Note: The information we collect from you, what we use it for and to whom we disclose it depends on whether you are an individual consumer who uses CanPay to make purchases (a “Customer”), or a merchant customer who uses CanPay to process payments (a “Merchant”). We refer to the term “you” in this policy where our data collection practices apply equally to both Customers and Merchants.
- PERSONAL INFORMATION WE COLLECT
- HOW WE USE YOUR INFORMATION
- HOW WE DISCLOSE YOUR INFORMATION
- YOUR PRIVACY CHOICES AND RIGHTS
- SECURITY OF YOUR INFORMATION
- INTERNATIONAL DATA TRANSFERS
- RETENTION OF PERSONAL INFORMATION
- CHILDREN’S INFORMATION
- THIRD-PARTY WEBSITES/APPLICATIONS
- CONTACT US
3. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
- Account Creation
- Customers: To create an account, we may collect information such as your name, email address, a valid driver’s license or state identification card, checking and savings account information, phone number, birthday, address, last 4 digits of your social security number or other government-issued identification number, security questions and answers, any loyalty card number, and a unique PIN.
- Merchants: To create an account, you must provide your contact name, email address, phone number, title, business and legal entity names and addresses, legal entity’s federal tax identification number, corporate contact name and contact information (title, email address, and phone number), the state in which you do business, average monthly revenue and ticket sales, POS provider, cannabis business license details (if applicable), banking details (financial institution name, contact person’s name and email address, routing number, and account number), and documentation for underwriting purposes that may include, but are not limited to the following: driver’s licenses, voided checks and bank statements, legal entity documents, bank letters, and other business licenses.
- Purchases: We may collect personal information and details associated with the purchases Customers make using our Services.
- Account Creation
- Your Communications with Us. When you request information about our Services, (such as Merchants who inquire about using CanPay in their business), register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us, we may collect personal information that you elect to provide to us, such as your email address, phone number, name, employer, and/or mailing address.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities that enable you to communicate with others. For example, we may allow Customers to provide information about their friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. We may also allow you to suggest businesses to us who you would like to use CanPay. If you elect to do so, we may ask you to provide the name, email address and phone number from the referred business’ representative.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
- Sweepstakes, Contests or Games of Skill. We may collect personal information from Customers they provide for any sweepstakes, contests or games of skill that we offer. In some jurisdictions, we are required to publicly share information of our sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
- Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, general location information (derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Geolocation. If a Customer uses a location-enabled device with our Service, we may collect geographical location data or use various means to determine their location, such as sensor data, GPS, Wi-Fi, or cell site triangulation. Note that if Customers do not agree to our collection of Geolocation Information, some of our Services may not function properly. Customers may learn more about their ability to restrict the collection and use of Geolocation Information by referring to the controls available on their devices.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
See Section 6 below to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
- Twitter Analytics. For more information, please visit Twitter’s help page
C. Information We Collect from Others.
We may obtain information about you from other sources, including through referrals, third-party services and organizations who provide services on our behalf, such as service providers who verify the information you provide to us and assess your eligibility to use our Services.
4. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.
We may use Customers’ phone number to send important text messages regarding their use of the Services (such as purchase receipts, verification codes, and similar transactional messages); standard messaging and data rates apply.
We may collect Customers’ precise geographic location to protect against fraud and other security risks. In addition, we may use location information in order to enhance our Services, and to provide offers and discounts in connection with Services that Customers consent to use.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including verifying your identity if you contact us to exercise your legal rights;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices, or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us as set forth below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
- Automated Decision Making. We may engage in automated decision making, including profiling. For example, our algorithms may automatically prevent Customers from making certain purchases if we suspect fraudulent activity on their account. CanPay’s processing of Customers’ personal information will not result in a decision based solely on automated processing that affects the Customer’s legal rights, unless such a decision is necessary as part of a contract we have with the Customer, (such as to prevent fraud), we have a Customer’s consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth below.
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
5.HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, as described below.
A.Disclosures to Provide our Services
- Disclosures to Merchants. We disclose Customers’ names and CanPay-specific identifiers to Merchants, who may use this information to provide their services to Customers, including providing Customers with loyalty programs and/or advertising.
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services. We also share Customers’ account information (as described in “Personal Information We Collect” above) with verification service providers, who combine this information with information they obtain from public records, (including a Customer’s name, social security number, etc.), to verify Customers’ identities and ensure they are eligible to use our Services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with our company affiliates.
- Advertising Partners. We may share Customers’ personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding Customers’ activities and their devices (e.g., Customers’ IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to Customers when they visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
- APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
6.YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
- Mobile Devices. We may send you push notifications through our mobile applications. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. Where provided under applicable law, you may have the right to:>
- Access Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to our processing of your personal information; and
- Withdraw your Consent to our processing of your personal information.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.
7. SECURITY OF YOUR INFORMATION
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
8. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
9.RETENTION OF PERSONAL INFORMATION
10. CHILDREN’S INFORMATION
The Services are not directed to children under 18, and we do not knowingly collect personal information from children, other than with the parent’s consent (in the case of a parent creating a sub-account for their minor child).
If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account as applicable.
11. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage you to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
12. CONTACT US
CONSUMER PRIVACY NOTICE
|Facts||What does CanPay do with your personal information?|
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all of this sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect, and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice.
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons CanPay chooses to share; and whether you can limit this sharing.
|Reasons we can share your personal information||Does CanPay share?||Can you limit this sharing?|
|For our everyday business purposes—|
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
|For our marketing purposes—|
to offer our products and services to you
|Reasons we can share your personal information||Does CanPay share?||Can you limit this sharing?|
|For joint marketing with other financial companies||Yes||No|
|For our affiliates’ everyday business purposes—|
information about your transactions and experiences
|For our affiliates’ everyday business purposes—|
information about your creditworthiness
|No||We don’t share|
|For our affiliates to market to you||No||We don’t share|
|For nonaffiliates to market to you||No||We don’t share|
|To Limit our sharing||
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
|Questions?||Call 888-395-4992 or email us at iCanPay@canpaydebit.com.|
Mark any/all you want to limit:
Trusted Debit LLC (“CanPay”)
PO Box 856, Mercer Island, Washington 98040
|City, State, Zip|
|Who we are|
This privacy notice is provided by CanPay, and is applicable to your personal CanPay account.
|What we do|
|How does CanPay protect my personal information?||
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
|What we do|
|How does CanPay collect my personal information?||
We collect your personal information, for example, when you
We also collect your personal information from others, such as our verification service providers, affiliates, or other companies.
|Why can’t I limit all sharing?||
Federal law gives you the right to limit only
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
|Other important information|
We may transfer personal information to other countries, for example, for customer service or to process transactions.
California: If your CanPay account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.
Vermont: If your CanPay account has a Vermont mailing address, we will not share personal information we collect about you with non-affiliates unless the law allows, or you provide authorization.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information CanPay has collected about them, and whether CanPay disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.
Information Collected. The categories of personal information collected by CanPay in the preceding 12 months is described in Section 2 of the Privacy Notice above..
Information Disclosed. The categories of personal information shared by CanPay in the preceding 12 months are described below:
|Category of Personal Information Disclosed by CanPay||Category of Third Parties Information is Disclosed to for a Business Purpose|
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers.
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))|
A name, signature, Social Security number, address, telephone number, driver's license or state identification card number, bank account number, or any other financial information.
|Protected classification characteristics under California or federal law|
Age (40 years or older).
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|Internet or other electronic network activity|
Browsing history, information on a consumer's interaction with an internet website, application, or advertisement.
Physical location or movements.
|Inferences drawn from other personal information to create a profile about a consumer|
Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in Section 2 of the Privacy Notice above.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, CanPay does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in Section 12 of the Privacy Notice above, and provide written confirmation via a scanned document containing your signature and the name of your authorized agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to verify information you have given us to set up your account, or to provide details regarding recent transactions.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in Section 12 of the Privacy Notice above. We will process such requests in accordance with applicable laws.
- Personalized discounts. We may offer personalized discounts and financial incentives to Customers based on information we retain regarding Customers’ individual spending habits. Customers may opt out of receiving these personalized discounts at any time by adjusting their account settings. These programs allow us to deliver additional value to Customers and generate additional profit from our arrangements with the Merchants who provide the discounts. The value of each Customer’s data varies depending on the Merchant providing the promotion and the details of each promotion, and said value will be reflected in the discount offered to each Customer.
- Refer-a-friend programs. As described above in Information You Provide to Us Directly (“Share Content with Friends or Colleagues”), we may offer incentives to you such as discounts or promotional credit in connection with programs that we may run, wherein you provide personal information regarding their friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These referral programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the referred party’s data to us depends on whether the referred party ultimately becomes a Customer or Merchant and uses our Services. Said value will be reflected in the incentive offered for each referral.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at iCanPay@canpaydebit.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.