Privacy Notice
for residents of the state of California
This
Privacy Notice for residents of the state of California (hereinafter referred
as the “Notice”) is part of NorthStar Currency Global Privacy Policy. This
Notice applies solely to consumers who reside in the State of California, and
to information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or household ("Personal Information").
We
provide this Notice to comply with our obligations under the California
Consumer Privacy Act of 2018 ("CCPA") where such exists, where and
when we have the capacity of “Business” under this Law. Usually this will be
the case when we provide our clients based in California with our payment
services (the “Service” or “Services”) or they interact with our website.
This
Notice does not apply to information that we may process in our capacity as a
"Service Provider" under CCPA on behalf of our clients, where and
when we have such capacity. If we process your information in such capacity, we
will direct your inquiry to our relevant clients.
Personal Information that We collect
from California Residents
In
the twelve (12) months prior to the Effective date of this Notice, we have
collected the following categories of Personal Information from California
Residents:
- Payment Information. When submitting
a payment through our Service, we ask the payer for information such as the payer’s name, address, phone number. You will also need to
provide information about the person for whom you are submitting a payment. For
example, when submitting a payment to an educational institution, we will also
ask for the student’s name, student ID, invoice number, date of birth, year of
graduation, educational institution, and student email address. As part of the
payment process, or to process a refund or charge-back, we and/or our partners
may need the payer’s financial account information, such as bank account
numbers, names, and routing codes.
- Referrals. To invite others to use
the Service, you may submit their names, emails, and, for students, their
educational institution.
- Messages and Customer Service
Requests. We collect the information you submit when you communicate with us by
email, chat, or other methods. This includes customer support where you may
choose to submit information regarding a problem or whether you speak to one of
our representatives directly or otherwise engage with our support team. A
summary of the problem you are experiencing, screen shots, documentation or information
that would be helpful in resolving the issue.
- Use of the service. We collect
information about you when browsing our website and taking certain actions.
This information includes links you click on; the type, size and filenames of
attachments you upload to the services, content using analytics techniques that
hash, filter or otherwise scrub the information and we collect clickstream data
about how you interact with and use features of the services.
- Device Information. We collect
information about your computer, phone, tablet or other devices you use to
access the services. Including browser type, IP address, device identifiers and
crash data. We will also use your IP address and/or country preference to
provide you with better service.
- When you visit our Service or open
our emails, we and our third-party service providers may collect certain
information by automated means, such as cookies, web beacons and web server
logs. The information collected in this manner includes IP address, browser
characteristics, device IDs and characteristics, operating system version,
language preferences, referring URLs, and information about the usage of our
Service. We may link this data to your profile.
Categories of sources from which the
personal information is collected
The
Categories of sources from which We collect personal information about you, are
the following:
- Directly from you, including when
you provide information to us and use our services;
- Indirectly from you, such as when we
automatically collect technical and usage information when you use our websites
or other online;
- Financial Institutions and Service
Providers. In the course of processing your payment transaction we may work
with a number of institutions, who we have partnered with, to help us provide
our Service including banks and non-bank financial institutions such as card
processors, electronic money institutions and payment service providers. To
process a payment, a financial institution or service provider may share with
us information about the payer’s account such as account name, number, routing
code and other identifying information.
-
We may be provided with your name and email address, from
the educational institutions and other entities for which we serve as a payment
agent, in order to contact you to encourage you to make a payment through our
Service. Furthermore, these educational institutions, may use the Service to
communicate with you and manage the receipt of payments.
Our business or
commercial purpose for collecting or selling personal information
Our
purposes to collect and process your personal information are the following:
-
To Provide and improve
the Service;
-
We use information
about you to verify accounts and activities, to monitor suspicious or
fraudulent activities and to identify violations;
-
Process your payment
transaction and keep you informed about the status of your payment;
-
Comply with and enforce
applicable legal requirements, industry standards and our policies;
-
Prevent potentially
illegal or prohibited activities and enforce our Terms of Use;
-
Respond to your
inquiries, resolve disputes and provide support;
-
We use collective
learnings about how people use our services to troubleshoot and to identify
trends, usage, patterns and areas of integration to better analyze, operate and
improve our business and the Service (including enhancing the user experience,
managing communications and functionality, and developing new products and
services);
-
Communicate with you
for Service-related purposes, such as sending payment reminders;
-
Compare information for
accuracy and verify it with third parties;
-
Further our business
relationship with you, if we have collected your personal information in the
context of an actual or potential business relationship;
-
De-identify or
aggregate data collected through the Service and use and disclose it for any
purpose; and
-
Fulfill other purposes
to which you have consented, which would be reasonably expected by you, or
which are otherwise authorized or required by law. Where required by law or
where we believe it is necessary to protect or legal rights; we will use
information about you in connection to legal claims, regulatory issues, audit
function, merger or funding.
The categories of third
parties with whom We share personal information.
We
may share Personal Information with the following categories of third parties:
-
Our affiliated
companies and our service providers and vendors who assist us with the delivery
of our Service;
-
To process your
payment, we may share some of your information with the Educational
Institution, for whom we serve as the payment agent;
-
In some cases, to
successfully process your payment or refund, we may share bank/payment receipt
documents that you have sent to us with financial institutions under contract
with whom we work, to assist with the processing and/or refund of that payment;
-
Additionally, your
information may be shared with other financial institutions, trade bodies,
anti-fraud organizations and law enforcement agencies for the purposes of
identifying and preventing fraud, money laundering, terrorist financing and
other financial crimes;
-
Other third parties to
protect our legal rights or comply with legal requirements;
-
Other third parties
involved in a merger, sale, joint venture or other transaction involving a
transfer of our business or assets;
-
Other third parties
with your prior consent.
In
the twelve (12) months prior to the Effective date of this Notice, we have
disclosed the following categories of Personal Information, which are described
in more detail above, for a business purpose:
-
Identifiers (Names,
email addresses);
-
bank account numbers, names, and routing codes;
- Internet
or other electronic network activity information;
-
Inferences drawn from
the network activity information;
Sales
of Personal Information
In
the twelve (12) months prior to the Effective Date of this Notice, We have not sold
any of your Personal Information. We will not
sell any of your Personal Information and in the future.
Your rights under the
CCPA
Under
the CCPA, as resident of the State of California, you will be entitled with the
following rights regarding your Personal Information:
-
Right of Access:
You have the right to request from us to disclose to you the categories and
specific pieces of Personal Information that we have collected about you over
the past 12 months. We will be able to provide you these once we receive and confirm your
verifiable consumer request.
We will let you know also about the sources of the data and the third parties
with whom we have shared it.
-
Right of Deletion:
You have the right to request from us to delete any of your Personal
Information, subject to certain exceptions. Once we receive and confirm your
verifiable consumer request , we will delete (and
direct our service providers to delete) your Personal Information from our
records, unless an exception under CCPA applies.
-
Non-Discrimination:
You have a right to not receive discriminatory treatment for exercising your
CCPA rights, and we will not discriminate against you for exercising any of
your CCPA rights.
Please
note that we may reply to your request at any time (in the terms regulated by
the CCPA), but We are not required to provide an answer to a consumer’s request
more than twice in a 12-month period.
We
do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision,
and we reserve the right to either refuse to act on your request or charge you
a reasonable fee to complete your request if it is excessive, repetitive, or
manifestly unfounded.
Contact Information and exercising
of your rights under this policy
To
exercise your rights described above in this Notice, please submit a consumer
request to us on the below listed contacts.
If
you have any questions or concerns related to this privacy policy, or if you
wish to request access to, or correction of, your personal information or make
a privacy complaint you may contact us at:
NorthStar
Currency
Attn:
Privacy Officer
Email:
studentpay@northstarcurrency.com
We
reserve the right to change this Notice at any time as the updated Notice will
be published on our website.