Introduction
At ePon, we connect people with the best services in their communities by enabling businesses to meet consumers’ needs for convenience and ease, while also creating new opportunities for individuals to earn, work, and live better.

This Privacy Policy (“Policy”) describes how ePon, LLC and its affiliates (“ePon,” “we,” “our,” or “us”) collect, process, retain, and disclose your Personal Information when providing our services. These services include, but are not limited to, our consumer platforms, websites, and mobile applications, any website, platform, or application that links to this Policy, and all channels of communication (collectively referred to as the “Services”).

This Policy does not apply to couriers or other contractors, or to the personnel of Merchants, Service Providers, or Vendors, which are subject to separate privacy policies.

What Personal Information does ePon collect or process?
Personal Information refers to any information that ePon can reasonably use to identify you, either on its own or when combined with other data. Anonymous information and data that has been de-identified so it cannot identify you are not considered Personal Information.

We may process the following categories of Personal Information in connection with our Services:

• Contact Information: Includes name, address (e.g., home, work, or delivery address), email addresses (support@epon.app, contact@epon.app), phone number (1-860-786-9888), and other contact details provided to us.
• Account and Profile Information: Includes username and credentials, privacy settings, notification preferences, pictures, information added to your ePon profile, and any subscription details like memberships or identifiers linked to your account.
• Identification Documentation and Signature for Age-Restricted Products: May include driver’s license or other government-issued IDs, processed in limited situations like orders for age-restricted items (e.g., alcohol) or to comply with legal regulations.
• Communications with ePon, Couriers, and Merchants: Includes the content of messages exchanged through our app, SMS/texts, phone calls, emails, and customer support inquiries related to our Services. We may record and retain call details, including the date, time, and outcome of these communications.
• Content You Create or Share: Includes reviews, ratings of couriers, service providers, and merchants, as well as any photos you upload.
• Payment Information: Includes credit or debit card details and payment method data (e.g., PayPal, Venmo), primarily stored and processed by our third-party payment processors. We may retain limited payment-related information such as the last four digits of your card or the payment service used.
• Activity and Transactions: Information about your orders, order history, delivery preferences, transaction amounts, promotional codes, and special programs (e.g., referral or loyalty programs) as well as any searches and interactions within our Services.
• Geolocation Information: If you allow location access, we may store your precise location when our app is running in the foreground or background. You can opt out of location sharing by following these steps: a. Open the ePon consumer mobile app.
  b. Tap the account icon at the top right of the screen.
  c. Under “Account Settings,” select “Privacy.”
  d. Under “Location Access,” choose your desired location-sharing preferences.
• Device Information: This includes information about the devices you use to interact with ePon or our Services, including IP addresses, device identifiers, operating system and version, browser details, and preferred language.
• Information from Co-Branded or Third-Party Offers: We may collect information used to register for third-party offers or co-branded products, such as when you sign up for promotions in partnership with other companies.

Some of the information you provide to us (e.g., government-issued IDs and signatures for age verification, precise location data) may be considered sensitive Personal Information under certain jurisdictions. We collect and process this data to comply with legal requirements and ensure the accuracy of services like delivery or product access. You can disable precise location tracking at any time in your app settings. ePon does not use sensitive Personal Information for any purpose beyond what an average consumer would reasonably expect for legal, security, and service provision purposes. We do not attempt to re-identify de-identified data unless permitted by law.

For more details on age and identity verification, visit our FAQs on alcohol delivery.

The rest of the policy will continue with further descriptions of how data is used, stored, and shared under ePon’s specific services, covering categories like courier delivery, pharmacy services, service providers, hotel bookings, vacation rentals, and on-demand or scheduled taxi services.

III. How does ePon collect or receive Personal Information?

From Users of Our Services:
We collect information directly from users of our Services during activities such as account or profile creation and updates, placing orders, participating in surveys, sweepstakes, promotions, or contests, posting content such as photos or reviews, contacting us, uploading or syncing contacts, or signing up for additional Services or programs (e.g., membership programs, referrals, or gift programs). If a user provides Personal Information about others (such as through referral or gift programs), the user affirms that they have obtained the necessary rights and consents to share that information with us.

Automatically Through Our Services:
When you use our Services, some Personal Information is collected automatically from your device or browser.

Through Cookies and Similar Technologies:
Cookies are small text files placed on your device, often via your browser, and are used to record information such as settings. Depending on your preferences, certain Services, including our website at https://epon.app, may gather information from or through cookies or similar technologies (e.g., pixels, software development kits).

From Our Service Providers:
We may receive Personal Information from service providers working on our behalf, including communication service providers (e.g., email or SMS/text message providers), payment processors and providers (such as PayPal and Venmo), market research service providers, those handling promotions, sweepstakes, and contests, gift card program providers, as well as marketing, advertising, analytics, security, fraud prevention, and identity/age verification services.

From Partners:
We may also receive Personal Information from business partners in connection with co-branded or third-party offers you engage in through ePon and its partners.

From Employers:
If an employer has signed up for specific programs or Services offered by ePon, we may receive certain Personal Information from them to facilitate your use of our Services.

From Merchants:
If a Merchant has integrated their loyalty program with our Services, we may receive Personal Information from the Merchant related to the integration. This might include identifying users who are members of the Merchant’s loyalty program or creating a link between the user’s ePon account and the Merchant’s loyalty program to provide loyalty benefits or discounts.

From Legal Claims, Disputes, Requests, and Orders:
We may collect Personal Information from third parties or other individuals, such as law enforcement agencies, government authorities, users and non-users of our Services, or any party involved in a legal matter.

IV. How does ePon use Personal Information?

Depending on which Services you use and how you interact with us, ePon may use your Personal Information (as described in Section II above) for the following purposes:

To Provide and Customize ePon Services:
This includes allowing you to place and pay for orders, facilitating the orders you place through our Services, recommending and ranking Merchants or Service Providers based on your searches, location, reviews, and order history. If you have uploaded or synced your contacts, we may also use this information to suggest businesses your contacts have used (without disclosing specific order details of your contacts). We also facilitate participation in promotions, sweepstakes, and contests, as well as provide special offers, and enable the purchase or ordering of gift cards. We will display reviews, photos, and other content you post publicly and customize your experience based on your preferences, location, and past interactions with our Services.

To Provide Customer Support:
This includes handling communications with you, investigating, analyzing, and resolving support issues, including matters related to service delivery. We evaluate and improve our customer support services to ensure that issues are managed in line with our internal standards and applicable legal requirements.

To Develop, Analyze, and Improve Our Services:
We use your data to understand how you and other customers use our Services, identify your preferences, and improve or develop new services. This includes debugging, troubleshooting, and testing to provide the best experience possible.

To Advertise and Promote ePon and Our Services:
We may display advertising related to our Services or partner Merchants on our own platforms as well as on third-party websites. We also use data to improve and implement marketing campaigns, assess their effectiveness, and deliver ads that are relevant to you based on your interactions with ePon. To opt-out of personalized advertising on third-party platforms, please review your right to opt-out as described below.

To Facilitate Communications with ePon, Couriers, and Merchants:
This includes communicating with you about our Services, service updates, orders, and account-related matters, as well as changes to our terms and policies. We also facilitate communication between you, couriers, service providers, and Merchants as necessary to ensure a smooth service experience.

For Authentication, Integrity, Security, Quality, and Safety:
We use Personal Information to verify your account and identity as necessary, provide a secure payment and service environment, detect and prevent fraudulent or illegal activities, and ensure age-restricted orders are delivered to the appropriate recipient. This also includes taking steps to protect your safety, the safety of others, and securing the integrity of our Services.

For Legal Reasons and Policy Compliance:
We may use your Personal Information to comply with applicable laws and respond to valid legal processes such as law enforcement requests, court orders, or regulatory obligations. This also includes participating in civil litigation or legal proceedings, investigating violations of our terms or policies, complying with tax requirements, performing audits, and enabling you to exercise your legal rights as required.

V. ePon’s Disclosure of Personal Information

Depending on which ePon Services you use or interact with, ePon may provide or disclose Personal Information (as described in Section II above) as follows:

To Service Providers:
To meet our business operations needs and perform our Services, we may provide Personal Information to our service providers and vendors. These providers include, but are not limited to, those offering identification and verification services, cloud services, payment services, gift card program services, auditing services, security services, marketing and advertising services, promotions, sweepstakes and contest services, market research services, communication services, and analytics services that help us understand usage of our Services. They also include providers for customer support, market enrichment, location, and mapping services. These service providers may access, store, and process your Personal Information outside your country of residence, including, without limitation, outside of the United States, Canada, Australia, and New Zealand.

To Couriers:
To facilitate the delivery of your orders, we disclose some information to couriers, such as the recipient’s name (e.g., first name and last initial), delivery address, location information (if location sharing is turned on), masked phone numbers, order details (which may include information about the products ordered), and user instructions (e.g., special delivery instructions). In some cases, for verification purposes, we may ask that the recipient provide a PIN to the courier to confirm the delivery.

To Merchants:
We disclose Personal Information to Merchants in connection with the preparation and delivery of orders. This includes sharing necessary details for preparing the product or service and facilitating its delivery (whether by a courier or the Merchant’s delivery service). Merchants may also use this information to communicate with you via phone, email, or SMS about your order and its delivery. Merchants are solely responsible for all communications they initiate. Additionally, if you pick up an order from a Merchant and have enabled location sharing, we may use your location to inform the Merchant when you are arriving to pick up your order.

Publicly:
We may display content you choose to share publicly, such as reviews or photos of your orders, to allow other users to learn about your experiences with Merchants and service providers on our platform.

To Marketing and Advertising Partners:
We may use third-party marketing and advertising partners to deliver advertisements on behalf of ePon or our Merchants, including ads that may be personalized based on your interactions with our Services and your activity on third-party services.

For Actual or Potential Corporate Transactions:
If ePon is involved in a strategic transaction, such as a sale, merger, acquisition, joint venture, assignment, transfer, reorganization, bankruptcy, or receivership, we may disclose your Personal Information as part of the due diligence process. This information may be transferred to a successor or affiliate as part of the transaction along with other assets.

To Government Authorities or Where Legally Required or Permitted:
We and our service providers may share your Personal Information with government authorities or other third parties as legally required or permitted. This includes enforcing our agreements, preventing fraud, and protecting the rights, property, and safety of ePon, its employees, Merchants, couriers, customers, or others. These disclosures may also include lawful access by U.S. or foreign courts, law enforcement, or government authorities.

ePon’s Group of Companies:
We may disclose your Personal Information to our corporate subsidiaries and affiliates in connection with our Services and business activities, for use in connection with the purposes outlined in this Policy.

Other Third Parties or Persons:
We may disclose your Personal Information to third parties or individuals at your direction, with your consent, or in connection with other activities. This may include individuals to whom you send gifts or refer ePon Services, in connection with co-branded opportunities, when linking accounts with third-party platforms, or when using ePon Services through your employer’s partnership with our platform.

VI. Your Privacy Rights and Choices

Your Privacy Rights

We provide tools and processes to help you manage and make choices regarding your Personal Information. Depending on your jurisdiction, and subject to applicable exceptions, exemptions, and restrictions, you or your authorized agent may exercise the following rights:

• Access/Portability: You may have the right to request access to your Personal Information and receive it in a portable and machine-readable format.
• Deletion: You may have the right to request the deletion of your Personal Information, including your ePon account. Please note that doing so may impact your ability to use the Services. We will keep a record of all rights requests and may retain limited Personal Information in connection with these records.
• Correction: You may have the right to correct, rectify, or update any inaccurate Personal Information that we hold about you.
• Opt-Out of Sale or Sharing (Targeted Advertising or Ads Personalization): We may disclose Personal Information (e.g., identifiers and platform usage data) to advertising partners for the purpose of providing personalized ads on third-party platforms, which may be considered a "sale" or "sharing" of your Personal Information. You have the right to opt-out of the sale or sharing of your Personal Information. To opt-out, please use the “Do Not Sell or Share My Personal Information” link on epon.com or go to www.epon.com/consumer/personalize. If you're not logged in, you can also opt-out by disabling Ad Personalization for a specific browser. To access our browser-level opt-out option, click here. To associate your opt-out choice with your registered account, log in and turn off personalization. You can also opt back in using the same methods.

You may also enable global privacy controls (GPC) with your browser, where available, to automatically communicate your opt-out preferences to us when using said browser. We will treat this as equivalent to opting out through the browser-level opt-out option mentioned above.

• Right to Appeal: You may have the right to appeal decisions regarding your rights requests.
• Right to Withdraw Consent: If your consent is legally required for the processing of your Personal Information, you may withdraw it at any time (subject to our legal or contractual restrictions and reasonable notice). Please note that withdrawing consent may affect our ability to provide certain services.

ePon will not discriminate against you for exercising any applicable rights. We reserve the right to deny your request if we cannot verify your identity or if an exception or exemption applies.

Exercising Your Rights

If you have an ePon account, you can exercise certain rights directly through your account. We provide the ability to update and correct your account information within the account settings. To exercise your right to access or delete your Personal Information, please see:

For ePon, you can exercise these.
For Service, you can exercise these rights.

If you have any questions on how to exercise your rights or do not have an account, you can contact us at privacy@epon.com. We will respond in a timely manner in accordance with applicable laws. You may also contact us via our toll-free number at (855) 973-1040 to exercise your rights. When contacting us, please provide your first and last name, email address, residency address, and specify the right(s) you wish to exercise. Let us know if you are a user, non-user, or part of another grouping.

For rights requests submitted by authorized agents, please email privacy@epon.com with the following information:

• First and last name and email address for both the data subject and the authorized agent.
• Evidence of authority granted to the agent (e.g., power of attorney).
• Information on the data subject’s relationship with ePon (e.g., registered user, non-user).
• The specific rights being exercised.
• "Authorized Agent Request" in the subject line.

Additional Choices

Communication Preferences:

To manage promotional and marketing notifications and emails, follow these steps:

Notification Preferences for Mobile App Users:

• Select Account and scroll to Account Settings.
• Select Notifications.
• Turn off specific notifications by sliding the toggle (e.g., Store Offers, ePon Offers, and Recommendations).

Email Preferences Through Unsubscribe Functionality:

• Promotional emails include an opt-out option at the bottom. Click Unsubscribe.
• After selecting Unsubscribe, choose which types of emails you wish to stop receiving (e.g., ePon Offers, Store Offers, Recommendations).

To opt out of receiving marketing SMS for consumer platforms/services, reply STOP to any marketing SMS or text STOP.
To opt out of all transactional SMS, reply STOP to a transactional SMS.
To stop receiving all communications, you must delete your account.
To stop seeing in-app messages, you must delete your account.

For co-branded credit card offers, to stop receiving certain pre-screened offers of credit from participating credit reporting agencies (including pre-screened offers from us), call 1-888-567-8688 or visit www.optoutprescreen.com.

You can learn more about interest-based advertising and how to opt-out of tailored ads by visiting the Network Advertising Initiative’s Consumer Opt-Out link or the Digital Advertising Alliance opt-out options via https://digitaladvertisingalliance.org/. These links are provided for convenience; ePon is not responsible for compliance practices of the companies managing the opt-out processes.

VII. Additional Jurisdiction-Specific Disclosures

1. United States:

a. California:

i. Notice at Collection:

• For details on the categories of Personal Information collected, refer to Section II of this Policy.
• For details on the sources from which we collect Personal Information, refer to Section III of this Policy.
• For details on the purpose(s) for which Personal Information is collected or used, refer to Section IV of this Policy.
• For details on the categories of third parties to whom we may disclose your Personal Information, refer to Section V of this Policy.
• For details about ePon's selling or sharing of Personal Information, refer to Section VI of this Policy.

*Deletion requests include requests to delete Personal Information as a privacy right and requests for account management, such as deleting accounts.

• Individuals can update or correct their Personal Information directly through their account.

b. Nevada:

• Nevada residents have rights under Nevada Revised Statutes Chapter 603A (Security and Privacy of Personal Information), which applies to "Covered Information" such as name, physical address, email, phone number, and social security number.
• While EPon does not believe it sells Covered Information under Nevada Privacy Law, Nevada residents can still opt-out of the sale or sharing of Personal Information through the same mechanisms provided under other data protection laws.

c. Consumer Health Data Privacy Disclosures (Connecticut):

i. Our Collection of Consumer Health Data:

• We collect health-related data, including:
  • Allergies or other conditions: You may disclose this information through free-text fields when ordering food or other products.
  • Product Purchase Information: Your purchase history of health-related items (e.g., contraceptives, diabetic supplies) may indicate health status.
  • Activity on our Services: Searches, browsing, or interaction with health-related products, or submitting related content, may reveal health data.
• De-identified information remains de-identified, and we do not attempt to re-identify it.

ii. Sources of Consumer Health Data:

• We collect Consumer Health Data from the following:
  • Your use of Services: Information may be collected during order placement and interactions with health-related content.
  • EPon account holder on your behalf: Information may be collected if an account holder orders on your behalf.
  • Communications: We may collect health data from customer support inquiries or communications.

iii. Purposes for Collecting and Using Consumer Health Data:

• We use Consumer Health Data for:
  • Providing EPon Services: To enable you to place orders, facilitate deliveries, and make recommendations.
  • Customer Support: For communication, issue resolution, and improving support processes.
  • Service Improvement: To debug, troubleshoot, analyze, and improve our Services.
  • Security and Legal Compliance: To ensure safety, detect fraud, and comply with legal obligations.

iv. Sharing Consumer Health Data:

• We may share Consumer Health Data with:
  • Dashers: To facilitate deliveries, including disclosing names, addresses, order information, and special instructions.
  • Merchants: To process orders, including disclosing names, addresses, and order details.
  • Service Providers: To assist in delivering services, such as payment, IT, fraud prevention, and customer support.
  • Government Authorities: As required or permitted by law, including fraud prevention and rights protection.
  • Corporate Transactions: During mergers, sales, or other strategic transactions.
  • Other Third Parties: With your consent or direction.

v. Your Privacy Rights:

• EPon will not discriminate against you for exercising your privacy rights. Subject to legal restrictions, you may have the following rights concerning Consumer Health Data:
  • Access: Request access to your Consumer Health Data in a portable format.
  • Deletion: Request deletion of your Consumer Health Data.
  • Withdraw Consent: Withdraw consent for the collection or sharing of Consumer Health Data.
• Exercising Rights:
  • If you have a EPon account, you can exercise certain rights through your account.
  • Contact us at privacy@ePon.com or call our toll-free number (855) 973-1040 to exercise your rights. Provide your full name, email, and residency address, and specify the rights you wish to exercise.
• For authorized agent requests, include:

1. First and last names of the data subject and authorized agent.
2. Evidence of agent authority (e.g., power of attorney).
3. The data subject’s relationship with EPon.
4. The specific rights being exercised.
5. “Authorized Agent Request” in the subject line.

• If your rights request is denied, you may appeal the decision by contacting us. If you are a Washington resident, you may also lodge a complaint with the Washington State Attorney General.

VIII. Security and Retention

We implement commercially reasonable administrative, organizational, technical, and physical security controls to protect your Personal Information from unauthorized access, modification, disclosure, or destruction. However, we cannot guarantee that your Personal Information is completely secure, as no Internet or email transmission is entirely secure or error-free. You should exercise caution when deciding what information you share with us through our Services, email, SMS/text messages, chat, or other communication methods. Additionally, we are not responsible for the circumvention of privacy settings or security measures on our Services or third-party websites. We encourage you to take appropriate precautions to protect your Personal Information. If you believe that your ePon account or interaction with us is no longer secure, please contact ePon support immediately, as detailed in Section XII (How to Contact Us) of this Policy.

We retain your Personal Information only as long as necessary to provide our Services and for the purposes described in this Policy, unless a longer retention period is required by law.

The criteria used to determine our retention periods include:

• The time necessary to fulfill the purposes for which we collected the information.
• The duration and status of your relationship or connection with us, including whether your account is active.
• Any retention period required by legal, regulatory, or government requirements, including the time during which civil claims or regulatory actions may be filed or commenced, and the period needed to resolve ongoing legal proceedings.
• Our internal obligations, contractual commitments (including those with Merchants), and other relevant requirements.

IX. Cross-Border Transfers of Personal Information

The Personal Information processed in connection with this Policy, including, without limitation, by us and/or our third-party service providers, may be stored and processed on systems and servers and accessed by persons and parties located outside of the jurisdiction where you live (including, without limitation, outside of Australia, Canada (including outside of the province in which you live), New Zealand, and the United States). This includes storing, accessing, and processing the Personal Information in the United States and other global locations whose data protection laws may differ from those where you live.

X. Personal Information from Children

Our Services are not intended for individuals under the age of majority in applicable jurisdictions, which means that our Services are not intended for individuals under the age of 18. Therefore, we do not knowingly process Personal Information from individuals under 18 years old.

For compliance with the California Consumer Privacy Act of 2018 (as amended), ePon also does not knowingly sell or share the Personal Information of consumers under 16 years of age. Additionally, we do not knowingly collect Personal Information from individuals in the Province of Quebec, Canada, who are under the age of 14. If a parent or legal guardian of a child under the applicable legal age believes that we have collected Personal Information from or about such an individual, please contact us at privacy@epon.app.

XI. Third-Party Sites

Our Services may link to other third-party websites that are not controlled by ePon, such as when you sign up for a loyalty card on a Merchant’s website or interact with other service providers. These third parties are not under our control, and we are not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party websites, it will be subject to the privacy policies and practices of that third party.

XII. How to Contact Us

For questions or concerns related to this Policy, please contact us at privacy@epon.app or:

ePon, LLC
Attn: Legal
PO Box 321, Willimantic, CT 06226
Help Form: https://epon.app/

Email:
support@epon.app
contact@epon.app

XIII. Changes to this Privacy Policy

We may update this Policy periodically to account for changes in how we collect and process your Personal Information. Any updates to this Policy will be posted on our website with a revised “Last Updated” date at the top, and we will provide additional notice in the event of any significant changes in how we use your Personal Information. Your continued use of our Services after any updates to this Policy constitutes your agreement and acceptance of this Policy as updated.