Privacy Policy

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Last Updated: December 10, 2025

This privacy notice for Conduit Commerce dba Recurrent Finance, LLC (“Recurrent,” “we,” “us,” or “our”) explains how and why we collect, store, use, and share (“process”) information when you use our services (“Services”), such as when you:

Use Recurrent’s billing and payment infrastructure and related APIs, dashboards, and integrations;
Visit any website or dashboard we operate that links to this privacy notice; or
Communicate with us in connection with sales, onboarding, support, or other business activities.

If you have questions or concerns, this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If anything is unclear, you can contact us at support@recurrentfinance.com.

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Summary of Key Points

What personal information do we process?

We process business contact information, account information, usage and billing data, and tokenized financial information.

Do we process sensitive personal information?

We process financial information such as bank-account and card tokens only as needed to provide the Services.

Do we receive information from third parties?

Yes. We receive information from our payment partners (Finix, Plaid) and other providers supporting the Services.

How do we process your information?

To provide and maintain the Services, facilitate payments, support customers, ensure security, prevent fraud, and comply with law.

Who do we share personal information with?

A small group of infrastructure providers (Finix, Plaid, AWS, Twilio, OpenAI) and government authorities when required.

How do we keep information safe?

Through encryption, access controls, logging, and a range of technical and organizational protections.

What are your rights?

Depending on your jurisdiction, you may access, correct, or request deletion of your information.

How do you exercise your rights?

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What Information Do We Collect?

Personal Information You Provide

We collect the following categories of information when you or your organization use the Services:

Business contact information (name, business email, mailing address, job title)
Account and authentication information (usernames, hashed passwords, API keys, account preferences)
Billing and usage data (usage inputs, invoices, charges, dunning actions, payment amounts)
Support communications (messages, attachments, explanations of issues)

Payment and Financial Information

We process:

tokenized bank-account and routing data,
ACH instructions and transaction metadata, and
tokenized credit-card information.

These are provided through secure partner flows (Finix, Plaid).

Recurrent does not store raw bank-account numbers or full card numbers.

Information Automatically Collected

We automatically collect:

Log and usage data (timestamps, API request metadata, error logs, webhook events, response codes)
Device and network information exposed through standard internet protocols (such as IP address, browser type)

We use this information primarily for platform security, diagnostics, and performance monitoring—not advertising.

How Do We Process Your Information?

We process information to:

provide, maintain, and improve the Platform;
enable ACH and card-based payment processing;
support billing, usage measurement, and automated dunning;
monitor and protect the Platform against security threats or abuse;
comply with NACHA and other legal or regulatory requirements;
respond to customer requests and support needs; and
analyze aggregate platform usage to improve reliability and performance.

We do not sell personal information or use it for unrelated marketing.

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Legal Bases for Processing

We process information only where permitted by law, including:

fulfilling our contracts with Customers;
complying with applicable laws or banking regulations;
protecting rights, property, or safety; and
pursuing legitimate operational interests that do not override user rights.

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When and With Whom Do We Share Personal Information?

We share information only where necessary to operate the Services:

Service Providers Supporting the Platform:

Finix (payment processing, tokenization, payouts)
Plaid (bank-account verification and ACH tokenization)
AWS (hosting and cloud infrastructure)
Twilio (SMS and telephony communications)
OpenAI (automated dunning message generation or insights)

These parties access only the information needed to perform their functions.

We also share information:

with government or regulatory authorities when required;
with affiliates supporting the Services;
in connection with mergers, acquisitions, or similar corporate transactions.

We do not share information publicly or with social features, as the Platform does not provide public posting functionality.
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Cookies and Tracking Technologies

Recurrent does not currently use cookies, pixels, or similar tracking tools in the Platform.

If this changes, we will update this notice and provide appropriate disclosures or consent mechanisms.
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International Transfers

All data is stored and processed in the United States using AWS infrastructure.

Our Services are intended for U.S.-based Customers only.
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How Long Do We Keep Your Information?

We retain personal information for as long as necessary to:

operate the Platform,
support your organization’s use of the Services,
comply with legal obligations (including banking and NACHA rules), and
maintain appropriate business records.

In practice, this may result in data being retained indefinitely unless a Customer requests deletion or law requires removal. When feasible, we delete or de-identify information once it is no longer needed.

Deletion requests can be submitted to: support@recurrentfinance.com.
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How Do We Keep Information Safe?

We use a combination of technical and organizational measures, including:

encryption at rest and in transit,
access controls and multi-factor authentication,
internal policies governing access and handling,
continuous logging and security monitoring.

No method is perfectly secure, but we design our infrastructure and processes specifically for financial-grade data protection.

Accessing the Services from a secure environment and protecting your credentials is also important.

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Do We Collect Information From Minors?

The Services are for business users only.

We do not knowingly collect information from children under 13. If such information is discovered, we will delete it promptly.

To report a concern, contact support@recurrentfinance.com.

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Your Privacy Rights

Depending on applicable law, you may have rights to:

access personal information;
correct inaccurate information;
request deletion;
restrict or object to certain processing;
opt out of marketing communications (if any are sent).

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Account Information

To review, update, or request deletion of information tied to a user account, contact us at support@recurrentfinance.com.

If your organization directs us to deactivate an account, we will honor that request and may retain some data as required for fraud prevention, compliance, or other legitimate business needs.

We respond to all privacy-related requests in accordance with applicable law.
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Do-Not-Track (DNT)

Browsers may send a Do-Not-Track signal, but no standard governs how services should respond.

At this time, Recurrent does not respond to DNT signals. If this changes, we will update this notice.
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Changes to This Notice

We may update this notice periodically. The “Last Updated” date reflects the most recent revision. If changes are material, we may provide notice by email or through the Platform.
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Contact Us

If you have any questions or comments about this notice, you may contact us at:

Email: support@recurrentfinance.com

Mail:

Recurrent Finance

Attn: Privacy Officer

3120 139th Ave SE, Suite 500

Bellevue, WA 98005

United States
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Requesting Access, Updates, or Deletion of Your Data

To request to review, update, or delete the personal information we hold, please contact us at support@recurrentfinance.com with enough detail for us to locate your records.
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Conclusion

We include many of these terms to protect all parties and ensure clear expectations. If you encounter an issue or believe something is not working as intended, please reach out at support@recurrentfinance.com, and we will do our best to resolve it promptly and fairly.