This Privacy Policy explains how Unified Transact LLC collects, uses, stores, and discloses personal information in connection with the Acepio website, platform, and services.
Who We Are and Scope#
1.1 Unified and Acepio
Unified Transact LLC, a limited liability company organized under the laws of the State of Montana, United States of America (“Unified”, “we”, “us”, or “our”), operates the financial technology platform available at acepio.com under the “Acepio” brand (the “Platform”) and provides financial services through it (the “Services”). Unified is the sole controller and entity responsible for personal information covered by this Policy.
Unified's mailing address is 1001 S Main St Ste 500, Kalispell, MT 59901, United States of America. Privacy questions and requests may be sent to [email protected].
1.2 Scope
This Policy applies to personal information Unified processes about website visitors, applicants, individual customers, representatives and beneficial owners of business customers, authorized users, and other individuals who communicate with Unified or interact with the Platform or Services.
In this Policy, “personal information” means information relating to an identified or identifiable individual, and “you” means an individual whose personal information is covered by this Policy.
This Policy does not apply to a third party's independent processing under its own privacy policy.
Personal Information We Collect and Sources#
The personal information Unified collects depends on how you interact with Acepio and the Services you use.
2.1 Account, contact, and business information
This includes your name, account identifiers, email address, telephone number, residential and business addresses, job title, authority, and relationship to a customer. For a business customer, it also includes formation and registration information, ownership and control, beneficial owners, directors, officers and authorized representatives, tax information, licences, commercial activities, websites, and supporting business records.
2.2 Identity and compliance information
This includes date of birth, nationality, residence, occupation, government-issued identification details and copies, proof of address, source-of-funds information, and information requested to verify identity, eligibility, or a transaction. It also includes selfies, live images or video, liveness results, and facial-comparison or other biometric information used for identity verification.
Unified may also collect sanctions, politically exposed person, adverse media, fraud, and other screening results; risk indicators and scores; compliance inquiries and responses; and records of verification or compliance reviews and decisions.
2.3 Financial, wallet, and transaction information
This includes bank and payment details, virtual-account details, electronic-wallet and payment-instrument balances, virtual-asset wallet addresses, transaction instructions and history, counterparty and destination information, and deposit, withdrawal, transfer, exchange, return, reversal, and correction records. Transaction records may include amounts, currencies or virtual assets, networks, dates and times, source and destination information, exchange rates, fees, references, and processing status.
2.4 Device, usage, and analytics information
This includes IP address, device and browser identifiers, operating system, authentication and security events, approximate location derived from an IP address, pages and features used, referral information, cookies and advertising identifiers, error and performance data, and other Platform or server logs. Unified may collect interactions and partial session recordings, with sensitive fields excluded or masked.
2.5 Communications and marketing information
This includes communications with Unified, support requests, feedback, product-update and notification preferences, optional mailing-list status, marketing choices, and information about interactions with emails, Platform notifications, advertisements, and retargeting campaigns.
2.6 Sources of personal information
Unified collects personal information directly from you through onboarding, your Account, the Platform, communications, and transaction instructions. We also collect information automatically from devices, cookies, logs, and usage of the website or Services; from business customers, authorized users, representatives, and beneficial owners; from Service Providers such as Sumsub, banks, payment institutions, custodians, exchanges, and fraud or compliance providers; from analytics and advertising partners; and from public or official sources used for verification and compliance.
2.7 User-submitted transaction information
Payment instructions and transaction records may contain information about a destination or counterparty supplied by you. Unified processes that information as part of the requesting user's transaction and account records to perform the Services, prevent fraud, maintain records, and comply with law. Its inclusion does not by itself create an Account or customer relationship with the identified person.
How We Use Information and Automated Review#
Unified uses personal information for the following purposes, as appropriate to your relationship with the Platform and the Services you use.
3.1 Provide and administer the Platform and Services
We use personal information to create and manage Accounts; provide virtual accounts, electronic wallets, payment instruments, payment and virtual-asset services, and foreign-exchange or conversion services; process instructions and transactions; maintain balances and records; provide support; and operate, troubleshoot, and maintain the Platform.
3.2 Verify identity, eligibility, and source of funds
We use personal information to identify and authenticate users; verify business, ownership, and authority information; conduct customer due diligence; assess eligibility for the Platform and particular Services; verify source of funds and transaction information; and satisfy onboarding and ongoing review requirements.
3.3 Compliance, legal, and security purposes
We use personal information to screen for sanctions, politically exposed persons, adverse media, fraud, and other risks; monitor and review activity; detect and investigate suspicious, prohibited, fraudulent, abusive, or unlawful activity; make required filings and disclosures; maintain required records; respond to lawful requests; comply with applicable laws, regulations, rules, and orders; authenticate users; secure Accounts and systems; prevent unauthorized access and cyberattacks; enforce the Terms and product schedules; and protect the integrity and continuity of the Services.
3.4 Communicate and improve our services
We use personal information to send service messages, security alerts, transaction and account notices, support responses, and product updates; understand how the Platform is used; measure performance; test and improve features; and develop and maintain our products, systems, and operations.
3.5 Marketing and advertising
We may use limited personal information to communicate marketing messages to users who have joined the optional mailing list and to measure or deliver advertising and retargeting through providers such as Google Ads and Meta. We do not sell personal information. Marketing preferences are described in Section 7.3.
3.6 Automated review and human review
Automated tools may assist with identity verification, sanctions and other screening, fraud detection, transaction monitoring, risk assessment, and account or transaction security. Their results may lead to requests for information, additional review, a delay or refusal of a transaction or Service, or restrictions, suspension, or closure of an Account. Human review is available for all compliance processes. Automated review does not prevent Unified from applying its own judgment or taking action required to protect users, the Platform, or comply with law.
Sharing and International Processing#
Unified discloses personal information only as reasonably necessary to provide the Services, carry out the purposes in Section 3, or meet legal and regulatory requirements.
4.1 Service providers and transaction participants
We may disclose personal information to Service Providers that support identity verification, compliance, banking and payment processing, virtual-asset custody or exchange, payment networks, hosting and infrastructure, security and fraud prevention, communications, customer support, analytics, or advertising. This may include Sumsub, banks, payment institutions, custodians, exchanges, and other providers needed for a requested Service.
To process a transaction, we may also disclose relevant information to a recipient, payee, counterparty, account provider, intermediary, network operator, or other participant identified by you or required by the applicable payment or virtual-asset network. We require Service Providers, as appropriate, to receive only information needed for their assigned functions and to protect it through confidentiality, security, and use restrictions. Recipients may also be subject to their own legal duties and privacy policies.
4.2 Legal, compliance, and protection disclosures
We may disclose personal information to regulators, law-enforcement authorities, courts, governmental agencies, auditors, professional advisers, insurers, and other persons when required or permitted by law, legal process, or applicable rules. We may also disclose information when reasonably necessary to investigate suspected fraud, money laundering, security incidents, violations of the Terms, or other unlawful or harmful activity, or to protect the rights, property, safety, and integrity of Unified, users, or others.
4.3 Corporate transactions
We may disclose or transfer personal information in connection with a proposed or completed merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction. We will seek to ensure that a successor or other recipient handles the information consistently with applicable law and the commitments in this Policy.
4.4 International processing
Unified controls servers located in Germany and the United States. Service Providers, financial institutions, custodians, exchanges, and transaction networks may operate in other countries, so personal information may be processed outside the country where it was collected. Unified will apply the safeguards required by applicable law and limit access to authorized purposes, but the laws and protections in another country may differ from those in your country.
Cookies, Analytics, Advertising, and Recordings#
5.1 Cookies and similar technologies
We may use cookies, local storage, pixels, tags, and similar technologies to operate and secure the Platform, remember preferences, understand usage, measure performance, and support advertising and retargeting. You can manage cookies through your browser or device settings, but disabling certain technologies may affect Platform functionality.
5.2 Analytics
We may use Google Analytics and Microsoft Clarity to understand how visitors and users interact with the Platform, diagnose errors, measure performance, and improve the Services. These tools may collect information such as device identifiers, IP address, pages and features viewed, referral information, and interaction data. Their providers may process information under their own privacy policies.
5.3 Logs and session recordings
We may create and retain Platform and server logs and partial session recordings for security, fraud detection, compliance, troubleshooting, and service improvement. Not every interaction is recorded. We configure session-recording tools to exclude or mask sensitive fields, including credentials and financial or identity information that should not be captured.
5.4 Advertising
We may use limited personal information with Google Ads, Meta, and similar providers to deliver or measure advertising and targeting or retargeting. Cookie and similar-technology settings that affect advertising are described in Section 5.1.
Retention and Security#
6.1 Retention
We retain personal information for as long as reasonably necessary for the purposes described in this Policy, to provide the Services, prevent fraud and abuse, resolve disputes, enforce agreements, and meet legal, regulatory, accounting, and reporting obligations. Compliance and verification records may be retained indefinitely and, where a minimum period applies, for at least five years from creation or for any longer period required by applicable law. Other records may be retained for different periods based on their purpose and legal requirements.
When personal information is no longer needed, we will delete it, anonymize it, or securely isolate it, unless we must retain it for a legal hold, an unresolved dispute, security or fraud investigation, or a backup and recovery process. Residual copies may remain in backups until they are overwritten or securely deleted.
6.2 Security safeguards
We maintain technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. These safeguards may include access controls, authentication, least-privilege permissions, monitoring, secure system administration, personnel controls, and procedures for handling security incidents. Access is limited to persons and providers who need it for authorized purposes.
6.3 Security limitations and incidents
No method of transmitting or storing information is completely secure, and Unified cannot guarantee absolute security. If we determine that a security incident requires notification under applicable law, we will provide notice to affected persons or authorities in the manner and within the time required by law. We may limit incident details where disclosure would create additional security, legal, or investigative risks.
Rights, Choices, Changes, and Contact#
7.1 Rights and choices
Depending on your location and applicable law, you may have the right to request access to, correction of, deletion of, or a copy of your personal information, or to request restriction of or object to particular processing. You may also have rights relating to portability or to withdraw consent where processing is based on consent. These rights are subject to legal, regulatory, security, fraud-prevention, and record-retention exceptions.
7.2 Submitting a privacy request
Send privacy requests to [email protected]. Please describe the request and provide enough information for us to locate the relevant records and verify your identity. We may request additional information or authentication, and an authorized representative may be required to provide evidence of authority. We will respond within the period required by applicable law or, where no period applies, within a reasonable period. We may decline or limit a request where permitted or required by law and will explain the reason where we can do so lawfully.
7.3 Communication and marketing choices
Marketing content is sent only to users who join the optional mailing list. You may unsubscribe or change that preference through the available mechanism or by contacting us. Operational messages, including security alerts, transaction notices, and account or service communications, may still be sent when necessary. Cookie and similar-technology choices may be managed through your browser or device settings as described in Section 5.
7.4 Complaints and concerns
Questions or concerns about our handling of personal information may be sent to [email protected]. We will review and respond to complaints in accordance with our procedures and applicable law. Nothing in this Policy limits any right you may have to contact a competent privacy, data-protection, or other regulatory authority.
7.5 Changes and contact
We may update this Policy from time to time. The revised version will state its effective date, and we will provide additional notice through the Platform or by email where a change materially affects how we use personal information and notice is required or appropriate. Questions about this Policy may be sent to [email protected] or by mail to 1001 S Main St Ste 500, Kalispell, MT 59901, United States of America.