Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how and why we might collect, store, use, and/or share ("process") your information when you use your Mural account, our Services, when you visit our site at https://muralpay.com (“Site”), or when you engage with us in other related ways, including job inquiries, sales, marketing, or events. 

In this Privacy Policy, “Mural,” “we,” “us,” or “our” refers to the Mural entity providing you with the Service. If you reside in a jurisdiction in which Mural holds a money transmission license, then Mural Networks, Inc. is providing you the Service. If you reside in any other U.S. jurisdiction, Mural Technologies, Inc. is providing you the Service.

Please read this Privacy Policy carefully before accessing or using our Site or Services. Certain capitalized terms that are not otherwise defined in this Privacy Policy are explained in our “Definitions” section below.

We revise this Privacy Policy from time to time to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by emailing your Mural account, or by posting notice of the change on our Site, otherwise the revised Privacy Policy will be effective as of the published effective date.

Overview

Mural may collect your information when you access or use our Services. This information which may include Personal Information or Personal Data, statistical data such as Aggregated and Anonymized Information, and in some jurisdictions Personal Data that is considered Sensitive information.

For most of our Services, we act as a “data controller” or “business,” however there are some situations where Mural may also act as a “data processor” or “service provider” when providing services to our financial institution partner (“Third-Party Financial Institution”). The “data controller” or “business” is the entity that has the control over the purposes and means by which the data processing is performed. The “data processor” or “service provider” is the entity that processes the Personal Information for the data controller, for the data controller’s specific purposes, and as otherwise permitted under applicable laws.

Categories Of Personal Information We Collect

Personal Information Collected from you

Categories of Personal Information and examples we collect from you, including from your interactions with us and your use of the Site or Services include:

• Individual Identifiers and Demographic Information, including your name, business name, address, phone number, email, IP address, device information, information collected from cookies or other tracking technologies, other information necessary to establish a Mural account. 

• Records and Financial Information, including your credit and debit card information, amounts you send or request, and other financial information we may have access to, such as bank account numbers and wallet keys.

• Internet or network activity, including your interactions with our Services, information about response time for web pages, download errors, date and time when you used the Site or Service, IP address, location, browser type, browser plug-in details, operating system, local time zone, date and time of each visitor request (e.g. web pages selected and time spent on each page), referring site and/or search engine, device type (e.g. desktop, laptop, tablet, phone, etc.), language preferences, transaction details, including the purchase, the amount, currency, and method of payment, the websites you visited before coming to the Site and other usage and browsing information collected through Technologies.

• Sensory Information, such as Audio, Visual or other similar information, including Mural account profile pictures and audio records of customer support call recordings when you talk to customer service.

• Professional or employment information, including business information, job title, contact emails, phone numbers and taxpayer ID numbers, employment history, and education history.

• Information you provide when you contact us, including your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account or profile status, repayment history, voice identification, and information about others if you choose to share it with us.

• Sensitive Information, including your social security number, government-issued identification, financial details such as bank account and routing numbers, credit and debit card information, wallet keys, or voice identification and photo IDs.

Personal Information Collected from the following Sources

We may also obtain the above categories of Personal Information from the following categories of sources:

• Third parties: We may collect Personal Information about you from service providers; any Third-Party Financial Institution; payment partners such as payment processors; security, fraud, and similar service providers; previous employers; government entities; or advertising networks, analytics providers, and search information providers.

• Other Users: We may collect Personal Information about you from our users in connection with their use of our Service, including adding you as a user to their organization, or authentication information for funds to be sent to you. 

How We Use Your Information

Overview

We may use and process your Personal Information for a variety of reasons, including to provide our Services, for security and fraud prevention and to comply with law. 

Use

We may use Personal Information to:

• Provide the Services, including for you to access and use our Site and Service, including to send payments, authorize transactions, pay a bill, or contact us. We may also use your Personal Information to provide any other Services we may offer, including for you to attend our events. In providing you with the Service, we also use information we collect to communicate with you, maintain your Mural account, and provide you with support.

• Create an account connection between your User Account and a Third-Party Financial Institution, including if you access or use our Service through a Third-Party Financial Institution, we may use your Personal Information to provide the Services to you through such partnership.

• Communicate with you, including to contact you when you need us, such as answering a question you sent to our customer service team.

• Manage Preferences, including your preferences for the next time you use the Services, such as whether you choose to receive digital receipts via email or text when you checkout.

• Payment Processing, including your payment information in connection with your use of our Service. Please note that we do not store your billing information, but the third-party payment processors we engage may retain your billing information in accordance with their own privacy policies and terms.

• Improve the Services, including to conduct surveys and research, develop new products and features, test those products and features in development, improve the effectiveness of our Site, Service and marketing efforts, and conduct audits and troubleshooting activities. 

• Comply with law, including to comply with applicable laws and rules and enforce our agreements with you and other people who use our Services.

• Investigate misconduct, including to investigate and address any potential misconduct or misuse of our Services. This includes preventing or stopping, or attempting to prevent or stop, illegal activities, protecting the safety and legal rights of ourselves or others, and enforcing our Terms of Use and other agreements. 

• Security and Monitoring, including to diagnose technical issues, conduct audits, and monitor our Service, including unauthorized or illegal use and fraud prevention. In doing so we will protect the rights, safety, and information of our users, third parties, as well as our own. 

• Marketing, including to advertise and market our Services including to send or provide you with advertisements, promotions and offers; analyze whether our advertisements, promotions, and offers are effective; and help us determine whether you may be interested in new products or services.

• Other, including for any purpose described when you explicitly give your consent for us to do so, which can be withdrawn at any time. If we need to use your information for other purposes, we will ask your permission first.

IF WE COLLECT YOUR SENSITIVE INFORMATION, WE DO NOT USE THAT SENSITIVE INFORMATION FOR ANY OTHER PURPOSE THAN FOR YOU TO ACCESS AND USE OUR SERVICE.

Our Legal Basis for Processing Personal Information

If our processing of your Personal Information is subject to certain data protection laws, Mural processes Personal Information on the following legal bases: 

• Contract Performance. When you access and use our Service, you agree and accept the Mural Terms of Service, which is a contract between you and Mural, and we process your information to provide you with the Service based on performing that contract. 

• Consent. We rely on your consent to use your Personal Information under specific circumstances, including when you decide to participate in any Mural events, research project, beta program, or surveys; when you contact us or inquire about a job; or for marketing purposes, where applicable. We may also rely on your consent when you interact with our Site. You may withdraw your consent at any time.

• Legitimate Interests. Generally, the remainder of the processing of Personal Information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of Mural’s systems, Site and Service.

Who And How We Disclose Personal Information 

Overview

We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any Sensitive Information. 

We will disclose your Personal Information with third parties to help us provide our Services, protect our users from risk and fraud, market our products, and comply with legal obligations. 

IF WE DISCLOSE YOUR SENSITIVE INFORMATION, WE DO NOT DISCLOSE THAT SENSITIVE INFORMATION FOR ANY OTHER PURPOSE THAN FOR YOU TO ACCESS AND USE OUR SERVICE, OR AS APPROPRIATE TO CARRY OUT LEGITIMATE BUSINESS ACTIVITIES ALLOWED OR REQUIRED BY LAW.

How We Disclose Personal Information

We may disclose Personal Information with the following categories of parties, including third parties:

• Mural. Mural will share your Personal information with its employees, agents, and affiliates who are authorized by us to access it, and for the purpose of providing you with the Services or as required by law. 

• Collaborating Organizations and Partners. We may collaborate with other organizations to further provide you with services or other events. In these cases, we may disclose your Personal Information when you sign up or inquire about the additional services.

• Service Providers. We work with a wide range of third-party service providers who help provide and make the Services accessible. These include contractors, system integrators, auditors, and others. Mural and our service providers may disclose your Personal Information with each other and use it consistent with this Privacy Policy. We may disclose your Personal Information with such service providers, so long as those parties agree to keep your Personal Information confidential.

• Other Users. We may disclose your Personal Information to other users, including organizations who invite you to access and use our Service or send you payments on or through our Service. Please remember that any information you share in public areas of our Site or Services, such as on message boards, feedback sections or reviews, becomes public and anyone may take and use that information. Please be careful about what you disclose in these portions of our Site or Service and do not post any Personal Information that you expect to keep private. 

• Third-Party Financial Institutions and other financial institutions. We may disclose your Personal Information to financial institutions with whom you have a relationship in order to fulfil our obligations and provide our Services.

• Payment Processors. We may disclose your Personal Information to facilitate payment processing. 

• Fraud Prevention and Identity Verification Agencies. We may disclose your Personal Information to verify you or your organization’s identity and transaction through our Service. 

• Authorities. We may be required by law to disclose your Personal Information, when it is necessary to conform to legal requirements or comply with legal process. We may also use your Personal Information to protect our intellectual property and enforce the Agreement.

• As Part of a Merger or Sale of Business. We may disclose your Personal Information in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Personal Information Retention, Protection And Location

How Long We Retain Your Personal Information

We retain Personal Information for as long as needed or is permitted in the context of the purpose for which it was collected and consistent with applicable law.

• Personal Information used for the Service is stored for the duration of the relationship plus a period of up to 1 year, unless we need to keep it longer, such as:

  • a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under applicable bankruptcy laws and anti-money laundering obligations

  • litigation, investigations, audit and compliance practices, or to protect against legal claims.

• We retain certain audio data for as long as needed or permitted given the purpose for which it was collected and no more than 1 year after your User Account closes, unless otherwise required by applicable law.

How We Protect Your Personal Information

We take reasonable technical and organizational measures to protect the confidentiality, security, and integrity of your Personal Information. The security measures include firewalls, data encryption, physical access controls to data centers, and information access authorization controls. Although we use security measures to help protect your information against loss, misuse, or unauthorized disclosure, we cannot guarantee the security of Personal Information transmitted to us over the Internet. You remain responsible for maintaining the privacy of your Mural account, including passwords. While we strive to use commercially acceptable means to protect your Personal Information, including aggregating and anonymizing information, there is no guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed.

The Personal Information we collect is stored on servers located in the United States. 

Use Of Cookies And Tracking Technology

Use of Technologies

When you interact with our Services, open email we send you, or visit a third-party website for which we provide Services, we use cookies and other tracking technologies such as pixel tags, web beacons, and widgets (collectively, “Technologies”) to recognize you as a user, customize your online experiences and online content, including to serve you interest-based advertising, perform analytics; mitigate risk and prevent potential fraud, and promote trust and safety across our Services.

We use Technologies to collect statistical information about the ways you use our Service including which pages you visit, which links you use, and how long you stay on each page. Mural may also use Technologies to create a database of your previous choices and preferences, saving you time and effort. When you first access our Service, you will receive a message advising you that cookies are in use. By continuing to browse the Site or use the Service, you agree to our use of cookies as described here. The use of Technologies by third parties is not covered by our privacy policy, as we do not have access to or control over their cookies.

We use Technologies to collect your device information, internet activity information, and use such data as described above. You can disable or decline some Technologies for our Services. But, since some parts of our Site or Service rely on Technologies to work, those services could become difficult or impossible to use.

Restricting the Use of Technologies

Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.

To learn how to opt-out of this kind of tracking technology, visit About Ads.

Opting Out of Advertising. If you wish to limit third parties’ collection of information about your use of our Services, you can opt-out of such marketing through the Digital Advertising Alliance or Network Advertising Initiative. Please note that opting out of behavioral advertising does not mean that you will not receive advertisements while using our Services. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. Please note that cookie-based opt-outs are not effective on mobile applications. That said, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

We may also utilize certain forms of display advertising and other advanced features through third-parties such as Google Analytics, (Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting). You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available here, or by visiting NAI’s online resources on their website.

Minors And Children's Privacy

Neither our Site and Service, nor any other services provided by or through Mural, are directed or intended to be used by individuals under the age of 18; if you are not 18 years or older, do not use our Services. We do not knowingly collect Personal Information from children under the age of 18 unless a parent has consented to it. If we learn that Personal Information of persons less than 18 years-of-age has been collected through our Services, we will take the appropriate steps to delete that information. If you are a parent or guardian and discover that your child or a minor under the age of 18 has posted, submitted, or otherwise communicated Personal Information to our Service without your consent, then you may alert us at support@muralpay.com so that we may take appropriate action to remove the minor's Personal Information from our systems. 

International Users

If you are located in another jurisdiction, you should be aware that once your Personal Information is submitted through our Service, it will be transferred to our servers in the United States. By visiting our Site, using our Service, or providing us with any Personal Information, you consent to the transfer, processing and storage of your Personal Information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside, and that the United States currently does not have uniform data protection laws in place.

Third Parties

Our Site may contain links to third party websites, applications and services not operated by Mural, including those provided by our service providers and Third-Party Financial Institutions. Our Privacy Policy only covers the information Mural collects, uses, and discloses to provide our Services. Our Privacy Policy does not explain what third parties do with any Personal Information we provide them or any information they collect about you independently from us. Our Privacy Policy also does not cover any websites, products, or services others provide. We encourage you to review their privacy policy, terms of use, or other published information to learn how they use, collect, and disclose your information.

Changes To Our Privacy Policy

We reserve the right to update this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting. If we make material changes to this privacy policy, we will notify you by email via the primary e-mail address specified on your User Account or through a notice on Site or Service. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you or if you do not have a Mural account, and for visiting our Site and this Privacy Policy to check for any changes. Your continued use of our Services following posting of any Privacy Policy changes constitutes your acceptance of such changes. The effective date of this Privacy Policy, and the last revised date is identified at the top of the page. 

Contact Us

If there are any questions regarding this privacy policy, you may contact us at support@muralpay.com.

Definitions

Personal Information or Personal Data. “Personal Information” or “Personal Data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular person. Personal Information does not include Aggregated or Anonymized Data. 

Aggregated and Anonymized Data. “Aggregated and Anonymized Data” means that the information is only viewable in groups and as part of a summary, not per the individual, or that the information can no longer reasonably be linked to a particular person or household. Aggregate and Anonymized Data is not Personal Information as personal identities have been removed and is not linked or reasonably likely to link any one individual or household.

Sensitive Information. “Sensitive Information” is a specific subset of Personal Information that includes different types of Personal Information depending on the jurisdiction in which you reside. Sensitive Information may include financial account information, account access credentials, precise geolocation or other data such as health data, genetic data, or biometric information.

Services. “Services” means any software, systems, and services that Mural provides to you, including facilitating payments for goods and services through stablecoins, providing a cloud-based software-as-a-service platform that provides payment processing, transaction management, and financial technology solutions built on Stablecoin payment rails, providing technology and application software on a hosted basis, and other services you receive through Mural via the Site or any other medium.