Effective July 1, 2020

We appreciate your preference for making informed choices when it comes to the collection and use of information about you. This notice (our “Privacy Policy”) tells you about our collection of information about you through this website. Our Privacy Policy also tells you about the use and disclosure of that information.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).

What general types of data do we handle?

To help describe the types of personal data we possibly could collect, we have grouped those types together in the list below. The listing here does not mean that we have or will collect this type of information about you.

• Identity Data includes name, aliases, user name, driver's license number, social security number, passport number, and similar identifiers.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Technical Data includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website.
• Characteristic Data includes birthdate and sex.
• Transactional Data includes details about payments to us and other details about purchases of our products and services.
• Credit Data includes information about amounts owing and payments to creditors generally.
• Biometric Data includes facial imagery, fingerprints, and physical descriptions (such as eye color and height).
• Profile Data includes interests, preferences, feedback and survey responses.
• Usage Data includes information about the use of our website, products, and services.
• Communications Data includes preferences in receiving marketing from us and our third parties and preferences in receiving other communications from us and our third parties.
• Organization Data includes title and the organization represented.
• Professional Data includes employment history, professional licenses, occupational certifications, and professional references.
• Public-record Data includes information about civil litigation history, garnishments, liens, encumbrances,  and listing on government exclusion lists.
• Predictive Data includes inferences drawn from the other categories of data.

We do not collect any of the following:

• Information covered by California Civil Code section 1798.80 except to the extent identified in some category above;
• Geolocation data, except to the extent that it is Technical Data or Profile Data;
• Audio, thermal, olfactory, or similar information;
• Electronic information except to the extent identified in some category above; or
• Visual information except to the extent that it is Biometric Data.

From whom do we collect information?

We collect information from four main sources.

When any of the four sources interact with our website, email servers, fax machines, or telephone systems, we automatically collect Technical and Usage Data. On our website, we collect data about equipment, browsing actions, and patterns by using cookies, server logs and other similar technologies. In our email servers, we collect data about who transmitted the email to us and how. In our fax machines and telephone systems, we collect data including the telephone number transmitting to us.

We collect some data from Visitors, meaning people who:

• use our public website without logging in to an account for a Customer or an Account, beginning the process to register as a Customer or an Account, or explicitly identifying as a Customer or an Account; or
• send us email, call one of our telephone numbers, send us mail, or send us a fax, with content that does not cause us to associate the information with a Customer, Account, or Furnisher.

Examples of Visitors' activities from which we collect data include subscribing to our publications; requesting marketing materials to be sent to you; entering a competition, promotion, or survey; or giving us feedback.

We collect some data from Customers, meaning people who:

• log in to our website as a Customer;
• begin the process of registering as a Customer on our website; or
• send us email, call one of our telephone numbers, send us mail, or send us a fax, with content that causes us to associate the information with a Customer.

Examples of Customers' activities from which we collect data include registering to receive services, providing payment information for billing, and identifying users who can order services.

We collect some data from Accounts, meaning people about whom we are performing services. Examples of Accounts' activities from which we collect data include completing forms about themselves, acknowledging disclosures and notices, requesting disclosure of information in our files, and requesting a reinvestigation of that information.

We collect some information from Furnishers, meaning people who:

• have information about our Customers (or their representatives);
• have information about the Accounts;
• perform processing for our Customers; or
• act as an intermediary to one of the above.

Examples of Furnishers' activities from which we collect data include providing marketing leads; providing information establishing the legitimacy of prospective Customers; processing of payments from Customers; verifying the information of Accounts; providing summaries of public records about Accounts; and providing credit reports about Accounts. Most of our services involve us obtaining information from Furnishers, so there are Furnisher activities that are specific to each of our services.

How do we collect data about you through your visiting this website?

When you visit this website, the website automatically collects Technical Data in server logs and Technical Data and Usage Data through cookies, web beacons and other technologies.

When you visit this website, the website places one or more text files (each called a “cookie”) in the browser directory of your computer's hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve. The typical information that cookies store includes the date and time of your visit, your registration information, and your navigational and purchase activity. Our website uses the cookies to identify your computer consistently as you navigate through the website and to control what it displays to you. Most browsers allow you to decline cookies. But if you decline cookies, the website may not operate properly. Our website does not currently recognize “do not track” signals transmitted by web browsers. You are free to delete cookies after your session. Your browser should contain instructions on how to do this.

We use Google Ads. As you navigate to this website from Google Ads, the website may place advertising cookies on your computer. These advertising cookies identify your computer as one that has visited the website. When you visit another site that has an agreement with our advertising network, the other site will use the cookie to display our advertisements to you on the other site. This does not involve collecting personal data about you such as your name, email address, postal address or telephone number. Google makes available a number of ways to control this at https://support.google.com/ads/answer/2662922?hl=en. Additionally, the National Advertising Initiative makes available a tool to opt out of multiple advertising networks at http://optout.networkadvertising.org/.

We use Google Analytics to help us analyze the use of our own website. You can find more information about what data gets collected and used at this website: https://policies.google.com/technologies/partner-sites.

How do we collect data about you through email?

When you interact with us through email,  we may collect Technical and Usage Data through pixel tags and other technologies.

Do we collect information from children?

We do not intend to collect personal data from anyone under the age of 18. If you are under 18, you should not enter information on this website and should ask a parent to do so for you.

On whom do we collect information?

We generally collect information on two types of individuals:

First, we collect information on Users, meaning individuals who interact with us. In the table below, the User column indicates whether we collect information about the User as the user with whom we are interacting, rather than as the Account.

Second, we collect information on Account Holders, meaning individuals who are associated with the Accounts. In the table below, the Holder column indicates whether we collect information about the Holder associated with the Account, rather than as the User with whom we are interacting.

When the source of data is the Account, the User and the Holder are the same person:

In that case, we indicate in the User column the types of data that we collect primarily for the purpose of interacting with the User and we indicate in the Holder column the types of data that we collect mainly for the purpose of using or providing it in the performance of services for our customer.

Data Type	User	Holder
Identity Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	Yes, if supplied by Account, Customer, or Furnisher
Contact Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	Yes, if supplied by Account, Customer, or Furnisher
Financial Data	Yes, if supplied by Customer or Furnisher	Yes, if supplied by Account, Customer, or Furnisher
Technical Data	Yes, automatic if electronic interaction	Yes, automatic
Characteristic Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	Yes, if supplied by Customer, Account, or Furnisher
Transactional Data	Yes, automatic	Yes, automatic
Credit Data	No	Yes, if supplied by Customer, Account, or Furnisher
Biometric Data	No	Yes, if supplied by Customer, Account, or Furnisher
Profile Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	No
Usage Data	Yes, automatic	Yes, automatic
Communications Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	Yes, if supplied by Customer or Account
Organization Data	Yes, if supplied by Visitor, Customer, Account, or Furnisher	Yes, if supplied by Customer, Account, or Furnisher
Professional Data	No	Yes, if supplied by Customer, Account, or Furnisher
Education Data	No	Yes, if supplied by Customer, Account, or Furnisher
Public-record Data	No	Yes, if supplied by Customer, Account, or Furnisher
Predictive Data	No	Yes, if supplied by Customer or Furnisher or generated internally

What happens if you do not provide your personal data?

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will inform you if this is the case at the time.

Where we need to collect personal data about you in order to provide a service to our customer and you fail to provide that data when requested, we may not be able to provide that service to our customer. If we are unable to provide that service, then our customer might not grant you whatever benefit you were seeking that caused the customer to obtain services from us.

Once we collect personal data, how do we use it?

We use personal data about you when we have one of the following lawful bases:

• Legitimate Interest, which means the interest of our business in conducting and managing our business to enable us to serve you, the organization you represent, or our Customer. We consider and balance any potential impact on you (both positive and negative) and your rights before we process personal data about you for our legitimate interests. We do not use personal data about you for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or authorized to by law).
• Contract Requirement, which means a requirement to process personal data about you for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legal Requirement, which means a requirement to process personal data about you for compliance with a legal or regulatory obligation that we are or might be subject to.
• Legal Authority, which means a law that gives us authority to process personal data about you.
• Consent, which means your express, written consent to process personal data about you.

Note that we may process personal data for more than one lawful basis depending on the specific purpose for which we are using personal data about you.

We have set out below, in a table format, a description of the ways we plan to use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of data	Basis for use
To register you as a new customer	Identity Contact Technical Organization	Contract Requirement Consent
To register you as a representative of a customer	Identity Contact Organization	Contract Requirement Legitimate Interest (to treat you as a representative of our customer) Consent Consent
To deliver our software services to you as a representative of our customer	Identity Contact Technical Transactional Communications Organization	Contract Requirement Legitimate Interest (to deliver services to our customer, for whom you are a representative) Consent
To process customer payments in our software services, including: Manage payments, fees and charges Collect and recover amounts	Identity Contact Financial Technical Transactional Communications Organization	Contract Requirement Legitimate Interest (to recover debts due to us) Consent
To manage our relationship with you, including: Notifying you about changes to our terms or Privacy Policy Asking you to leave a review or take a survey	Identity Contact Characteristic Profile Usage Communications Organization	Contract Requirement Legal Requirement Legitimate Interest (to keep our records updated and to study how customers use our services) Consent
To enable you to take part in a drawing, competition, or survey	Identity Contact Characteristic Profile Usage Communications Organization	Contract Requirement Legitimate Interest (to study how customers use our services, develop them, and grow our business) Consent
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Transactional Profile Usage Communications Organization	Legitimate Interest (to run our business, obtain administration services, manage information technology, assure security, prevent fraud, and conduct business reorganizations or group restructurings) Legal Requirement Consent
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Technical Characteristic Profile Usage Communications Organization	Legitimate Interest (to study how customers use our services, develop them, grow our business, and inform our strategy) Consent
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Technical Profile Usage Communications	Legitimate Interest (to define types of customers for our services, keep our website updated and relevant, develop our business, and inform our strategy) Consent
To make suggestions and recommendations to you about services that may be of interest to you	Identity Contact Technical Characteristic Transactional Profile Usage Communications	Legitimate Interest (to develop our services and grow our business) Consent
To provide you disclosures or notices about services or to obtain your authorization or consent to services	Identity Contact Technical Characteristic Transactional Usage Communications	Legitimate Interest (to provide information or to obtain permission on our customers' behalf) Legal Requirement Consent
To provide software services that are about you to a user of those services	Identity Contact Characteristic Credit Biometric Professional Education Public-record Predictive	Legitimate Interest (to perform services that are legally permitted for our customers) Legal Authority Consent
To provide software services that are about you to another provider of those services, for its use in providing those services to its users	Identity Contact Characteristic Biometric Professional Education Public-record	Legitimate Interest (to perform services that are legally permitted for our customers) Legal Authority Consent
To permit reinvestigation or verification of information on your request	Identity Contact Characteristic Biometric Communications Professional Education Public-record Predictive	Legitimate Interest (to assure that records are correct, correct or delete information, and prevent recurrence of future incorrect information) Legal Authority Consent

What happens if there is a change in the purpose?

Certain laws require us to do something if the purpose of our use changes. (For example, it might require us to get your consent or give you notice.) This section applies only to the extent that those laws apply to you and the data.

If we want to use personal data about you for a purpose other than the purpose for which we collected it, we will consider whether that purpose is compatible with the original purpose. If the purpose is compatible, we will use the personal data for that additional purpose. If you want to get an explanation about how the additional purpose is compatible with the original purpose, please contact us by email (at the email address shown in contact details below). If the additional purpose is not compatible but we have a legal basis for using the personal data anyway, we will inform you and we will explain the legal basis which allows us to use the personal data for the additional purpose.

Please note that our software service may be used to process personal data about you without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How do we control using personal data for marketing purposes?

We provide you with choices regarding certain uses of personal data about you, particularly around marketing and advertising. We have established the following personal data control mechanisms:

We may use your Identity, Contact, Characteristic, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share personal data about you with any outside organization for their marketing purposes (this does not apply to service providers who are assisting us with our own marketing, whom we use to send emails on our behalf and manage your opt-out preferences in response to them.)

You can ask us or our service providers to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you continue to receive marketing messages from us more than a few days after opting out, please contact us at support@payready.com. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services you purchase from us or that our customers purchase from us about you.

Do we disclose personal data to third parties?

We may share personal data about you with the parties set out below for the purposes set out in the table above about how we plan to use personal data about you.

• Internal processors, meaning other companies under our common control.  We and they may disclose information to our and their employees, directors, and individuals acting as contractors. We assure that these companies, our personnel, and their personnel use the information in accordance with this Privacy Policy.
• External processors, meaning the categories set out below. We employ procedures to require our external processors to respect the security of personal data about you and to treat it in accordance with the law. We do not grant permission for our external processors to use personal data about you for their own purposes and only grant permission for them to process personal data about you for specified purposes and in accordance with our instructions.

• Providers of information technology and system administration services to us.
• Professional advisers (including lawyers, bankers, auditors, brokers, insurers, and marketing agencies) who provide consultancy, banking, legal, insurance, accounting, and marketing services to us.
• Organizations and individuals who obtain information on our behalf from data sources described below.
• Other organizations that provide services to us or our Customers.

Payment processors. The privacy policies and practices of these payment processors may be different from ours. We do not control them and assume no responsibility for them. We understand that their conduct for the information we provide them is governed by law, such as the Gramm-Leach-Bliley Act, or by card association rules, such as the rules of the Visa and MasterCard networks and the Payment Card Industry Security Standards Council.

Marketing affiliates and program sponsors. If you register using a promotional code for one of our marketing affiliates or program sponsors, we may disclose information about you and your purchases (such as the name of your company and the value of your purchases each month) to the marketing affiliate or program sponsor. The privacy policies and practices of these marketing affiliates or program sponsors may be different from ours. We do not control them and assume no responsibility for them.

Data Sources, meaning organizations and individuals who provide us data that we use in our services. The privacy policies and practices of these information sources may be different from ours. We do not control them and assume no responsibility for them. We understand that, in most cases, their conduct for the information we provide them is governed by law, such as the Fair Debt Collection Practices Act, Fair Credit Reporting Act and other consumer protection laws.

Regulators, taxing authorities, law enforcement, and courts who require reporting of data in certain circumstances. We may disclose your information in the good faith belief that disclosing it is reasonably necessary to comply with law or legal process, respond to claims, or protect the rights, property or safety of our company, employees, or customers or of the public.

Organizations to whom we may choose to sell or transfer all or part of our business or assets, or with whom we may merge, consolidate, or amalgamate. If a change happens to our business, then the new owners may use personal data about you in the same way as set out in this Privacy Policy.

Customers, meaning organizations who purchase our services.

What additional information is relevant for California?

The following is information organized in a way that the California Consumer Privacy Act (the “CCPA”) requires us to supply. It only applies to you if you live in California, though out of an abundance of caution we are applying it to the entire United States. This table has the following information in it:

• The first column identifies the type of data, using the definitions above.
• The second column says whether, in the 12 months before we posted this Privacy Policy, we sold any personal data of that type.
• The third column says whether, in the 12 months before we posted this Privacy Policy, we disclosed any personal data of that type for a business purpose. If so, we disclosed it as described in the section above.
• The fourth column identifies whether, in the 12 months before we posted this Privacy Policy, we provided any personal data of that type in a consumer-reporting activity. California Civil Code section 1798.145(d) excludes consumer-reporting activity from the CCPA, so we have not included it in the second or third columns. (In some circumstances, section 1798.145(e), (f), or (h) may also apply as an exclusion.) We include it in the fourth column to prevent confusion about what the table means. Additionally, section 1798.140(o)(2) excludes Public-record data from the definition of “personal information.” Again, we include that row to prevent confusion about what the table means.

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Type of Data	Sold?	Disclosed?	Consumer Reporting?
Identity	No	Yes	Yes
Contact	No	Yes	No
Financial	No	Yes	Yes
Technical	No	Yes	No
Characteristic	No	Yes	Yes
Transactional	No	Yes	No
Credit	No	Yes	Yes
Biometric	No	Yes	Yes
Profile	No	Yes	No
Usage	No	Yes	No
Communications	No	Yes	No
Organization	No	Yes	No
Professional	No	Yes	Yes
Public-record	No	Yes	Yes
Predictive	No	Yes	Yes

Additionally, California law defines the term “sell” to include any disclosure of “personal information” in exchange for anything of value. Depending on how this law is interpreted, it could include a situation in which we provide your information to another organization so that it can do something with the information for us. Because we receive the benefit of that processing, which is of value to us, any such relationship might be the sale of personal data. Therefore, we hereby notify you that we may sell personal data about you to the extent that the term “sell” is interpreted in that manner.

Do we oversee the privacy of sites to which we link?

This website may provide links to third-party websites. Those third-party websites are outside of our control and are not covered by this Privacy Policy. The privacy policies and practices of these sites may be different from ours. We do not control them and assume no responsibility for them. If you have questions about how another website uses your information, consult that website's privacy statement.

Where might your information be stored, used, or disclosed?

We (and anyone to whom we disclose information) may store, access, disclose, and use information in jurisdictions whose privacy laws are different and less protective than those of your home jurisdiction.

What security measures do we use?

We are committed to protecting the personal data that we receive. While we cannot guarantee the security of that data, we utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.

We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our website. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our employees' computers, and employees are regularly trained on our security and privacy policies. The servers used to store consumer information are maintained in a secure physical environment with appropriate physical security measures.

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What are your rights?

If you would like to obtain disclosure of or dispute information that we have included, have provided for inclusion, might later include, or might later provide for inclusion in a consumer report, please contact us as set out in the contact details below.

Under certain circumstances, you have rights under data protection laws in relation to personal data about you. Please see below for specific rights that may apply to your location. If you wish to exercise any of those rights, please contact us as set out in the contact details below.

Please note that we may need to retain certain information for recordkeeping and risk management purposes, including but not limited to compliance with laws relating to anti-money laundering and counter-terrorist financing, and/or to complete any transactions.

What rights do you have in California?

California Consumer Privacy Act Notice

The California Consumer Privacy Act provides you certain rights if you are a California resident. But the CCPA also has exceptions. Generally, our business falls within those exceptions, and the CCPA does not apply. But if you want disclosure or correction of information that we hold about you within these parts of our business, you can still request a disclosure or reinvestigation from us. Information about how to do so is available by contacting us as set out in the contact details below.

You have the following rights if you are a California resident:

• You have the right to request us to disclose information that we have collected about you, including the general categories of information, the categories of sources from which we collected the information, the purpose for collecting or selling that information, the categories of third parties with whom we share the information, and the specific pieces of information we have collected.
• If we sell personal information or disclose it for a business purpose, you also have the right to request the categories of third parties to whom we sold your information or disclosed your information for a business purpose (by category of personal information in each case).
• You have the right to request to opt-out of our sale of personal data about you.
• You have the right to be free of retaliation for exercising your rights under the CCPA.

You may make a request under the CCPA by emailing us at support@payready.com or calling us toll free at 855-857-8164. You must include the following information: your full name; all physical addresses we may have associated with you; all email addresses we may have associated with you; all telephone numbers we may have associated with you; all housing providers we may have associated with you. If you are requesting that we disclose, correct, or delete specific personal data information to you (as opposed to disclosing categories of personal data), you must also provide a legible image of a government-issued ID. You may hide the identification number and photo from that ID, but you must not hide the name or address shown on it. We will use the information you supply to identify relevant information in our systems. If you want us to disclose the information to an agent, you must say so in writing and provide us with the mailing address of the agent.

Do Not Sell My Personal Information

To opt out of our sale of information to the extent required under the California Consumer Privacy Act (the “CCPA”), please send an email tosupport@payready.com:

• your full name
• all physical addresses we may have associated with you
• all email addresses we may have associated with you
• all telephone numbers we may have associated with you
• all employers we may have associated with you
• a legible image of a government-issued ID showing your address in California (You may hide the identification number and photo from that ID, but you must not hide the name or address shown on it.)

Personal Information Disclosure: United States or Overseas

This is a disclosure under California law, applicable only to the extent that law applies.

Our services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using or accepting our services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Additionally, we may use contractors located outside the United States to perform functions that our own employees also perform, such as public records research; employment, education, and license verification; and customer service.

How do we change this Privacy Policy?

We may change our Privacy Policy at any time, but will not do so without posting the revised policy on this website. We encourage you to review this Privacy Policy whenever you visit our website to make sure you understand how we use the information we collect.

How can you get more information?

For more information about our privacy practices or policies, please contact our Support Team by:

Email at support@payready.com; or

Pay Ready, Inc.
ATTN: Privacy
5811 McFadden Ave
Huntington Beach Ca 92649