California Privacy Notice (CCPA)

Last updated: October 26, 2026

This notice is for California residents and supplements our Privacy Policy. It explains how ChatRefill, a service of TransUp Tech LLC ("we", "us"), handles personal information under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), and how you can use your rights.

We do not sell your personal information for money. You can opt out of any sharing for advertising at any time.

Do Not Sell or Share My Personal Information

1. Personal information we collect and disclose

In the past 12 months we collected the categories below. We collect them from you, from your device when you use our website and apps, and from service providers such as payment processors and fraud prevention services. "Shared" means disclosed to Meta for cross-context behavioral advertising, which only happens if you accepted advertising cookies and have not opted out.

Category	Examples	Disclosed for business purposes to	Sold	Shared
Identifiers	Name, email address, phone number, account ID, IP address, cookie and device identifiers	Payment processors, fraud prevention and verification providers, SMS and hosting providers	No	Yes, with Meta
Customer records	Name, contact details, payment-related identifiers (we do not store full card numbers)	Payment processors, fraud prevention providers	No	No
Commercial information	Products bought, amounts, order and refund history, recipient phone numbers	Mobile operators and product providers to deliver orders, payment processors	No	Yes, with Meta
Internet or other network activity	Pages viewed, products viewed, searches, items added to cart, login and security events	Hosting and security providers, Google Analytics (only if you accept cookies)	No	Yes, with Meta
Approximate geolocation	Country or region derived from your IP address	Fraud prevention and compliance providers	No	No
Sensitive personal information	Account login credentials, identity documents you submit for verification	Verification providers, only to review your account or payment	No	No
Inferences	Fraud and security risk signals generated from account activity	Fraud prevention providers	No	No

We never send Meta your phone number, a top-up recipient's phone number, card details, passwords or identity documents. Account details sent to Meta are hashed.

2. Why we use personal information

To process and deliver orders, take payments, verify identity and payment ownership, prevent fraud and abuse, meet legal and sanctions obligations, provide customer support, send account and security messages, improve our services and, if you accept cookies, measure our website use and advertising. Details are in sections 1 and 2 of our Privacy Policy.

4. Your California privacy rights

Right to know. Ask what personal information we collected about you, where it came from, why we use it and who we disclosed it to, and get a copy of it.
Right to delete. Ask us to delete personal information we collected from you, subject to legal exceptions (for example, records we must keep for payments, fraud prevention or tax law).
Right to correct. Ask us to correct inaccurate personal information.
Right to opt out of sale or sharing. Tell us not to sell or share your personal information for cross-context behavioral advertising.
Right to limit use of sensitive personal information. We use sensitive personal information only for purposes the law allows without offering this right, such as providing the service, security and fraud prevention, and verifying your identity.
Right to non-discrimination. We will not deny you service, charge you a different price or give you a different quality of service because you used any of these rights.

5. How to make a request

Email hello@chatrefill.com with the subject "California privacy request", or use our contact page. Tell us which right you want to use.

For requests to know, delete or correct, we verify your identity by matching the information you give us with the information we hold, usually by asking you to write from the email address on your ChatRefill account or to sign in. We may ask for more information when a request involves sensitive data. Opt-out requests do not need verification.

We confirm receipt within 10 business days and respond within 45 days. If we need more time (up to another 45 days), we will tell you why. You can make a request to know up to twice in 12 months, free of charge.

Authorized agents. Someone you authorize can make a request for you. We may ask the agent for your signed permission and ask you to verify your identity with us directly.

6. How long we keep personal information

We keep personal information only as long as we need it for the purposes above. Account information is kept while your account is open. Order, payment and compliance records are kept for as long as payment, tax, anti-fraud and sanctions laws require. Advertising event details on our servers are deleted within 7 days, or as soon as Meta has received them.

7. Other California notices

Shine the Light. We do not disclose personal information to third parties for their own direct marketing purposes.

Financial incentives. We do not offer financial incentives in exchange for personal information.

Changes. We update this notice at least once every 12 months. The date at the top shows the latest version.

Questions about this notice: hello@chatrefill.com.

California Privacy Notice