Privacy Policy

1. Overview

Referral Pilot is an AI-powered referral program app for Clover merchants, operated by Evidence Ventures, LLC (“Evidence Ventures,” “we,” “our,” or “us”). This Privacy Policy explains how we collect, use, store, and share information when you install and use Referral Pilot through the Clover App Market. By installing Referral Pilot, you agree to the practices described in this policy.

This policy complies with Clover's Developer Legal Guidelines and applicable data protection laws including, where applicable, the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR).

2. Information We Collect

When you install and use Referral Pilot, we collect the following categories of information:

• Clover merchant data. Orders, customers, items, payments, and your merchant profile, accessed via the Clover API once you authorize the app. This includes transaction history and customer contact information used to identify and track referrals.
• Referral program data. Referral codes, reward configurations, referral events, redemption status, and program performance metrics generated through your use of Referral Pilot.
• Customer contact data. Names and phone numbers of your customers, accessed through Clover, used solely to deliver referral reward notifications that you configure and approve.
• Account metadata. Your Clover merchant ID, merchant name, and email address associated with your Clover account.
• Usage data. Logs of actions taken within Referral Pilot, such as program configuration changes and approved communications.

3. How We Use Your Information

We use the information we collect to:

• Operate and provide the Referral Pilot service
• Power referral tracking, reward configuration, and performance analytics features
• Send referral-related communications (e.g., SMS reward notifications) only when you explicitly approve each send
• Improve the reliability, accuracy, and features of the service
• Comply with applicable legal obligations and Clover's developer policies

We do not use your data or your customers' data to train AI models for purposes unrelated to operating your referral program.

4. How We Share Your Information

We do not sell your data or your customers' data to advertisers, data brokers, or any other third parties. We share data only in the following limited circumstances:

• Service providers. We share data with third-party vendors strictly necessary to operate the service, such as SMS delivery providers to send referral reward messages you have approved. These providers are contractually bound to use data only for service delivery and may not use it for their own purposes.
• Legal compliance. We may disclose information if required by law, regulation, legal process, or governmental request.
• Business transfers. In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred. We will provide notice prior to any such transfer and offer you an opportunity to opt out.

5. Data Retention

We retain your merchant data and referral program data for as long as your Referral Pilot account is active or as needed to provide the service. If you uninstall Referral Pilot, we will retain your data for up to 90 days to allow for account reactivation, after which it will be permanently deleted from our systems. You may request earlier deletion at any time by contacting us (see Section 7).

6. Security

We implement industry-standard technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. This includes encrypted data transmission (TLS/HTTPS), encrypted data storage, and strict access controls limiting who can access your data. In the event of a security breach affecting your personal data, we will notify you promptly and in accordance with applicable law.

7. Your Rights and Controls

You have the following rights regarding your data:

• Access. You may request a copy of the personal data we hold about you and your account.
• Correction. You may request correction of inaccurate or incomplete data.
• Deletion. You may request deletion of your account data and referral program history by emailing privacy@counterpilot.ai.
• Revoke access. You can uninstall Referral Pilot from your Clover dashboard at any time, which immediately revokes our API access to your Clover data.
• Opt-out of communications. You control all customer-facing communications within the app. No messages are sent without your explicit per-send approval.

8. Children's Privacy

Referral Pilot is designed for use by business merchants and is not directed at individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us immediately.

9. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the “Last updated” date at the top of this page and, where appropriate, by providing notice through the Clover dashboard or via email. Your continued use of Referral Pilot after changes take effect constitutes your acceptance of the updated policy.

10. Contact

Questions or concerns about this Privacy Policy? Contact us at:

Evidence Ventures, LLC
Email: privacy@counterpilot.ai