NICKLPASS PRIVACY POLICY

Last Updated: January 23rd, 2026

This Privacy Policy (“Policy”) describes how Nic.kl Inc. (“Nicklpass,” “Company,” “we,” “us,” or “our”) collects, uses, processes, and protects information in connection with the Nicklpass platform, including our websites, applications, browser extensions, integrations, and related services (collectively, the “Services”).

This Policy should be read together with our Terms of Service and applies to individuals and organizations accessing the Services, including Enterprise Customers, Authorized Users, and website visitors.

1. ROLES AND RESPONSIBILITIES

Enterprise Customers as Controllers

When the Services are used by an organization (an “Enterprise Customer”), that Enterprise Customer acts as the data controller with respect to information relating to its organization, employees, contractors, or agents processed through the Services (“Enterprise Data”).

Enterprise Customers determine:

which data sources are connected to the Services;
how the Services are configured and used;
whether to participate in buyer clubs or purchasing programs; and
whether to engage with supplier offers or recommendations.

Nicklpass as Service Provider / Processor

Nicklpass acts as a service provider and data processor, processing Enterprise Data solely on behalf of and at the direction of Enterprise Customers (and, where applicable, trade organizations), in accordance with applicable agreements, the Terms of Service, and this Policy.

Nicklpass does not sell personal data and is not a data broker under applicable law.

Trade Organizations and Buyer Clubs

Certain buyer clubs or purchasing programs made available through the Services may be operated by trade organizations, associations, or other third parties.

In such cases:

the trade organization acts as the controller of its membership and program data;
Enterprise Customers act as controllers of their own Enterprise Data; and
Nicklpass processes data on behalf of each party pursuant to their respective instructions and agreements.

Nicklpass does not control trade organization membership and does not disclose Enterprise Data or membership lists between parties unless expressly authorized.

Suppliers as Independent Third Parties

Third-party vendors, publishers, or service providers (“Suppliers”) are independent of Nicklpass. Suppliers do not receive access to Enterprise Data or personal data unless an Enterprise Customer expressly authorizes such disclosure.

2. INFORMATION WE COLLECT

A. Information You Provide Directly

name, email address, and contact details;
account credentials;
support requests and communications; and
billing and subscription information.

B. Enterprise / Organizational Data

Collected at the direction of Enterprise Customers and processed on their behalf, including:

user and license counts;
tool and application usage metadata;
configuration, access, and audit information;
spend and transaction metadata (excluding bank credentials);
eligibility indicators for buyer clubs or purchasing programs.

Enterprise Data generally reflects organizational usage and operations rather than individual behavior.

C. Browser Extension Data

Where enabled by an Enterprise Customer, the Nicklpass browser extension may collect:

domain-level activity associated with approved business tools;
usage frequency and duration signals; and
device and browser metadata.

The browser extension does not collect:

keystrokes;
page content; or
personal browsing activity outside approved domains.

Enterprise Customers are responsible for providing notice to, and obtaining any required consent from, users.

D. Automatically Collected Data

IP address;
device type and operating system;
access timestamps;
diagnostic and performance logs; and
cookies or similar technologies.

3. HOW WE USE INFORMATION

provide, operate, maintain, and support the Services;
generate analytics, insights, reports, and recommendations;
determine eligibility for buyer clubs and programs;
enable integrations authorized by Enterprise Customers;
ensure security, reliability, and compliance;
respond to inquiries and provide customer support; and
meet legal and regulatory obligations.

Nicklpass does not use Enterprise Data for advertising purposes.

4. COHORTS, SIGNALS, AND INSIGHTS

Nicklpass may process Enterprise Data to generate aggregated or anonymized insights, cohort-based groupings, and derived indicators.

5. BUYER CLUBS AND SUPPLIER INTERACTIONS

Enterprise Customers may elect to participate in buyer clubs or purchasing programs and to receive Supplier offers through the Services.

We may share information with service providers, integrations, legal authorities, or in connection with a corporate transaction.

7. DATA RETENTION

We retain information for the duration of an active subscription, as necessary to provide the Services, to comply with legal obligations, and to resolve disputes.

8. SECURITY

Nicklpass implements commercially reasonable administrative, technical, and organizational safeguards.

9. INDIVIDUAL RIGHTS

Depending on jurisdiction, individuals may have rights to access, correct, delete, or restrict processing of personal data.

10. INTERNATIONAL DATA TRANSFERS

Information may be processed in the United States or other jurisdictions where Nicklpass or its service providers operate.

11. CHANGES TO THIS POLICY

We may update this Policy from time to time. Material changes will be communicated through the Services.

12. CONTACT US

Email: info@nicklpass.com