Privacy Policy

Privacy Policy

InclusivePay — A DBA of Inclusive Holdings

Effective Date: May 11, 2026 | Last Updated: May 11, 2026

1. Introduction

InclusivePay (“we,” “us,” or “our”) is a registered DBA of Inclusive Holdings. We specialize in payment processing solutions for high-risk merchants, including businesses in the CBD, hemp, delta-8, peptides, nootropics, supplements, and adult content industries.

This Privacy Policy explains how we collect, use, disclose, and protect information submitted to us through our website at inclusivepay.com, our merchant application forms, and any related communications (“Services”). By using our Services or submitting an application, you agree to the practices described in this policy.

If you have questions, contact us at: [email protected]

2. Information We Collect

Because we place high-risk merchants with acquiring banks and payment processors, we collect more detail than a typical website. Here’s what we may collect:

2a. Business Information

Business name, DBA names, and entity type (LLC, Corp, Sole Prop, etc.)
EIN / Tax ID and business formation documents
Business address, phone number, and website URL
Years in business and ownership structure
Product or service descriptions, including any claims, certificates, or compliance documentation (e.g., CoA, LegitScript)
Processing history: prior processors, monthly volume, average ticket size, chargeback history

2b. Principal / Owner Information

Full legal name and ownership percentage
Date of birth and Social Security Number (SSN) for identity verification and underwriting
Home address and personal contact information
Government-issued ID (driver’s license or passport) — image may be requested by acquiring bank
Personal credit background (reviewed by our banking partners during underwriting)

2c. Financial & Banking Information

Business bank account details (for underwriting verification)
Bank statements (typically 3 months)
Business tax returns (may be required for higher processing volumes)
Existing or previous merchant account statements

2d. Website & Technical Information

IP address, browser type, and device information when you visit our site
Pages visited, time on site, and referral source (via cookies and analytics tools)
Form submissions and inquiry content

2e. Communications

Emails, phone call notes, and chat messages exchanged with our team
Any documents or attachments you send us in connection with your application

3. How We Use Your Information

We use the information collected for the following purposes:

Merchant application processing: Reviewing your business for risk profile, product type, and eligibility for placement
Bank placement: Submitting your application package to acquiring banks and payment processors on your behalf
Underwriting support: Facilitating due diligence required by our banking partners, including KYC (Know Your Customer) and KYB (Know Your Business) checks
Account setup and onboarding: Configuring your merchant account once approved, including gateway setup (Authorize.Net, NMI, or similar)
Ongoing account management: Monitoring account health, responding to chargeback inquiries, and communicating processing updates
Legal and compliance: Meeting our obligations under applicable financial services regulations and card network rules
Communications: Responding to inquiries, sending application status updates, and sharing relevant account information
Site analytics: Improving our website and understanding how merchants find us

We do not sell your personal information to third parties for their own marketing purposes.

4. How We Share Your Information

Given our role as an ISO (Independent Sales Organization), sharing your application data with banking partners is central to the service we provide. Here’s exactly who may receive your information:

4a. Acquiring Banks & Payment Processors

We submit your full application package — including business documents, owner information, and financial records — to acquiring banks and payment processors for underwriting review. Current banking partners may include North American Bancard (NAB), and others depending on your business type and volume.

4b. Payment Gateways

Gateway providers such as Authorize.Net and NMI may receive business and account information necessary to configure and operate your merchant account.

4c. Alternative Payment Processors

For merchants requiring alternative processing solutions (such as ACH/eDebit for peptide or nootropic merchants), we may work with partners such as Green.Money (greenbyphone.com), which processes via bank rails rather than card networks.

4d. Service Providers

We may share information with trusted vendors who support our business operations, including CRM systems, document storage, email platforms, and analytics tools. These providers are contractually required to protect your information and may only use it to provide services on our behalf.

4e. Legal & Regulatory Requirements

We may disclose your information if required by law, subpoena, court order, or to protect the rights, property, or safety of InclusivePay, our clients, or others.

4f. Business Transfers

If Inclusive Holdings is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a materially different privacy policy.

5. How We Protect Your Information

We take the security of your application data seriously. Our practices include:

Encrypted data transmission (SSL/TLS) across all web forms and communications
Access controls limiting who on our team can view sensitive documents
Secure document handling and storage protocols
Application data shared only with banking and processing partners who maintain their own compliance programs (PCI-DSS, SOC 2, etc.)

However, no method of transmission over the internet is 100% secure. While we implement industry-standard safeguards, we cannot guarantee absolute security. If you believe your information has been compromised, contact us immediately at [email protected].

6. Data Retention

We retain application and account information for as long as:

Your merchant account remains active with us or our banking partners
Required by law or regulation (financial records are typically retained for 5–7 years)
Necessary to resolve disputes or enforce our agreements

For declined or withdrawn applications, we retain records for a minimum of 3 years to comply with financial services regulations. To request deletion of your data (subject to legal retention obligations), contact us at [email protected].

7. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

7a. For All Applicants

Access: Request a copy of the personal information we hold about you
Correction: Request that we correct inaccurate or incomplete information
Portability: Request a portable copy of your data in a structured, machine-readable format
Withdrawal of Consent: Withdraw consent for processing where consent is the legal basis (note: this does not affect processing conducted prior to withdrawal)

7b. California Residents (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):

Right to Know: Request disclosure of the categories and specific pieces of personal information we’ve collected, used, disclosed, or sold
Right to Delete: Request deletion of your personal information, subject to certain exceptions
Right to Correct: Request correction of inaccurate personal information
Right to Opt-Out: We do not sell personal information. However, you may contact us to confirm this or submit an opt-out request
Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights

To submit a CCPA/CPRA request, contact us at [email protected] or call us directly. We will respond within 45 days (extendable by 45 days when reasonably necessary).

8. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to improve your browsing experience and analyze traffic. These include:

Essential cookies: Required for site functionality (cannot be disabled)
Analytics cookies: Used to understand how visitors interact with the site (e.g., Google Analytics). Data is anonymized where possible
Marketing cookies: May track your visit for retargeting purposes (you can opt out via your browser settings or the opt-out tools below)

You can manage cookie preferences through your browser settings or by visiting optout.aboutads.info or optout.networkadvertising.org.

9. Third-Party Links

Our site may contain links to third-party websites (such as banking partners, gateways, or industry resources). We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

10. Children’s Privacy

Our Services are intended for businesses and adults aged 18 and older. We do not knowingly collect personal information from individuals under 18. If we become aware that we have collected information from a minor, we will delete it promptly.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or banking partner requirements. When we make material changes, we will:

Update the “Last Updated” date at the top of this page
Notify active merchants by email when changes are significant

Your continued use of our Services after changes are posted constitutes your acceptance of the updated policy.

12. Contact Us

Questions about this Privacy Policy or your data? Reach out:

InclusivePay / Inclusive Holdings

Email: [email protected]

Website: inclusivepay.com

Mailing Address: 2870 NE Hogan Dr, Ste E #126, Gresham, OR 97030