Tippal — Terms of Service and Privacy Policy

1. About TipPal

TipPal is the first app dedicated exclusively to processing gratitude expressed through tips and thank-you gifts, available to all sectors (rideshare, restaurants, hotels, valet parking, housekeeping, digital content creators, and any person or business that wishes to give or receive gratitude directly and transparently), and not only to the traditional service industry. The Service initially launches in Orlando, Florida, United States, with planned expansion throughout the United States.

TipPal is not a bank, is not an independently authorized money transmitter, and does not offer FDIC-insured deposit accounts. TipPal facilitates payment processing between users through its payment processing provider, Stripe, Inc.

2. Acceptance of the Terms

By creating an account or using TipPal, you confirm that:

• You are at least 18 years of age.
• You have read, understood, and accepted these Terms of Service in their entirety.
• You have the legal capacity to enter into this agreement under the laws of your jurisdiction.
• Your use of the Service complies with all applicable federal, state, and local laws of the United States.
• You consent to receive these Terms and all related communications electronically, in accordance with the Electronic Signatures in Global and National Commerce Act (E-SIGN Act, 15 U.S.C. § 7001 et seq.).

TipPal Corp may modify these Terms at any time. Continued use of the Service after a modification constitutes acceptance of the new terms.

3. The Account and the Balance

3.1 Nature of the displayed balance

The balance displayed in the app is an accounting record of credit (a pending settlement in your favor), and does not constitute a bank deposit, a securities account, or an insured financial product. The funds corresponding to that balance are processed and held by TipPal through its payment processor (Stripe) under TipPal's processing credentials, not under an individual user account, until the applicable verification requirements are completed.

3.2 Processing model (Payment Facilitator / Master Merchant – Sub-merchant)

TipPal operates under a payment platform model (Payment Facilitator), analogous to a mobile point-of-sale device assigned by an employer to a salesperson: the user processes charges using TipPal's processing credential, not a bank account of their own. Under this model:

1. The user expressly authorizes TipPal to process charges on their behalf, without this making TipPal the ultimate owner of the funds.
2. The displayed balance is a pending settlement, not a deposit.
3. Withdrawal (cash out) is subject to the identity verification (KYC) required by applicable regulation and by the payment processor.
4. TipPal is not a financial institution; it is a technology platform for payment processing that operates together with a registered payment processor (Stripe).
5. TipPal maintains sufficient operating reserves to support the availability of funds corresponding to authorized withdrawals.

3.3 Identity verification (KYC) and holding of funds

In order to withdraw funds ("Cash Out"), the user must complete the identity verification (KYC) process required by applicable law, including anti-money laundering (AML) regulations under the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and its implementing regulations (31 C.F.R. Chapter X). TipPal may withhold, delay, suspend, or reject withdrawal requests while KYC is incomplete or during compliance reviews, without this giving rise to any liability of TipPal toward the user.

3.4 Internal credit transfers

Users may transfer their available balance to other registered users within the app. These transfers constitute internal accounting adjustments and not new external financial transactions. KYC is not required for internal transfers as long as neither party requests a withdrawal to an external bank account or card.

3.5 No interest

TipPal does not pay interest on balances held on the platform.

3.6 Use of funds in custody

Funds corresponding to balances that have not been withdrawn may be held in TipPal's operating accounts while in pending-settlement status, and do not generate any yield or interest for the user.

4. Prohibited Use of Third-Party Accounts

The following is expressly prohibited:

• Using a TipPal account registered in the name of a third party, or allowing a third party to use one's own account, for the purpose of receiving credit, tips, or payments intended for another person for subsequent forwarding ("pass-through" or unauthorized intermediation of funds).
• Structuring transactions to evade limits, KYC, taxes, or compliance controls (structuring).
• Using the Service as an unauthorized remittance transmission or currency exchange mechanism.

TipPal implements active, good-faith controls to prevent and detect this type of misuse, including: monitoring of transaction patterns (a single recipient receiving funds from multiple unrelated senders), IP and device monitoring, frequency and amount limits, and suspension of accounts with suspicious activity, with reporting to the relevant authorities when required by law. Violation of this section is grounds for immediate suspension or closure of the account and may result in a report to regulatory authorities and/or legal action.

5. Prices and Product Descriptions on the Platform

When TipPal allows merchants, businesses, or users to advertise products, services, or suggested amounts within the platform, it is prohibited to present prices in a misleading, hidden, or disguised manner as a "tip" or "gratitude" when it in fact constitutes the mandatory payment for a good or service. Legal responsibility for the accuracy, legality, and transparency of published prices rests exclusively with the user or merchant who publishes them, not with TipPal, which acts solely as a technological processing intermediary.

6. Fees and Charges

TipPal Corp may charge fees for transactions, withdrawals, or premium features. Applicable fees will be disclosed to the user before completing each transaction.

These fees may be modified by TipPal upon prior notice in accordance with Section 2.

7. User Obligations and Prohibited Conduct

The user agrees not to:

• Use the Service for illegal activities, including money laundering, terrorist financing, fraud, or tax evasion.
• Provide false, incomplete, or fraudulent information.
• Attempt to evade the KYC verification requirements.
• Use third-party accounts to receive funds belonging to others for forwarding purposes (see Section 4).
• Disguise the price of products or services as if they were voluntary tips or gratitude (see Section 5).
• Harass, defame, or harm other users.
• Manipulate, reverse-engineer, or alter the application.
• Use bots, scripts, or unauthorized automated tools.
• Transfer, sell, or share access to your account.
• Use the Service in jurisdictions where it is prohibited by law.

Breach of this section may result in immediate suspension of the account, forfeiture of the pending balance to the extent permitted by law, reporting to competent authorities, and legal action.

8. Intellectual Property

The "TipPal" mark, its logo, the design of the application, the source code, and all associated content are the exclusive property of TipPal Corp and are protected by the intellectual property laws of the United States, including the Lanham Act (trademarks) and the Copyright Act (17 U.S.C. § 101 et seq.). Unauthorized reproduction, distribution, or use is prohibited.

9. Disclaimer of Warranties

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW.

10. Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, TIPPAL CORP, ITS OFFICERS, EMPLOYEES, AND AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING LOSS OF PROFITS, DATA, GOODWILL, OR PLATFORM BALANCE, ARISING FROM THE USE OR INABILITY TO USE THE SERVICE, EVEN IF TIPPAL HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. TIPPAL'S TOTAL AGGREGATE LIABILITY TO THE USER SHALL NOT EXCEED THE AMOUNT PAID BY THE USER TO TIPPAL IN FEES DURING THE SIX (6) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

11. Indemnification

You agree to indemnify, defend, and hold harmless TipPal Corp, its officers, employees, agents, and affiliates from any claim, demand, loss, liability, or expense (including reasonable attorneys' fees) arising from: (a) your breach of these Terms; (b) your misuse of the Service; (c) your violation of any applicable law; or (d) your violation of the rights of third parties.

12. Dispute Resolution: Mandatory Arbitration and Class Action Waiver

Any dispute, controversy, or claim arising out of or relating to these Terms or the use of the Service shall be resolved through binding, individual arbitration, in accordance with the Federal Arbitration Act (9 U.S.C. § 1 et seq.), and not through litigation in court, except for claims that may be brought in small claims court.

CLASS ACTION WAIVER: You and TipPal agree that any dispute resolution proceeding will be conducted only on an individual basis and not as a class, consolidated, or representative action. By accepting these Terms, you waive your right to participate in a class action against TipPal.

13. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the State of Florida, United States, without giving effect to its conflict-of-laws provisions, and without prejudice to the arbitration section above.

14. Termination

TipPal Corp may suspend or cancel accounts at any time, with or without cause, including for breach of these Terms, suspected fraud, or regulatory requirements. The right to use the Service will cease immediately upon termination, without prejudice to the obligations to release legitimate balances in accordance with applicable law.

15. Severability and Entire Agreement

If any provision of these Terms is held invalid or unenforceable, the remaining provisions will remain in full force and effect. These Terms constitute the entire agreement between you and TipPal Corp regarding the Service.

16. Acceptance

By using TipPal, you acknowledge that you have read, understood, and accepted these Terms of Service in their entirety.

1. Scope

This Privacy Policy describes how TipPal Corp collects, uses, shares, and protects the personal information of users of the Service in the United States.

2. Definitions

• User: any person or entity that uses TipPal.
• Sender: a user who sends a tip or gratitude payment.
• Recipient: a user who receives a tip or gratitude payment.

3. Information We Collect

3.1 Information you provide

• Email address.
• First and last name.
• Username and TipPal ID.
• Phone number.
• Profile photo.
• Financial and transactional information.
• Information for identity verification (KYC).
• Communications with support.

3.2 Information collected automatically

• IP address.
• Device type.
• Operating system.
• Usage and diagnostic logs.
• Push notification tokens.

3.3 Information collected with your permission

• Camera and photo gallery.
• Precise location (for Tap to Pay features).
• NFC, Bluetooth, and local network (for contactless payments).

4. How We Use Your Personal Data

We use the data to:

• Provide and maintain the Service.
• Manage your account.
• Verify identity and comply with legal obligations (KYC/AML).
• Detect and prevent fraud.
• Process payments, transfers, and withdrawals.
• Send communications and notifications.
• Improve the Service through analytics.

5. Who We Share Your Information With

You authorize us to use your information and share it with:

Business partners: hotels, restaurants, rideshare platforms, and other affiliated businesses, to the extent necessary for the operation of the Service and partnership programs.

Service providers:

• Stripe (payment processing).
• Resend (email communications).
• Google Firebase (infrastructure and notifications).
• Hosting and database providers.

6. Your Rights

You may request access to, correction of, or deletion of your personal data, subject to legal record-keeping obligations (including those required under AML/BSA regulations, which may require retaining certain information even after you request its deletion).

For step-by-step instructions on how to delete your account and what data is removed, see our Account Deletion page.

7. Disclosures for Legal Reasons

We may disclose your information when required by law, court order, or to prevent fraud, abuse, or unlawful activity, including reports to FinCEN or other authorities under the Bank Secrecy Act.

8. Links to Third-Party Websites

We are not responsible for the privacy practices of external websites linked from our Service.

9. Information Security

TipPal implements reasonable technical and organizational measures to protect your information, although no system is completely secure, and we cannot guarantee the absolute security of transmitted data.

10. Minors

The Service is not directed to individuals under 18 years of age. We do not knowingly collect information from minors.

11. Changes to This Policy

We may update this Privacy Policy and will notify you of material changes through the app or by email.

12. Contact

You may contact TipPal Corp for inquiries related to privacy and the exercise of data protection rights through the official channels indicated in the app and on the website.