Last Updated: 04/10/2025

This Privacy Notice (“Notice”) applies to information and data collected by Zero Technologies, LLC (“Strictly,” “we,” “us,” or “our”) and describes how we collect, receive, use, store, share, transfer, and process personal information, as well as the choices and rights of Data Subjects pertaining to their personal information. By submitting an application for our Services or continuing to use our Services or website, you explicitly consent to the collection, use, and storage of your personal and business information by Strictly and our third-party partners, as described in this Notice. Use of our Services, including the merchant account application process, is also governed by our Terms of Service (available at https://strictlyzero.com/terms-and-conditions).

“End Users” are businesses, such as dental practices, that are prospective or actual customers of the products and services developed and/or marketed by Strictly, including our proprietary payment solutions and ancillary modules (collectively, the “Services”), as well as their employees, contractors, and agents who interact with the Services on behalf of the End User.

“Cardholders” are individuals interacting with the Services through visits to an End User’s place of business or other means, such as an End User’s Strictly Online Ordering instance.

“Visitors” are individuals who are visiting Strictly’s website.

Please note that, with certain exceptions, Strictly processes Cardholders’ and End User employees’ personal information under the direction of the End User and does not maintain direct control or ownership of such data. End Users are responsible for complying with applicable laws and regulations related to their use of the Services, including those requiring notice, disclosure, and/or consent for the collection, transfer, and processing of personal information, as well as providing accurate information to Strictly and our third-party partners for purposes such as credit reviews. End Users generally control, and are responsible for correcting, deleting, or updating, personal information collected on their Cardholders and employees via the Services. Strictly is not responsible for the privacy practices or policies of third-party websites or services not operated or controlled by Strictly, even if linked from our website or interoperable with the Services. You are responsible for reviewing the privacy policies of such third parties, including our third-party partners performing credit reviews. We may periodically update this Notice. When we do, we will post the updated Notice on our website and revise the effective date. Your continued use of our Services or website following the posting of changes constitutes your acceptance of such changes.

We may periodically update this Notice. When we do, we will post the updated Notice on our website and revise the effective date. Your continued use of our Services or website following the posting of changes constitutes your acceptance of such changes.

1. INFORMATION COLLECTED OR OTHERWISE RECEIVED. Strictly collects or otherwise receives personal information of various Data Subjects, and the personal information collected or otherwise received is contingent upon the nature of your interaction with Strictly, as more particularly described below. Subject to certain limitations, personal information is retained for as long as is reasonably necessary to provide the Services or comply with applicable law. This means that even after you cease interactions with Strictly, we may retain copies of personal information (including, without limitation, transactional information and use of the Services) for a period of time consistent with applicable law, statute of limitations or as Strictly believes is otherwise reasonably necessary to comply with applicable law, legal process or government request, to detect or prevent fraud, to collect fees, to resolve disputes, to enforce our agreements or take other actions consistent with applicable law.

a) Personal Information Collected in Connection with Interactions with Strictly and the Services. Strictly will collect certain personal information from Data Subjects in connection with their initial application and agreement for use of the Services and including any updates during the course of the parties’ business relationship, as well as through continued use of the Services. Such information includes, as applicable, your name, telephone number, home address, business address, email address, date of birth, identification number (e.g. Social Security number, drivers’ license number and/or passport number), bank account information, payment information, tax identification number, job title, employment-related information, Services log-in information, correspondence to and from Strictly and telephone recordings. The personal information collected from a End User in connection with their initial application and agreement for use of the Services, and any updates during the course of the parties’ business relationship, may include personal information about the individual(s) executing the application and agreement, beneficial owners of the End User entity, and employees of End User. Strictly may further collect personal information from third-party sources in connection with a End User’s initial application and agreement for use of the Services and any updates during the course of the parties’ business relationship as more particularly described below.

b) Personal Information Collected or Otherwise Received Through Cardholders’ Use of the Services. As mentioned above, with certain limited exceptions, Strictly processes Cardholders’ personal information and data under the direction of End User, and does not maintain direct control or ownership of such personal information or data. Notwithstanding, Strictly collects or otherwise receives Cardholders’ personal information when Cardholders interact with the Services, including, without limitation, when a Cardholder consummates a credit card transaction at a End User location via the Services (whether on-premise or remotely). Depending upon the nature of a Cardholder’s interaction with the Services, personal information collected or otherwise received includes, as applicable, your name, telephone number, home address, business address, email address, date of birth, payment information, transaction information (including purchased items and visit details), and your Services log-in information.

c) Personal Information Collected Through Our Website. Strictly collects personal information when Visitors proactively provide it on our website (e.g., to request a product demonstration, inquire about partnerships, sign up for webinars, or access gated content). This may include your name, telephone number, email address, physical address, employer, and job title, plus any additional information you provide. Additional data may be automatically collected (see Section 1(e)).

d) Personal Information Collected Through Third-Party Sources. Depending on your interaction with Strictly, we or our third-party partners may collect personal information from third-party sources, such as credit bureaus, data providers, card brands, government records, or other sources to supplement End User application data and meet underwriting and legal obligations (e.g., KYC verification). Our third-party partners may also use this information to perform credit reviews as part of the application process for the Services. We may also collect personal information by way of referrals from End Users or business partners recommending our Services.

e) Personal Information Collected Automatically. We may collect information via cookies and similar technologies when you visit our website or use certain Services. This may include web browser and device characteristics, geolocation data (restrictable at the device or browser level), usage data (e.g., login information, browser type, language, pages viewed), and online identifiers (e.g., IP address). See Section 4 for details.

f) Personal Information Pertaining to Children. Neither the Services nor our website are intended for or targeted at children under 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided such information without consent, contact us to request deletion.

2. USE OF INFORMATION. Strictly or our third party partners use Data Subjects’ personal information for the following purposes, as applicable:

a) Facilitating, Developing and Supporting the Services. To perform credit underwriting, anti-money laundering, and other compliance obligations to approve and provide End Users with the Services; assess and present applicable rates and fees for the Services, disclosed during the application process; or facilitate implementation and use of the Services, website, and content; improve and develop new offerings; provide support and administrative services (e.g., fee collection); analyze usage and performance; meet contractual obligations; facilitate payment transactions; authenticate sign-ins; conduct internal research; and otherwise provide the Services.

b) Communicating About the Services and Other Matters. To communicate with you via email, telephone, ringless voicemail, SMS or otherwise in order to obtain feedback; advertise Services, content, or End User offerings; provide requested information; send digital receipts, invoices, or account-related communications; and discuss contests, promotions, or rewards offered by Strictly or partners. See Section 5 for communication rights.

c) Compliance and Protection of the Services. To conduct investigations; comply with laws, regulations, and card organization rules; respond to legal processes or government inquiries; ensure compliance with agreements (e.g., Terms of Service); detect, prevent, investigate, or report fraud, security incidents, or illegal activities; ensure security and integrity; and pursue or defend legal claims.

d) Other Uses. To communicated to you from time to time about the Services or affiliates.

3. SHARING OF INFORMATION. Strictly may share personal information in the following circumstances: with your consent (e.g., when authorizing third-party access); with individuals or businesses you interact with to facilitate transactions or provide Services; with service providers and integration partners (e.g., merchant processors complying with anti-money laundering and data protection laws) to perform services, facilitate transactions, or enable interoperability at an End User’s request; at your direction (e.g., requesting an introduction to a partner); to protect Strictly’s rights, security, or Services, or to detect, prevent, or report fraud or illegal activities; to comply with applicable law, regulation, legal process, or governmental requests (e.g., with law enforcement or tax authorities); with our parent, subsidiary, or affiliated entities; in connection with a corporate merger, acquisition, divestiture, or dissolution; and in aggregated or anonymized form not identifying specific Data Subjects.

4. COOKIES AND SIMILAR TECHNOLOGIES. Strictly and its partners may use cookies, web beacons, pixels, tags, and JavaScript to gather information about your use of the Services, website, and email interactions. This data enhances functionality and personalization. You may disable certain cookies, though this may impact your experience.

• Strictly Necessary Cookies: Essential for website and Service functionality (e.g., login, forms); cannot be disabled without affecting operation.

• Performance Cookies: Aggregate, anonymous data on visits and usage to improve performance.

• Targeting Cookies: Set by advertising partners to personalize ads; based on browser/device identifiers, not direct personal data.
  Opt out via “Manage Cookies” on our website or visit https://www.allaboutcookies.org. We do not currently respond to “Do Not Track” signals.

5. DATA SUBJECTS’ ACCESS TO & CONTROL OF PERSONAL INFORMATION. Depending on your relationship with Strictly and the Services used, you may manage your personal information via your account. For assistance, contact us at support@strictlyzero.com. We may be unable to accommodate some requests due to technical, legal, or contractual limitations. You may receive marketing and promotional communications from Strictly (provided either directly by Strictly or through a third-party service provider or partner). You may opt out of or unsubscribe from such communications by following the prompts provided within the communication, informing the caller that you do not wish to receive any future promotional communications or updating your communications preferences. Please be advised that to the extent you receive marketing and promotional communications from End User with whom you’ve interacted, service provider or other third-party partners of Strictly, that entity is responsible for the communication and providing you a method to opt out or unsubscribe. You may receive non-marketing and non-promotional communications from Strictly, which are primarily related to your interaction with and use of the Services. These communications may include transaction-related information (e.g. receipts and order confirmation) and account-specific communications related to your subscription to or use of the Services (e.g. to respond to a End User support request). These communications are integral to the Services, and you cannot opt out of receiving them. Notwithstanding the foregoing, you may be entitled to additional rights and protections under applicable state law, as further detailed within this Notice.

6. STATE-SPECIFIC PRIVACY RIGHTS. We may amend this Notice at our discretion, posting updates on our website with a revised effective date. Continued use constitutes acceptance.

• California: See our Privacy Notice for California Consumers for rights under the California Consumer Privacy Act (Cal. Civ. Code §§ 1798.100–1798.199).

• Other States: Depending on your residence, you may have rights under laws like the Virginia Consumer Data Protection Act or Colorado Privacy Act. Contact us for details.

7. SECURITY. Strictly employs administrative, technical, and physical safeguards, including encryption of data in transit and at rest, to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. However, no system can guarantee absolute security.

8. CONTACT. For questions or concerns about this Notice, email us at support@strictlyzero.com.