Privacy Policy

TWP Investments LLC (“TWP,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy (the “Policy”) explains how we collect, use, disclose, retain, and protect information when you visit fxpov.com (the “Site”), create or use an FXPOV account, or otherwise interact with our software-as-a-service analytics platform for last-mile pickup-and-delivery (P&D) contractors (the “Service”).

This Policy supplements, and is incorporated by reference into, the FXPOV End User License Agreement (the “EULA”). Capitalized terms not defined here have the meanings given in the EULA.

FXPOV is a business-to-business product offered exclusively to business entities (such as FedEx Ground or Home Delivery Independent Service Providers). The Service is not intended for personal, family, or household use, and we do not knowingly market the Service to consumers or to children under 18.

1. Scope of This Policy

This Policy applies to information we collect through the Site, the Service, our marketing communications, and other interactions with TWP. It does not apply to:

• Third-party websites, apps, or services that may be linked to from the Service — those are governed by their own privacy policies;
• Information that FedEx Corporation or its affiliates collect about you under their own agreements and policies; or
• Aggregated, anonymized, or de-identified information that no longer identifies any individual or business.

2. Our Role: Controller and Processor

With respect to information about our Customers, prospective Customers, and visitors to the Site (e.g., account-registration data, billing data, and Site usage data), TWP acts as a data controller and is responsible for that processing.

With respect to Customer Data that a Customer uploads to or generates within the Service — including operational, route, scanner, telematics, vehicle, payroll, and contractor performance data — TWP acts as a data processor (or service provider) on behalf of the Customer. The Customer is responsible for ensuring it has the legal right to submit Customer Data to the Service and for honoring the privacy rights of the individuals to whom that data relates.

3. Information We Collect

3.1 Information You Provide Directly

• Account Information: business name, business address, owner/admin name, work email, work phone, FedEx CSP/ISP terminal or station identifier, and login credentials.
• Billing Information: billing contact, billing address, last four digits of payment card, card brand, country, postal/ZIP code (for tax determination), and transaction history. Full payment-card numbers are collected, processed, and stored by Paddle.com Market Limited (“Paddle”), our Merchant of Record and PCI-DSS-compliant payment processor, and are not received or stored by TWP. Paddle’s handling of your payment information is governed by Paddle’s own Buyer Terms and Privacy Policy at paddle.com/legal.
• Communications: messages you send to support, sales, or other TWP teams; survey responses; and content of any feedback you provide.
• Customer Data: any data you upload, import, or generate in the Service, including driver and helper records, route assignments, scanner stop counts, on-road performance, fuel and maintenance records, and other operational metrics.

3.2 Information Collected Automatically

• Usage Data: pages or features accessed, dashboard interactions, queries run, timestamps, and referring URLs.
• Device and Log Data: IP address, browser type and version, operating system, device identifiers, language, time zone, and crash logs.
• Cookies and Similar Technologies: see Section 7 for details.

3.3 Information from Third Parties

• Integrations You Authorize: if you connect FXPOV to third-party systems (e.g., scanner data exports, fuel-card portals, payroll providers, accounting software), we receive the data those systems share with us at your direction.
• Service Providers: our payment processor and other vendors share limited information with us as needed to deliver the Service.
• Public Sources and Marketing Partners: we may receive business-contact information from publicly available sources or marketing partners for prospecting.

3.4 Sensitive Information

We do not intentionally collect government-issued ID numbers (other than EINs needed for billing), precise geolocation data, biometric identifiers, health information, or financial-account numbers (except as needed to process payments through our payment processor). Please do not upload such information to the Service unless a feature specifically requests it.

4. How We Use Information

We use the information we collect for the following purposes:

We do not sell personal information for money. We also do not “share” personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act (CCPA) or the Colorado Privacy Act (CPA).

5. How We Share Information

We share information only as described below.

5.1 Service Providers / Sub-processors

We use vetted third-party vendors to operate FXPOV (collectively, “Sub-processors”). Categories include cloud-hosting providers, payment processors, transactional-email services, error-monitoring and analytics providers, and customer-support tools. Sub-processors access information only to perform services for us, are bound by written confidentiality and data-protection terms, and are prohibited from using the information for their own purposes.

Payment Processing — Paddle (Merchant of Record). All payments for FXPOV Subscriptions are processed by Paddle.com Market Limited (“Paddle”), which acts as the Merchant of Record for the Service. This means Paddle — not TWP — is the seller of record on your statement, and Paddle is responsible for collecting and remitting applicable Taxes (including U.S. state sales taxes, EU VAT, UK VAT, GST, and other consumption taxes). Paddle independently collects and processes your payment-card and billing information for purposes of authorizing transactions, calculating and remitting Taxes, screening for fraud, sending invoices and receipts, and handling refunds and chargebacks. Paddle’s processing of your information is governed by Paddle’s Buyer Terms and Privacy Policy, available at paddle.com/legal/checkout-buyer-terms and paddle.com/legal/privacy.

An up-to-date list of FXPOV Sub-processors (including Paddle) is available at fxpov.com/subprocessors. We will provide reasonable advance notice of material changes.

5.2 At Customer Direction

We share information when you instruct us to (for example, by enabling an integration with a third-party tool or by inviting another user to your account).

5.3 Affiliates and Corporate Transactions

We may share information with TWP affiliates that are subject to similar privacy obligations. If TWP is involved in a merger, acquisition, financing, reorganization, or sale of all or substantially all of its assets, information may be transferred to the successor or acquirer subject to this Policy or an equivalent.

5.4 Legal and Safety

We may disclose information when we have a good-faith belief that disclosure is necessary to: (a) comply with a law, regulation, subpoena, court order, or other legal process; (b) protect the rights, property, or safety of TWP, our Customers, or others; (c) detect, prevent, or address fraud, security, or technical issues; or (d) enforce the EULA or this Policy.

5.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data (such as benchmarks across the contractor industry) that cannot reasonably be used to identify any individual or business.

5.6 No Sharing with FedEx

TWP does not share Customer Data with FedEx Corporation or its affiliates except when required by law or when expressly directed by the Customer (for example, if a Customer enables an integration that pushes data to a FedEx system). FXPOV is independent of, and not affiliated with, sponsored by, or endorsed by FedEx.

6. Legal Bases for Processing

Where required by applicable data-protection law (such as in jurisdictions that recognize concepts like “legal basis”), we process information on the following bases:

• Performance of a contract — to provide and bill for the Service under the EULA;
• Legitimate interests — to operate, secure, and improve the Service, communicate with Customers, and prevent fraud, balanced against your privacy interests;
• Legal obligation — to comply with tax, accounting, and other laws; and
• Consent — where we ask for it (for example, for certain marketing communications or non-essential cookies). You may withdraw consent at any time without affecting prior processing.

7. Cookies and Tracking Technologies

FXPOV uses cookies and similar technologies (such as local storage and pixel tags) for purposes including:

• Strictly necessary: authentication, session management, load balancing, and security.
• Functional: remembering preferences and settings.
• Analytics: understanding how the Service is used so we can improve it (e.g., privacy-respecting product analytics).

We do not use cookies for cross-context behavioral advertising. You can manage cookies through your browser settings; disabling strictly necessary cookies will impair the Service. We honor recognized opt-out signals such as the Global Privacy Control (GPC) where required by law.

8. Data Retention

We retain information for as long as needed to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account information: for the life of the account, plus a reasonable period after termination (typically up to 7 years for tax and audit purposes).
• Customer Data: for the duration of the Subscription Term. Upon termination, Customer Data is deleted from active systems within approximately thirty (30) days, with backups expiring on their normal rotation cycle (typically up to 90 days), unless retention is required by law.
• Billing records: as required by tax and accounting law (typically 7 years).
• Marketing contacts: until you opt out or three (3) years of inactivity, whichever is earlier.
• Logs and security data: typically up to 12 months, longer if needed for an active investigation.

9. Information Security

We maintain administrative, physical, and technical safeguards designed to protect information against unauthorized access, use, disclosure, alteration, and destruction. These include encryption in transit (TLS), encryption of sensitive data at rest, role-based access controls, multi-factor authentication for administrative access, regular vulnerability scanning, and incident-response procedures. No system is 100% secure, however, and we cannot guarantee absolute security. If we become aware of a security incident affecting your information, we will notify you in accordance with applicable law.

10. International Data Transfers

FXPOV is operated from, and information is primarily processed in, the United States. Certain Sub-processors may be located outside the United States; for example, our payment processor and Merchant of Record, Paddle.com Market Limited, is established in the United Kingdom and processes payment information in the UK and the European Economic Area. If you access the Service from outside the U.S., your information will be transferred to and processed in the U.S. and other countries where we or our Sub-processors operate. Privacy and data-protection laws in those jurisdictions may differ from those in your home country. By using the Service, you understand that information may be transferred to facilities and parties outside your country of residence.

11. Your Privacy Rights

Depending on where you live and the laws that apply to you, you may have the following rights with respect to personal information about you:

• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate or incomplete personal information.
• Deletion: request deletion of your personal information, subject to certain exceptions.
• Portability: receive your personal information in a portable, machine-readable format.
• Opt-out of targeted advertising, sale, or profiling: we do not engage in these activities, but you may submit a request to confirm.
• Appeal: if we deny a request, you may appeal our decision.
• Withdraw consent: where processing is based on consent, you may withdraw it at any time.

11.1 How to Exercise Your Rights

To exercise any of these rights, email privacy@fxpov.com from the email address associated with your account, or use any in-app privacy controls we provide. We will verify your identity before responding (which may require additional information). We will respond within the timeframes required by applicable law (generally 30–45 days).

11.2 Customer Data

If your information appears in a Customer’s account because you are an Authorized User, employee, or contractor of one of our Customers, please contact that Customer first; we will refer your request to them and assist as needed.

11.3 Colorado Residents

If you are a Colorado resident, the Colorado Privacy Act (CPA) gives you the rights described above. We do not sell personal data, do not process personal data for targeted advertising, and do not engage in profiling that produces legal or similarly significant effects.

11.4 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended, gives you similar rights. We have not sold or shared (as those terms are defined under the CCPA) personal information in the preceding 12 months. We do not knowingly collect personal information of consumers under 16 for the purpose of selling or sharing it. You will not be discriminated against for exercising your CCPA rights.

11.5 EEA, UK, and Other Jurisdictions

Residents of the European Economic Area, the United Kingdom, and certain other jurisdictions may have additional rights under applicable law, including the right to lodge a complaint with a data-protection authority.

12. Children’s Privacy

FXPOV is a B2B service intended for use by businesses and adult professionals. We do not knowingly collect personal information from children under 13 (or under 16 in jurisdictions where that age applies). If we learn that we have collected such information without verified parental consent, we will delete it as required by law.

13. Marketing Communications

You may opt out of promotional emails at any time by clicking the “unsubscribe” link in the email or emailing privacy@fxpov.com. Even if you opt out of marketing communications, we will continue to send you transactional and service-related messages (e.g., security alerts, billing notices, and policy updates) that you cannot opt out of while you have an active account.

14. Third-Party Links and Integrations

The Service may contain links to third-party websites, services, or integrations that we do not own or control. This Policy does not apply to those third parties. Please review the privacy policies of any third-party services you use.

15. Do-Not-Track Signals

Our Site does not currently respond to browser “Do Not Track” signals because no consistent industry standard for compliance has been adopted. As noted above, we do honor the Global Privacy Control (GPC) signal where required by law.

16. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Effective Date” at the top of this Policy and post the updated version at fxpov.com/privacy. If the changes are material, we will provide additional notice (such as by email to the account contact or through an in-Service notification) at least thirty (30) days before they take effect. Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.

17. Contact Us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact us: