Effective Date: August 1, 2014
Last Updated Date: January 21, 2018
What Information Do We Collect About You?
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You.
The type of information that we collect about you depends on your interaction with our Site and Services. Our Services allow companies (Payors) to distribute payments to multiple recipients (Payees). Payors may determine what features of the Services are available to their Payees; some of these features require Payees to register with us. If you register as a Payee, we collect the following:
- To register as an Individual Payee. Name, Social Security number, date of birth, address, email, how we should send your payments, bank account information (if you select ACH as your payment method), username, and password. We will verify your identity before we create your account.
- To register as a Corporate Payee. You must provide your: Company name, EIN, address, and provide the same information Individual Payees provide, as discussed above, for one of your company’s executives.
We also collect information from you when you contact us, such as your name, contact information, such as your email address and phone number, and your company’s name, and when you receive a payment.
Information We Collect From Third Parties.
- Info from Payors: We collect information about you from Payors when they want to initiate a payment to you as a Payee, such as your name, e-mail address, payment amounts, dates of payments, and a unique identifier that the Payor may have assigned to you.
- Info from Other Payees: If a Payor permits this feature, Payees may invite other individuals to access their Payee account. When a Payee extends an invitation, we collect the invited individual’s email address from the Payee. If an individual accepts the invitation, we will collect the individual’s name directly from the invitee.
- Info from Consumer Reporting Agencies and Public Records: To comply with our legal obligations, we are required to verify our customers’ identities. To do so, we collect information about our customers from consumer reporting agencies and public records.
Information We Collect Automatically.
We automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies:
- Your domain name;
- Your browser type and operating system;
- Web pages you view and links you click;
- Your IP address;
- The length of time you visit our Site and or use our Services; and
- The referring URL, or the webpage that led you to our Site, and your device ID.
We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes.
- To create your account as a Payee.
- To provide our Services to you, including to execute payments.
- To communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
- For customer identity verification and antifraud purposes.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.
- With your consent, to send you text message notices to confirm payments sent through the Services.
- For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
- To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes. If you are a Participating Union Payee, this use is subject to any applicable terms in the Participating Union Agreements between Exactuals and your Participating Union which may contain more stringent terms than this Policy.
- To protect our rights and interests and the rights and interests of other users.
How We Share Your Information
We may share your information, including personal information, as follows
- Payee Information. We may share your name, user name, transaction information, other information and the status of payments sent to you with the Payor who initiated the payment and that Payor’s affiliates, agents, or service providers. We may share this information for our everyday business purposes, such as to process your transactions, maintain your accounts, and other purposes.
- Payor Information. With your permission, we may share your contact information with potential customers to act as a reference for our Services.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy. Our affiliates may use your personal information for everyday business purposes, such as to process information about your transactions and experiences. We do not share personal information about your creditworthiness with our affiliates.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf as permitted by law.
- Non-Affiliates. We do not disclose any personal information about you to non-affiliates to market to you.
We also may share your information for the following purposes:
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users that does not identify you personally with third parties for marketing, advertising, research or similar purposes. If you are a Participating Union Payee, this use is subject to any applicable terms in the Participating Union Agreements between Exactuals and your Participating Union which may contain more stringent terms than this Policy.
Your California Privacy Rights and Choices
Because we value your privacy, we will not provide personal information about you to non-affiliated third parties for their solicitation or marketing purposes.
California law permits Users who 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 e-mail to the contact information below with "California Shine the Light Privacy Request" in the subject line and your full name, email address, postal address and specific services you have used in the body of your email.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
Children Under 18
Our Services are not designed for children under 18. If we discover that a child under 18 has provided us with personal information, we will delete such information from our systems.
U.S. Website and European Data Protection Rights
We protect the personal identification information of non-U.S. visitors in the same way as we do U.S. visitors, but we operate in the United States under United States law.
Any information you choose to send to this Site or Exactuals be subject to the laws of the United States. If you do not wish your information to subject to United States law, please do not send it to us.
Some jurisdictions, such as the European Union, do not consider the U.S. legal system to offer privacy and data protections that are “adequate” in their judgment. Should any European visitor wish to have access to, correct, modify, delete or dispute any personal information that we holds about them, please contact us using the information below.
We do not intend to offer its product or Services in any jurisdiction where the offering of such products or Services would be contrary to applicable local law, and any such offer of products or Services is void if illegal under applicable law.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.