Online Privacy Statement

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Accertify, Inc. (Accertify) is committed to protecting your privacy. This Privacy Policy applies to activities directly related to your visit to the Accertify website. This statement does not describe Accertify’s treatment of consumer data provided by our merchant clients that is described in the Client Data Privacy Statement. It does not apply to third parties’ websites linked through Accertify’s website. We strongly recommend that you read these third parties’ privacy policies prior to providing any information to such sites. Accertify has no responsibility or liability in connection with any third parties’ websites.

Accertify also has registered branch offices in England and Australia, both of which also adhere to all aspects of this Privacy Statement, including the EU-US Privacy Shield Principles and the US-Switzerland Safe Harbor Framework.

COLLECTION, USE AND TRANSFER OF YOUR INFORMATION

You can visit portions of the Accertify site without disclosing your personally identifiable information (personal data). However, you may choose to provide us with your personal data, for example when you contact us, register for seminars, activities and programs available on our website, seek employment or when you request information or services. You also may decide to provide us voluntarily with personal data of a third person, such as your colleague or coworker. In such case, we assume that you have the unrestricted permission of such person to provide his/her personal data to Accertify. Accertify may use third-party suppliers to collect, process, store, use, analyze and/or transfer the data on its behalf. In such cases, it is Accertify’s practice to require that these suppliers handle the personal data they process or transfer in a manner consistent with Accertify’s policies. By submitting the personal data to us, you acknowledge and agree with your data being processed and/or transferred on Accertify’s behalf by its suppliers. Accertify will handle the information we learn from you from your visit to our website in the following manner:

IF YOU VISIT OUR SITE TO READ OR DOWNLOAD INFORMATION, SUCH AS NEWS, PRODUCT INFORMATION, CASE STUDIES OR ARTICLES

We may collect, process or transfer the following information about you: the name of the domain from which you access the Internet; the date and time you access our site; and the Internet address of the website from which you linked directly to our site. We use the information we collect to measure the number of visitors to the different sections of our site, and to help us make our site more useful to visitors. We may transfer the information we collect to our corporate affiliates. We may use “cookies” and/or technologies to collect non-personally identifiable information from your visits to our website and your browser sessions to enhance your overall site experience and for statistical purposes. You can set your browser to turn off “cookies” or to warn you when a website attempts to place a “cookie” on your computer. However, if you turn off the “cookies,” our and other websites may not work as intended.

IF YOU SUBMIT PERSONAL DATA WHEN VISITING AN ACCERTIFY WEBSITE

We may collect, process or transfer the specific information you voluntarily provide to us in accessing the client portal or in the contact form you choose to fill in on our website, including the personal data you provide. By submitting any personal data on Accertify’s site, you authorize Accertify to use, process and transfer (if necessary across national borders) such data, even in and to countries where the level of data protection may not be commensurate with the high standard of protection adopted by certain countries, such as the standard suggested by the EU Data Protection Directive. In such countries, Accertify will still handle your personal data in the manner described in this Privacy Policy. Accertify will not sell personal data to third parties; however your personal data may be automatically transferred to any successor to substantially all of the assets and business of Accertify. Also, we may transfer the information to our corporate affiliates.

IF YOU ARE A CLIENT, OR ARE PART OF A CLIENT ORGANIZATION, OR ARE A SUBCONTRACTOR

Personal data you provide to Accertify, including personal data of a third party, such as your spouse, colleague and friend may be collected, stored, used and transferred as necessary for Accertify and our corporate affiliates to carry out business or seek potential business in the future with your company. If you provide us with personal data, whether in the form of an e-mail, business card, verbally during business meeting or otherwise, we assume that you have granted us a permission to collect, store, use and transfer such information with no limitations even in and to countries where the level of data protection may not be commensurate with the high standard of protection adopted by certain countries, such as the standard suggested by the EU Data Protection Directive. We also assume that you have unrestricted permission from the third party for the transfer of his or her personal data.

DISCLOSURES TO THIRD PARTIES

Accertify may share your personal data with third parties in the following limited circumstances: (1) personal information may be accessible to third-party service providers processing data on behalf of Accertify; however, any such service providers are required by contract to implement privacy and security safeguards consistent with this policy, including the EU-US Privacy Shield and the US-Switzerland Safe Harbor; (2) We may be required to disclose your personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements; and (3) your personal information may be provided to a third party to the extent Accertify enters into a transaction for the acquisition of all or substantially all of Accertify’s assets. Accertify faces potential liability when we onward transfer to third parties.

SENSITIVE PERSONAL INFORMATION

Accertify will not generally collect, process or transfer sensitive personal data through its site, unless you expressly consent with such collection, processing or transfer. “Sensitive personal data” for the purposes of this Accertify Privacy Policy shall mean data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life. By providing us with unsolicited sensitive personal data, you explicitly consent to such data being collected, processed and transferred by Accertify.

ACCESS, CHOICE, CORRECTION AND DELETION OF PERSONAL DATA

Accertify provides you with a possibility to request that the personal data you provided to us is accurate and up to date by contacting Accertify directly at the contact information noted below. We will honor your choice and refrain from sending you such announcements. You may change your choice at any time. To update or delete your data or correct an inaccuracy, we may ask you to verify your identity and cooperate with us in our effort.

E-mail:                          legal@accertify.com (put “Privacy Compliance” in subject line)

Mailing address:          Legal/Privacy Compliance

                                      Accertify, Inc.

                                      2 Pierce Place, Suite 900

                                      Itasca, Illinois, 60143 USA

Telephone:                  +1 (630) 735-4400 (ask for Legal/Privacy Compliance)

EU-US PRIVACY SHIELD FRAMEWORK

Accertify complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries with respect to personal information we receive from our merchant clients. Accertify has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

U.S. – SWITZERLAND SAFE HARBOR FRAMEWORK

Accertify complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Accertify has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/.

PRIVACY COMPLAINTS BY EUROPEAN UNION (EU) OR SWISS INDIVIDUALS

EU Individuals:

In compliance with the EU-US Privacy Shield Principles, Accertify commits to resolve complaints about consumers’ privacy and our collection or use of consumers’ personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Accertify at the contact information noted below.

E-mail:                           legal@accertify.com (put “Privacy Compliance” in subject line)

Mailing address:           Legal/Privacy Compliance

                                       Accertify, Inc.

                                       2 Pierce Place, Suite 900

                                       Itasca, Illinois, 60143 USA       

Telephone:                   +1 (630) 735-4400 (ask for Legal/Privacy Compliance)

Accertify has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Swiss Individuals:

In compliance with the US-Switzerland Privacy Shield Principles, Accertify commits to resolve complaints about consumers’ privacy and our collection or use of consumers’ personal information. Accertify seeks to resolve consumer complaints about privacy and our collection or use of your personal information as soon as is practicable. Swiss individuals with inquiries or complaints regarding this privacy policy should contact Accertify at:

E-mail:                          legal@accertify.com (put “Privacy Compliance” in subject line)

Mailing address:          Legal/Privacy Compliance

                                      Accertify, Inc.

                                      2 Pierce Place, Suite 900

                                      Itasca, Illinois, 60143 USA

Telephone:                  +1 (630) 735-4400 (ask for Legal/Privacy Compliance)

Accertify has further committed to refer unresolved privacy complaints under the US-Switzerland Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

ENFORCEMENT

Accertify has implemented internal mechanisms to verify ongoing adherence to this policy. We periodically verify that this policy remains accurate, comprehensive for its intended purpose, and is accessible in accordance with applicable law. Accertify is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

AMENDMENTS

This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield and Safe Harbor. Accertify will post any revised policy on this website.

CONTACT FOR QUESTIONS

Any questions about the accuracy, use, processing or storage of data received by Accertify should be directed to legal@accertify.com.

SECURITY OF YOUR PERSONAL INFORMATION

Accertify uses various organizational and technical measures to protect your privacy and avoid unauthorized use or disclosure of your personal data. However, you should note that no transfer of data over the Internet is completely secure. While we use reasonable efforts to protect your data on our systems, when the data is transferred over the Internet, it may be accessed and used by unauthorized third parties. Accertify has no control over the performance, reliability, availability or security of the Internet and does not warrant that any information transfer via the Internet or any communication through the Internet is secure. Accertify shall not be liable for any disclosure, unauthorized use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception, corruption, intervention, misuse or alteration of any personal information due to any action beyond Accertify’s reasonable control.

CHILDREN’S PERSONAL INFORMATION

www.accertify.com is a site not targeted to children and is not intended to collect personal data from children under age of 13. If you have questions regarding privacy of your personal information you submit to us through our website, please send an e-mail to legal@accertify.com.

EFFECTIVE DATE: September 1, 2016