Privacy Policy

1. Introduction

ECC11 Ventures LLC, doing business as Narrows Digital ("Narrows Pay," "we," "us," or "our"), is a financial technology company — not a bank. We provide payment technology integration, platform, and advisory services that connect merchants to third-party payment processors and acquiring banks. This Privacy Policy explains what information we collect, how we use it, and the choices you have. By using our website or services, you agree to this Policy.

2. Information We Collect

We collect the following categories of information:

• Business and contact information: name, business name, email, phone number, role, and similar identifiers you provide when contacting us or applying for services.
• Merchant onboarding information: business legal name, ownership structure, beneficial owners, EIN/Tax ID, bank account details, and other information required by our payment processor and acquiring bank partners to perform Know-Your-Customer ("KYC") and Know-Your-Business ("KYB") screening.
• Transaction metadata: non-sensitive metadata about transactions processed through integrated platforms (e.g., transaction ID, amount, timestamp, status). We do not store full payment card numbers ("PAN") on our systems; cardholder data is handled by PCI-DSS compliant processors.
• Technical information: IP address, browser type, device identifiers, referring URLs, and cookie data when you visit our website.
• Communications: records of correspondence, support tickets, and meeting notes.

3. How We Use Information

We use information to:

• Provide, operate, and improve our services and integrations.
• Facilitate merchant onboarding and underwriting through our processor and acquiring bank partners.
• Detect, prevent, and investigate fraud, money laundering, and other prohibited activity.
• Comply with applicable law, including the Bank Secrecy Act, OFAC sanctions screening, and card-network rules (Visa, Mastercard, Discover, American Express).
• Communicate with you about updates, support, and marketing (you can opt out of marketing at any time).

4. How We Share Information

We share information only as needed to deliver services and meet legal obligations:

• Payment processors and acquiring banks (e.g., Fiserv, TSYS, CardPointe, Worldnet) that authorize, clear, and settle transactions.
• Service providers for hosting, analytics, fraud screening, identity verification, and customer support, bound by contractual confidentiality.
• Regulators, law enforcement, and card networks when required by law, subpoena, or network rule.
• Successors in the event of a merger, acquisition, or sale of assets.

We do not sell personal information.

5. Cardholder Data and PCI-DSS

Narrows Pay does not directly store, process, or transmit cardholder primary account numbers in the clear. Cardholder data is collected and processed by PCI-DSS Level 1 compliant third-party processors using tokenization, point-to-point encryption (P2PE), and hosted payment fields. Our integration architecture is designed to keep our systems out of PCI scope wherever possible.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information, including encryption in transit (TLS 1.2+), encryption at rest, role-based access controls, audit logging, and least-privilege principles. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

7. Data Retention

We retain information for as long as needed to provide services and meet legal, accounting, and regulatory requirements, including record-retention obligations under the Bank Secrecy Act (typically five years from account closure or transaction date). When information is no longer needed, we delete or anonymize it.

8. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or port your personal information, and to opt out of certain processing. California residents have additional rights under the CCPA/CPRA. To exercise rights, email hello@narrowspay.com. We will verify your request and respond within the timeframe required by applicable law.

9. Cookies and Tracking

We use essential cookies to operate the site and limited analytics cookies to understand usage. You can control cookies through your browser settings; disabling essential cookies may break functionality.

10. International Users

Our services are operated from the United States. If you access our services from outside the U.S., you consent to the transfer and processing of information in the United States, which may have different data protection laws than your jurisdiction.

11. Children's Privacy

Our services are not directed to children under 13, and we do not knowingly collect information from children.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted on this page with a revised "Last updated" date. Continued use of the services constitutes acceptance.

13. Contact

ECC11 Ventures LLC d/b/a Narrows Digital
Brooklyn, NY
Email: hello@narrowspay.com