Privacy Policy

Merchant Whisperer Privacy Policy. Effective date: October 23, 2026. Last updated: October 23, 2026

1. Who we are

This Privacy Policy explains how Living Out US, LLC, a Wyoming limited liability company doing business as Merchant Whisperer ("we," "us"), handles information collected through merchantwhisperer.com (the "Site") and in providing the Merchant Processing Fee Evaluation (the "Evaluation"). We provide payment-processing cost consulting. We are not a payment processor or payment facilitator, and we never hold or handle your processing funds.

2. What this policy covers

This policy covers the Site, the Qualify form, purchase of the Evaluation, the statements and other materials you submit for the Evaluation, and our communications with you. It does not cover third-party websites or services we link to or rely on (such as Airwallex, Apple, and Google), which have their own policies. A later Advisory Agreement may add its own data terms.

3. Information we collect

a. Qualify form. Required: full name, email, phone, business name, monthly card volume (from a menu), current processor or provider (from a menu), and primary concern (from a menu). Optional: website and gateway. The form has no free-text message box, and it asks for your consent to receive non-marketing text messages about your inquiry only.

b. Order and payment information. When you buy the Evaluation, you enter your payment details on a page hosted by Airwallex. We do not receive or store your full card number or security code. We receive limited order information from Airwallex, such as your name, email, the transaction ID, amount, date, payment status, and payment method type (card, Apple Pay, or Google Pay), plus card brand and last four digits where provided by our payment processor. We also keep refund records.

c. Evaluation materials. The processing statements you submit (the most recent 3 months, sent by email to [email protected] or through a secure upload link we provide), and the information in them, such as business and owner names, addresses, processor name, merchant ID, fee and pricing details, volume and card mix, chargeback data, and sometimes partial account numbers. We treat your statements as confidential business information (see Section 6).

d. Communications. Emails, call notes, and texts between you and us, including our order reminders.

e. Automatic information. Like most websites, our setup may record your IP address, browser and device type, pages viewed, links clicked, forms submitted, referring site, and dates and times of visits, and may set cookies and similar technologies, including advertising cookies, pixels, and tags from Meta and Google (see Section 7).

f. What not to send us. Please do not send full payment card numbers or security codes, bank login credentials, passwords, or Social Security numbers. We do not need them. Redact full card numbers from any statement before sending it.

4. How we use information

We use information to:

• Review your inquiry and decide whether our service fits
• Take payment, issue refunds, keep records, and prevent fraud
• Perform the Evaluation and deliver your written report
• Contact you about your inquiry and order, including receipts, reminders (we email reminders around days 7 and 21 after purchase), and delivery of your report
• Send you marketing emails about our services (see below)
• Measure and improve our advertising, and show you our ads on other sites and platforms, including through retargeting and custom audiences (see Section 7)
• Operate, secure, and improve the Site
• Meet legal, tax, and accounting obligations, and enforce our terms

AI tools. We use artificial intelligence (AI) tools to review your statements and to help generate your report. These tools process the information in your statements. We do not use your data to train third-party AI models, to the extent our AI providers' terms permit. AI tools help us review statements and draft reports; they are not used to make decisions about you that have legal or similarly significant effects.

Marketing email. We send marketing emails about our services to people who have submitted the Qualify form, purchased an Evaluation, or otherwise been in contact with us. Every marketing email identifies us as the sender, includes our postal address (1914 Thomes Avenue, Suite 2, Cheyenne, WY 82001), and contains a clear unsubscribe link. We honor unsubscribe requests within 10 business days. Unsubscribing does not stop order, refund, reminder, or report-delivery emails.

Text messages. If you consent on the Qualify form, we may text you about your inquiry only. We do not send marketing text messages. Message frequency varies, and message and data rates may apply. Reply STOP to opt out or HELP for help.

5. Apple Pay, Google Pay, and card data

If you pay with Apple Pay or Google Pay, the wallet provider and Airwallex process the payment. The payment data and the billing and contact details you authorize through your wallet are used only to process the transaction (including any refund or dispute about it) and to detect and prevent fraud. We do not use wallet data for marketing, we do not sell it, and we do not combine it with other data for unrelated purposes. Apple's and Google's own privacy policies govern what they do with your information. We do not store your card data.

6. Confidentiality of your statements

Your statements and the information in them are used only to perform the Evaluation and any advisory engagement you request. We do not use them for marketing, we do not sell them, we do not share them with advertising platforms, and we do not give them to your processor or any other third party unless you ask us to or authorize it in writing. Access is limited to contractors of Living Out US, LLC and Merchant Whisperer, and to our service providers, who need it for those purposes and are bound by confidentiality obligations. We store statements in our CRM and on our own servers (see Section 13), and we delete them as Section 8 describes. We deliver reports as a Google Drive file shared only with your email address, or through an equivalent secure link, and we record delivery and access.

7. How we share information; cookies

We do not sell your personal information for money. We do share limited personal information (identifiers and internet activity) with advertising platforms for cross-context behavioral advertising, which some laws also treat as a "sale," as described below. You can opt out at any time.

We disclose information only to:

• Service providers who help us run the Site and our business, and may use the information only to serve us: Airwallex (payments and fraud prevention); SpringBoard CRM, a white-label of HighLevel (LeadConnector), which hosts the Site, the Qualify form, our customer-relationship management system, and stored statements; our email and communications providers; our AI tool providers (see Section 4); Cloudflare (security and bot protection); and Google (Google Drive, which we use to share your report with you, and fonts loaded by the Site, which may receive your IP address and basic browser information).
• Advertising platforms such as Meta and Google, through the cookies, pixels, and tags described below (identifiers and internet activity only)
• Our contractors, who access information only as needed to perform our services and are bound by confidentiality obligations
• Professional advisers (attorneys, accountants, insurers) under confidentiality
• Authorities or other parties when required by law, or to protect rights, safety, or property
• A successor in a merger, acquisition, financing, or sale of assets, with notice as required by law

Cookies and similar technologies. Our Site uses:

• Necessary cookies and tools, including a Cloudflare cookie named __cf_bm that helps identify bots and protect the Site, Cloudflare Turnstile on the Qualify page, and cookies set by our website platform. These are needed for the Site to work and are not used for advertising.
• Advertising cookies, pixels, and tags from Meta and Google, which we use to run and measure our ads, to retarget Site visitors, and to build custom audiences.

You can block or delete cookies in your browser and use the choices below; parts of the Site may not work as intended.

Advertising and "sharing" of personal information. When you visit the Site, our advertising cookies, pixels, and tags may send identifiers (such as your IP address, cookie IDs, and device and advertising IDs) and internet activity (such as pages viewed, clicks, form submissions, time on the Site, and the page that referred you) to advertising platforms such as Meta and Google. We use this to measure ad performance, show you our ads on other sites and platforms (retargeting), and build custom audiences. This is "sharing" of personal information for cross-context behavioral advertising under California law, and some laws also treat it as a "sale." We do not share your statements, reports, or payment information with advertising platforms, and our advertising tags are not placed on the Airwallex payment page. The platforms handle this information under their own terms and privacy policies.

Your choices: Do Not Sell or Share My Personal Information. You can opt out of this sharing at any time by clicking the "Do Not Sell or Share My Personal Information" link in the footer of every page of the Site (https://www.merchantwhisperer.com/privacy-choices) and turning off advertising cookies, or by emailing [email protected] with the subject "Do Not Sell or Share." We do not require an account to opt out. An opt-out made through the link is saved for the browser you are using, so clearing your cookies may reset it. You can also use the ad settings on Meta and Google.

Do Not Track. The Site does not currently respond to Do Not Track signals.

Global Privacy Control. We honor Global Privacy Control (GPC) signals. When your browser sends a GPC signal, we treat it as a request to opt out of sale and sharing for that browser, and our advertising cookies, pixels, and tags are turned off for it.

8. How long we keep information

Statements. We delete the processing statements you submit no later than 3 months after we receive them, from our CRM and our servers. Copies in routine backups are deleted on the backup cycle, and we may keep information longer only where the law requires it or to resolve a dispute.

Reports. We keep your report for 12 months after delivery (or, if you enter an advisory engagement with us, for the duration of that engagement plus 12 months), unless you ask us to delete it sooner, subject to legal requirements.

Order and payment records. We keep order and payment records for 7 years to meet tax, accounting, and legal requirements.

Qualify-form inquiries. If you do not become a client, we keep your inquiry information for 12 months.

Other information. We keep any other information (such as emails with you) only as long as needed for the purposes above and to meet legal, tax, and accounting requirements.

Advertising and cookie data. Cookies expire as described by the provider that sets them. Information collected through advertising cookies, pixels, and tags is kept by the advertising platforms under their own terms and retention periods, and we keep the audience and campaign data we hold only as long as needed for advertising, subject to platform terms and legal requirements.

9. Security

We use reasonable administrative, technical, and physical safeguards appropriate to the information we handle. No website, email, or transmission is completely secure, so we cannot guarantee absolute security; where available, we recommend the secure upload link over email for statements. If a breach affects California residents' personal information, we will notify affected individuals as required by California law (Cal. Civ. Code § 1798.82).

10. Children

The Site is for business use and is not directed to anyone under 18. We do not knowingly collect personal information from minors. If you believe a minor has sent us information, contact us and we will delete it. We do not sell or share the personal information of anyone we know to be under 16.

11. California privacy information

a. CalOPPA. This policy identifies the categories of personal information we collect, the categories of third parties we disclose it to, how you can review and request changes, how we respond to Do Not Track signals, and its effective date (Cal. Bus. & Prof. Code §§ 22575 to 22579).

b. CCPA/CPRA. The California Consumer Privacy Act, as amended by the CPRA (Cal. Civ. Code § 1798.100 et seq.), applies to for-profit businesses that do business in California and meet a threshold: annual gross revenue above $26,625,000 (the amount adjusted effective January 1, 2025), buying, selling, or sharing the personal information of 100,000 or more California consumers or households, or earning 50% or more of annual revenue from selling or sharing personal information. We do not believe we currently meet any of these thresholds, so the CCPA may not legally apply to us. We have nevertheless chosen to voluntarily follow CCPA-style practices. We do not sell personal information for money, and we share identifiers and internet activity with advertising platforms for cross-context behavioral advertising, as Section 7 describes. Whether or not the CCPA applies to us, we honor the following rights for California residents:

• Know the categories and specific pieces of personal information we hold about you, the sources, purposes, and recipients
• Access a copy
• Correct inaccurate information
• Delete your information, subject to legal and recordkeeping exceptions
• Opt out of sale or sharing, using the "Do Not Sell or Share My Personal Information" link in our Site footer, a Global Privacy Control signal, or an email to us (see Section 7)
• Limit use of sensitive personal information (we do not intentionally collect it)
• Not be discriminated against for exercising these rights

Categories collected in the past 12 months:

| Category | Examples | Source | Disclosed to | | --- | --- | --- | --- | | Identifiers | Name, business name, email, phone, website, IP address, cookie IDs, device and advertising IDs | You; your device | SpringBoard CRM (HighLevel/LeadConnector); email providers; Airwallex; Cloudflare; Google (IP address, fonts); advertising platforms such as Meta and Google (shared for advertising) | | Customer records and commercial information | Order and payment details (no full card numbers); card volume range, current processor, gateway, concerns; statements and fee data; reports | You; Airwallex | Airwallex; SpringBoard CRM (HighLevel/LeadConnector); email providers; AI tool providers; Google (Drive, for report delivery); contractors | | Internet or network activity | Browser and device data, pages viewed, clicks, form submissions, bot-protection signals | Automatically | Cloudflare; SpringBoard CRM (HighLevel/LeadConnector); advertising platforms such as Meta and Google (shared for advertising) |

We do not sell personal information for money. In the categories above, we share identifiers and internet or network activity with advertising platforms such as Meta and Google for cross-context behavioral advertising. We do not knowingly collect sensitive personal information as defined by the CCPA, and we do not sell or share the personal information of anyone we know to be under 16.

How to make a request. Email [email protected] or call (307) 509-0701. We may verify your identity by matching information you give us to what we hold. An authorized agent may act for you with written permission. We respond within 45 days and may extend once by 45 days with notice.

c. "Shine the Light." California residents may request information about disclosures to third parties for their direct marketing (Cal. Civ. Code § 1798.83). We do not disclose personal information to third parties for their own direct marketing, other than as described in Section 7 for advertising.

12. Other states

Other state laws may give you similar rights, including the right to opt out of targeted advertising. We apply the opt-out choices and Global Privacy Control handling described in Section 7 to all visitors, wherever they live, and we will review other requests you send us in good faith.

13. Where information is stored

We serve US merchants. Your information is stored with our service providers (including our CRM provider, our email provider, Google Drive for reports, and Airwallex for payment data) and on our own servers. Advertising platforms store the information they receive under their own terms. Where each provider stores information depends on that provider.

14. Changes to this policy

We may update this policy by posting the new version with a new "last updated" date. Material changes will be highlighted on the Site.

15. Contact

Living Out US, LLC, doing business as Merchant Whisperer 1914 Thomes Avenue, Suite 2, Cheyenne, WY 82001 [email protected] | (307) 509-0701