Electronic Payments Privacy Policy

Your privacy is important to us at Electronic Payments, Inc. (“Electronic Payments,” “Company,” “we,” “us,” or “our“), and we are committed to transparently informing you how we use your personal information.

This privacy policy (the “Privacy Policy“) describes the types of information we may collect from you or that you may provide when you visit the website currently located at https://electronicpayments.com/ (the “Website“) and as otherwise provided for herein with respect to the Company’s social media pages on various third party social media platforms or through other Company channels (each, an “Other Channel,” together with the Website, collectively, the “Site“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this policy carefully to understand our practices regarding your information and how we will treat it. This policy may change from time to time (see the latest version of this Privacy Policy) https://electronicpayments.com/privacy-policy/. Please check the live Privacy Policy link periodically for updates.

This policy applies to information we collect:

  • on the Site;
  • in email and other electronic messages between you and the Site;
  • when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to the Site; and
  • by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal information through your use of the Site, including any data you may provide through the Site when you access or use any of our products/services made available to you.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

Controller

Electronic Payments is the controller and responsible for your personal information. Where it is necessary or appropriate for the purposes for which we hold your information, we may share your relevant information across our affiliated companies. All our affiliated companies covered by this notice manage your personal information in the manner and to the standards set out in this Privacy Policy.

We have a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact Electronic Payments in writing at privacy@electronicpayments.com, or 7800 Congress Ave, Suite 108, Boca Raton, FL 33487.

Collection of Information

Personal information means any information about an individual from which that person can be identified. It does not include information where the ability to identify someone has been permanently removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal information about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your 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 you use to access the Site.
  • Profile Data includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our Site, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information by law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data). Nor do we collect from you any information about criminal convictions and offenses.

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by postal mail, phone, email or Other Channels. This includes personal information you may provide when you:
    • subscribe to our publications;
    • request marketing to be sent to you;
    • create an account on our Site;
    • inquire about our products or services; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. See our section on Cookies.
  • Third parties or publicly available sources. We may receive personal information about you from various third parties as set out below:
    • Contact Data from providers of technical services; or
    • Technical Data about you from analytics providers or search information providers. For example:
      Google Analytics. We may use Google Analytics or a similar service, as a web analysis service in order to better understand your use of our Site and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages they visit, and what other websites they used prior to coming to such website. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Notice. Google utilizes the data collected to track and examine the use of the Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Site to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Site please review “How Google uses information from sites or apps that use our services” (located here https://policies.google.com/technologies/partner-sites?hl=en-US or any successor URL).

It is the intent of the Company to use personal information only for the purpose for which it was requested and any additional uses specifically provided on the Site and in accordance with the terms of our Privacy Policy and Terms of Use.

It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent as a means to better understand the way in which other websites garner, make use of, and share information collected.

Use of Information Collected

We will only use your personal information when the law allows us to. In certain jurisdictions, including the European Economic Area (“EEA”) and the United Kingdom (“UK”) we are required by law to always have a permitted reason or justification (called a “lawful basis”) for processing your personal data. There are six permitted lawful bases for processing standard personal information.

Most commonly, we will rely on the following lawful bases :

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party including our affiliates) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Where you have provided us with your consent.

Note that we may process your personal information pursuant to more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal information where more than one basis has been set out in the table below. Where we rely on your consent as a legal basis for processing your personal information, you have the right to withdraw consent to marketing at any time by contacting us.

The table below explains the different purposes for which we process your personal information, and the relevant lawful basis or bases we rely on for that processing.

PURPOSE/ACTIVITY TYPE OF Personal information LAWFUL BASIS FOR PROCESSING (INCLUDING details of LEGITIMATE INTERESTs)
To register you as a new contact, customer, or partner of the Company (a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep our records updated and to grow our business)
To process and deliver our services to you including manage relationships with our service providers. (a) Identity
(b) Contact
(c) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (communicate with you about your use of the services and respond to inquiries).
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy(ies)
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate business interests (to keep our records updated and to study how customers use our products)
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical
(f) Profile
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our company group business and to inform our marketing strategy)
Consent (e.g. in the UK/EEA where consent is required for any cookies relied upon for this processing)
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences – this may include tracking your use of other websites visited in the same session as the Site, in order to glean what types of services and/or products may be the most popular. (a) Technical
(b) Usage
(c) Marketing and Communications
Necessary for our legitimate interests (to define types of customers for our products, to keep our Site updated and relevant, to develop our company group business and to inform our marketing strategy)
Consent (e.g. in the UK/EEA where consent is required for any cookies relied upon for this processing)
To make suggestions and recommendations to you about products or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our company group business) and where you have not opted-out of receiving such communications.
Consent (e.g. in the UK/EEA) where we are responding to your request for information about our company, its products and services using the contact information provided on our website.

Third Party Marketing

The Company does not now, nor will it in the future, sell, rent or lease any of our customer lists and/or names to any third parties for the purposes of third-party marketing.

Disclosures of Your Personal Information

We may share specific data with our company group and trusted partners, or our payment processing vendors, in order to provide our services to you, to conduct statistical analysis, provide you with email, text messages and/or postal mail, deliver support, fill orders and/or arrange for deliveries to be made, or otherwise for the purposes set out in the table above. Any third parties acting as our service providers shall be required to maintain the strictest of confidentiality with regards to all your information. We may share your personal information with Internal Third Parties [HYPERLINK] (as set out in the Glossary) or External Third Parties [HYPERLINK] (as set out in the Glossary).

We may disclose your personal information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required in an effort to:

  • Remain in conformance with any decrees, laws, and/or statutes or in an effort to comply with any process which may be served upon us and/or our Site;
  • Maintain, safeguard and/or preserve all the rights and/or property of the Company; and
  • Safeguard the personal safety of users of the Site and/or the general public.

We may also disclose your personal information to third parties to evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users/consumers is among the assets transferred. If any such change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with applicable law.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

If You Fail to Provide Personal Information

Where we need to collect personal information 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 products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Cookies and Similar Technologies

Please note that certain information about your computer hardware and software and browsing actions and patterns may be collected by the Company through automatic data collection technologies as you navigate through and interact with our Site. This information is used by us for operation of our Site and our business, to maintain quality of the Site and our business, and to provide general statistics regarding use of the Site. The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Please review the “Use of Cookies” subsection below for more information on cookies and how you can manage your cookies settings.

Use of Cookies

The Site uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. They are widely used in order to make websites work, or work more efficiently, as well as to provide information us. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you visit certain Site pages, a cookie helps us to recall your specific information on subsequent visits. When you return to the Site, the information you previously provided can be retrieved. Cookies help us give you a better browsing experience and improve the quality of our products, personalizing content, ads and providing a more secure experience.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please see the “Choices About How We Use and Disclose Your Information” [HYPERLINK] subsection below for more information about managing your computer’s settings for cookies.

The cookies we use may change over time as we improve and update our products. We typically use the following cookies:

  • Necessary cookies: These cookies are essential for the operation of our Site. For example, they enable us to recognise you when you sign-in to use our services, return to our website, login more easily and keep track of your specified preferences (such as location, language preference and currency). They also let us save your cookie preferences and keep our site secure.
  • Functional cookies (optional): These cookies help to perform certain functionalities like sharing the content of the Site on social media platforms, collect feedback, and other third-party features.
  • Analytics or Performance cookies (optional): We use these cookies to understand how customers interact with our site so we can make improvements. For example, we use cookies to collect information including the number of visitors to the website, where visitors have come to the website from, and the pages they visited. This helps us improve the content, features and tools on our website and measure and analyse the performance of our services, ensuring that users are finding what they are looking for easily.
  • Advertisement cookies (optional): We also use cookies to make our website and the advertising displayed on it more relevant to your interests. You can find information on how to opt-out of advertising cookies here.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Site are served by approved third parties, including servers, search engines, content providers, and application providers. These third parties may use cookies alone or in conjunction with web-beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Choices About How We Use and Disclose Your Information” [HYPERLINK] subsection below.

We do not control third parties’ collection or use of your information to serve interest-based advertising (the collection of data across web domains owned or operated by different entities, or the use of such data, for the purpose of tailoring advertising based on preferences or interest known or inferred from the data collected). However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Cookies Schedule

Below we have listed the cookies or similar technologies deployed on our Site and the purposes for which these are used:

Cookies Duration/Period Tool/Provider Cookie Purposes
[to insert] [to insert] [to insert]

Choices About How We Use and Disclose Your Information

You can manage your cookie preferences through our cookie banner when you first visit our Site. You can adjust the available sliders to ‘Enabled’ or ‘Disabled’, then clicking ‘Save & Accept’. You may need to refresh your page for your settings to take effect.

If you wish to change your cookie preferences after your initial visit, you can contact us at privacy@electronicpayments.com to opt out of behavioral advertising, or interest-based advertising.

Alternatively, the settings on your browser (or your device) may allow you to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire.

You can find out how to manage cookies on popular browsers:

Tracking Technologies and Advertising – Flash cookies settings. To learn how you can manage your Flash cookies settings, visit the Flash player settings page on Adobe’s website.

Note that cookies on our website allow you to take advantage of some of our essential features. We also utilise non-essential cookies in order to improve your experience on our site. If you block or otherwise reject our cookies, some features on our site may not work.

For more information about the cookies we use, please see our section on “Use of Cookies” and our “Cookies Schedule”.

You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising at the following websites:

NAI Website (US): https://optout.networkadvertising.org/?c=1

DAA Website (US): https://optout.aboutads.info/?c=2&lang=EN

Notice to Residents of the United States

Accessing and Correcting Your Information

You may send us an email at privacy@electronicpayments.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional personal information rights and choices.

Please see Your Additional State Privacy Rights [HYPERLINK] for more information.

Your Additional State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and obtain a copy of personal information you provided to us in a portable format and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information’s nature and processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal information processing for targeted advertising (excluding Iowa), sales; or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process sensitive personal information.

The exact scope of these rights may vary by state. To exercise any of these rights please email us at privacy@electronicpayments.com. To appeal a decision regarding a consumer rights request please send an email to privacy@electronicpayments.com stating the reasons with reasonable detail for such appeal.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: privacy@electronicpayments.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Notice to European Union Residents; European Economic Area, and residents of the United Kingdom

Controller

Electronic Payments Inc. is the controller of the personal data handling practices in connection with the Site described above. Where we process personal data on behalf of merchants to provide our Services, the relevant merchant you engaged with will be the controller of your personal data and we will act as their processor.

Data Subject Rights under EEA and UK data protection Laws

Where the General Data Protection Regulation (“GDPR”) and UK GDPR applies to our processing of your personal data, and we are the controller of that processing activity, data subjects have the rights described below, under certain circumstances and grounds.

  • Right to obtain confirmation as to whether your personal data is being processed, access to your personal data, and information regarding the processing;
  • Right to rectify inaccurate or incomplete personal data concerning you;
  • Right to erasure of your personal data;
  • Right to restrict processing of your personal data;
  • Right to object to the processing of your personal data;
  • Right to object to decision making based solely on automated processing;
  • Right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller (i.e., “data portability”);
  • Right to unsubscribe from marketing materials; and/or
  • Right to withdraw consent to any consent-based processing activities (however, this will not affect the lawfulness of any processing carried out before you withdraw your consent).

To file a request or take action on one of your rights, please contact us as indicated in the “Contact Us” section below. Please note that the above rights are not absolute, and are subject to various exemptions set out in law, or third party rights, which may override.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We do not use automated decision making technologies, including profiling, to support our data processing activities. In some instances, you may be required to provide us with personal data for processing as described above, or in order for you to use all of the features on our website.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

This Privacy Policy does not create, extend or modify any of the foregoing rights under the GDPR or UK GDPR.

If you believe that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the relevant supervisory authority.

If you are based in the UK, the relevant authority is the Information Commissioner’s Office (soon to become known as the Information Commission). You can contact them by calling 0303 123 1113, or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites).

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

International Data Transfers

Electronic Payments Inc. has its headquarters in the United States. Information we collect from you will be processed in the United States. In the course of providing our services, we may also need to transfer your personal information to other locations outside the jurisdiction in which you provide it or where you are viewing or using our Site. If you are based in the UK or EEA, this will mean that your personal information may be transferred to, accessible from, and/or stored at, a destination outside the UK/EEA in which data protection laws may not be as comprehensive as in the UK/EEA.

We will apply data protection safeguards and implement appropriate measures in respect to the transfers of your personal information that we make to ensure that your personal information is protected in accordance with applicable data protection laws.

Similarly, where a third-party service provider processes the personal information of UK or EEA residents on our behalf, we will ensure that appropriate measures are in place to ensure an adequate level of protection for your personal information.

If any of our processing activities require your personal information to be transferred by us to third parties outside the UK/EEA, we will only make that transfer if:

  • the country to which the personal information is to be transferred ensures an adequate or approved level of protection for personal information under the relevant data protection laws;
  • we have put in place appropriate safeguards to protect your personal information, such as an appropriate contract with the recipient;
  • the transfer is necessary for one of the reasons specified in data protection legislation, such as the performance of a contract between us and you; or
  • you consent to the transfer.

You may be entitled, in accordance with applicable law, to request a copy of relevant safeguards by contacting Electronic Payments Privacy Office via email: privacy@electronicpayments.com.

Contact Us

If you have any questions regarding this Privacy Policy, please contact us by any of the following means:

By Email: privacy@electronicpayments.com

By Mail: 7800 Congress Ave, Suite 108, Boca Raton, FL 33487

Children Under the Age of 18

Our Site is not intended for children under eighteen (18) years of age. No one under age eighteen (18) may provide any personal information to or on the Site. If you are under eighteen (18), do not use or provide any information on the Site, including through any of its
features, if any; make any purchases through the Site; use any of the interactive or public comment features of the Site; or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. The Company does not knowingly collect personal information from children under the age of eighteen (18) without verifiable parental consent. If it is determined that such information has been inadvertently collected on anyone under the age of eighteen (18), we will promptly take the necessary steps to ensure that such information is deleted from our system’s database.

Unsubscribe or Opt-Out

All users and/or visitors to our Site have the option to discontinue receiving communications from us and/or reserve the right to discontinue receiving communications by way of email, text messages, or newsletters. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. If you wish to unsubscribe or opt-out from any third party websites, you must go to that specific website to unsubscribe and/or opt-out.

Where you opt out of receiving these marketing messages, this will not apply to personal information/our communications to you which are provided as a result of a product/service purchase or other transactions.

Links to Other Web Sites

Our Site may contain links to affiliate and other third party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. The Company does not control, claim, nor accept responsibility for any privacy policies, practices, and/or procedures of such other websites. Therefore, we encourage all users and visitors to be aware when they leave our Site to read the privacy statements/policy of each and every website you visit.

Data Security

The Company has put in place appropriate security measures and shall take reasonable precautions to maintain adequate physical, procedural, and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of the user’s personal information under our control. In addition, we limit access to your personal information to those employees, agents, contractors, service providers, and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

The safety and security of your information also depends on you. If, when and where we may give you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information, to the extent possible, in public areas of the Site. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or other requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. If you would like further information on our retention periods, please reach out to us through the details in the “How To Contact Us” section for further information.

Your Duty to Inform Us of Changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

How to Contact Us

If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please feel free to contact our Data Privacy Manager at the following email or mailing address:

Email address: privacy@electronicpayments.com

Mailing Address: 7800 Congress Ave, Suite 108, Boca Raton, FL 33487

Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to offer and give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary 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.

Comply with a legal obligation means processing your personal information where it is necessary for compliance with a legal obligation that we are subject to.

Internal Third Parties mean other companies in our company group acting as joint controllers or processors and who are based in the United States. For further details of the entities which make up our group please contact us for more information.

External Third Parties mean:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Marketing providers, including public relations specialists, advertisers, and sales.

Privacy Notice for California Residents

Effective Date: August 18, 2025

This Privacy Notice for California Residents supplements the information contained in Electronic Payments’ Privacy Policy [HYPERLINK] and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as may be amended from time to time (“CCPA”), including the California Privacy Rights Act (“CPRA”), and any terms defined in the CCPA or CPRA have the same meaning when used in the Privacy Notice. Further, as used in the Privacy Notice, except as may be otherwise provided herein, all capitalized terms which are defined in the Privacy Policy shall have the same meaning herein as therein, all of such terms and their definitions being incorporated herein by reference.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.
  • protection of trade secrets;
  • protection of free speech and press rights for noncommercial activities protected by California’s Constitution;
  • exemption of certain commercial credit reporting agency actions from the deletion and opt-out rights;
  • exemption of household data from the business’s right to know, deletion, and correction response obligations;
  • exemption of student grades, educational scores, or educational test results held for a local educational agency from the deletion right;
  • exemption of educational standardized assessments, including specific responses, from the right to know’s disclosure requirements when disclosure could jeopardize its validity or reliability; and
  • exemption of physical items containing personal information from the deletion and opt-out rights, such as the consumer’s photograph, if the consumer previously consented to the item’s creation and other circumstances apply.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete, such as the “Contact Us” form on the Site, or other communications with us.
  • Indirectly from you. For example, from observing your actions on our Site.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about the Site or our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Site, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users/consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Automated Decision-Making and Profiling

We do not use automated decision-making (where an electronic system uses personal information to make a decision about you without human intervention), but we do use Profiling [HYPERLINK]. We do not consider that the use of profiling has any legal effect on you or significantly affects you.

You have the right to object to our use of profiling described in this section. You can do that by opting out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (such as the IP address assigned to you by your Internet Service Provider) when you visit our Site, you can use a virtual private network (VPN).

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyze or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Use of Profiling for Web Analytics

Our web analytics services, such as Google Analytics, collect information such as your location (based on your IP address) and your behavior (based on cookies) when you access our Site (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer.

By automatically analyzing and categorizing information such as the location (based on IP address) as well as the behavior and devices of visitors to our Site (using cookies), we are able to gain a better understanding of what our Site visitors require (in terms of the content of our Site and our products and services), how to improve our Site and how to advertise and market our products and services to them.

Cookies will be used to track and store information about your behavior and device on our Site (unless you have opted out from receiving such cookies by rejecting cookies) and your location will be analyzed based on your IP address. We have a legitimate interest in processing this information for the purpose of improving our Site for our Site users and getting to know our Site user’s preferences so our Site can better meet their needs and desires.

Selling and/or Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose as defined under California Civil Code § 1798.140(e). We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information. In the preceding twelve (12) months, we have not sold personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights [HYPERLINK].

Personal Information Category Category of Third-Party Recipients
Business Purpose Disclosures Sales Sharing
A: Identifiers. Finance and Accounting Tool
Sales and Marketing Tool
Business Communication and Collaboration Tool
Data Storage Service Provider
Ad Network
None None
B: California Customer Records personal information categories. Finance and Accounting Tool
Sales and Marketing Tool
Business Communication and Collaboration Tool
Data Storage Service Provider
None None
C: Protected classification characteristics under California or federal law. None None None
D: Commercial information. Finance and Accounting Tool
Sales and Marketing Tool
Business Communication and Collaboration Tool
Data Storage Service Provider
None None
E: Biometric information. None None None
F: Internet or other similar network activity. Data Analytics Provider
Sales and Marketing Tool
Business Communication and Collaboration Tool
Data Storage Service Provider
Ad Network
None None
G: Geolocation data. None None None
H: Sensory data. None None None
I: Professional or employment-related information. None None None
J: Non-public education information. None None None
K: Inferences drawn from other personal information. None None None
L: Sensitive personal information. None None None

Retention of Personal Information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention Periods

Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason, whether by email, via mail or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and at such time we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods:

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long the information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how difficult it may be to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by emailing us at privacy@electronicpayments.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

While we do not permit users of the Site to be under the age of 18, you may also make a request to know or delete or correct on behalf of your child by sending an email to privacy@electronicpayments.com

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

  • 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 the disclosure of identifying information.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see “Personal Information Sales Opt-Out and Opt-In Rights”.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@electronicpayments.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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 provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

Under California law, consumers have the right to direct us to not sell or share their personal information at any time (the “right to opt-out”). We do not sell or share personal information of consumers whom we have actual knowledge are less than sixteen (16) years of age, and such consumers must affirmatively authorize ("opt-in") the sale or sharing of their personal information before any such sale or sharing occurs. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time by visiting our "Do Not Sell or Share My Personal Information" webpage or by contacting us through the methods described in this policy.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

[IMAGE PG26]

[HYPERLINKED URL with the title “Do Not Sell or Share My Personal Information”]

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales or sharing. We will process your opt-out request within 15 business days of receipt. However, you may change your mind and opt back in to personal information sales at any time by:

[OPT-IN INSTRUCTIONS OR URL LINK]

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request. You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific third-party website to unsubscribe and/or opt-out in accordance with the terms and conditions of such third-party website.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@electronicpayments.com.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

California consumers will also have the right to:

  • Correct inaccurate personal information.
  • Opt-out of sharing personal information for cross-context behavioral advertising purposes.
  • Restrict sensitive personal information use and disclosure.
  • Changes to Our Privacy Notice

We reserve the right to amend the Privacy Notice at our discretion and at any time. When we make changes to the Privacy Notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@electronicpayments.com.

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Last Updated Date: 8/18/2025]