Effective Date: November 1, 2025.

INTRODUCTION

Welcome to Tipucino, a digital micro-tipping platform owned and operated by METDAQ LLC, a Florida-registered company. Tipucino is a technology interface, not a financial institution. Tipucino does not:

  • Act as a bank or e-money issuer
  • Hold, store, or control user funds
  • Directly process or settle payments

All financial operations (payment processing, wallet funding, payouts, chargebacks, compliance checks) are performed exclusively by licensed third-party Payment Service Providers (PSPs), such as Stripe and Stripe Connect (“Stripe”).

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to:

  • All Tipucino services and digital products
  • All users of Tipucino (“Users”, “you”) including Senders and Receivers
  • All jurisdictions where Tipucino is made available

This Privacy Policy does NOT apply to:

  • Third-party websites or services that are not controlled by Tipucino
  • PSPs’ own processing of your data (Stripe), which is governed by their separate privacy policies

KEY DEFINITIONS

For the purposes of this Privacy Policy:

  • “Tipucino” – The platform, apps, website, and related services operated by METDAQ LLC.
  • “User” – Any individual or entity using Tipucino.
  • “Sender” – A User who sends a Digital Tip.
  • “Receiver” – A User who receives a Digital Tip.
  • “Digital Tip” – A voluntary electronic transfer of value made through Tipucino using QR, NFC, link sharing, or geolocation tools.
  • “Wallet” – The displayed balance and transaction view shown in Tipucino, sourced from PSP records (Stripe). Tipucino does not hold or control the funds.
  • “PSP Wallet” – The regulated financial wallet maintained by a licensed Payment Service Provider (PSP) such as Stripe.
  • “Geolocation Data” – Location information from your device (with your consent) used to enable “Tip Near Me” and verify proximity-based tipping.
  • “NFC Data” – Device-to-device data exchanged via Near Field Communication to enable tap-based tipping (“Tap-to-Tip”).
  • “Compliance Limits” – Platform-wide transaction limits for all Tipucino wallet actions, designed to comply with U.S. FinCEN MSB thresholds, EU PSD2, UK FCA, FINTRAC, AUSTRAC, and GCC AML frameworks.
  • “KYC” – Know Your Customer identity verification.
  • “AML” – Anti-Money Laundering compliance.

INFORMATION WE COLLECT

We collect information in several categories.

Account & Profile Information

  • Name
  • Display name / username
  • Contact details (email, phone number, where applicable)
  • Country or region
  • Profile photo or avatar (if provided)
  • Business / role (for service staff or agents)

You must not provide false identity information or impersonate others. Misuse may lead to suspension or termination.

Payment & Transaction Information

Processed via PSP (e.g., Stripe):

  • Payment method details (card, bank account, etc.)
  • Payment authorization tokens
  • Transaction IDs, amounts, timestamps
  • Payout and withdrawal information

Visible in Tipucino (display only):

  • Digital Tips you send or receive
  • Wallet balance (as reported by PSP)
  • Transaction history (within Tipucino)

Tipucino does not store or have direct access to full card numbers, bank credentials, or raw payment instrument data. This information is managed and secured by Stripe or other PSPs.

Device, Technical & Usage Data

  • Device type, operating system, app version
  • IP address
  • Device identifiers (e.g., advertising ID, device ID)
  • Log files (actions performed in-app, error logs, crashes)
  • Session metadata (timestamps, access methods)

This data helps us operate, secure, and improve the platform.

Geolocation Data (Tip Near Me)

With your consent, we may collect:

  • Approximate or precise location from your device (GPS, Wi-Fi, IP-based, or network-based)

We use this to:

  • Enable “Tip Near Me”
  • Show nearby staff or agents for tipping
  • Support fraud detection and compliance (e.g., unusual GPS behaviors)

You can disable location permissions in your device settings, but some features may not function.

NFC Data (Tap-to-Tip)

When you use NFC functionality:

  • Device interaction data
  • NFC tag identifiers
  • Transaction context (who tapped, when, and where approximate)

We do not read or store arbitrary personal data via NFC; it is used solely to identify the target tip profile and route your tip request through the PSP.

QR Code Activity

  • QR codes you scan or present
  • Associated user or business profile
  • Time and context of scans
  • Referral or campaign identifiers (if applicable)

We use this to route tips, prevent fraud (e.g., QR spoofing), and monitor misuse.

KYC / Identity Verification Data (Hybrid KYC Model)

Under our Hybrid KYC Policy, we may collect additional information only when required, such as:

  • Government-issued identification (ID, passport, driver’s license)
  • Selfie or biometric confirmation (via PSP-approved provider)
  • Proof of address
  • Tax or business information (if applicable)

KYC is required if:

  • You exceed compliance thresholds
  • You attempt withdrawals or higher-risk actions
  • Suspicious activity is detected
  • A PSP or regulator requests it

Failure to complete KYC may result in limitations or suspension of your account.

Communications & Support

When you contact us:

  • Email content, tickets, and attachments
  • Chat logs or support messages
  • Feedback and survey responses

We use this to respond to you, document issues, and improve service.

Cookies, SDKs & Similar Technologies

We may use:

  • Cookies and local storage on the website
  • Mobile SDKs in the app
  • Analytics tools (e.g., for usage statistics, performance, crash reporting)

These technologies help us:

  • Maintain sessions
  • Measure usage and performance
  • Prevent fraud and abuse

You can manage cookie settings in your browser, and app permissions in your device settings.

HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

Provision of Services

  • To create and manage your Tipucino account
  • To display your Wallet and transaction history
  • To route Digital Tips between Senders and Receivers
  • To enable QR, NFC, and geolocation-based tipping

Payment Processing (via PSPs)

  • To initiate, display, and reconcile transactions with PSPs (Stripe Connect)
  • To coordinate with PSPs for payouts, chargebacks, disputes, and refunds (where applicable)

All actual payment processing is handled by licensed PSPs.

Security, Fraud Prevention & AML/KYC

  • Monitor device/account mismatches
  • Detect abnormal NFC proximity or QR code spoofing
  • Identify unusual transaction velocity or tip cycling between accounts
  • Monitor suspicious GPS behaviors
  • Enforce AML and KYC policies
  • Comply with global regulatory frameworks (FinCEN, PSD2, FCA, FINTRAC, AUSTRAC, GCC AML, and others)

We may freeze transactions, disable profiles or QR/NFC codes, restrict wallet functionality, hold funds (as instructed by PSPs), or terminate accounts in cases of suspected fraud or regulatory requirements.

Disputes & Chargebacks

  • Assist PSPs in resolving disputes between Senders and Receivers
  • Provide logs and metadata as evidence to PSPs or banks
  • Document dispute and decision history

Tipucino does not overrule PSP or bank decisions.

Service Improvement & Analytics

  • Improve app performance, UX/UI, and reliability
  • Analyze aggregated usage patterns
  • Develop new features related to tipping, geolocation, and security

Whenever feasible, we use de-identified or aggregated data.

Legal & Regulatory Compliance

  • Respond to lawful requests from regulators or law enforcement
  • Comply with reporting obligations (AML/CTF, sanctions, fraud)
  • Enforce our Terms of Use and protect Tipucino, METDAQ LLC, our users, and our partners

Marketing & Affiliate Offers

  • Display optional affiliate offers (e.g., financial products, utilities, telecom, NFC/QR accessories)
  • Track affiliate participation for commissions without increasing your cost

Affiliate offers are optional and do not affect your ability to use tipping features. We do not sell your personal financial data.

LEGAL BASES FOR PROCESSING (EEA/UK USERS)

If you are located in the European Economic Area (EEA) or the United Kingdom, we process your personal data under one or more of the following legal bases:

  • Contract – To provide the Tipucino service you request (account, tipping, wallet display).
  • Legal Obligation – To comply with AML/KYC, tax, Sanctions, and financial regulations.
  • Legitimate Interests – To prevent fraud, secure the service, improve functionality, and defend our legal rights.
  • Consent – For certain uses such as geolocation, notifications, or specific marketing communications (where required). You can withdraw consent at any time via device settings or by contacting us.

HOW WE SHARE YOUR INFORMATION

We share your information only as necessary and as described below:

Payment Service Providers (Stripe)

We share:

  • Identity and contact details
  • Transaction metadata (amount, timestamps)
  • Device and risk signals
  • KYC documents (when required)

for purposes of:

  • Payment processing and payouts
  • Fraud detection, AML/KYC compliance
  • Dispute and chargeback handling

PSPs have their own legal obligations and privacy policies.

Service Providers & Vendors

We may share data with vetted third-party vendors for:

  • Cloud hosting and infrastructure
  • Analytics and performance monitoring
  • Identity verification (KYC providers)
  • Customer support tools
  • Security and fraud solutions

These providers are bound by confidentiality and data protection obligations.

Regulators, Law Enforcement, and Legal Requests

We may disclose information when required by:

  • Law, regulation, or legal process
  • Government authorities, financial regulators, or law enforcement
  • Court orders, subpoenas, or similar legal demands

We may also share data to:

  • Protect our rights, privacy, safety, or property
  • Protect the rights, safety, or property of users or the public
  • Investigate suspected fraud or misconduct

Business Transfers

If METDAQ LLC or Tipucino undergoes a merger, acquisition, restructuring, or asset sale, your information may be transferred as part of that transaction, subject to appropriate safeguards.

No Sale of Personal Data

Tipucino does not sell personal data. We do not sell user lists or financial-transaction data to data brokers.

INTERNATIONAL DATA TRANSFERS

Tipucino operates globally. Your data may be processed in:

  • The United States
  • The European Union
  • Other countries where our service providers or PSPs operate

Where required, we implement appropriate safeguards for cross-border data transfers, such as:

  • Standard Contractual Clauses (SCCs)
  • Data Processing Agreements
  • Technical and organizational security measures

DATA RETENTION

We retain data only as long as necessary for:

  • Providing the Tipucino service
  • Meeting legal and regulatory obligations
  • Fraud prevention and dispute resolution
  • Security and audit requirements

Typical retention includes:

  • Transaction logs and metadata (per PSP and regulatory requirements)
  • Device fingerprints and GPS/meta-logs for fraud & AML purposes
  • KYC records (for periods mandated by law)

After the retention period, data is securely deleted or anonymized.

SECURITY MEASURES

We implement appropriate technical and organizational measures, including:

  • Encryption in transit (HTTPS/TLS)
  • Access controls and least-privilege principles
  • Monitoring and logging of security events
  • Use of vetted PSPs for sensitive financial data
  • Periodic review of security practices

No system can be 100% secure, but we take security very seriously and continuously work to improve it.

YOUR RIGHTS & CHOICES

Depending on your jurisdiction, you may have certain rights regarding your personal data, including:

  • Access – Request a copy of your personal data.
  • Correction – Request correction of inaccurate or incomplete data.
  • Deletion – Request deletion of your data (subject to regulatory retention requirements).
  • Restriction – Request restriction of processing under certain conditions.
  • Objection – Object to certain processing (e.g., based on legitimate interest).
  • Portability – Request a copy of your data in a structured, machine-readable format (where applicable).
  • To exercise these rights, contact us at: tipucino.com@gmail.com

CHILDREN’S PRIVACY

Tipucino is intended for users aged 18 and older.

  • We do not knowingly collect personal data from children under 18.
  • If we become aware we have collected data from a minor, we will take steps to delete that data and may terminate the account.

If you believe a minor is using Tipucino, please contact us.

APP PERMISSIONS (APPLE & GOOGLE COMPLIANCE)

Tipucino may request the following permissions:

  • Camera – For scanning QR codes.
  • Location – For “Tip Near Me” and geolocation-based features.
  • NFC – For “Tap-to-Tip” functionality.
  • Notifications – For transaction alerts, dispute updates, and security messages.

You can manage or revoke these permissions in your device settings. Certain features may not work without the necessary permissions.

THIRD-PARTY SERVICES (APPLE, GOOGLE, PSPs, AFFILIATES)

  • Apple and Google are not responsible for Tipucino’s operations, financial transactions, or data processing beyond their own platforms.
  • Payments are facilitated through PSPs (e.g., Stripe), which act as separate controllers or processors for payment data, under their own terms and privacy policies.
  • Affiliate offers are provided by third-party companies; Tipucino is not liable for their products, services, credit decisions, or data handling.

We encourage you to review the privacy policies of all third-party services you use.

DISPUTES, ARBITRATION & RELATIONSHIP TO TERMS OF USE

This Privacy Policy is incorporated by reference into Tipucino’s Terms of Use.

  • Any disputes arising under or related to this Privacy Policy may be subject to the mandatory arbitration and venue provisions set forth in the Tipucino Terms of Use.
  • In case of conflict between this Privacy Policy and the Terms of Use regarding dispute resolution, the Terms of Use control.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

  • Changes to our services
  • Changes in legal or regulatory requirements
  • Security or operational updates

When we make material changes, we will:

  • Update the “Effective Date” at the top of this document
  • Provide notice within the app or website where appropriate

Your continued use of Tipucino after changes become effective constitutes acceptance of the updated Privacy Policy.

CONTACT INFORMATION

For questions, requests, or concerns regarding this Privacy Policy or our data practices, you may contact us at: METDAQ LLC, 250 Seminole Ave, #1, Palm Beach, FL 33480, USA, Email: tipucino.com@gmail.com We will make reasonable efforts to respond within a commercially reasonable timeframe and in accordance with applicable laws.