Privacy Policy

This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

Effective Date: 17 October 2025

Summary

This Policy is issued by Outpost Technologies, which is made up of each of the Outpost Global entities owned and operated by the parent company Outpost Technologies 1 LTD UK which acts as Controller (together, "Outpost", "we", "us" and "our"), and is addressed to individuals outside our organisation with whom we interact in our course of business as a Merchant of Record, including End Customers, visitors to our Sites, other users of our products or services, personnel of Merchants and vendors, applicants for employment, and visitors to our premises (together, "you").

This Policy was last updated on 17 October 2025.

You may also have certain rights regarding the information we collect about you. Specifically:

  • The rights of Data Subjects of the EEA and UK are explained in Section (L) below
  • Brazilian residents may find information on their rights under the LGPD in Section (M) below
  • Mexican residents may find information on their rights under the LFPDPPP in Section (N) below
  • Australian residents may find additional disclosures in Section (O) below

(A) Collection and Obtaining of Personal Data

Summary: We collect or obtain Personal Data: when that data is provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you appoint us as your Merchant of Record or if you make a purchase through Outpost); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site; we may also receive Personal Data about you from third parties (e.g., law enforcement authorities, Merchants, Payment Service Providers).

We collect or obtain Personal Data about you from the following sources:

Data provided to us

We obtain your Personal Data when you provide it to us, such as where you contact us via email or telephone, or by any other means, or when you make a purchase of products or services where we act as the Merchant of Record.

Data we collect in the course of our relationship with you

We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we collect Personal Data when you purchase products or services where we act as Merchant of Record, or where a business appoints us to provide Merchant of Record services).

Data you make public

We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us).

Data provided to us by third parties

We collect or obtain Personal Data from third parties who provide it to us. This includes:

  • Merchants from whom you purchase products or services (providing us with transaction details necessary for us to fulfil our role as Merchant of Record)
  • Payment Service Providers (providing us with payment authorization and fraud prevention data)
  • fraud detection service providers
  • identity verification providers
  • credit reference agencies
  • our service providers and sub-processors
  • law enforcement and regulatory authorities (only where permitted or required by applicable law)

Site data

We collect Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.

Other sources

From time to time we may obtain Personal Data from other sources, such as public databases, joint marketing partners, social media platforms, or from other third parties.

(B) Creation of Personal Data

Summary: We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where that data is collected from different sources.

(C) Categories of Personal Data We Process

Summary: We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., billing address); information about your interaction with our Sites (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

  • Personal details: name; date of birth/age.
  • Demographic information: gender; nationality; country of residence.
  • Contact details: correspondence address; telephone number; email address; details of your public social media profile(s).
  • Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
  • Location data: geographic location (inferred from IP address).
  • Purchase details: records of products and services purchased by you where we act as Merchant of Record; transaction details; invoice records.
  • Payment details: invoice records; payment records; billing address; payment method; cardholder name; payment amount; payment date; transaction identifiers.
  • Data relating to our Sites: device type; operating system; browser type and version; browser plug-in types and versions; IP address; internet service provider; pages accessed; dates and times of Site access; referring URLs; page interaction information (such as scrolling, clicks, and mouse-overs).
  • Employer details: where you interact with us in your capacity as an employee or personnel of a Merchant, the name, address, telephone number and email address of your employer, to the extent relevant.
  • Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising.
  • Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
  • Tax and compliance data: tax identification numbers; beneficial ownership information; KYC/AML documentation.

Please note that not all of the above will apply to you, as it will depend on your relationship with Outpost (e.g., End Customer, Merchant, etc.).

(D) Sensitive Personal Data

Summary: We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business as a Merchant of Record. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

  • Compliance with applicable law: where the Processing is required or permitted by applicable law
  • Detection and prevention of crime: where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud)
  • Establishment, exercise or defence of legal rights: where the Processing is necessary for the establishment, exercise or defence of legal rights
  • Consent: where we have, in accordance with applicable law, obtained your prior, explicit consent prior to Processing your Sensitive Personal Data

(E) Purposes for Which We Process Personal Data

Summary: We Process Personal Data for the following purposes: providing our Sites, products, and services to you; compliance checks; operating our business as Merchant of Record; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, products, and services; analytics and reporting; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, include:

Provision of Sites, products, and services

Providing our Sites, products, or services; acting as Merchant of Record; processing transactions and issuing invoices; calculating and collecting taxes; fulfilling digital product/service delivery; communicating with you in relation to those Sites, products, or services.

Legal Basis: The Processing is necessary in connection with any contract that you may enter into with us, or for the performance of our role as Merchant of Record.

Compliance checks

Fulfilling our regulatory compliance obligations as Merchant of Record; 'Know Your Client' checks; confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions; tax compliance and reporting.

Legal Basis: The Processing is necessary for compliance with a legal obligation. The Processing is also necessary for our legitimate interests, namely protecting our business and your interests against fraud, money laundering, terrorist financing, and other illegal activity.

Operating our business

Operating and managing our Sites, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our products, or our services; and notifying you of changes to any of our Sites, our products, or our services.

Legal Basis: The Processing is necessary for our legitimate interests, namely the proper administration of our business and communications with users.

Fraud prevention

Detecting, preventing and investigating fraud and other criminal activity; verifying identity; screening transactions.

Legal Basis: The Processing is necessary for our legitimate interests, namely the protection of our business and End Customers against fraud and other illegal activity. The Processing is also necessary for compliance with legal obligations relating to fraud prevention.

Legal compliance

Compliance with our legal and regulatory obligations under applicable law, including tax law, financial regulations, anti-money laundering law, and payment industry standards; responding to lawful requests from authorities.

Legal Basis: The Processing is necessary for compliance with a legal obligation.

(F) Disclosure of Personal Data to Third Parties

Summary: We disclose Personal Data to: Merchants whose products/services you purchase; legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business or successor in title to our obligations under a contract; and any third party providers of advertising, plugins or content used on our Sites. We do not sell, rent, or otherwise disclose Personal Data for monetary or other valuable consideration.

We disclose Personal Data to other entities within the Outpost group, for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

  • Merchants: where you purchase products or services where we act as Merchant of Record, we share transaction details and contact information with the Merchant to enable fulfillment of the purchase. Merchants are independent Data Controllers with their own privacy policies.
  • Payment Service Providers (PSPs): we share payment information with licensed payment service providers such as Stripe, Adyen, Airwallex and others to process transactions on your behalf. PSPs are subject to PCI DSS compliance requirements and have their own privacy policies.
  • Legal and regulatory authorities: we disclose Personal Data to legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
  • External advisors: we disclose Personal Data to external professional advisors (such as accountants, auditors, lawyers and other professional advisors), subject to binding contractual obligations of confidentiality.
  • Tax authorities: we disclose Personal Data to tax authorities as required for tax compliance, including calculation, collection, and remittance of indirect taxes (VAT, GST, sales tax) and issuance of compliant invoices.

We do not sell, rent, or otherwise disclose Personal Data for monetary or other valuable consideration.

(G) International Transfer of Personal Data

Summary: We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the UK/EEA to a recipient outside the UK/EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses and in the presence of appropriate safeguards. Where we transfer from Brazil, we comply with LGPD requirements. Where we transfer from Mexico, we comply with LFPDPPP requirements.

Because of the international nature of our business, we transfer Personal Data within the Outpost group, and to third parties as noted in Section (F) above, in connection with the purposes set out in this Policy. For this reason, we may transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

From UK/EEA

Where we transfer your Personal Data from the UK/EEA to recipients located outside the UK/EEA who are not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses approved by the European Commission and/or the UK Information Commissioner's Office (as applicable). Please contact us at companies@outpostnow.com if you wish to request a copy of our Standard Contractual Clauses.

From Brazil

Where we transfer your Personal Data from Brazil to other countries, we comply with the requirements of the LGPD, including the use of Standard Contractual Clauses based on ANPD-approved models, adequacy decisions, or other transfer mechanisms permitted by applicable law.

From Mexico

Where we transfer your Personal Data from Mexico to other countries, we comply with the requirements of the LFPDPPP, including obtaining your consent where required and implementing appropriate safeguards.

From Australia

Where we transfer your Personal Data from Australia to other countries, we comply with the requirements of the Privacy Act 1988, including ensuring that overseas recipients are subject to laws or binding schemes substantially similar to the Australian Privacy Principles, or that you have consented to the transfer after being informed that such protections may not apply.

(H) Data Security

Summary: We have implemented appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law. These measures include:

  • encryption of data in transit and at rest
  • PCI DSS Level 1 compliance for payment data handling (we never store full payment card numbers, only tokenized references, and we never store CVV/CVC codes)
  • multi-factor authentication and role-based access controls
  • regular security testing and vulnerability assessments
  • security monitoring and incident response procedures
  • employee confidentiality agreements and security training

(I) Data Accuracy

Summary: We take reasonable steps to ensure that your Personal Data is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies.

We take reasonable steps to ensure that: your Personal Data that we Process is accurate and, where necessary, kept up to date; and any of your Personal Data that we Process that is inaccurate (having regard to the purposes for which it is Processed) is erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Data.

(J) Data Minimisation

Summary: We take reasonable steps to limit the volume of your Personal Data that we Process to what is necessary.

We take reasonable steps to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

(K) Data Retention

Summary: We take reasonable steps to ensure that your Personal Data is only retained for as long as it is needed in connection with its lawful purpose.

We take reasonable steps to ensure that your Personal Data is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data includes:

  • We maintain an ongoing relationship with you (e.g., where you are a user of our services or where we act as your Merchant of Record)
  • Your Personal Data is necessary in connection with the lawful purposes set out in this Policy
  • Where we are required to retain your Personal Data for legal, tax, accounting, or regulatory compliance purposes (for example, transaction records are retained for 5-10 years depending on the jurisdiction)

(L) Your Rights (EEA and UK Data Subjects)

Summary: Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities.

Subject to applicable law, you may have the following rights regarding the Processing of your Personal Data:

  1. The right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, products, or services, if you do not provide us with your Personal Data)
  2. The right to request access to, or copies of, your Personal Data, together with information regarding the nature, Processing and disclosure of those Personal Data
  3. The right to request rectification of any inaccuracies in your Personal Data
  4. The right to request, on legitimate grounds: erasure of your Personal Data; or restriction of Processing of your Personal Data
  5. The right to object, on legitimate grounds, to the Processing of your Personal Data by us
  6. The right to have certain Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format
  7. Where we Process your Personal Data on the basis of your consent, the right to withdraw that consent
  8. The right to lodge complaints regarding the Processing of your Personal Data with a Data Protection Authority. For the UK, this is the Information Commissioner's Office (ICO) - https://ico.org.uk

(M) Additional Disclosures for Brazilian Residents (LGPD)

Summary: Brazilian data subjects have specific rights under the Lei Geral de Proteção de Dados (LGPD). This section explains those rights and how to exercise them.

Your Rights Under LGPD

As a Brazilian data subject, you have the following rights:

  1. Confirmation and access: confirmation of the existence of Processing and access to your Personal Data
  2. Correction: correction of incomplete, inaccurate, or outdated data
  3. Anonymization, blocking or deletion: anonymization, blocking or deletion of unnecessary or excessive data, or data Processed in non-compliance with LGPD
  4. Portability: portability of your data to another service or product provider, upon your express request
  5. Deletion: deletion of Personal Data Processed with your consent, except where retention is required by law
  6. Information about sharing: information about public and private entities with which we have shared your data
  7. Revocation of consent: revocation of your consent
  8. Right to petition ANPD: the right to petition the Autoridade Nacional de Proteção de Dados (ANPD) regarding alleged non-compliance with the LGPD

To exercise your rights under the LGPD, please contact us at companies@outpostnow.com. We will respond to your request within 15 (fifteen) days.

(N) Additional Disclosures for Mexican Residents (LFPDPPP)

Summary: Mexican data subjects have specific rights under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP). This section explains those rights and how to exercise them.

Your ARCO Rights

Under the LFPDPPP, you have the following rights (known as "ARCO Rights"):

  1. Access (Acceso): the right to know what Personal Data we hold about you and the details of its Processing
  2. Rectification (Rectificación): the right to request correction of inaccurate or incomplete Personal Data
  3. Cancellation (Cancelación): the right to request deletion of your Personal Data when you consider it is not being Processed in accordance with the LFPDPPP
  4. Opposition (Oposición): the right to oppose the Processing of your Personal Data for specific purposes

To exercise your ARCO Rights, please submit a written request to companies@outpostnow.com with the subject line "ARCO Rights Request" or "Solicitud de Derechos ARCO". We will respond within twenty (20) business days.

(O) Additional Disclosures for Australian Privacy Act Compliance

Summary: Australian residents have specific rights under the Privacy Act 1988. This section provides additional information for Australian users.

We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) in relation to the Personal Information of Australian residents.

Your Rights

Under Australian privacy law, you have the right to:

  • access your Personal Information
  • request correction of inaccurate Personal Information
  • make a complaint about our handling of your Personal Information

If you believe we have breached the Australian Privacy Principles, you may lodge a complaint with us at companies@outpostnow.com. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

(P) Cookies and Similar Technologies

Summary: We Process Personal Data by using Cookies and similar technologies.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law.

Types of Cookies

  • Strictly Necessary Cookies: Essential for the operation of our Sites and services, including security, fraud prevention, and session management. These cannot be disabled.
  • Performance Cookies: Help us understand how visitors use our Sites, allowing us to improve our services. These collect aggregated, anonymized data.
  • Functional Cookies: Remember your preferences and choices to provide enhanced functionality.
  • Marketing Cookies: Where you have consented, these track campaign effectiveness and enable targeted advertising.

(Q) Children's Privacy

Summary: Our Sites and services are intended for use by adults and business users. We do not knowingly collect Personal Data from children.

Our Sites and services are intended for use by adults and business users. We do not knowingly collect Personal Data from individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction) without parental or guardian consent. If you believe that we may have collected Personal Data from a child, please contact us immediately at companies@outpostnow.com.

(R) Direct Marketing

Summary: We Process Personal Data to contact Merchants and business contacts with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.

For Merchants and Business Contacts

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe from our promotional email list at any time by clicking on the unsubscribe link included in every promotional electronic communication.

For End Customers

We only send transactional emails necessary for the performance of our role as Merchant of Record (such as receipts, invoices, and refund confirmations). We do not use Transaction Data for Outpost's own marketing purposes.

(T) Contact Details

For Privacy Inquiries and Rights Requests

Email: companies@outpostnow.com

Website: https://outpost.ai/

Subject Line: Please use "Privacy Rights Request" or "Data Protection Inquiry" in your email subject line

Response Times:

  • General privacy inquiries: within 5 business days
  • GDPR/UK GDPR rights requests: within 1 month (extendable to 3 months for complex requests)
  • LGPD rights requests: within 15 days
  • LFPDPPP rights requests: within 20 business days
  • Australian Privacy Act requests: within 30 days

(U) Controller Entity

For the purposes of this Policy, the relevant Controllers are:

Outpost Technologies Ltd.

Registered in England and Wales

Company Number: 13465097

Registered Office: 4th Floor Office, 205 Regent Street, London, England, W1B 4HB

(V) Definitions

"Controller" means the entity that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

"Cookie" means a small file placed on your device when you visit a website, enabling the website to recognise your device on future visits.

"EEA" means the European Economic Area.

"End Customer" means an individual who purchases products or services where Outpost acts as Merchant of Record.

"GDPR" means the General Data Protection Regulation (EU) 2016/679.

"Merchant of Record" or "MoR" means the legal entity of record for a transaction, acting as the seller to End Customers, and responsible for payment processing, invoicing, tax compliance, refunds, chargebacks, and regulatory compliance in the relevant jurisdiction.

"Personal Data" or "Personal Information" means any information relating to an identified or identifiable natural person.

"Process", "Processing" or "Processed" means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, use, disclosure, erasure or destruction.

"Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning a person's sex life or sexual orientation.

END OF PRIVACY POLICY