of Personal Information

We may disclose personal information to:

• Identity verification providers

• Payment processors

• Cloud hosting providers

• IT service providers

• Professional advisers

• Regulators where legally required

In the preceding 12 months, we have disclosed the categories of personal information described above to the categories of recipients listed in this section for business purposes.

We do not sell personal information.

We do not share personal information for cross-context behavioural advertising unless expressly disclosed in this Policy.

We do not sell personal information as defined under applicable U.S. state privacy laws.

We do not share personal information for cross-context behavioural advertising.

7. Retention

We retain personal information only for as long as reasonably necessary to:

• Provide services

• Comply with legal obligations

• Resolve disputes

• Enforce agreements

Retention periods vary depending on the nature of the information and the purposes for which it was collected.

Identity verification outcomes are retained only as necessary to meet contractual and compliance requirements.

8. Your U.S. State Privacy Rights

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

• Access personal information

• Correct inaccurate information

• Request deletion

• Request information about the categories of personal information we have collected, disclosed, or shared in the preceding 12 months

• Opt out of the sale or sharing of personal information, where applicable

• Limit use of sensitive personal information

• Not be discriminated against for exercising your rights

We will not discriminate against you for exercising any of your privacy rights under applicable state law. This means we will not deny you services, charge different prices, provide a different level of service, or otherwise penalise you for submitting a privacy rights request.

To exercise your rights, contact:

(Contact Email)

We will respond to verifiable consumer requests within the timeframe required by applicable law.

We may verify your identity before fulfilling a request.

Authorized agents may submit requests on your behalf, subject to verification requirements.

Residents of certain states may also have the right to:

• Opt out of targeted advertising

• Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects

If we deny your request, you may have the right to appeal our decision by contacting us at (Contact Email).

9. International Data Transfers

Personal information may be processed outside the United States, including in India. We implement appropriate safeguards to protect such data.

10. Data Security

We implement reasonable administrative, technical, and organisational safeguards designed to protect personal information.

However, no system is completely secure.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted with a revised effective date.

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