Paycentric Online Bill Pay System - Privacy Policy

Effective Date: June 18, 2019

At Elavon, Inc. (hereinafter “Elavon,” “we,” “us” or “our”), trust has always been the foundation of our relationship in all of our interactions. We understand your desire for privacy and recognize that you trust us with your personal information. We want you to understand what information we collect about and from you, and how we use such information, in connection with the Paycentric online bill pay system (the “Payment System”).

This Privacy Policy (the “Policy”) applies to all users who have elected to use the Payment System, including by initiating a payment, scheduling a payment(s), or completing a payment to a billerthrough the Payment System. This Policy describes Elavon’s use of information that is provided by you, or collected about you, at or through the Payment System where a copy of this Policy is posted.

This Policy only applies to Elavon’s collection and use of your information provided by youor the biller at or through the Payment System. This Policy does not apply:

• to information about you that is not provided by you, or collected about you, at or through the Payment System;
• to any other product or service that may be offered to you by Elavon or any of its affiliates; or to the collection and use of your information by a biller. The collection and use of your information by a biller is governed by the terms of the biller’s privacy policy available at the biller’s website. For example, in order to register a user to make a payment, a biller may collect user information and that collection is subject only to that biller’s privacy policy

1. Types of Information We Collect.

   We may collect the following types of information from the biller and users of the Payment System:

• "personal information" refers to information that identifies (whether directly or indirectly) a particular individual, such as information you provide when interacting with the Payment System. Examples may include your name, postal address, email address, telephone number, or date of birth.
• "anonymous information" means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual. Examples may include information about your internet browser, usage information about your use of the Payment System, and other information collected through tracking technologies (see the below section titled Online Tracking and Advertising for additional information regarding our use of tracking technologies).
2. How We Collect Your Information.

   We collect information about you when you provide this information directly to the Payment System and from the biller in connection with a transaction. For example, we may obtain information directly from you when you register with the Payment System, submit a payment on the Payment System, or other otherwise interact with the Payment System. Additionally, we may receive information about you directly from the biller, including in relation to scheduled or recurring payments.

3. How We Use Your Information.

   We use the information we collect to help us personalize and continually improve your experience on the Payment System. We may also use that information in the following ways:

   • to provide you with access to the Payment System;
   • to send you information, including the transaction receipt;
   • to send you historical payment or billing information;
   • to process the payment and complete the transaction, which may include sharing your information with the biller;
   • to respond to requests or inquiries from you
   • to communicate with you about changes to our policies;
   • consistent with local law, to verify your identity and/or location for security, fraud prevention and other risk control purposes;
   • to detect, investigate and prevent activities that may violate our policies or be illegal
   • to comply with our legal and regulatory obligations; and
   • to perform statistical, demographic, and marketing analyses of users of the Payment System.


4. How We Share Your Information.

   We will not share your information collected through the Payment System with any party, for any purpose, except as otherwise provided in this Policy. We may share your information with third parties as follows:

   • with the biller in connection with the processing of the payment;
   • in response to subpoenas, or during the course of an audit or investigation, issued or initiated by courts, independent auditors, law enforcement agencies, or other governmental authorities, bodies or agencies;
   • to prevent fraud; and
   • as otherwise required by law.
   
   

   We may share your information with service providers of Elavon, who may be agents, subsidiaries, affiliates, partners or other third parties that perform functions on our behalf. These entities have access to the information needed to perform their functions and are obligated to maintain the confidentiality and security of that information

   Elavon may share or disclose information about you that is aggregated, anonymous or that otherwise does not personally identify you to unaffiliated third-parties.

5. Online Tracking and Advertising.

   We and certain trusted service providers operating on our behalf collect information about your activity on the Payment System using tracking technologies, including:

   • Cookies:

     Cookies are pieces of information that are stored directly on the device that you are using to access the Payment System. Cookies allow us to collect information such as the type of browser you are using, the amount of time you spend using the Payment System, the websites or applications you visit and the preferences you have set up for your accounts. We use this information to personalize your experience, enhance security, facilitate navigation, display material more efficiently and recognize the device that you are using to access the Payment System. The Payment System does not use cookies that capture unencrypted personal information about you.

     You can choose to have your device refuse to accept any cookies, and the majority of devices and browsers offer additional privacy settings for cookies. You do this through your browser settings. Each device and each browser is a little different, so look at your device settings or your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you will not have access to many features that make your user experience more efficient and some of the Payment System will not function properly. Please note that you will need to manage your cookie settings for each device and browser that you use.

   • Pixel tags, web beacons, clear GIF’s and other similar technologies. These are typically small pieces of data that may be embedded in images on the Payment System, our site or certain e-mail communications. They may involve the transmission of information directly to us, to another party on our behalf or to another party in accordance with its privacy policy. We mayuse these technologies to bring together information we collect about you.
   
   
   • Location trackng on mobile devices. Certain applications on mobile devices may transmit information to us about your location when you request information from them. We may use that information to improve the products and services we provide to you as well as to improveour services generally in your area. You may disable location tracking on these mobile applications.
   
   

   Information collected through tracking technologies is used for many purposes including, for example, to:

   • provide useful features to simplify your experience when you return to the Payment System;
   • monitor and evaluate the use and operation of the Payment System; and
   • analyze traffic on the Payment System and on websites or mobile applications of third parties


6. Data Security.

   Your privacy is very important to Elavon and we are committed to protecting your personal information from unauthorized access or use. We have implemented physical, technical and administrative security measures that comply with federal law and industry standards, including network firewalls, Secure Sockets Layer (SSL) encryption for online sessions, dedicated security teams and secured files and buildings. The Internet, however, is inherently unsecure, and Elavon does not guarantee the security and confidentiality of information you provide through the Payment System.

7. Preventing Identity Theft.

   Note that Elavon will never initiate a request via email or otherwise for your personal information (e.g., name, address, telephone number). If you receive an email asking for your personal information, you should be suspicious of the request and contact our customer service department at 1-800-377-3962 or custsvc@elavon.com to report the suspicious activity.

8. Children’s Privacy.

   We do not use the Payment System to knowingly solicit data from or market to children under the age of thirteen (13) without parental consent. We request that such individuals do not provide personal information through the Payment System. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us as set forth in Section 10 below, and we will delete such information from our files. For additional information regarding the Children's Online Privacy Protection Act (COPPA), please visit the Federal Trade Commission website.

9. Changes to the Policy.

   From time to time, we may make changes to this Policy in order to accommodate new technologies, industry practices, and regulatory requirements or for other purposes. We encourage you to review this Policy periodically to ensure that you understand how we collect, use and share information through the Payment System. If we do make changes to this Policy, we will also update the "Effective Date" posted at the top of the Policy.

   Any changes to the Policy will become effective when the revised Policy is posted on the Payment System. By continuing to use the Payment System following such changes, you are agreeing to accept the terms of the revised Policy.

10. Contact Us.

    If you have any questions or comments about this Policy, or our privacy practices generally, we encourage you to contact our customer service department at 1- 800-377-3962 or custsvc@elavon.com.

11. Notice to Non-US Users.

    If you are located outside the United States of America, you should be aware that your personal information will be transferred to the United States of America, the laws of which may be deemed by your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit your information to us, you thereby consent to the general use of such information as provided in this Policy and to the transfer of that information to, and/or storage of that information in, the United States of America and you understand that your information may be available to government authorities under lawful orders and laws applicable there.