Fragile Privacy Policy
Last Updated March 7th, 2023
This Privacy Policy ("Policy") explains how Fragile Inc and its affiliates, including partner merchants, (collectively “Fragile,” “we,” “us,” or “our”) collects, uses and discloses your information when you request or obtain a product with Fragile, interact with Fragile as a representative of another business, use our website and mobile applications, or otherwise interact with us (our "Services"). We also explain your data privacy rights and how you can exercise them.
1. Updates to This Policy
We may change this Policy from time to time. Please take a look at the "Last Updated Date" legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective on the "Last Updated Date" date indicated above. If We make any material changes to this Policy, We will endeavor to notify You by email or by posting a prominent notice on the Sites prior to the change becoming effective. Your continued use of the Site after the publication of the Privacy Policy is Your agreement to be bound to these changes. If You do not accept the terms of this Privacy Policy, Your only remedy is to discontinue use of the Services.
2. How Fragile Collects Information
If you use our Services, we may collect information about you. Some information may be readily associated with you individually (“Personal information”) and other information may be collected from your behavior which is not directly attributable to you (“Other Information”). We may collect information from you directly, or from third parties (such as financial institutions, fraud prevention agencies, collection agencies, credit bureaus, merchant partners, social media platforms, and marketing agencies). We may also collect publicly available information about you from other public sources, such as social media sites and public records, to the extent permitted by applicable law. Information collected about you may not be obvious, such as background tracking software or data collected from third parties. IF YOU SUBMIT ANY PERSONAL INFORMATION RELATING TO ANYONE OTHER THAN YOURSELF, YOU REPRESENT THAT YOU HAVE OBTAINED ANY NECESSARY CONSENT FROM THAT INDIVIDUAL FOR USE AND DISCLOSURE OF THAT INDIVIDUAL’S PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.
3. Types of Personal Information Collected
We may collect a variety of Personal Information about you, including:
Identity Information. Information related to your identity, such as full name, date of birth, email address, current or former physical address(es), phone number(s), password, Social Security Number, and photos of your identification.

Financial Information. Information related to your current and past finances, such as credit and debit card details, analytics regarding your credit and debit cards (such as past authorization rates and dispute history), banking institutions, details on your bank accounts (including institution, account number, routing number, and historical transaction records), and information from credit bureaus (such as credit scores and credit history).

Customer Service Interactions. Information related to your customer service interactions with Us, including correspondence details, audio or video recordings of your interaction, chat transcripts, and surveys.

Technical Data. Information related to the technical ways you interact with the Services, including device identity information (such as IP addresses, MAC addresses, cookies, and other unique identifiers or digital fingerprints), your operating system type and data generated by your operating system, your browser type and data generated from your browser, technical data surrounding how you interact with Services (such as where you click on pages, what pages you view, and how long you view pages).

Other Third Party Information. Information related to your interactions with third parties, which we may or may not be directly affiliated with, such as which third parties you maintain an account with.
4. Usage
We use, analyze, and distribute information collected in a variety of ways. This includes:
4.1. Providing our Services.
We use and distribute your information to provide our Services, which may include sharing information we collect with our merchant partners, vendors, and other third parties. For example, we use data to process transactions, resolve disputes, authenticate and verify identities, collect payments, prevent fraud and other illegal activities, customize the Services, and verify the accuracy of data.
4.2. Improving our Services and growing our business.
We use your information to understand our customer base, conduct research and analysis, develop new or improved products and Services, and build relationships with merchant partners. If you are an employee, representative, or agent of a merchant, vendor, or other business entity, we may use the information collected from you in connection with the business relationship between the entity and Fragile, or to market a prospective relationship to the entity you represent.
4.3. Responding to your requests.
We use your information to provide customer service and support, respond to your questions, comments, and other requests.
4.4. Communications and marketing.
We may use information to provide service update notices and to notify you about products, services, and promotions that may be of interest to you, based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize your experience, including advertising. We may also use your information to facilitate and offer contests and sweepstakes.
4.5. Complying with legal and regulatory obligations.
We may process your information to comply with our regulatory requirements or in connection with inquiries from regulators, law enforcement agencies, or parties involved in litigation, in each case anywhere in the world, as necessary for Fragile and its merchant partners to bring claims and exercise defenses, including to enforce the Terms of Service.
4.6. Collecting Balances and Recovering Assets
We may use information collected in order to collect on past due payments or unreturned products. This may include sensitive Personal Information such as photos of your identification, your contact information, information about your identity, and where you reside. This information may be shared with financial institutions, collection agencies, credit bureaus, merchant partners, and other providers to support in the collection of past due funds or assets we either own or are entitled to recover.
5. Retention
We will retain information, including Personal Information, for a period of time necessary where such data remains useful. We may also retain information above and beyond the period it remains useful if (i) we are required to by any applicable law or regulation, (ii) it may become useful in the future, (iii) it is within the retention period we defined for such information, or (iv) you maintain an account or maintain an active relationship with Fragile, a merchant partner, or a Fragile affiliate.
6. Protection of Information
Fragile maintains electronic, procedural, and physical safeguards to prevent unauthorized access or disclosure for data in our custody. Certain information we designate as especially sensitive, such as photographs of your identification, may be secured separately from other information with additional access controls in place. We limit disclosure of information to third parties to the extent commercially reasonable. When information is disclosed to third parties, we make no assurance to the level of protection such third parties provide.
7. Legal Rights
California Consumer Privacy Act (CCPA). For California residents only. Fragile is exempt from the CCPA and does not meet the requirements under the CCPA statute.

General Data Protection Regulation (GDPR). Fragile is exempt from GDPR and does not conduct business in Europe.

Fair Credit Reporting Act (FCRA). Fragile currently does not obtain information from credit bureaus, however, we may in the future. Therefore, the FCRA does apply to information collected by us at this time.

Virginia Consumer Data Protection Act (VCDPA). For Virginia residents only. Fragile is exempt from the VCDPA and does not meet the requirements under the statute.

Colorado Privacy Act (ColoPA). For Colorado residents only. Fragile is exempt from the ColoPA and does not meet the requirements under the statute.