Echo Points Privacy Policy

Effective date: September 4, 2026

FunnelStart LLC (“Echo Points,” “we,” “us,” or “our”) operates the Echo Points service (the “Service”). This Privacy Policy describes the information we collect, how we use and share it, how long we retain it, and the choices available to you. It applies to echo-points.com, the Echo Points application and dashboard, and the pages a customer sees after scanning a Business’s code or opening a Business’s link (collectively, the “Service”).

This policy applies to two categories of users:

Businesses create an account with us to operate a rewards program.
Participants are customers of a Business who scan that Business’s code or open its link. Participants do not create an account with us.

By using the Service, you acknowledge the practices described in this policy.

1. Information we collect

From Businesses

Account details: your name, email address, business name, and business address or service area.
Program settings: your points rate, rewards, the payment method to which Participants are directed, your review platform link, and any optional branding you provide.
Billing information: paid plans are billed through our third-party payment processor (currently Stripe). The processor collects and stores your payment card details under its own privacy policy. We receive confirmation of payment and limited card metadata (such as card brand and last four digits). We do not store full card numbers.
Support and communications: messages and other content you send to us.
Technical data: IP address, browser and device type, pages visited, referring pages, and timestamps when you use the Business dashboard.

From Participants

Browser identifier: a random identifier stored in your browser so that your points balance with a Business is recognized when you scan that Business’s code again. It does not contain your name or contact details.
Transaction details: the amount entered by the Business, the points credited or redeemed, and the date and time.
Review activity: if you choose to use the review feature, the star rating you select and any review text you draft, whether or not you go on to post it.
Technical data: IP address, browser and device type, and timestamps.
Optional contact information: some Businesses may enable an optional feature that asks for your email address so you can access your points from another device. When this feature is enabled, you will be clearly notified before any information is captured, and providing it is voluntary. We collect an email address from Participants only in that case.

What we do not collect from Participants by default: your name, phone number, or payment card or bank details. Any payment you make to a Business occurs through the Business’s own payment method or in cash, outside the Service. We do not receive or process those payments.

2. How we use information

We use the information we collect for the following purposes:

To operate the Service: to credit, redeem, and track points, display balances, generate codes, prepare review drafts for you to post on the platform you choose, and direct you to the Business’s payment method.
To provide Businesses with their own program activity: including transactions, points issued and redeemed, ratings, and review text from their own Participants.
To bill Businesses and administer their accounts.
To provide support and send service communications: such as sign-in links, usage or limit notices, security alerts, and notices of changes to our policies.
To send Businesses product updates and marketing about Echo Points. You may opt out of marketing communications at any time using the unsubscribe link in the email or by contacting us. Service communications will continue for as long as you maintain an account.
To secure, maintain, debug, and improve the Service: including detecting fraud or abuse and producing aggregated or de-identified statistics that do not identify any individual.
To comply with applicable law and to enforce our Terms of Service and other agreements.

We do not sell personal information. We do not use Participant information for advertising, and we do not share Participant information with anyone except as described in this policy.

3. How we share information

We may share information in the following circumstances:

With the Business whose code you scanned. A Participant’s transaction details, points, rating, and review text are shared with that Business because the rewards program belongs to that Business. We do not share one Business’s Participant data with any other Business.
With review platforms, at your direction. If you choose to post a review, you are directed to the review platform and post the review yourself, subject to that platform’s terms and privacy policy. We do not submit your review to the platform on your behalf.
With service providers that perform services for us, such as cloud hosting, email delivery, payment processing, analytics, and customer support tools. These providers are permitted to use the information only as necessary to provide services to us.
For legal and safety reasons, where we believe in good faith that disclosure is required by law, regulation, subpoena, or court order, or is reasonably necessary to protect the rights, safety, or property of Echo Points, our users, or others.
In connection with a business transfer, such as a merger, acquisition, financing, reorganization, or sale of all or part of our assets, in which case this policy will continue to apply to the transferred information unless you are notified otherwise.
With your consent or at your direction.

4. Cookies and similar technologies

The Participant experience uses a strictly functional cookie or equivalent browser storage that is required for the Service to work. It is not used to track you across other websites or for advertising.
The Business dashboard uses cookies necessary for sign-in, security, and session management.
Our marketing website may use analytics tools to understand how visitors use the site. You may block these tools through your browser settings or an ad blocker without affecting the Service.

We do not currently respond to “Do Not Track” browser signals because no common industry standard exists for them. In any case, we do not track Participants across other websites.

5. How long we keep information

Retention periods may vary based on the type of information, the plan a Business is on, and our legal obligations. Our general practices are:

Business account data: for as long as your account is active, and for up to 90 days after closure so you can request an export. Billing records are retained for as long as tax, accounting, and other applicable laws require.
Participant transaction, points, and review data: for as long as the associated Business’s account is active. We may delete or aggregate records older than 24 months, and we may apply shorter retention periods for accounts on the free plan.
Technical logs: generally up to 12 months.
Support messages: generally up to 2 years.

We may retain information for longer periods where required by law, where needed to resolve disputes or enforce our agreements, or where the information has been aggregated or de-identified.

6. Security

We use reasonable technical and organizational measures designed to protect information, including encryption in transit, access controls, and one-time sign-in links instead of stored passwords. No method of transmission or storage is completely secure, and we cannot guarantee the absolute security of information you transmit to us.

7. Your choices and rights

Participants. Because your balance is tied to an identifier stored in your browser, you may end your relationship with the Service by clearing your browser data for this site. To ask what information is associated with your identifier, or to request its deletion, you may contact the Business whose code you scanned or contact us at support@echo-points.com. Because we do not store your name or contact details by default, we may need additional information from you, such as recently scanned codes or links, in order to locate and verify your records.

Businesses. You may view and update your account information in the dashboard at any time. You may close your account at any time and request an export of your data within 90 days of closure.

State privacy rights. Depending on where you live, including Connecticut, California, and other states with comprehensive privacy laws, you may have the right to access, correct, delete, or obtain a copy of your personal information, to opt out of the sale of personal information or targeted advertising (we do neither), and not to be discriminated against for exercising these rights. To exercise a right, contact us at support@echo-points.com. We will verify your request and respond within the time required by applicable law. If we deny your request, you may appeal by replying to our response. Where we act as a service provider or processor on behalf of a Business, we may direct your request to that Business and will assist it in responding.

8. Children

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13. Business accounts may only be created by individuals 18 years of age or older. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

9. Users outside the United States

The Service is operated from the United States and is intended for Businesses and Participants located in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States.

10. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify Businesses by email or through the application with reasonable advance notice (generally at least 14 days) before the changes take effect, and we will update the effective date above. Non-material changes may take effect upon posting. The current version is always available at echo-points.com/privacy-policy.

11. Contact

FunnelStart LLC (Attn: Echo Points) 19 High Ridge Rd, #8124 Stamford, CT 06905 support@echo-points.com