Effective Date: 01/10/2018
Choice Pay Now, LLC (“CPN”, “we”, “us” or “our”), is committed to the safety of your personal, company, and financial information. We value our relationship and your trust.
Types of Information
The following types of information about you are collected by us:
Information about a Merchant’s or Sales Partner’s business, including its taxpayer identification number and certain other identifiable information (such as its financial history, when applicable);
Certain personally identifiable information of the owner of a Merchant or Sales Partner, including the owner’s name, address, social security number, and email address. This information may be necessary to process applications and other paperwork, and to contact the owner;
Your name, including username or screen name and password;
Postal and/or e-mail address;
Mobile, home, fax and/or business telephone (including toll-free) number, service provider name, and the date, time and content of your message;
IP Address, and other technical information collected by the servers utilized by us or our vendors;
Credit/debit card and other billing information, including cardholder transaction data, card numbers, and expiration dates;
Information regarding the use of the Services, including but not limited to the redemption of gift and loyalty offers; and
Other information provided by you to us in any way.
The Services are not intended for anyone under the age of 18, nor do we knowingly collect or retain information in connection with the Services from children under the age of 13.
How Information is Collected
We may collect information in the following ways:
Through registration, or electronic forms filled out, by you on CPN’ website or a CPN-hosted website, and/or a website hosted by a third party;
Through paper forms filled out by you;
Through SMS (Short Message Service) messages sent via your cell phone by you;
Through telephone calls made by you to us or vice versa;
Through emails sent by you to us or vice versa;
Through any other communications between you and us;
Through surveys and prize promotion entries;
Through referring websites or third parties, such as by Merchants regarding Customers, or Sales Partners regarding Merchants;
Through third parties, such as third-party verification services, credit bureaus, mailing list providers, and other publicly available sources;
Through card or other transactions between Merchants and Customers;
Through the maintenance and analysis of Web server logs; and
Via “cookies” (small text files placed on a computer), single-pixel GIF image files (also called “Web beacons”), Web server log analysis and other similar technological means.
We require both the personal social security number of the owner of a Merchant or Sales Partner and the Merchant’s or Sales Partner’s federal taxpayer ID to provide the Merchant with a merchant account or to consummate a relationship with the Sales Partner. When the Merchant or Sales Partner enters its owner’s social security number and its federal taxpayer ID on our registration application form, we encrypt it using secure socket layer technology (SSL). We may use the Merchant’s or Sales Partner’s and/or its respective owner’s name and social security number to request a credit report and to obtain a background report on the Merchant or Sales Partner and its business and on its owner. We take a number of security measures, such as encryption, to protect the privacy of information about the Merchant or Sales Partner and its owner.
Information Use and Sharing
To market, operate, monitor and deliver the Services, such as processing transactions and requests, providing and sending instructions and messages, measuring interest in the Services, customizing content, and contacting you;
To market, operate, monitor and deliver any products and/or Services powered by CPN that are provided to you by third parties;
To enable you to enter promotions and receive prizes from us and/or third parties;
To improve or tailor the user experience with regard to the Services;
To provide information and offers regarding the Services, as well as other products and services offered by or through us or selected third parties;
To provide, sell, or transfer information to a company that acquires, is acquired by or is merged with us; and
To identify you.
We may advertise the Services using a third party, and these third parties may utilize cookies or other technological means within the advertising to collect and utilize non-personal information. We are not responsible for information collected by any such third parties, nor for the collection or use of information by other websites to which the Services are linked.
Based upon the personally identifiable information that you provide us, we may send you a welcoming email. We will also communicate with you in response to your inquiries, to provide the Services you request, and to manage your account.
We store information that we collect through cookies, log files, and clear gifs to create a “profile” of your preferences. We do not share your profile with other third parties, except that we may share your profile with (i) third parties from whom you receive products or Services powered by CPN, (ii) Sales Partners that board you as a Merchant, and (iii) Merchants for whom you are a Customer.
Choices Regarding Your Information
If you have provided personally identifiable information to us, we may, from time to time, send you mail or e-mail regarding the Services. We provide you the opportunity to unsubscribe from having your information used for certain purposes, provided that such an opportunity may require you to discontinue your use of the Services and any products related thereto. If you no longer wish to receive promotional communications or our newsletter, or if you wish to unsubscribe from having your information used for certain purposes, you may do so by following the instructions included in each communication or by notifying us by email to firstname.lastname@example.org.
We take every reasonable precaution to protect the confidentiality and security of your personal information by using industry-recognized security safeguards such as site monitoring, secured networks and servers, firewalls, and encryption. When we ask for sensitive information, we protect it through the use of encryption during transmission, such as SSL (Secure Socket Layer). We regularly test and update our technology to enhance security. No method of transmission over the internet is 100% secure, however. Therefore, while we strive to protect your personal information within industry standards, we cannot guarantee its absolute security.
Our employees are trained and required to safeguard your information. Our strict internal controls limit access to information based on job functionality.
Protection of Cardholder and Customer Data
We are subject to the rules and regulations of credit and debit card associations and networks, such as VISA, MasterCard, American Express, Discover, Accel, NYCE, and Interlink. We are also compliant in regards to the security and safeguarding of cardholder information with “PCI DSS” (Payment Card Industry Data Security Standards), and “CISP” (Cardholder Information Security Program). We comply with all related rules and regulations at all times. We undergo periodic third-party assessments and network scans to ensure that we have installed and maintained a firewall configuration to protect data; encrypt transmission of cardholder data and sensitive information across networks; restrict access of data to those that need to know; track and monitor all access to network resources and cardholder data; regularly test security systems and processes; assign a unique ID to each person with computer access; restrict physical access to cardholder data; and maintain a policy that addresses information security. Additional information regarding these requirements can be found at https://www.pcisecuritystandards.org/pdfs/pci_fs_data_storage.pdf
Use of Web Technologies
We employ a software technology called clear gifs (aka web beacons/web bugs), that helps us better manage the content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of a sentence. We do not tie the information gathered by clear gifs to your personally identifiable information.
We use clear gifts in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Choice/Opt-Out”.
As is true of most websites, we gather information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.
Do Not Track
When you use one or more of our websites, we may receive “do not track” requests from you, whether via signals from Web browsers or other mechanisms. At this time, we do not respond to such “do not track” requests, although we may choose to do so in the future.
Manage Accurate Information
If your personally identifiable information changes, or if you no longer choose to use our Services, contact customer service by email; or telephone at the contact information listed below to assist you with changes to your account.