for residents of the state of California
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;
- 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.
Attn: Privacy Officer
We reserve the right to change this Notice at any time as the updated Notice will be published on our website.