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 · Last Updated: 14 July 2026

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, and applicants for employment (together, “you”).

This Policy was last updated on 14 July 2026.

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 (M) below
  • Brazilian residents may find information on their rights under the LGPD in Section (N) below
  • Mexican residents may find information on their rights under the LFPDPPP in Section (O) below
  • Australian residents may find additional disclosures in Section (P) below

(A) Collection and Obtaining of Personal Data

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
  • Payment Service Providers (providing us with payment authorisation 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

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

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.
  • 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; IP address; internet service provider; pages accessed; dates and times of Site access; referring URLs.
  • 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.
  • 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 — it will depend on your relationship with Outpost (e.g., End Customer, Merchant, etc.).

(D) Sensitive Personal Data

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

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; 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.

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) Automated Decision-Making and Profiling

Outpost does not use automated decision-making or profiling in a way that produces legal effects concerning you, or that similarly significantly affects you. This means that no decision that has a legal or significant impact on you is made solely by automated means without human involvement.

We do use automated processes in certain operational contexts, including fraud detection and transaction screening. These processes are used to identify and prevent potentially fraudulent activity and protect our customers and merchants. Where an automated process flags a transaction or account for review, a human member of our team will review the flagged activity before any action is taken that has a significant impact on you.

If you have questions about how we use automated processes, or if you believe an automated process has produced an incorrect outcome that has affected you, please contact us at companies@outpostnow.com with the subject line ‘Automated Processing Query’. You have the right to request human review of any such decision.

(G) Disclosure of Personal Data to Third Parties

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 fulfilment 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.

(H) International Transfer of Personal Data

Because of the international nature of our business, we transfer Personal Data within the Outpost group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy.

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.

(I) Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data 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 or 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

(J) Data Accuracy

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 is inaccurate is erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Data.

(K) Data Minimisation

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.

(L) Data Retention

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 retention duration include:

  • 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)

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

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

  • Right not to provide Personal Data: 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
  • Right of access: 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
  • Right to rectification: the right to request rectification of any inaccuracies in your Personal Data
  • Right to erasure or restriction: the right to request, on legitimate grounds, erasure of your Personal Data or restriction of Processing of your Personal Data
  • Right to object: the right to object, on legitimate grounds, to the Processing of your Personal Data by us
  • Right to data portability: the right to have certain Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format
  • Right to withdraw consent: where we Process your Personal Data on the basis of your consent, the right to withdraw that consent
  • Right to lodge complaints: 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)

(N) Additional Disclosures for Brazilian Residents (LGPD)

Your Rights Under LGPD

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

  • Confirmation and access: confirmation of the existence of Processing and access to your Personal Data
  • Correction: correction of incomplete, inaccurate, or outdated data
  • Anonymisation, blocking or deletion: anonymisation, blocking or deletion of unnecessary or excessive data, or data Processed in non-compliance with LGPD
  • Portability: portability of your data to another service or product provider, upon your express request
  • Deletion: deletion of Personal Data Processed with your consent, except where retention is required by law
  • Information about sharing: information about public and private entities with which we have shared your data
  • Revocation of consent: revocation of your consent
  • 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.

(O) Additional Disclosures for Mexican Residents (LFPDPPP)

Your ARCO Rights

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

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

(P) Additional Disclosures for Australian Privacy Act Compliance

We comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) in relation to the Personal Information of Australian residents. Under Australian privacy law, you have the right to access your Personal Information, request correction of inaccurate Personal Information, and 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.

(Q) Cookies and Similar Technologies

When you visit our Sites or use our platform (app.outpostanywhere.com), we use only strictly necessary cookies. We do not place analytics, functional preference, or marketing cookies.

Strictly necessary cookies: These are essential for the operation of our platform and cannot be disabled. They are used for session management, authentication, security, and fraud prevention. No consent is required for these cookies under UK PECR Regulation 6(4) and the ePrivacy Directive Article 5(3).

We do not currently use performance, functional, or marketing cookies. Google Analytics was removed from our website in July 2026 and is no longer in use. Because we use only strictly necessary cookies, no cookie consent banner is currently displayed or required.

For a full inventory of the cookies we use, including cookie names, domains, purposes, and retention periods, please see our Cookie and ePrivacy Policy, available on request from companies@outpostnow.com.

If we introduce any non-essential cookies in the future, this Policy will be updated and a Consent Management Platform (CMP) will be implemented to obtain your prior consent before any such cookies are placed.

(R) Children’s Privacy

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.

(S) Direct Marketing

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 End Customers’ 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”

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.