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0Privacy Terms Privacy Policy Last Updated: August 21, 2026 1.0Privacy Terms Privacy Policy Last Updated: October 13, 2026 1.
2Introduction Ramp is on a mission to help finance teams build healthier businesses.2Introduction Ramp is on a mission to help companies save time and money so they can focus on their missions.
3We rely on data and insights to save our customers time and money so they can focus on their core missions.3We rely on data and insights to do that.
7We want you to understand how we collect, use, and disclose personal data, and your rights and choices regarding your personal data, including the right to object to certain types of processing we carry out (for more information see Section 6 - Your Rights and Choices below).7We want you to understand how we collect, use, and disclose personal data, and your rights and choices regarding your personal data, including the right to object to certain types of processing we carry out (for more information see Section 7 - Your Rights and Choices below).
10You can also visit Section 14 - Contact Us; Data Controller below for more information. 2.10You can also visit Section 15 - Contact Us; Data Controller below for more information. 2.
12Scope of this Privacy Policy This Privacy Policy applies to personal data we collect and process about you as a Controller (defined below) when you use or interact with: our platform and apps, which include corporate cards and spend management, travel, procurement, banking, accounts payable, accounts receivable, Token Spend Management, Stack, Glass, and other related services and technology (e.g., app.ramp.com and our mobile applications) (the "Services"); www.ramp.com (the "Website"); and our social media, emails, newsletters, advertisements, and other locations or platforms, online or offline, where you interact with our business (collectively, with the Services and Website, the "Business").12Scope of this Privacy Policy This Privacy Policy applies to personal data we collect and process about you as a Controller (defined below) when you use or interact with: our finance platform and apps, which include corporate cards and spend management, travel, procurement, banking, accounts payable, accounts receivable, and related services and technology (e.g., app.ramp.com and our mobile applications); our software applications, including Token Spend Management, Router, and Stack (collectively, with our financial platform and apps, the "Services"); www.ramp.com, www.router.com ↗, and other Ramp-owned websites (the "Websites"); and our social media, emails, newsletters, advertisements, and other locations or platforms, online or offline, where you interact with our business (collectively, with the Services and Websites, the "Business").
13Personal data we collect through Router is subject to the Router Privacy Notice.—Removed
14Personal data collected by Juno is handled in accordance with the Juno Privacy Policy ↗, and personal data collected by Billhop is handled in accordance with the applicable Billhop Privacy Policy ↗.
19If we receive a request intended for the Company, we will forward communications we receive from you to the Company for resolution.19If we receive a request intended for the Company, we will forward communications we receive from you to the Company for resolution as described in Section 7.
20Ramp is not responsible for the privacy practices of any Companies, which may differ from our own.20Ramp is not responsible for the privacy practices of any Companies that use the Services, which may differ from our own.
22For example, a Company may connect, directly or through another application, accounting systems, e-mail services, human resources information systems, bank accounts held at depository institutions, rideshare applications, e-commerce platforms, and other products and services to its Services account ("Ramp Account").22For example, a Company may connect accounting systems, e-mail services, human resources information systems ("HRIS"), rideshare applications, or other products and services to the Services.
23These Third-Party Services help us provide Companies with an integrated spend management solution but are not part of our Services.23These Third-Party Services help us provide integrated solutions but are not part of our Services.
25Personal Data Ramp Processes Permanent link: 3.25Personal Data We Process Permanent link: 3.
26Personal Data Ramp Processes Ramp processes personal data to deliver Services to you and to operate our Business.26Personal Data We Process Ramp processes personal data to deliver Services to you and to operate our Business.
28The table below provides an overview of the relevant person, product or interaction, data categories, and purposes.28The table below is intended as a helpful overview of the relevant person, product or interaction, data categories, and purposes.
30Additional detail is included in the remainder of this Section.30Full details are included in the remainder of this section and in Sections 4-6 below.
31Person or interaction Products or context Personal data we may process Main purposes Business applicants, owners, control persons, guarantors, and other Company representatives involved in an application Applications for corporate cards, credit, deposit or treasury products, payment services, and other regulated financial products Name; business contact information; date of birth; residential address; citizenship; tax or government identifiers; photograph; biometrics (faceprint); government-issued identification and information captured from it; ownership or control information; employer, title, and role; financial, credit, and business information; application and underwriting information; device and fraud-risk signals; audio and/or video call recordings (unless you opt out or do not consent) Verify identity and authority; satisfy know-your-customer, anti-money-laundering, sanctions, and other legal requirements; assess Company eligibility and risk; detect and prevent fraud, security incidents, and policy and legal violations; comply with legal obligations; open and administer the selected financial product Company administrators and Authorized Users, including spend management, bill pay, reimbursements, accounts payable, accounts receivable, procurement, or related payment features Ramp account product and feature use and administration, including AI-enabled products Name; business contact information; address; employer, title, and role; permissions and login credentials; email, SMS, or search communications; product settings; files and other content submitted or connected to the Services; prompts, queries, instructions, and outputs associated with AI-enabled features; browser, device, and network information; approximate location data; connected data from third-party applications or accounts connected to your Ramp account; audio and/or video call recordings (unless you opt out or do not consent); biometric data (account recovery); transaction data; receipts, invoices, contracts, and purchase orders; tax documentation; bank account details; precise geolocation data (optional for mileage reimbursement); product usage data; business travel booking information (name, email, date of birth, gender; phone number; known traveler or redress number; and loyalty or rewards number); itinerary, booking, and approximate location information; travel preferences and support communications; product feedback Create and secure accounts; authenticate users; configure permissions and workflows; provide the selected software and AI-enabled functionality; generate requested outputs; provide support; operate, maintain, and improve the selected Services; communicate about the account; detect and prevent fraud, security incidents, and policy and legal violations; comply with legal obligations; authorize and process transactions; administer cards and spend controls; pay bills and reimbursements; reconcile and code transactions; manage vendors and purchasing; detect errors, fraud, and policy violations; provide reporting and support; complete travel bookings, reservations and communication; search, book, change, and support business travel; apply Company travel policies; provide itinerary and expense-management features; communicate with travel providers Vendors, payees, merchants, contractors, and other transaction counterparties Bill pay, accounts payable, accounts receivable, procurement, card, and payment features Name and business contact information; payment and bank-account details; contracts, invoices, and purchase orders; tax classification and tax identification information; transaction status and communications; product feedback Verify vendors; send and receive payments; communicate about payments; operate, maintain, and improve the selected Services; communicate about the account; detect and prevent fraud, security incidents, and policy and legal violations; comply with legal obligations Company administrators and Authorized Users (SaaS) AI product and feature use and administration (Stack, Token Spend Management, Glass) Name and business contact information; permissions, role, and account credentials; connected account information; browser, device, and network information; AI prompts, outputs, and related metadata; artifacts and content uploaded to the Service; approximate geolocation; product feedback Create and secure accounts; authenticate users; configure permissions and workflows; provide the selected software and AI-enabled functionality; generate requested outputs; provide support; operate, maintain, and improve the selected Services; communicate about the account; detect and prevent fraud, security incidents, and policy and legal violations; comply with legal obligations Website visitors, prospects, referral contacts, and social-media users Website, advertising, sales, referrals, newsletters, and social media Contact and professional information; communications; referral source; cookie, device, browser, IP-address, approximate location, advertising identifier, website-use, and campaign-engagement data; public profile information Respond to requests; provide demonstrations and sales communications; understand and improve the Website; measure campaigns; advertise Ramp products; prevent abuse and secure the Website; honor privacy choices Support contacts, event participants, and other people who communicate with Ramp Customer support, research, surveys, sales calls, events, and other business communications Contact and professional information; communications and product feedback; files or other content provided; audio or video recordings where disclosed and permitted; event registration information, including dietary or accessibility information you choose to provide Respond to requests; provide support; train and improve our teams and Services; administer events; keep business and compliance records; honor recording choices A.31The collection, use, and disclosure described below concern purposes for which Ramp acts as a Controller.
32Product-Specific Collection Permanent link: A.32Personal data processed solely on a Company's behalf is governed by the Agreement and data processing addendum between Ramp and that Company.
33Product-Specific Collection 1.33The same category of personal data may support different roles for different purposes; its inclusion here does not authorize an independent use of information processed solely on a Company's behalf.
34Financial Products and Services Permanent link: 1.—Removed
35Financial Products and Services We collect identity-verification, ownership, control-person, financial, credit, and risk information when it is needed for an application for or use of a regulated financial product or service, or when required by our Financial Institution Partners or applicable law.—Removed
36The exact information depends on the product, the Company's structure, the individual's role, and the applicable legal requirements. 2.—Removed
37SaaS Products Permanent link: 2.—Removed
38SaaS Products If a Company signs up only for a Ramp SaaS product that does not include a regulated financial product, Ramp does not collect know-your-customer or underwriting information solely to provide that SaaS product, but we may collect certain information for identity verification and anti-fraud measures.—Removed
39We may collect ordinary account, user, security, product-use, support, and Company-provided or connected content needed to provide the software.—Removed
40For AI-enabled features, this may include prompts, outputs, related metadata, source materials, configuration information, which may contain personal data.—Removed
41We process personal data included in this information to provide, secure, support, maintain, and improve the applicable product; detect and prevent fraud, abuse, or security incidents; manage our business; and comply with our legal obligations.—Removed
42Before using Company Content to train a general-purpose or generative artificial-intelligence model for use across customers, Ramp will provide required notices and obtain required permissions as applicable.—Removed
44The sections below provide additional detail about the categories and sources of personal data we process.35Person or interaction Products or context Personal data we process Main purposes (see Section 5 for more detail) Business applicants, owners, control persons, guarantors, and other Company representatives involved in an application Applications for corporate cards, credit, deposit or treasury products, payment services, and other regulated financial products Name; business contact information; date of birth; residential address; citizenship; tax or government identifiers; government-issued identification and information captured from it; biometric data (subject to consent); photograph; ownership or control information; employer, title, and role; financial and business information; other personal data collected during the application and underwriting processes; device, network, and browser information; audio and/or video call recordings (subject to consent); communications and materials provided to Ramp for support or feedback Verify identity and authority; comply with know-your-customer, anti-money-laundering, sanctions, and other legal requirements; assess Company eligibility and risk; detect and prevent fraud, security incidents, and policy and legal violations; comply with contractual obligations; open and administer the selected financial product Company administrators and Authorized Users, including spend management, bill pay, reimbursements, accounts payable, accounts receivable, procurement, and related payment features Ramp finance platform and feature use and administration, including AI-enabled products Name, business contact information, address, employer, title, role, account identifiers and Ramp login information; browser, device, and network information; approximate location; usage data, metadata, and billing data; communications and materials provided to Ramp for support or feedback; government-issued identification, information captured from it, and biometric data (subject to consent for account recovery); photograph; financial, transaction, receipt, invoice, vendor, tax, bank-account, and travel information (to the extent used for a purpose specified in Section 5) Manage Ramp's relationship with and provide services to your Company, including authentication and access; provide support for Ramp's account and billing relationship; communicate with you about the Services; detect, investigate, and prevent fraud, misuse, security incidents, and violations of Ramp's terms or applicable law; comply with legal obligations; and operate, evaluate, and improve the Services, Websites, and Business Vendors, payees, merchants, contractors, and other transaction counterparties Bill pay, accounts payable, accounts receivable, procurement, card, and payment features Name and business contact information; browser, network, and device information; tax classification and tax identification information, payment and bank-account details; contracts, invoices, and purchase orders (to the extent used for a purpose specified in Section 5); usage and metadata; communications and materials provided to Ramp for support or feedback Verify counterparties and assess transaction risk; communicate about payments and the Services; detect, investigate, and prevent fraud, misuse, security incidents, and violations of Ramp's terms or applicable law; comply with legal and contractual obligations; manage Ramp's own relationship with the counterparty; and operate, evaluate, and improve the Services, Websites, and Business Company administrators and Authorized Users (SaaS-only) AI Service and feature use and administration (Stack, Token Spend Management, Router) Name and business contact information; role, Services account identifiers and login information; billing and payment information; browser, network, and device information; approximate location; identifiable information included in Service usage data or metadata; support requests and feedback; prompts, outputs and artifacts that include personal data solely to the extent flagged for security or abuse violations or violations of law Manage Ramp's relationship with and provide services to your Company, including authentication and access; assess service eligibility and availability; detect and investigate fraud, abuse, security incidents, and violations of Ramp's terms; comply with legal obligations; respond to support requests and feedback; and evaluate and improve Services, subject to applicable data-use choices and settings; compliance with legal obligations; and support communications, including content, and feedback Website visitors, prospects, referral contacts, and social-media users Website, advertising, sales, referrals, newsletters, and social media Contact and professional information; browser, network, and device information; approximate location; communications and feedback submitted to Ramp; advertising identifier(s), Website use and social media and marketing campaign engagement data; publicly-available profile information; audio and video recordings of meetings (subject to requirements under applicable law) Respond to requests; provide demonstrations and sales communications; understand and improve the Websites; measure campaigns; advertise Ramp products and Services; implement marketing preferences; detect and prevent abuse and secure the Websites; conduct business operations Other people who interact with Ramp Research, surveys, reports, sales calls, product development feedback, and other business-related communications Contact and professional information; communications and feedback; files or other content provided that include personal data; audio or video recordings where disclosed and permitted Respond to requests; provide support; train our teams; develop and improve the Services; maintain business and compliance records; detect and investigate fraud, abuse, security incidents, and violations of Ramp's terms; and comply with legal obligations A.
36Financial Products and Services Permanent link: A.
37Financial Products and Services We collect information that constitutes or that may include personal data, such as identity-verification, ownership, control-person, financial, credit, and risk information when it is needed for an application for or use of a regulated financial product or service, or when required by our Financial Institution Partners or applicable law.
38The exact information depends on the product, the Company's structure, the individual's role, and the applicable legal requirements.
46Personal Data Provided Directly to Ramp Permanent link: B.40SaaS Products Permanent link: B.
47Personal Data Provided Directly to Ramp The Services are intended for use by Companies and their employees and other authorized users ("Authorized Users").41SaaS Products If a Company signs up only for a Ramp SaaS product (including Token Spend Management, Router, or Stack) that does not include a regulated financial product, Ramp does not collect know-your-customer or underwriting information solely to provide that SaaS product, but we may collect personal data for identity verification and anti-fraud measures. 4.
48If you or someone at your Company creates an account, we may receive ordinary account and user information about you, your Company, and individuals associated with your Company.42Sources of Personal Data We Collect Permanent link: 4.
49If the Company also applies for or enables a regulated financial product, we may receive the additional identity-verification, ownership, underwriting, and risk information needed for that product. 1.43Sources of Personal Data We Collect A.
50Personal Data You Provide to Us Permanent link: 1.44Personal Data You Provide to Us Permanent link: A.
51Personal Data You Provide to Us We collect and process personal data when you submit it to our Business, including: Contact Information, including your name, email address, phone number, employer, job title, and address; Identity Verification & Risk Information, where relevant to an application for or use of a regulated financial product, including personal data of the Company's owners, control persons, and other relevant Company personnel, such as their name, email address, phone number, employer, job title, date of birth, residential address, country of citizenship, photograph, social security number, driver's license, passport or other government-issued identification, and any other information captured on the government identification or through our identity verification process, and other personal data requested by or provided to us as part of the application and underwriting processes.45Personal Data You Provide to Us We collect and process the following categories of personal data when you submit it to us: Contact Information, including your name, email address, phone number, employer, job title, and address.
46Login Credentials.
47Identity Verification Information, including government and tax identification documents (e.g., to open a Ramp account or recover access to an account), as well as other personal data requested by or provided to us as part of the application and underwriting processes to open a financial account.
48Biometric Data, when you consent to provide a faceprint for identity verification purposes.
49Photographs you upload to your profile.
53Content, including any documentation, files, or information you provide, which may include personal data about you.51Content Provided to Ramp for Controller Purposes, including documents, files, or other materials you submit in connection with an application, support request, complaint, investigation, or feedback, which may include personal data about you or others.
54Third-Party Information, including personal data you provide about any co-workers, contractors, vendors, or potential referrals, such as their name, email address, phone number, employer, job title, or address.52Third-Party Information, including personal data you provide about any co-workers, contractors, vendors, or potential referrals.
55Audio and/or Video Recordings, which we may collect during sales or support calls or meetings, unless you opt out or do not provide consent, as applicable. 2.53Audio and/or Video Recordings, which we may collect during sales or support calls or meetings, unless you opt out or do not provide consent, as applicable.
56Personal Data We Collect about Authorized Users Permanent link: 2.54Account and Billing Data: Ramp account identifiers, contact and billing details, payment-method information, charges, invoices, credits, refunds, and identifiable usage records used for Ramp's billing, account administration, or independent fraud and security purposes.
57Personal Data We Collect about Authorized Users In connection with providing Services, we collect and process additional personal data of Authorized Users submitted by, on behalf of, and relating to a Company's Authorized Users, such as: Authorized User personal data, including your name, email, phone number, address, employer, job title, login credentials, and other information used by your Company to invite and manage Authorized Users.55B.
58Transaction Data, including information associated with your bill payments, reimbursements, and card transactions made through your Company's Ramp Account, whether online or in person, which may include personal data.56Personal Data Collected through the Services Permanent link: B.
59Token Spend Management Data, including payment-token identifiers and lifecycle information, the related card or account identifiers, device or merchant information, transaction authorization data, authentication events, and fraud and security signals.57Personal Data Collected through the Services We collect and process the following categories of personal data when you use the Services to the extent we are carrying out a Controller purpose described in Section 5 - How We Use Personal Data, such as underwriting, fraud and security incident detection and response, or compliance with our legal obligations: Authorized User Transaction Data, including information associated with your card transactions, payments, reimbursements, and accounts receivable in relation to your Ramp Account to the extent this information includes personal data.
60Connected Data, including information and documentation relating to you made available to us by Third-Party Services connected to the Services.58Receipt and Invoice Data, including information submitted through the Services to pay Company invoices and process your receipts, and personal data extracted from those documents, such as a name, email, phone number, photograph, bank account or other payment details, or the contents of messages.
61Connected Data may be made available to Ramp during the application process and after a Ramp Account is opened for your Company.59Connected Data, including information and documentation relating to you made available to us through Third-Party Services connected to the Services; for example, if your Company connects Ramp to your HRIS.
62For example, if you link your bank account to receive or provide expense reimbursements, we will receive Bank Account Information about the linked account, like the bank routing and account numbers and account balance.60Vendor and Customer Information, including the contact information, such as name, email, phone number and address; payment details; contracts and purchase orders; and information necessary to complete tax documentation (e.g., the vendor's tax classification and tax identification number).
63In addition, some Third-Party Services (e.g., accounting systems and business bank accounts) will provide us with information about activities outside of the Services, which may include personal data, like your business expenses and your Company's external transactions.61Metadata and Usage Data to the extent either includes personal data.
64Other Third-Party Services, like your Company's HRIS, may disclose personal data of Authorized Users, and if your Company connects its email service, we may receive your email communications and attachments for processing.62Browser, device, and network information, such as information about the type of device or browser you use, your device's operating software and settings, your internet service provider, and device identifiers, such as a MAC address or other unique device identifier, which we may collect through cookies and other technologies, such as beacons, tags and scripts, pixels, and software development kits to help us collect and process information automatically as described in our Cookie Policy.
65We may continue to access and receive Connected Data from a Third-Party Service until it is disconnected from the Services by you or your Company.63Approximate Location derived from your IP address.
66Travel Data, including your business travel booking information (name, email, date of birth, gender, phone number, known traveler or redress number, and loyalty or rewards number) and itinerary.—Removed
67This may include approximate location information, such as when your travel itinerary indicates you have booked a flight to or hotel in a particular location.—Removed
68This does not include the mileage reimbursement feature, which uses precise geolocation data.—Removed
69Receipt and Invoice Data, including information you submit to us to pay Company invoices and process your receipts, which may include personal data, such as photos, PDFs, and the contents of e-mails, and SMS messages, if you opt-in to text messages, along with associated metadata.—Removed
70Vendor Data, including the identity of vendors, which may include personal data, such as their contact information, including their name, email, phone number and address, payment details, contracts and purchase orders, and information to complete tax documentation (e.g., the vendor's tax classification and tax identification number).—Removed
72Personal Data Generated and Collected Automatically by Ramp Permanent link: C.65Personal Data Collected When You Visit our Websites Permanent link: C.
73Personal Data Generated and Collected Automatically by Ramp 1.66Personal Data Collected When You Visit our Websites We collect and process the following categories of personal data when you use our Websites: Metadata and Usage Data, including the pages or content you visit, the features you interact with, workflows you construct, how much time you spend on a particular Website, your preferences or selections, and your referring and exiting pages.
74When You Use or Interact with Our Business Permanent link: 1.67Browser, device, and network information, such as information about the type of device or browser you use, your device's operating software and settings, your internet service provider, and device identifiers, such as the IP address and advertising identifier; we also use cookies and other technologies, such as beacons, tags and scripts, pixels, and software development kits to help us collect and process information automatically as described in our Cookie Policy.
75When You Use or Interact with Our Business We collect and process personal data of Authorized Users and other individuals, as applicable, when you use or interact with our Website, Services, and other products and services provided or used by our Business: Use Data, including information and metadata about the pages or content you visit, the features you interact with, the workflows you construct, how much time you spend on a particular Website or using the Services, login and crash data, Third-Party Services you elect to connect to or use with the Services ("Connected Data"), your preferences or selections, the time of day you browse, and your referring and exiting pages.68Approximate Location derived from your IP address.
76SaaS and AI Product Data, including information about workspaces, projects or spaces, skills, tools, workflows, sharing settings, product interactions, prompts, messages, queries, instructions, files, connected records, generated outputs, feedback, and feature-performance or diagnostic information.—Removed
77Device Data, including information about the type of device or browser you use, your device's operating software and settings, your internet service provider, and device identifiers, such as the IP address and advertising identifier.—Removed
78Location Data, including an approximate location derived from your IP address or business information and precise geolocation if you choose to enable certain features, such as trip mileage reimbursement.—Removed
79We use cookies and other technologies to help us collect and process information automatically.—Removed
80The technologies we use to assist with this data collection include log files, cookies, web beacons, tags and scripts, pixels, and software development kits (or "SDKs").—Removed
81For additional information about cookies and similar technologies we use, including how you can opt out of some of those technologies, please visit our Cookie Policy and review Section 6 - Your Rights and Choices of this Privacy Policy.—Removed
82You can also limit our collection of certain information by changing your device and software settings.—Removed
83However, doing so may affect or limit the features available to you. 2.—Removed
84Ramp Events Permanent link: 2.—Removed
85Ramp Events If you register for an event or conference hosted or sponsored by Ramp, we may require additional information (e.g., your company name, your job title or your dietary restrictions).—Removed
86Some events may have different or additional terms or privacy policies, which we will make available to you at or before the time we collect personal data for those events.—Removed
87For more information, review our Ramp Events Privacy Notice.—Removed
89Personal Data Collected by Ramp from Other Sources Permanent link: D.70Personal Data Collected by Ramp from Third Parties Permanent link: D.
90Personal Data Collected by Ramp from Other Sources We also collect and process personal data of Authorized Users and other individuals, as applicable, from other sources, including: Financial Institution Partners, including banks (e.g., the bank issuing your Company's card or originating loans to finance Company expenses), card networks, payment processors, money transmitters, and other entities that provide or support delivery of financial services.71Personal Data Collected by Ramp from Third Parties We also collect and process personal data of Ramp account owners, administrators, Authorized Users, prospects, and other individuals from third parties, including: Financial Institution Partners, such as banks (e.g., the bank issuing your Company's card), card networks, payment processors, money transmitters, and other entities that provide or support delivery of financial services.
91Identity Verification, Fraud and Compliance Monitoring, and Financial and Business Information Providers, which help us supplement our understanding of your Company and its personnel, maintain security, prevent fraud, and comply with legal obligations.72Identity Verification, Fraud and Compliance Monitoring, and Financial and Business Information Providers, which help us supplement our understanding of your Company and its personnel, detect and prevent fraud and security incidents and comply with legal obligations.
92This may include information such as your name, address(es), phone number(s), photograph, government ID, device information, or other personal data required to verify your identity, detect and prevent fraud, and comply with our legal obligations.73Vendors and Console Users transacting with or supporting Companies (e.g., merchants and accounting firms), such as when a vendor provides payment information, which may include personal data.
93Vendors and Console Users transacting with or supporting Companies (e.g., merchants and accounting firms).—Removed
94For example, a merchant might provide us with their name, tax identification number, and payment account information so that Companies can make bill payments and report on their tax obligations.—Removed
95That information may include personal data.—Removed
97Social Networks, Advertising Providers, and Private Databases, which help us to identify and enrich our understanding of prospective customers and to serve and measure advertising, provide us with personal data that may include your name, email, phone number, mailing address, gender, age, and other demographic data.75Social Networks, Advertising Providers, and Private Databases, which help us to identify and enrich our understanding of prospective customers and to serve and measure advertising, provide us with personal data.
98We also receive personal data when you interact with our pages, groups, accounts, and posts on social media platforms, which generally includes aggregate data about our followers (e.g., age, gender and location), engagement data (e.g., "likes," comments, shares, reposts, and clicks), and awareness data (e.g., number of impressions and reach), as well as individual users' public profiles.76Partners and Referring Entities that we engage for joint marketing activities and our referrals and rewards programs, which may share personal data about overlapping customers, such as their contact information and services they acquire; and individuals or organizations that refer you to Ramp.
99Joint Marketing, Business Partnerships, Referrals, and Rewards Partners that we engage for joint marketing activities and our referrals and rewards programs, which may share information, including personal data, about overlapping customers, such as their contact information and services they acquire.77Publicly-Available Sources, including personal data in the public domain that helps us identify potential customers and partners or conduct due diligence and risk management for potential and existing customers, such as personal data about a company's personnel on its website.
100Publicly-Available Sources, including information in the public domain that helps us identify potential customers and partners or conduct due diligence and risk management for potential and existing customers, such as personal data about a company's personnel on its website or in news articles and press releases.78The categories of personal data we collect and receive from these sources may include all of the categories identified in Section 3 - Personal Data We Process.
101The categories of personal data we collect and receive from these sources may include all of the categories identified above in this section under "Personal Data Provided Directly to Ramp" and "Personal Data Generated and Collected Automatically by Ramp".79We treat the personal data obtained from other sources in accordance with any laws or contractual obligations applicable to us. 5.
102We treat the personal data obtained from other sources in accordance with any laws or contractual obligations applicable to us. 4.80How We Use Personal Data Permanent link: 5.
103How We Use Personal Data Permanent link: 4.81How We Use Personal Data We use the personal data described in Section 3 - Personal Data We Process for the following purposes where Ramp determines the purposes and means as a Controller.
104How We Use Personal Data We use each category of personal data only for purposes that are relevant to the applicable person, product, and interaction described in Section 3.82Processing performed by Ramp on a Company's behalf is governed by the applicable Agreement and data processing addendum with that Company.
105These business and commercial purposes include: To Provide and Maintain Our Business.83These business and commercial purposes include: To Operate and Maintain Our Business, including to complete identity verification; perform underwriting and risk analyses; enable you to use cards and other payment and spend management tools; verify financial information; establish spend limits; detect and prevent or address technical issues and disruptions; analyze and monitor usage and activities; manage our relationship with your Company, including billing and invoicing; and meet our own financial, legal, and security responsibilities.
106To provide, operate, and manage our Services, Website, and other parts of our Business, including to perform customer validation and to enable you to use cards and our other payment tools, to verify financial information, establish spend limits, conduct identity verification, prevent or address technical issues and disruptions, and analyze and monitor usage and activities.84To Communicate with You, including sending you notices, updates, security alerts, and information regarding changes to our policies and terms; responding to support requests and feedback, and providing other transactional and relationship communications, and if applicable, marketing communications.
107This includes processing information at your direction, including as expressed through your or your Company's use of certain features in the Services, such as a request to connect a Third-Party Service, like Slack or Lyft.85To Detect, Prevent, and Respond to Fraud and Security Incidents, which includes maintaining the safety and security of our Business and managing risk by detecting, investigating, and responding to suspicious activity, potential security incidents or fraudulent or unauthorized transactions, breaches of policies and terms, and threats of harm, including in an automated fashion.
108To Provide Token Spend Management.86To Comply with Legal Obligations and Enforce Our Rights, including when responding to government authorities, courts, and regulators as required by law, maintaining records to demonstrate compliance with applicable law, protecting our legal rights, and pursuing remedies available to us.
109To provision, manage, secure, support, and reconcile token-based spend-management functionality; enable authorized transactions; administer related controls; and detect and prevent fraud, misuse, and security incidents.87To Provide Ramp Rewards if your Company chooses to participate in our rewards programs, and to determine your eligibility for rewards and to facilitate the rewards program effectively.
110To Provide SaaS and AI-Enabled Products.88To Develop and Improve Our Business so that the Services and other aspects of our Business are as useful as possible for our customers and their Authorized Users, including by identifying and troubleshooting issues with the Services, improving and expanding our products and operations, and offering new features and functionality.
111To respond to prompts, messages, queries, instructions, and other user requests; generate and deliver requested outputs; administer workspaces, sharing, skills, tools, and connected services; troubleshoot and improve product performance; and detect, prevent, and investigate misuse, policy violations, fraud, and security incidents.89For Auditing and Research, including internal reporting, auditing, and research, such as focus groups, design partnerships, and surveys.
112To Communicate with You.90For Marketing and Advertising, developing, sending, and measuring advertising, direct marketing, and communications about our products, offers, promotions, rewards, events, and Services.
113To send you notices, updates, security alerts, and information regarding changes to our policies and terms, to respond to support requests and feedback, and to provide other transactional and relationship communications, and if applicable, marketing communications.91We may also use personal data, other than personal data collected through the Services, to engage in personalized or targeted advertising.
114To Detect, Prevent, and Respond to Fraud and Security Incidents.92Where permitted by law, we use tracking technologies, such as cookies, pixels, tags, and SDKs, some of which track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and other content to you.
115To maintain the safety and security of our Business and to manage risk, including investigating suspicious activity, detecting and preventing potential security incidents or fraudulent or unauthorized transactions, breaches of policies and terms, and threats of harm, including in an automated fashion.93These activities concern personal data we process as a Controller, including where applicable, information about Website visitors, prospects, and other individuals, subject to applicable law and privacy choices.
116To Comply with Legal Obligations and Enforce Our Rights.94We do not carry out targeted advertising, sales, or sharing using personal data we process on a Company's behalf as a Processor or Subprocessor.
117To fulfill legal, regulatory, and contractual obligations, including when cooperating with government authorities, courts, and regulators in accordance with applicable law, maintaining records to demonstrate compliance with applicable law (such as financial regulations), protecting our legal rights, and pursuing remedies available to us.95For Offers, Promotions, Sweepstakes, and Contests ("Offers") we make available.
118To Provide Ramp Rewards.—Removed
119If your Company chooses to participate in our rewards program, to determine your eligibility for rewards and to facilitate the rewards program effectively.—Removed
120To Develop and Improve Our Business.—Removed
121To make the Services and other aspects of our Business as useful as possible for Authorized Users on behalf of their Companies, including by identifying and troubleshooting issues with the Services, improving and expanding our products and operations, and offering new features and functionality.—Removed
122For example, we may develop or improve Services by analyzing how you use features, the documentation you submit, or information associated with your transactions.—Removed
123For Auditing and Research.—Removed
124To conduct internal reporting, auditing, and research, including focus groups and surveys.—Removed
125For Marketing and Advertising.—Removed
126To develop, send, and measure advertising, direct marketing, and communications about our products, offers, promotions, rewards, events, and Services.—Removed
127We may also use information to engage in personalized or targeted advertising.—Removed
128As part of this process, where permitted by law, we use tracking technologies, such as cookies, pixels, tags, and SDKs, some of which track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and other content to you.—Removed
129For further information on the types of tracking technologies we use and your rights and choices regarding analytics and targeted advertising, please see Section 6 - Your Rights and Choices and our Cookie Policy.—Removed
130Even if you opt out of personalized advertising, you may continue to see advertising, including potentially from us.—Removed
131If you connect your bank account to your Company's Ramp account, we will not use your bank account information to market our Business on advertising platforms.—Removed
132For Offers, Promotions, and Contests.—Removed
133At times, we offer certain opportunities or rewards through contests, sweepstakes, and other special offers and promotions (collectively, "Offers").—Removed
135Certain Offers may be construed as "financial incentives" under California law; California residents should review our Notice of Financial Incentives.97Certain Offers may be construed as "financial incentives" under California law, and California residents should review our Notice of Financial Incentives.
136Generating De-identified, Aggregated, and/or Anonymized Information.98Generating De-identified, Aggregated, and/or Anonymized Information, including when we remove or mask personal data that could be used to identify you, or by aggregating or combining information so that it does not identify you; we may use information that does not identify you for any purpose permitted by law and our Agreement with your Company.
137To develop de-identified, aggregated, and/or anonymized information, including by removing or masking information that could be used to identify you, and by aggregating or combining information so that it does not identify an individual.99With Your Consent where we request your consent to process your personal data.
138We may use information that does not identify you for any purpose permitted by law and as required to meet our contractual obligations.100For information about your rights and choices regarding how we use your personal data, please see Section 7 - Your Rights and Choices below. 6.
139At Your Direction.101Disclosure of Personal Data by Ramp Permanent link: 6.
140To fulfill any other purpose at your direction, including as expressed through your or your Company's use of Services functionality.102Disclosure of Personal Data by Ramp This section describes disclosures of personal data Ramp processes as a Controller.
141For example, if you direct us to connect your Ramp Account to a Third-Party Service, such as Slack or Lyft, we will process that request accordingly.103Disclosures made solely on a Company's behalf are governed by the applicable agreement and data processing addendum between Ramp and the relevant Company.
142With Notice to You and Your Consent.—Removed
143We may otherwise use personal data we collect after providing notice to you and obtaining your consent.—Removed
144For information about your rights and choices regarding how we use your personal data, please see Section 6 - Your Rights and Choices below. 5.—Removed
145Disclosure of Personal Data by Ramp Permanent link: 5.—Removed
146Disclosure of Personal Data by Ramp We disclose personal data we collect in accordance with this Privacy Policy.—Removed
148We may disclose information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by law or contractual obligation applicable to us.105Affiliates ↗ of Ramp Business Corporation.
149Affiliates.106Professional Advisers, such as legal, audit, insurance, and other professional advisers as reasonably necessary for their advice and services.
150We disclose personal data to affiliates and related entities ↗ of Ramp Business Corporation.107Service Providers that process personal data on our behalf for services, such as cloud infrastructure, web hosting, analytics, developing and improving our Services and Websites, processing payments, providing rewards, serving advertisements, providing communications and technical support, detecting and responding to security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and debugging to identify and repair errors in the Services.
151Service Providers.108Where a Company independently engages an AI provider or connected service and directs Ramp to transmit personal data to it, that recipient's processing is governed by its agreement with the Company.
152We disclose personal data to service providers that process information on our behalf.—Removed
153Service providers assist us with services, such as cloud infrastructure, Website hosting, analytics, developing and improving the Services and Websites, processing payments, providing rewards, serving advertisements, providing communications and technical support, detecting and responding to security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and debugging to identify and repair errors in the Services.—Removed
154For SaaS and AI-enabled products, service providers may include model providers, hosting and infrastructure providers, safety and content-monitoring providers, and providers that support connectors, search, tools, and technical support.—Removed
155We disclose content and other personal data to these providers only as needed to provide, secure, support, and improve the applicable Service, at your or your Company's direction where applicable, or as otherwise described in the applicable agreement or notice.—Removed
156Depending on the service, we may provide personal data on a continuous basis (e.g., fraud services) or on an as-needed basis.—Removed
157We impose contractual restrictions on our service providers' processing of personal data, although we may permit them to use information that does not identify you (such as information that has been aggregated, de-identified, or anonymized) subject to applicable law.—Removed
159Business Customers.110Business Customers with whom we have an Agreement for tasks such as billing, administration of the Services, fraud and security investigations, and legal obligations.
160We disclose personal data to your Company so that we can provide Services on the Company's behalf.111Disclosures made solely to carry out the Company's instructions are governed by the relevant Agreement and DPA.
161For example, we may disclose personal data to your Company to process your payment transactions, provide Services, report on your use of your Company's Ramp Account, respond to your and their questions, comply with your and their requests, and otherwise comply with the law.112Providers of Connected Services to the extent necessary to carry out one of the purposes specified in Section 5 - How We Use Personal Data.
162In addition, your Company can assign different roles to Authorized Users, which will have different associated capabilities and permissions.113Financial Institution Partners, such as banks, card networks, and payment processors, to support their customer identification, risk, and compliance programs, and so they can determine eligibility for, and provide, products and services to your Company, either directly or through us.
163We will disclose some personal data about your use of the Services to other Authorized Users within, or individuals acting on behalf of, your Company.114Credit Reporting Agencies and Other Financial Information Providers to the extent necessary in relation to a Company to verify information about the Company, report on the Company's performance, or report missed or late payments or other defaults.
164Those individuals may include members of your Company's finance department, your manager, other Company personnel, or a Company service provider.115Vendors, Customers, and Console Users that transact with or support your Company through the Services.
165Each Company is an independent entity, and the Company's processing of personal data is subject to the Company's own policies and terms.116Ramp Rewards Providers as necessary to determine your Company's eligibility for rewards and to facilitate the rewards program effectively.
166SaaS Product Administrators and Authorized Users.117Analytics, Marketing, and Advertising Providers and Agencies to conduct analytics and to place advertisements on our behalf on third-party websites and services; these advertising disclosures exclude personal data Ramp processes on a Company's behalf as a Processor or Subprocessor.
167Where enabled by a Company, Company administrators and other Authorized Users may be able to access, manage, export, retain, or delete account information, workspaces, prompts, messages, files, connected data, generated outputs, and other content associated with Stack, Glass, or another SaaS or AI-enabled product.118Referrals and Joint Marketing Partners in connection with facilitating referral partnerships or engaging in joint marketing activities.
168The Company is responsible for configuring access and sharing permissions and providing any notices required for its administration of those products.—Removed
169Providers of Connected Services.—Removed
170We disclose personal data to Third-Party Services and their providers if you or your Company choose to use Third-Party Services in connection with the Services, such as Slack, Uber, Google, or NetSuite.—Removed
171Financial Institution Partners.—Removed
172We disclose personal data to Financial Institution Partners, such as banks, card networks, and payment processors, to support their customer identification, risk, and compliance programs, and so they can determine eligibility for, and provide, products and services to your Company, either directly or through us.—Removed
173This information also enables our Financial Institution Partners to deliver card, payments, treasury, and international transfer capabilities through our Services.—Removed
174For example, to comply with Know-Your-Customer requirements and requests for information, we may disclose to our Financial Institution Partners your name, email, phone number, employer, job title, date of birth, residential address, country of citizenship, photograph, social security number, and driver's license, passport or other government-issued identification, other information captured through our identity verification process, and Ramp card and transaction information.—Removed
175Credit Reporting Agencies and Other Financial Information Providers.—Removed
176We disclose personal data about your Company and its Ramp Account to credit reporting agencies to verify information about your Company, to report on your Company's performance, and to report late payments, missed payments, or other defaults.—Removed
177While this information is generally about the Company, it may include personal data.—Removed
178Vendors and Console Users.—Removed
179We disclose personal data to entities that transact with or support your Company.—Removed
180For example, we may disclose the status of your Company's payments to the recipient vendor, which may include personal data, such as contact information.—Removed
181Ramp Rewards Providers.—Removed
182We disclose personal data about you and your Company's Ramp Account as necessary to determine your Company's eligibility for rewards and to facilitate the rewards program effectively.—Removed
183Analytics, Marketing, and Advertising Providers and Agencies.—Removed
184We disclose personal data to agencies, advertisers, ad networks, and other technology services to conduct analytics and to place advertisements on our behalf on third-party websites and services.—Removed
185If you connect your bank account to your Company's Ramp account, we will not disclose your bank account information to market our Business on advertising platforms.—Removed
186Referrals and Joint Marketing Partners.—Removed
187We disclose personal data about you and your Company's Ramp Account to our partners in connection with facilitating referral partnerships or engaging in joint marketing activities.—Removed
189Mergers and Acquisitions.120Mergers and Acquisitions to the extent reasonably necessary, including to an acquiring entity, legal counsel, consultants, or others in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets or transfer of all or a portion of our business to another business.
190We may disclose personal data to an acquiring entity, legal counsel, consultants, or others in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition or business combination of all or any portion of our assets or transfer of all or a portion of our business to another business.121Identity Verification and Risk Providers that help us verify your and your Company's identity and perform other compliance functions.
191Identity Verification and Risk Providers.122Public Authorities, such as financial services or other regulators to comply with applicable law, payment network rules, and legal process, to investigate suspicious or potentially fraudulent activity, and where required in response to lawful requests by regulators, courts, law enforcement, and other public authorities, including to meet national security, anti-money laundering, or law enforcement requirements.
192We disclose personal data to third-party services that help us verify your and your Company's identity and perform other compliance functions.—Removed
193In addition, to prevent fraud and safeguard our customers and Business, we disclose information to risk and security partners, including personal data about interactions with our Services and transactions.—Removed
194Public Authorities.—Removed
195We may disclose personal data to public authorities, such as financial services or other regulators to comply with applicable law, payment network rules, and legal process, to investigate suspicious or potentially fraudulent activity, and where required in response to lawful requests by regulators, courts, law enforcement, and other public authorities, including to meet national security, anti-money laundering, or law enforcement requirements.—Removed
197For information about your rights and choices regarding how we share personal data about you, please see Section 6 - Your Rights and Choices below. 6.124For information about your rights and choices regarding how we share personal data about you, please see Section 7 - Your Rights and Choices below. 7.
198Your Rights and Choices Permanent link: 6.125Your Rights and Choices Permanent link: 7.
201Access, Correction, Deletion, and Objection to or Restriction of Processing Ramp Services are intended for use by business customers ("Companies"), and you may only use a Ramp account if you are an employee or other Authorized User of a Company that has opened a Ramp account.128Access, Correction, Deletion, and Objection to or Restriction of Processing Ramp Services are intended for use by business customers (each a "Company"), and you may only use a Ramp account if you are an owner, administrator, or Authorized User of a Company.
202The information in a Company's Ramp Account is governed by our Agreement with the Company.129The information in a Company's Ramp Account is governed by our Agreement with the Company, and the Company and its administrators determine how personal data is processed on the Company's behalf.
203You should direct questions about personal data we are processing on behalf of a Company to that Company and its administrators.130You should direct questions about personal data we process on behalf of a Company to that Company and its administrators.
204If you are an Authorized User, you may also be able to access, update, or delete certain personal data within your Company's Ramp account through the Services.131If you are an Authorized User, you may also be able to access, update, or delete certain personal data within your Ramp account through the Services.
205However, the Company and its administrators are generally responsible for determining how that personal data is processed.132You may contact Ramp directly about personal data processing described in this Privacy Policy for which Ramp acts as a Controller, whether or not you have a Ramp account.
206Subject to limitations under applicable law, residents of certain jurisdictions have rights and choices with respect to your personal data, including the right to: Know what personal data we process about you and to access and receive an electronic copy of your personal data.133Subject to limitations under applicable law, residents of certain jurisdictions have rights and choices with respect to your personal data, including the right to: Know what personal data we process about you and access and receive an electronic copy of your personal data.
209Under certain circumstances, in jurisdictions such as the U.K. and the E.U., the right to request that we restrict processing of your personal data and/or to object to how we process personal data about you.136Under certain circumstances, in jurisdictions such as the U.K. and the E.U., request that we restrict processing of your personal data and/or object to how we process personal data about you.
210Where we process your personal data based on consent, the right to withdraw that consent at any time with respect to future processing.137Where we process your personal data based on consent, withdraw that consent at any time with respect to future processing (however, depending on the circumstances, this may limit the usefulness or availability of certain services).
211These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have a compelling legitimate interest to keep.138These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by legal or contractual obligations to keep or have a compelling legitimate interest to keep.
213To exercise any of your rights, please submit a request through our Privacy Center ↗.140To exercise any of your rights, you can submit a request through our Privacy Center ↗ or email us at privacy@ramp.com.
215We may require additional information from you to help us verify your identity and process your request.142We may verify your identity to exercise certain rights, in which case we will request information reasonably needed to verify your identity and process the request; if we cannot complete required verification, we may deny that request.
216If we are unable to verify your identity, we may deny your request.—Removed
218However, if you wish to make your request directly to us, please provide the name of your Company on whose behalf we processed your personal data.144However, if you wish to make your request directly to us, please provide the name of the Company on whose behalf we processed your personal data.
219We will refer your request to that Company, and we will support them as required by applicable law to respond to your request.145We will refer your request to that Company, and we will support them as required by applicable law to respond to your request to the extent we are able to verify that you are associated with that Company and applicable law permits the notification.
220In certain jurisdictions, you have the right to appeal to us a decision we've made to refuse to take action in response to your exercise of one of the rights above.146If you do not have a Ramp account but your personal data appears in a Company's connected records, communications, prompts, or outputs because a Company supplied it, retrieved it through an authorized connection, or otherwise generated it through interactions with our Business, we will refer the portion of your request concerning processing on the Company's behalf and address any portion concerning Ramp's own Controller processing ourselves.
147Where the Company that instructed us is itself a Processor for another organization, we will refer your request to the Company we have a direct relationship with, which remains responsible for further routing consistent with its own obligations.
148If you are concerned about the way in which we are managing your personal data, please contact us using the contact details set out below.
149Complaints must be lodged in writing.
150We will deal with the matter within a reasonable time and will keep you informed of the progress of our investigation.
151If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns.
152You can appeal to us a decision we've made to refuse to take action in response to your exercise of one of the rights above.
222Residents of the E.U., Switzerland, and the U.K. also have the right to lodge a complaint with the data protection regulator in your jurisdiction.154If you reside in certain jurisdictions, including Australia, the E.E.A., Switzerland, and the U.K., you have the right to lodge a complaint with the data protection regulator in your jurisdiction.
156If you reside in the U.K., you also have the right to submit a data protection complaint to us directly by emailing us at privacy@ramp.com.
230If you are unable to opt-out through those methods, you can email us at privacy@ramp.com.163If you are unable to opt out through those methods, you can email us at privacy@ramp.com.
234After you send the SMS message "STOP" to us, we will send you a SMS message to confirm that you have been unsubscribed.167After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed.
236Text messaging originator opt-in data and consent will not be shared, sold, rented, or otherwise disclosed by us for marketing purposes.169For more information, refer to our Text & SMS Terms. 3.
237For more information, please see the Agreement.—Removed
238You may be required to communicate your preferences separately to opt out of receiving messages through other platforms, such as WhatsApp. 3.—Removed
251You can instruct your browser or device, by changing its settings, to decline or delete cookies and similar technologies ("Cookies").182You can instruct your browser or device to decline or delete cookies and similar technologies ("Cookies") by changing the appropriate settings.
252Please be aware that if you disable or remove Cookies some parts of our Business may not function correctly and settings and preferences controlled by those Cookies, including advertising preferences, may be deleted and may need to be reset.183If you disable or remove Cookies, some parts of the Services or our Websites may not function correctly and settings and preferences controlled by those Cookies, including advertising preferences, may be deleted and may need to be reset.
253You can modify your Cookie preferences for our Website by opting out on our Your Privacy Choices ↗ page.184You can modify your Cookie preferences for our Websites by opting out on our Your Privacy Choices ↗ page.
254If you use multiple browsers or devices, you may need to instruct each browser or device separately.185If you use multiple browsers or devices, you need to instruct each browser or device separately.
257We may use session-replay technologies to understand how users interact with the Service, including clicks, scrolling, page navigation, and technical information about a session, to troubleshoot, secure, and improve the Service.188We use session-replay technologies to understand how users interact with the Services, including clicks, scrolling, page navigation, and technical information about a session, to troubleshoot, secure, and improve the Service.
259Where required by law, we obtain your consent before enabling session replay. 2.190Where required by law, we will obtain your consent before enabling session replay. 2.
262Our Website is designed to respect your GPC preferences. 3.193Our Websites are designed to respect your GPC preferences. 3.
277To opt out of targeted advertising, "sales," or "sharing" (as defined by applicable law) of your personal data, visit our Your Privacy Choices page or click the "Your Privacy Choices" in the footer of our Website.208This section addresses personal data we process as a Controller in connection with our own advertising, such as data about Website visitors and prospects; we do not carry out targeted advertising, "sales," or "sharing" using personal data we process on a Company's behalf as a Processor.
209To opt out of targeted advertising, "sales," or "sharing" (as defined by applicable law) of your personal data, visit our Your Privacy Choices page or click the "Your Privacy Choices" link in the footer of our Websites.
289You will be notified prior to a recording, and if you want to opt out of or don't want to opt in to the recording, as the case may be, you should follow the instructions presented in the notice. 7.221You will be notified prior to a recording, and if you want to opt out of or don't want to opt in to the recording, as the case may be, you should follow the instructions presented in the notice. 8.
290International Data Transfers Permanent link: 7.222International Data Transfers Permanent link: 8.
295In certain situations, regulators, courts, and law enforcement agencies might be entitled to access your personal data (for more information see Section 5 - Disclosure of Personal Data by Ramp).227In certain situations, regulators, courts, and law enforcement agencies might be entitled to access your personal data (for more information see Section 6 - Disclosure of Personal Data by Ramp).
296For personal data transferred from the European Economic Area ("E.E.A."), Switzerland, or the U.K., we will provide appropriate safeguards for transfers of your personal data outside of those jurisdictions, including: (1) transferring the personal data to countries recognized by the European Commission ↗, the Swiss Federal Data Protection and Information Commissioner ↗, and/or U.K. Information Commissioner's Office ↗ as offering an adequate level of protection for personal data; (2) transferring the personal data pursuant to contractual obligations, including Standard Contractual Clauses ↗ ("SCCs") and addenda specific to Switzerland and/or the U.K., as applicable; and (3) confirming service providers to which we transfer personal data have active self-certification under the E.U.-U.S. Data Privacy Framework, the U.K. Extension to the E.U.-U.S. DPF, or the Swiss-U.S. DPF, as applicable.228For personal data transferred from the European Economic Area ("E.E.A."), Switzerland, or the U.K., we will provide appropriate safeguards for transfers of your personal data outside of those jurisdictions, including: (1) transferring the personal data to countries recognized by the European Commission ↗, the Swiss Federal Council ↗, and/or U.K. Secretary of State ↗ as offering an adequate level of protection for personal data; (2) transferring personal data pursuant to contractual obligations, including Standard Contractual Clauses ↗ ("SCCs") and addenda specific to Switzerland and/or the U.K., as applicable; and (3) confirming service providers to which we transfer personal data have active self-certification under the E.U.-U.S. Data Privacy Framework, the U.K. Extension to the E.U.-U.S. DPF, or the Swiss-U.S. DPF, as applicable.
300For more information about our security measures, visit our Trust Center ↗.232For more information about our security measures, visit our Trust Center ↗. 9.
301If you are a resident of the province of Quebec, please note that we transfer and store personal data outside of Quebec province. 8.233Lawful Basis for Processing Personal Data Permanent link: 9.
302Lawful Basis for Processing Personal Data Permanent link: 8.—Removed
304Where we are the Controller of your personal data, we rely on the following lawful bases: At your direction and in performance of a contract we have with you.235Where we are the Controller of your personal data, we rely on the following lawful bases: Performance of a contract, where the processing is necessary to perform that contract or take steps at your request before entering into it.
305Compliance with our legal obligations or to preserve or enforce our legal rights.236Compliance with our legal obligations.
307To further the legitimate interests of Ramp or a third party, for example, to: (1) administer and conduct our business, including maintaining and improving the Services; (2) detect, prevent, and respond to security incidents; (3) detect and prevent fraud; and (4) conduct marketing and analytics activities. 9.238To further the legitimate interests of Ramp or a third party, for example, to: (1) administer and conduct our business, including maintaining and improving the Services; (2) detect, prevent, and respond to security incidents; (3) detect and prevent fraud; (4) conduct marketing and analytics activities; and (5) establish, exercise, or defend legal claims, where these interests are not overridden by your interests or fundamental rights and freedoms. 10.
308Automated Decision-Making and Artificial Intelligence Permanent link: 9.239Automated Decision-Making and Artificial Intelligence Permanent link: 10.
310Depending on the product and workflow, AI Systems may assist with tasks such as: verifying identity and business information; detecting and preventing fraud, suspicious activity, sanctions or compliance risks, unauthorized transactions, and security threats; supporting business application review, underwriting, eligibility, and risk-management processes for financial products; matching receipts, invoices, transactions, accounting information, and other records; applying Company policies, controls, workflows, and product settings; generating policies and workflows; and improving, troubleshooting, and securing our Services.241Depending on the product and workflow, AI Systems may assist with tasks such as: verifying identity and business information. detecting and preventing fraud, suspicious activity, sanctions or compliance risks, unauthorized transactions, and security threats. supporting business application review, underwriting, eligibility, and risk-management processes for financial products. improving, troubleshooting, and securing our Services.
242The examples in this section concern Ramp's Controller processing.
243Customer-directed AI functionality is governed by the applicable agreement and data processing addendum between Ramp and the relevant Company.
312Ramp does not use AI Systems to make a decision based solely on automated processing that produces legal or similarly significant effects for an individual subject to this Privacy Policy. 10.245Ramp does not use AI Systems to make decisions based solely on automated processing that produces legal or similarly significant effects for an individual subject to this Privacy Policy.
313Security Permanent link: 10.246With respect to residents of the E.E.A., we do not use AI Systems classified as "High Risk." 11.
247Security Permanent link: 11.
316We recommend you use strong passwords, use multi-factor authentication to access your account, and otherwise follow your Company's information security practices.250We recommend you use strong passwords or passphrases, passkeys, multi-factor authentication, and otherwise follow your Company's information security practices.
317If you suspect unauthorized activity with respect to your Ramp account or you suspect a security incident has occurred, you should contact us immediately at security@ramp.com. 11.251If you suspect unauthorized activity with respect to your Ramp account or you suspect a security incident has occurred, you should contact us immediately at security@ramp.com. 12.
318Use by Minors Permanent link: 11.252Use by Minors Permanent link: 12.
322If you are a parent or guardian of a minor and believe your minor uses the Services, contact us at privacy@ramp.com. 12.256If you are a parent or guardian of a minor and believe your minor uses the Services, contact us at privacy@ramp.com. 13.
323Retention Permanent link: 12.257Retention Permanent link: 13.
326The following describes the principal retention triggers and criteria we use: Record category Retention period or criteria Account, user, and product records For the life of the relevant account, user relationship, or enabled product, followed by the period reasonably needed to close the account, complete pending activity, provide requested exports, maintain audit trails, resolve disputes, and meet legal obligations Applications, identity-verification, ownership, underwriting, and compliance records From collection or the application decision through the period required by financial-services, anti-money-laundering, sanctions, credit, recordkeeping, or other applicable law, generally measured from the application decision, account closure, transaction, or end of the relevant relationship Transaction, payment, card, reimbursement, invoice, receipt, travel, procurement, and accounting records For the life of the relevant account, user relationship, or enabled product, followed by the period reasonably needed to close the account, complete pending activity, provide requested exports, maintain audit trails, resolve disputes, and meet legal obligations Connected Data and Company content While the relevant connection or product is enabled and thereafter for the period needed to complete pending workflows, honor the Company's deletion or export instructions, protect account integrity, and satisfy legal, contractual, audit, and dispute requirements.260This section describes retention for Ramp's Controller purposes.
327This includes, where applicable, prompts, messages, files, connected records, generated outputs, feedback, and workspace or sharing information SaaS products.261For personal data processed on a Company's behalf, retention and deletion are governed by the Agreement, DPA, and Company's documented instructions, including settings and configurations within the Services.
328Security, fraud, authentication, and technical logs For periods based on the security purpose, sensitivity, and risk of the data, including the time needed to detect patterns, investigate incidents, prevent repeat abuse, maintain system integrity, and satisfy security or legal requirements Support, sales, research, event, and business communications For the duration of the interaction and thereafter based on the nature of the communication, the status of the relationship, quality and training needs, recording choices, and applicable legal, contractual, and dispute requirements Website, cookie, analytics, and advertising data For the periods described in our Cookie Policy or the applicable tool, consent, or preference setting; marketing contact information is retained until you opt out or it is no longer needed, with suppression records retained to honor your choice Privacy requests, consents, objections, and compliance records For the period needed to respond to the request or administer the choice and thereafter to demonstrate compliance, prevent repeated unauthorized requests, and meet applicable limitation and recordkeeping periods We periodically review whether personal data remains necessary for the stated purpose.262The following describes the principal retention triggers and criteria we use: Record Category Retention Period or Criteria Account, user, and product records For the duration of the relevant account or customer relationship and thereafter for the period needed to complete account closure and billing, maintain required records, resolve disputes, protect security, and meet legal obligations Applications, identity-verification, ownership, underwriting, and compliance records From collection or the application decision through the period required by financial-services, anti-money-laundering, sanctions, credit, recordkeeping, or other applicable law, generally measured from the application decision, account closure, transaction, or end of the relevant relationship.
329When a retention period expires or the applicable purpose no longer requires identifiable data, we delete, de-identify, or anonymize the data, or place it in a restricted archive when continued storage is required by law.263Biometric data is stored for the period set out in our Biometric Privacy Notice Transaction, payment, card, reimbursement, invoice, receipt, travel, procurement, and accounting records For the period needed for the applicable purpose for which Ramp acts as a Controller, including applicable recordkeeping periods.
330Data subject to a legal hold, regulatory inquiry, investigation, dispute, fraud-prevention need, or security incident may be retained until the matter and any related preservation period end.264Customer-directed records held solely on a Company's behalf are governed by the DPA Connected Data and content processed for Ramp's independent Controller purposes For the period needed for the specific Controller purpose, such as resolving a support request, investigating fraud or abuse, complying with law, or resolving a dispute, subject to applicable product-specific data controls.
265This does not establish retention periods for content processed solely on a Company's behalf Security, fraud, authentication, and technical logs For periods based on the security purpose, sensitivity, and risk, including the time needed to detect patterns, investigate incidents, prevent repeat abuse, maintain system integrity, and satisfy security or legal requirements Support, sales, research, and business communications For the duration of the interaction and thereafter based on the nature of the communication, the status of the relationship, quality and training needs, recording choices, and applicable legal, contractual, and dispute requirements Website, cookie, analytics, and advertising data For the periods described in our Cookie Policy or the applicable tool, consent, or preference setting; marketing contact information is retained until you opt out or it is no longer needed, with suppression records retained to honor your choice Privacy requests, consents, objections, and compliance records For the period needed to respond to the request or administer the choice and thereafter to demonstrate compliance, prevent repeated unauthorized requests, and meet applicable limitation and recordkeeping periods Data retention in certain Services can be configured by account administrators or users.
266Where that is the case, our retention complies with the relevant description made available in the settings, privacy notice, or the Agreement.
267We periodically review whether personal data remains necessary for the stated purpose.
268When a retention period expires or the applicable purpose no longer requires identifiable data, we delete, de-identify, or anonymize the personal data, or place it in a restricted archive when continued storage or processing is required by law.
269Personal data subject to a legal hold, regulatory inquiry, investigation, dispute, fraud-prevention need, or security incident may be retained until the matter and any related preservation period end.
332Where Ramp processes personal data solely on behalf of a Company, retention and deletion are also governed by the Agreement and the Company's instructions. 13.271Where Ramp processes personal data solely on behalf of a Company, retention and deletion are also governed by the Agreement and the Company's instructions. 14.
333Changes to this Privacy Policy Permanent link: 13.272Changes to this Privacy Policy Permanent link: 14.
336We reserve the right to change and reissue this Privacy Policy at any time by posting an updated version on our Website.275We reserve the right to change and reissue this Privacy Policy at any time by posting an updated version on our Websites.
337If we make material changes in the way we collect, use, or disclose your personal data, we will provide you reasonable advanced notice of the changes before they take effect for you.276If we make material changes in the way we collect, use, or disclose your personal data, we will provide you notice of the changes before they take effect for you.
338If we have an existing relationship with you, you represent a Company, or if you are an Authorized User, we may provide you notice through our Website, through your Company's Ramp Account, or directly using the contact information you have provided to us.277If we have an existing relationship with you, you represent a Company, or if you are an Authorized User, we may provide you notice through our Websites, through your Company's Ramp Account, or directly using the contact information you have provided to us.
339If we do not have an existing relationship with you (for instance, if you only visit our Website), any notice we provide will be posted to our Website.278If we do not have an existing relationship with you (for instance, if you only visit our Websites), any notice we provide will be posted to our Websites.
340If you continue using the Services after those changes are in effect, our processing of your personal data will be subject to the new Privacy Policy.279If you continue using the Services after those changes are in effect, our processing of your personal data as a Controller will be subject to the new Privacy Policy.
341We encourage you to regularly review this Privacy Policy to ensure that you remain aware of what personal data we collect, how we use and otherwise process it, under what circumstances we will disclose it to third parties, and your privacy rights and choices. 14.280We encourage you to regularly review this Privacy Policy to ensure that you remain aware of what personal data we collect, how we use and otherwise process it, under what circumstances we will disclose it to third parties, and your privacy rights and choices. 15.
342Contact Us; Data Controller Permanent link: 14.281Contact Us; Data Controller Permanent link: 15.
343Contact Us; Data Controller If you have questions about this Privacy Policy or our practices with respect to personal data, or if you have difficulty accessing the information in this Privacy Policy, please contact us: By email: privacy@ramp.com By mail: Ramp Business Corporation, Attn: Privacy Counsel, 28 West 23rd, Floor 2, New York, NY 10010 Ramp may process personal data in accordance with the instructions of or on behalf of a Company, including when providing Services to a Company under an Agreement.282Contact Us; Data Controller If you have questions about this Privacy Policy or our practices with respect to personal data, or if you have difficulty accessing the information in this Privacy Policy, please contact us: By email: privacy@ramp.com By mail: Ramp Business Corporation, Attn: Privacy Counsel, 28 West 23rd Street, Floor 2, New York, NY 10010 Where we act as the Controller, the Controller is Ramp Business Corporation, unless we specify otherwise in writing.
344In this context, Ramp acts as a Processor and the Company acts as a Controller.283If your Company's Agreement specifies another Ramp entity, that entity is the Controller of your personal data. 16.
345Ramp may also act as a Controller when directly determining the purposes for and means of processing personal data in other business contexts as set out in this Privacy Policy, like complying with regulatory obligations applicable to our Business.284Additional Information for California Residents Permanent link: 16.
346Where we act as the Controller, the Controller is Ramp Business Corporation, unless we specify otherwise in writing. 15.—Removed
347Additional Information for California Residents Permanent link: 15.—Removed
351At or before the time of collection of your personal data, you have the right to know the categories of personal data and sensitive personal data to be collected (see Section 3 - Personal Data Ramp Processes), the purposes for the collection and use of your personal data (see Section 4 - How We Use Personal Data), whether your personal data is "sold" or "shared" (as defined under California law), and how long your personal data is retained (see Section 12 - Retention).288At or before the time of collection of your personal data, you have the right to know the categories of personal data and sensitive personal data to be collected (see Section 3 - Personal Data We Process), the purposes for the collection and use of your personal data (see Section 5 - How We Use Personal Data), whether your personal data is "sold" or "shared" (as defined under California law), and how long your personal data is retained (see Section 13 - Retention).
354Categories of Personal Data We Collect California law requires businesses collecting or disclosing personal data to provide notices and means to exercise those rights.291Categories of Personal Data We Collect California law requires businesses collecting or disclosing personal data to provide notices and information about privacy rights and methods to exercise those rights.
357Employment Information.294Professional or Employment-related Information.
362Audio and/or Video Recording.299Audio, Electronic, Visual, or Similar Information, such as photographs, recordings, communications, and submitted content.
364Precise Geolocation Data when you choose to enable certain features such as trip mileage reimbursement.—Removed
366For further details on personal data we collect, including the sources from which we receive personal data, review Section 3 - Personal Data Ramp Processes.302For further details on personal data we collect, including the sources from which we receive personal data, review Section 3 - Personal Data We Process and Section 4 - Sources of Personal Data We Collect.
367We collect and use these categories of personal data for the business purposes described in Section 4 - How We Use Personal Data above.303We collect and use these categories of personal data for the business purposes described in Section 5 - How We Use Personal Data above.
368We disclose the personal data to the categories of persons set out in Section 5 - Disclosure of Personal Data by Ramp above.304We disclose the personal data to the categories of persons set out in Section 6 - Disclosure of Personal Data by Ramp above.
319This applies where we can verify your association with the Company and applicable law permits notification.
320We address requests concerning our own Controller processing directly.
386Do Not Sell or Share My Personal Data Our business model is to provide corporate card, spend management, and related services to Companies, not selling personal data.324Do Not Sell or Share My Personal Data Our business model is providing corporate card, spend management, and related spend management services to Companies, not selling personal data.
325We do not "sell" or "share" personal data we process on a Company's behalf as a Processor.
328We do not carry out targeted advertising, sales, or sharing using sensitive personal data or personal data we process on a Company's behalf as a service provider.
391You can exercise this right by modifying your preferences for our Website on our Your Privacy Choices ↗ page or by enabling the Global Privacy Control ↗ ("GPC") on your browser or extension.331You can exercise this right by modifying your preferences for our Websites on our Your Privacy Choices ↗ page or by enabling the Global Privacy Control ↗ ("GPC") on your browser or extension.
395We collect certain categories of Sensitive Personal Information, including Social Security numbers, driver's license numbers, passport numbers, other government-issued identification numbers, and biometric information collected through our identity verification process.335We collect certain categories of Sensitive Personal Information, including Social Security numbers, driver's license numbers, passport numbers, other government-issued identification numbers; citizenship information; Ramp account login information or financial-account or payment-card information in combination with credentials that permit access to an account; and biometric information processed to uniquely identify you during identity verification or account recovery.
404We may contact you to verify your identity directly, as well as the authorized agent's permission, before we send a response to the request.344We may contact you to verify your identity directly for requests to know, access, delete, or correct personal data, as well as the authorized agent's permission, before we send a response to the request.
408Notice of Financial Incentives At times, we offer certain opportunities or rewards through contests, sweepstakes, and other special offers and promotions (collectively, "Offers") (see Section 4 - How We Use Personal Data).348Notice of Financial Incentives At times, we offer certain opportunities or rewards through contests, sweepstakes, and other special offers and promotions (collectively, "Offers") (see Section 5 - How We Use Personal Data).
411We may disclose your personal data to third parties as described in Section 5 - Disclosure of Personal Data of this Privacy Policy, including data analytics providers, advertising technology vendors, and social media platforms.351We may disclose your personal data to third parties as described in Section 6 - Disclosure of Personal Data of this Privacy Policy, including data analytics providers, advertising technology vendors, and social media platforms.
414If you want to withdraw from an ongoing or upcoming Offer, you can do so by emailing privacy@ramp.com. 16.354If you want to withdraw from an ongoing or upcoming Offer, you can do so by emailing privacy@ramp.com. 17.
415Additional Information for Canadian Residents Permanent link: 16.355Additional Information for Canadian Residents Permanent link: 17.
416Additional Information for Canadian Residents Data Transfers from Quebec Permanent link: Data Transfers from Quebec If you are a resident of the province of Quebec, please note that we transfer and store personal data outside of Quebec province.356Additional Information for Canadian Residents Ramp designates Privacy Counsel to oversee privacy compliance.
417Data Disclosure to Telecommunications Carriers Permanent link: Data Disclosure to Telecommunications Carriers Personal data will be shared with telecommunication providers or mobile network operators for the purposes of identity verification. 17.357You may request access to personal data under Ramp's control and information about its use and disclosure, and challenge its accuracy or completeness.
418Additional Information for UK Residents Permanent link: 17.358To ask questions or challenge our compliance, contact privacy@ramp.com.
359We will respond within the time required by applicable law, explain any lawful denial, and investigate complaints and take appropriate measures where a complaint is justified.
360You may also contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.
361Personal data may be processed outside Canada, including in the United States, as described in Section 8 - International Data Transfers.
362Data Transfers from Quebec Permanent link: Data Transfers from Quebec If you are a resident of the province of Quebec, please note that we transfer and store personal data outside Quebec province.
363Ramp is committed to protecting personal data and has implemented measures to protect your personal data, including: Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of personal data and limit their access to that information on a "need-to-know" basis.
364Physical, electronic and procedural safeguards designed to comply with relevant standards to protect personal data.
365If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures.
366Designated personnel to monitor our compliance with applicable privacy laws.
367Procedures for receiving, investigating, and responding to complaints or inquiries about our information handling practices.
368Contractual protections designed to ensure that service providers with whom we share personal data maintain adequate protections and security standards.
369You may request access to personal data under Ramp's control and information about its use and disclosure, and may challenge its accuracy and completeness.
370Please see Section 7(A) of this Privacy Policy for more details on your privacy rights and how they may be exercised.
371To ask a question or challenge compliance, contact us as described in Section 15.
372Data Disclosure to Telecommunications Carriers Permanent link: Data Disclosure to Telecommunications Carriers Personal data will be shared with telecommunication providers or mobile network operators for the purposes of identity verification. 18.
373Additional Information for UK Residents Permanent link: 18.
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