Privacy Policy

SOVAT, Inc. ("Company", "we", "our", or "us") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, products, and services that link to this policy (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

Through the Services.
In communications, including email, text, chat, and other electronic messages, between you and the Services.
When you interact with our advertising on third-party websites and services, if those applications or advertising include links to this policy.
When you access applications, portals, onboarding tools, or other services made available by us or on our behalf that link to this policy.

It does not apply to information collected by:

Us through any other means, including on any other website operated by Company or any third party, including our affiliates and subsidiaries, that does not link to this policy; or
Any third party, including through any application, website, or service that may link to or be accessible from or through the Services, unless expressly stated otherwise.

We may provide additional or different privacy policies or notices that are specific to certain features, services, activities, jurisdictions, or categories of data.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree and acknowledge the collection, use, and sharing of your information as described in this privacy policy, subject to any rights or choices you may have under applicable law. In many cases, we process personal data in connection with services requested by a business customer, which means we may receive personal data directly from you, from the business that engages us, or from service providers, vendors, payment processors, expense or travel platforms, or tax authorities involved in a claim or refund process. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, credit card number, or social security number or any other identifier we may use to contact you online or offline). Depending on the context, this may include information about a client contact, employee, contractor, authorized representative, or other individual whose information is included in materials submitted through the Services.

The types and categories of personal data we collect or process include:

Account and contact information, including name, employer or company name, job title, username, mailing address, email address, phone number, username, and other contact information you provide us.
Payment and remittance information, including payment card or bank account information, billing address, payment method details, refund remittance instructions, and similar financial information used in connection with the Services.
Account, onboarding, and service history, including information about your account, onboarding status, transactions, service requests, communications, invoices, claim history, reimbursements, and related records.
Business and claimant information, including information about the business that engages us, its personnel, employees, contractors, or representatives, and other information needed to evaluate, prepare, administer, or support tax refund or reclaim requests.
Expense and tax claim documentation, including invoices, receipts, travel and lodging details, merchant or supplier information, VAT amounts, tax or registration identifiers, proof of payment, refund instructions, and other documents or information submitted to us or generated in connection with the Services.
Device and usage information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other information about how you access or use the Services.
General location information, including country, state or province, or city, derived from your IP address, billing information, or other information associated with your use of the Services.
Content and communications you provide or that are provided on your behalf through the Services or in emails, chats, support requests, or other communications with us, including documents uploaded during onboarding or claim processing.
Verification and authorization information, such as tax registration or business identification numbers, authorization letters, signatures, and, where reasonably necessary, limited identification information used to verify authority, prevent fraud, or support a claim.
Information we receive from third parties involved in providing or supporting the Services, such as expense management providers, travel providers, accounting systems, payment processors, local advisors or agents, and tax authorities.
AI, analytics, and processing information, including information processed through artificial intelligence or machine learning systems for document extraction, classification, validation, workflow automation, fraud prevention, support, or claim preparation purposes, and analytics or usage information collected through analytics, monitoring, or performance tools used to operate, improve, secure, and support the Services.

If you are a California resident, additional information about your privacy rights may apply to you as described below.

Some of the information identified above, including certain financial account information, tax identifiers, login credentials, or other information included in claim materials, may be considered sensitive personal data under certain laws. We do not use sensitive personal data to infer characteristics about individuals. Where required under applicable law, we will collect or process sensitive personal data only with your consent or as otherwise permitted by law.

We also collect:

Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate information to understand usage of the Services, service performance, claim activity, or customer trends.
Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services, including date and time, pages or features you view or use, page response times, download errors, length of your visits to certain pages, page interaction information, such as scrolling, clicks, and mouse-overs, and methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, complete online or clickwrap acceptance, upload or submit documents, request claim assistance, make a payment, or communicate with us.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, browser type, device information, information collected through cookies or similar technologies, details of your interactions with the Services, and information about the resources and Services features that you access and use.

We may use these automatic collection technologies to remember your settings, maintain sessions, understand how the Services are used, support security and fraud prevention, and improve the Services and user experience.

Using automatic collection technologies helps us improve our Services and deliver a better, more efficient, and more personalized and secure experience.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Services. We may use cookies and similar technologies for essential functionality, performance, analytics, authentication, security, and user preferences. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons, also referred to as clear gifs, pixel tags, and single-pixel gifs, that permit the Company, for example, to count users who have visited those parts or opened an email, measure campaign effectiveness, and verify system and server integrity.

To the extent any of these automated technologies are considered targeted advertising, profiling, "sharing," or a "sale" under applicable laws, depending on where you live, you may have rights to opt out by emailing us at hello@sovat.finance. We do not currently sell personal data for monetary consideration, and we do not knowingly use sensitive personal data to infer characteristics about you.

When you interact with the Services, certain third parties acting on our behalf may use automatic collection technologies to collect information about you or your device in connection with operating, supporting, securing, or measuring the Services. These third parties may include:

Advertisers, ad networks, and ad servers.
Analytics companies.
Your device manufacturer.
Cloud hosting, infrastructure, or security providers.
Payment processors, communications vendors, or verification providers.
Your internet or mobile service provider.

These third parties may collect information associated with your use of the Services or your device as needed to provide their services to us, subject to their own terms and any contractual or legal restrictions that apply.

We do not control third-party websites or services that are not part of the Services. If you have questions about third-party privacy practices, review the privacy policy of the applicable provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information from business customers, service providers we engage to perform services on our behalf, such as email platform providers, content delivery services, cloud hosting providers, payment processors, analytics, security and anti-fraud services, customer support providers, expense management platforms, accounting systems, local advisors or agents, and tax authorities or refund processors involved in a claim.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

Provide, operate, administer, and support the Services, including our website, onboarding, client portals, and tax refund or recovery assistance services.
Verify identity or authority, evaluate eligibility, collect and review documents, prepare, submit, administer, and support tax refund or reclaim requests, and facilitate related reimbursements or payments.
Fulfill any other purpose for which you provide information to us or for which your information is provided to us in connection with the Services.
Improve our Services, including by analyzing information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, secure, automate, validate, and report on our Services, their features, and how users interact with them. Our analysis and operations may include the use of technologies such as machine learning, artificial intelligence, and large language models to operate, support, improve, secure, and enhance the Services.
Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services.
Communicate with you, your employer or business customer, service providers, vendors, local advisors or agents, and tax authorities, and send marketing or business development communications about our Services where permitted by law.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our Terms of Use and related billing and collection activities.
Notify you when Services updates are available and about changes to any products or services we offer or provide through them.
Comply with legal obligations, defend or pursue legal claims, prevent fraud, protect the security and integrity of the Services, and protect the rights, property, or safety of the Company, our customers, or others.
In any other way we may describe when you provide the information.
For any other purpose with your consent, where consent is required by applicable law.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

Estimate our audience sizes and usage patterns.
Maintain information about your preferences and settings, allowing us to customize the Services according to your needs and interests.
Speed up your searches, troubleshoot issues, and maintain security and stability.
Recognize you when you return to our Services or maintain your session and settings.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our organization or the Services, such as hosting providers, communications vendors, payment processors, analytics providers, security providers, verification providers, and document or workflow management providers.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by the Company is among the assets transferred.
To tax authorities, refund processors, local advisors or agents, payment intermediaries, travel or expense management platforms, accounting systems, or other third parties as reasonably necessary to evaluate, prepare, submit, administer, or support tax refund or reclaim requests and related payments.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal data:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use, service agreements, and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, security, and credit risk reduction, where appropriate.

International Transfers

The Company is based in the United States, and the Services may involve the transfer of personal data to the United States, Canada, the United Kingdom, countries in the European Union, and other jurisdictions where our customers, service providers, partners, local advisors or agents, payment processors, or applicable tax authorities operate. By using the Services or providing information to us, you understand that your information may be transferred to and processed in jurisdictions that may have different data protection laws than the place where you reside. Where required by applicable law, we will take steps designed to provide appropriate safeguards for such transfers.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

Cookies, Marketing, and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. You may also opt out of marketing emails by using the unsubscribe mechanism in those emails or by contacting us. Some browsers include a "Do Not Track" setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the Do Not Track signal, our Services may not respond to all browser Do Not Track signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and contact methods described in this policy.

Your State Privacy Rights

Depending on your state of residency and the context in which we process your personal data, you may have certain rights related to your personal data under applicable state law. These rights may apply differently depending on whether we process your information in a consumer, commercial, employment, or business-to-business context, and certain rights may not apply where we process personal data on behalf of a business customer or where an exception or exemption applies.

Subject to applicable law, you may have the following rights:

Access and Confirmation. You may have the right to confirm whether we process your personal data and to access a copy of the personal data we process about you.
Data Portability. You may have the right to obtain a portable copy of certain personal data we process about you, to the extent technically feasible and required by law.
Correction. You may have the right to request that we correct inaccuracies in the personal data we maintain about you, taking into account the nature of the personal data and the purposes of processing it.
Deletion. You may have the right to request that we delete certain personal data we maintain about you, subject to applicable exceptions.
Opt Out of Certain Processing. You may have the right to opt out of certain types of processing, such as targeted advertising, profiling in furtherance of decisions that produce legal or similarly significant effects, or the sale, sharing, or other disclosure of personal data for purposes that trigger opt-out rights under applicable law.
Appeal. If we deny your privacy rights request, you may have the right to appeal that decision, to the extent required by applicable law.

To exercise any applicable privacy rights or submit a privacy-related request, you may contact us at hello@sovat.finance. We may take reasonable steps to verify your identity and authority before responding to your request, as permitted or required by applicable law.

Important: The exact scope of these rights varies by state, by the type of data at issue, and by the context in which the data is processed. In some cases, we may process personal data on behalf of a business customer in connection with the Services. In those cases, we may direct your request to the relevant business customer or work with that business customer to respond, as appropriate and permitted by law.

To exercise any rights available to you under applicable state law, please email us at hello@sovat.finance. Please describe your request with sufficient detail to allow us to understand, evaluate, and respond to it. We may take reasonable steps to verify your identity and, where applicable, your authority to make the request.

To appeal a decision regarding a privacy rights request, please use the same contact method and state that your submission is an appeal.

Some browsers or browser extensions support the Global Privacy Control ("GPC"), which can send a signal communicating your preference to opt out of certain processing, including sale, sharing, or targeted advertising, as defined by applicable law. We may recognize or respond to such signals where required by applicable law and where technically supported by our Services and providers.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Nevada residents who wish to exercise any such rights may submit a request at hello@sovat.finance. However, please know we do not currently sell data in a manner that we believe triggers that statute's opt-out requirements.

Supplemental Notice for California Residents

If you are a California resident, this section supplements the other parts of this privacy policy and applies solely to Personal Information subject to the California Consumer Privacy Act, as amended (the "CCPA"). For purposes of this section, "Personal Information" has the meaning given in the CCPA and generally corresponds to "personal data" as used elsewhere in this policy. "Sensitive Personal Information" has the meaning given in the CCPA.

This section applies to Personal Information we collect about California residents in connection with the Services, including business customer contacts, client representatives, employees, contractors, applicants, and other individuals whose information we collect directly or indirectly in connection with the Services. In some cases, we may process Personal Information on behalf of a business customer. In those cases, we may direct you to that business customer or work with that business customer to respond to your request, as appropriate.

During the preceding 12 months, we may have collected the categories of Personal Information described in the section titled "The Personal Data That We Collect or Process," from the sources described in the section titled "How We Collect Your Personal and Other Data," for the business and commercial purposes described in the section titled "How We Use Your Information," and disclosed such categories to the categories of recipients described in the section titled "Who We Disclose Your Information To."

We do not sell Personal Information for monetary consideration, and we do not have actual knowledge that we sell or share the Personal Information of individuals under 16 years of age. However, certain cookies, pixels, analytics, or similar technologies used on or through the Services may constitute "sharing" of Personal Information for cross-context behavioral advertising under the CCPA. California residents may opt out of such sharing as described below.

We do not use or disclose Sensitive Personal Information for purposes other than the limited purposes permitted by the CCPA, including to provide the Services, process transactions, verify information, prevent fraud, maintain security, comply with law, and perform services reasonably expected by an individual requesting the Services. Accordingly, we do not offer a separate right to limit the use or disclosure of Sensitive Personal Information except to the extent required by applicable law.

California residents may have the following rights, subject to applicable exceptions and verification:

Right to Know. You may request that we disclose the categories of Personal Information we collected about you, the categories of sources from which it was collected, the business or commercial purposes for collecting, selling, or sharing it, the categories of third parties to whom we disclose it, and the specific pieces of Personal Information we collected about you.
Right to Delete. You may request that we delete Personal Information we collected from you, subject to certain exceptions.
Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.
Right to Opt Out of Sale or Sharing. You may request that we stop selling or sharing your Personal Information, to the extent we engage in such processing as defined by the CCPA.
Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to direct us to limit certain uses and disclosures of your Sensitive Personal Information, to the extent that right applies to our processing under the CCPA.
Right to Non-Discrimination. We will not unlawfully discriminate against you for exercising rights under the CCPA.

To submit a request to know, delete, or correct, please email us at hello@sovat.finance or use any other designated request method we may make available through the Services. To exercise any right to opt out of sale or sharing, you may email us at hello@sovat.finance or use any cookie or privacy controls we make available through the Services. We will take reasonable steps to verify your request and may request additional information as necessary to verify your identity or authority to act on behalf of another person.

You may designate an authorized agent to make a request on your behalf, subject to our ability to verify the agent's authority and, where permitted by law, your identity.

If we deny your request, you may appeal that decision by replying to our response or emailing us at hello@sovat.finance with the subject line "California Privacy Rights Appeal".

For questions about this section or our California privacy practices, please contact us using the contact information set forth below.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described, including to provide the Services, complete onboarding, administer accounts, evaluate, prepare, submit, and support tax claims or refunds, process payments, comply with tax, accounting, legal, and audit obligations, resolve disputes, and for safety, security, and fraud prevention, or for as otherwise legally permitted or required. This means that we consider our legal and business obligations, the nature and sensitivity of the information, the duration of the customer relationship, the applicable claim lifecycle, and potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Different categories of personal data may be retained for different periods. For example, account and relationship information may be kept for the duration of the relationship and a reasonable period thereafter, claim documentation and financial records may be retained for longer periods to support ongoing services and legal, tax, accounting, audit, or dispute-resolution needs, and device or usage information may be retained for shorter periods unless required for security, troubleshooting, or legal compliance.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

6 Liberty Sq #91234,

Boston, MA 02109

hello@sovat.finance