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INTRODUCTION

This Privacy Notice describes how Connexpay, LLC collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you apply or sign up to use Connexpay Services.

This Privacy Notice applies to your use of our Services, and covers information collected in connection with your access to and use of our Services. Please read this Privacy Notice carefully. By continuing to interact with our Services, you are consenting to the practices described in this Privacy Notice.

INFORMATION WE COLLECT ABOUT YOU

We need to collect information about you to provide you with the Services or the support you request. The type of information we collect can vary depending on the country from which you access our Services. Additionally, you can choose to voluntarily provide information to us.

Information You Provide

We collect information you provide when you apply or sign up for a Connexpay account, go through our identity or account verification process, authenticate into your account, communicate with us, upload content, or otherwise use the Services.

We collect information about you when you use our Services, including:

Identification Information. Your name; email address; mailing address; phone number; photograph; birthdate; passport, driver’s license, Social Security, Taxpayer Identification, or other government-issued identification; or other historical, contact, and demographic information when you apply or sign up for a Connexpay account, signature, and authentication credentials (for example, information you use to login to your account), including IP address.

Financial Information. Information such as bank account, payment card numbers, credit reports, and other publicly available information.

Tax information. Withholding allowances and tax filing status.

Transaction Information. When you use our Services to make, accept, request, or record payments, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.

Information We Collect from Your Use of our Services

We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

Precise Geolocation Information. The location of your device. For more information and to learn how to disable collection of location information, please see below.

Device Information. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services.

Use Information.

Information about how you use our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, the website you visited before you visited or used the Services, data about how you interact with our Services, and other clickstream data.

Business Information.

Information about products and services you sell (including inventory, pricing and other data) and other information you provide about you or your business (including appointment, staffing availability, employee, payroll and contact data).

Employee Information.

Information provided to a Seller using our Services, for example information about employees whose employers use Connexpay Payroll or Employee Management (including hours worked and other timecard data).

Customer Information.

Information you collect from your customers, including email address, phone number, payment information, or other information.

Information We Collect from Other Sources

We also collect information about you from third parties, including:

Identity Verification. Information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number.

Background Information. To the extent permitted by applicable laws, we may obtain background check reports from public records of criminal convictions and arrest records. We may use your information, including your full name, government-issued identification number, and date of birth, to obtain such reports.

Credit, Compliance and Fraud. Information about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

For what purposes does Connexpay use your Personal Information?

We have grouped the Personal Information Connexpay captures related to its main processing activities, which include:

  • Operations
  • Risk Management
  • Transaction processing
  • Marketing
  • Relationship Management
  • Products

Connexpay uses and processes your Personal Information for purposes that are appropriate, based on legitimate interests or authorized by applicable law. These purposes may include:

  • Legal, regulatory or law enforcement purposes
  • HR purposes
  • Credit Risk purposes
  • Fraud monitoring
  • Security purposes
  • Marketing purposes
  • Product development purposes
  • Customer Services/Account Management purposes

These purposes are not limited to the areas as defined above. Please refer to the Appendix which provides an overview and connection between the main types of Personal Information, the purposes for processing, who will have access to that Personal Information and the purposes for the disclosure to those who have access.

Operations, which includes: IT, telephony, security and analytics services;

Risk Management, which includes: fraud mitigation and management, authentication and acceptance;

Transaction processing, which includes: compliance monitoring, scheme operations, disputes/chargebacks, capturing payments, settlement, gateway services, and programmed management and authorization;

Marketing, which includes: customer acquisition, usage analysis, lead generation and cross sell/up sell;

Relationship Management, which includes: supplier relationship management, credit risk monitoring and customer relationship management; and

Products, which includes: data analytics, business, finance, self-service, fraud service, foreign exchange service, currency services, as well as the development of new products.

Legal, regulatory or law enforcement purposes:
  • Comply with local and national laws, including card scheme rules and requests from law enforcement and regulatory authorities;
  • Enforce our legal rights and satisfy our legal obligations, including without limitation any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others;
  • Conduct our own due diligence checks;
  • Prevent, detect and prosecute fraud or crime or to assist others in doing so;
  • Assist in investigation by Connexpay, other financial organizations or third parties of suspected criminal activity;
  • Carry out obligations arising from any contracts entered into between you and Connexpay;
  • To manage and enforce Connexpay’s rights, terms of use or any other contracts with you and your business;
  • Assess financial and insurance risks;
  • Notify you about important changes or developments to Connexpay’s website or Connexpay’s services;
  • Recover debt or in relation to your insolvency, including tracing your whereabouts;
  • Identify and monitor for fraud;
  • Maintain internal recordkeeping and reporting;
  • Prepare and furnish compilations and analyses as well as other reports of aggregated and anonymized information;
  • Check your or your business’s credit status/profile and identity; and
  • Record and track details of your transactions or your customer’s transactions.
HR purposes:
  • To process your job application if you apply for a job vacancy at Connexpay;
  • To register and send you email alerts of future vacancies; and
  • Maintain internal recordkeeping and reporting.
Credit risk purposes:
  • Conduct our own due diligence checks;
  • Check you or your business’s credit status/profile and identity;
  • Record and track details of your transactions or your customer’s transactions;
  • Maintain internal recordkeeping and reporting;
  • Identify and monitor for fraud;
  • Assess financial and insurance risks;
  • Mitigate information security, sector or credit risk; and
  • Commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around cardholder transaction patterns and usage.
Fraud monitoring purposes:
  • Monitor merchant or other customer transactions in an effort to detect and prevent fraud;
  • Maintain internal recordkeeping and reporting;
  • Prepare and furnish compilations and analyses as well as other reports of aggregated and anonymized information; and
  • Provide or develop more innovative and effective fraud monitoring services for our merchants or other customers.
Security purposes:
  • Conduct our own due diligence checks;
  • Administer Connexpay’s site for internal operations, including troubleshooting;
  • Keep Connexpay’s site safe and secure;
  • Maintain internal recordkeeping and reporting;
  • Identify and monitor for fraud; and
  • Mitigate information security, sector or credit risk.
Marketing purposes:
  • Marketing or market research;
  • Perform analysis and comparisons;
  • Maintain internal recordkeeping and reporting;
  • To manage Connexpay events;
  • To improve and develop Connexpay’s business;
  • Information, products and services you requested, purchased or which may be of interest to you;
  • Provide or develop more innovative and effective Connexpay services for our merchants or other customers;
  • When Connexpay communicates with you or each other;
  • To enable you to enter a competition, promotion or survey;
  • Create profiles and marketing opportunities;
  • Promotional materials for future events;
  • Distribution to event participants;
  • Social media site integration and interaction;
  • To optimize Connexpay’s websites/portals, products and services;
  • Commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around cardholder transaction patterns and usage;
  • Better understand card usage patterns or to optimize your experience and intelligently route transactions;
  • Notify you about important changes or developments to Connexpay’s website or Connexpay’s goods and services;
  • Improve Connexpay’s site and ensure content presented in effective way;
  • Allow you to participate in interactive features of Connexpay’s service;
  • To enable you to participate in discussion boards or other social media functions on Connexpay’s site; and
  • Obtain your views on goods, services and Connexpay’s website(s).
Product development purposes:
  • Provide or develop more innovative, user friendly and effective products and services;
  • Maintain internal recordkeeping and reporting;
  • Prepare and furnish compilations and analyses as well as other reports of aggregated and anonymized information;
  • Ongoing intelligence on how to best route transactions;
  • Commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around cardholder transaction patterns and usage; and
  • Better understand card usage patterns or to optimize your experience.
Customer services/account management purposes:
  • To enable you to contact us;
  • For training purposes;
  • Provide or develop more innovative and effective Connexpay services for our merchants or other customers;
  • Authorize and establish commercial merchant accounts;
  • Maintain internal recordkeeping and reporting;
  • To enable you to upload and/or store information;
  • Information, products and services you requested, purchased or which may be of interest to you;
  • To enable you to participate in discussion boards or other social media functions on Connexpay’s site;
  • Facilitate collection or redemption of points or rewards currency of any Loyalty program;
  • Manage, investigate and resolve complaints;
  • Obtain your views on goods, services and Connexpay’s website(s);
  • Allow you to participate in interactive features of Connexpay’s service;
  • To respond to any enquires;
  • When Connexpay communicates with you or each other;
  • To provide Connexpay Services to you and your business;
  • To enable you to report a problem with Connexpay’s site;
  • Analyze and report on you or your customers use of any Loyalty service;
  • Manage disputes of transactions, rewards or points;
  • To subscribe you to a Connexpay service;
  • To register your use of any Connexpay Services;
  • To process your application for Connexpay Services;
  • Understand Connexpay’s customers’ requirements; and
  • Notify you about important changes or developments to Connexpay’s website or Connexpay’s goods and services.
With whom does Connexpay share your Personal Information and for what purposes?

Connexpay may share your Personal Information with members of our corporate family, which means our subsidiaries and our ultimate holding company and its subsidiaries. We may also share Personal Information with third parties for legal and regulatory purposes, in order to deliver our products and services, and in relation to mergers and acquisitions.

Before we share your Personal Information, we ensure there are adequate safeguards in place to protect the processing of that data. Except where permitted, Connexpay does not sell, rent, share or otherwise disclose Personal Information about its customers to third parties for the third party’s commercial purposes.

Connexpay does not disclose information which could identify you personally, to anyone except as described in this notice, including:
  • Any Connexpay group company;
  • Any group company (such as advisers, share plan, payroll and other third-party administrators, agents or contractors working on behalf of Connexpay);
  • Financial institution clients;
  • Service providers and other third parties under contract who help with our business operations (including, but not limited to, fraud investigations, site analytics and operations);
  • Regulatory authorities, such as the FCA, Data Protection Authorities, and the FTC;
  • Social media sites integrated into web services that we offer;
  • Governmental or quasi-governmental organizations;
  • Potential purchasers of Connexpay;
  • Business partners (including those in which Connexpay has an investment), suppliers and sub-contractors for the performance of any contract Connexpay enter into with them or you;
  • Analytics and search engine providers that assist Connexpay in the improvement and optimization of Connexpay’s websites, although ordinarily only non-Personal Information is shared;
  • Credit reference agencies for the purpose of assessing your credit score where this is a condition of Connexpay entering into a contract with you;
  • Fraud prevention agencies (as outlined above and including Action Fraud, Financial Fraud Action and the Financial Fraud Bureau); and
  • Third Party Credit and Financial Institutions (where allowed under any Terms of Use or other contract) including:
    • the credit institution, where you or your business maintains its bank account; or
    • the card schemes governing the issue and use of credit, debit, charge, purchase or other payment cards, alternative payment schemes and any other financial institutions who may process payments and who are not operating under Connexpay’s control nor for whom whose actions or omissions Connexpay has liability.
Legal or regulatory purposes, including:
  • Where Connexpay are required or permitted to do so by law or regulations, including for Tax purposes or to comply with financial services regulations;
  • Where Connexpay deem it in the national interest or otherwise lawful to do so;
  • In the course of Litigation;
  • Following requests from governmental or public authorities;
  • Following requests from law enforcement;
  • National security;
  • As part of a legal process; and
  • When we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
Business purposes, including:
  • To transfer information and/or assets in the event of a merger, acquisition, sale, bankruptcy filing, or other corporate restructuring; and
  • If Connexpay sell or buy any business or assets, in which case Connexpay may disclose your Personal Information to the prospective seller or buyer of such business or assets.
Suppliers who assist Connexpay with the provision of its services, including:
  • Fulfilling or processing orders or application forms e.g. for job vacancies;
  • Processing payments;
  • Managing credit, security, sector and fraud risk;
  • Market research; and
  • Survey activities.

Where Connexpay uses and/or discloses confidential or cardholder transactional data for preparing and furnishing compilations, analyses and other reports of aggregated information and anonymized information, it will do so provided it has taken reasonable measures to avoid identifying any customer of Connexpay other than the customer whose transactions were involved in the preparation of any compilation, analysis or other report. This data may be used for statistical, analytic, and administrative purposes, including for customizing our web sites, analyzing trends, tailoring products and services, or conducting risk and cost analysis.

HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your account, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

We use various technologies to collect information when you access or use our Services, including placing a piece of code, commonly referred to as a “cookie,” or similar technology on your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We will begin collecting information about you or from activity on devices you use as soon as you use our Services. By using our Services, you permit us to collect and use your information from activity on devices you use in accordance with this Privacy Notice. For more information and to learn how to block or delete cookies used in the Services, please see below.

Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We may use cookies to:
  • Remember that you have visited us or used the Services before. This allows us to identify the number of unique visitors we receive, so that we can provide enough capacity to accommodate all of our users.
  • Customize elements of the promotional layout and/or content of our Services.
  • Collect data about the way you interact with our Services (e.g., when you use certain features).
  • Collect data to assess and improve our advertising campaigns, including sending information to our business partners.
  • Allow our business partners (including third parties) to use these tracking technologies to track your behavior on our behalf on our Platform (including when you use multiple devices) and on partner websites.
  • Enable third parties to collect data about the way you interact across sites outside of our Services.
  • Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We use web beacons to deliver cookies, track the number of visits to our website and apps, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.

Links to third party sites and public posting

Connexpay’s websites may also contain links to and from the websites of partner networks, advertisers and affiliates. If you follow such a link or if you post information or content, such as commenting on content or participating in online forums or communities, or when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. Please note that these websites have their own privacy notices and cookies policies and Connexpay does not accept any responsibility or liability for these third-party websites.

If our websites link through to third-party websites, those processes may involve the placement of third-party cookies on your machine or device. Please be aware that we do not control these third-party websites or any of the content contained on those websites, including the third-party cookies used for these purposes. The inclusion of links to third party websites in no way constitutes an endorsement by us of such websites’ content, actions, or policies.

We may also, from time to time, partner with ad networks and other online advertising providers in order to serve ads on behalf of us or other non-affiliated parties on our websites and across the Internet. These ads may be presented to you based on products and services the advertising providers think are relevant to your interests. These preferences may be inferred based on information collected about your browsing behavior on our websites and other non-affiliated sites and apps across time. We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles. To learn more about, or opt-out of, this type of advertising from participants in the DAA, you can visit www.aboutads.info.

Your privacy rights (data subject rights)

Under the EU’s General Data Protection Regulation, individuals who reside in Europe are able to exercise rights regarding their Personal Information. You can find a more detailed summary of these rights on the UK’s Information Commissioner’s Office’s (“ICO”) website here. These rights include:

  • the right to access;
  • the right to rectification;
  • the right to restriction;
  • the right to erasure;
  • the right to object; and
  • the right to data portability.

If access cannot be provided within a reasonable time frame, Connexpay will provide you with a date when the information will be provided. If for some reason access is denied, Connexpay will provide an explanation of why access has been denied.

California’s “Shine the Light” law permits California residents to annually request and obtain (free of charge) a list of certain categories of Personal Information disclosed to third parties for direct marketing purposes in the preceding calendar year. The list should include the names and addresses of such third parties, and any other information deemed necessary to give the customer a reasonable indication of the nature of the third parties’ business. Please send any such request to the contact address below, and Connexpay will respond within 30 days.

The laws of other territories applicable to your dealings with Connexpay may also be relevant (and may also impact the above rights). Any such rights can be progressed through our customer services center or via the contact us section below. However, all cardholder requests must first be requested to the relevant customer. Connexpay will assist customers with such requests accordingly.

How does Connexpay ensure the security of your Personal Information

Connexpay works to maintain your confidence and trust in us and has therefore implemented physical, technical, and administrative measures designed to secure your Personal Information from accidental loss, unauthorized access, use, alteration and disclosure. However, the safety and security of your information is also dependent upon you. We store and process your information on our servers located within the United Kingdom and the United States and use other computing facilities around the globe.

By submitting Personal Information, you agree to such transfer, storing and processing. Connexpay will take reasonable steps to ensure that your Personal Information is treated securely and in accordance with this privacy notice.

Where Connexpay has given you (or where you have chosen) a password or access code which enables you to access certain parts of Connexpay’s websites/portals or mobile applications, you are responsible for keeping this password and/or access code confidential. You should not share your password or access code with anyone and you should use all reasonable endeavors to ensure that there is no unauthorized use. You therefore authorize Connexpay to act upon instructions and information received from any person that enters your user ID and password and you agree to be fully responsible for all use and any actions that may take place during the use of your account. You also agree to promptly notify Connexpay of any information you have provided which has changed.

Unfortunately, the transmission of information via the Internet is not completely secure. Although Connexpay will take reasonable steps to protect your Personal Information, Connexpay cannot guarantee the security of your data transmitted to Connexpay’s site; any transmission is at your own risk. Once Connexpay have received your information, Connexpay will use strict procedures and security features to try to prevent unauthorized access.

Connexpay maintain security standards that are designed to protect your information as it is transmitted from your computer to our network. This technology is called Secure Socket Layer (SSL). SSL is the leading security protocol for data transfer on the Internet and helps to protect the safety and confidentiality of your online banking information.

You have a role in helping Connexpay by safeguarding your information from others. You have several options when deciding how you can best protect your Personal Information. One option is simply not to volunteer it. The FTC’s websites (www.ftc.gov, www.ftc.gov/idtheft, and www.onguardonline.gov) offer useful information about how to protect your Personal Information.

Changes and updates to the privacy notice

Connexpay may, from time to time, make changes to this privacy notice. If any material changes are made as to how Connexpay treats your information, you will be notified through this Privacy Notice on this website/portal.

The date the Privacy Notice was last modified is at the bottom of the page. You are responsible for ensuring you periodically visit this websites/portals and privacy notice to check for any changes. By continuing to use Connexpay Sites and Services, you agree to the changes in this Privacy Notice.

This Privacy Notice is global in scope, but is not intended to override any legal rights in any territory where such rights prevail. In such event, the rights and obligations set out in this notice will apply, subject only to amendment under any applicable local law having precedence.

CONTACT

Please contact our Privacy Department with any questions or concerns regarding this Privacy Notice.

ConnexPay LLC

8530 Eagle Point Blvd., Suite 100

Minneapolis, MN 55042

privacy@connexpay.com

If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our Privacy Department listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.