Reviewed: November 18, 2019
Updated: February 6, 2020
All employees of RevaPay. LLC (RevaPay) referenced throughout this policy as the “Entity” or “RevaPay” must comply with the terms of this policy immediately. Managers, employees and technical personnel must modify system configurations and procedures, if necessary, to comply with the terms of this policy within 30 days of the Board of Directors’ approval of this document.
Responsible Department: Risk and Compliance
Responsible Position: Chief Compliance Officer
Your Privacy Rights
Scope and Consent
Information Collection and Use
For a better experience while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, and postal address. The information that we collect will be used to contact or identify you.
How We Use Personal Information
We primarily use your Personal Information to provide our SERVICE to you. We may use your Personal Information to:
- Fulfill your requests;
- Generate anonymized and aggregated datasets, that can be used for modeling, reporting, and analytics, such as to analyze payment, transaction or similar trends;
- Accomplish our business purposes, including to understand how you use our products, content and services; for analytics and product development purposes; to enhance, improve, or modify our current products and services, for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; and to identify usage trends.
Why Personal Information is Disclosed to Others
We disclose your Personal Information as follows:
- To merchants and other third parties that help facilitate the payment processing experience or to complete the actions you initiate, which may include, for example, completing a transaction, resolving a dispute, helping prevent fraud, providing customer service, and card-on-file storage.
- To issuer to authenticate and process your transactions, to operate any issuer services, and to enable your issuer to provide customer service, usage analysis, and fraud prevention.
- In some countries/territories, we may share your Personal Information with certain third-party digital wallets when we offer you the option to link to such digital wallets and you choose to do so. If this option is offered, you will have a choice whether to share Personal Information, including payment card information, between RevaPay and a given third party digital wallet. Transaction may not be “tokenized”. This means these transactions may result in the sharing of payment car information with merchants.
- To our Affiliates to develop, operate and improve products and services, to facilitate customer service, to comply with legal obligations, and for other uses described in this Privacy Notice.
- To our Service Providers to facilitate the services they provide us, who are required to only use your Personal Information in accordance with our instructions.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate:
- To comply with applicable laws and regulations.
- To cooperate with public and government authorities.
- To cooperate with law enforcement requests.
- For other legal reasons, such as to enforce our Terms of Service; to protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; to allow us to pursue available remedies or limit the damages that we may sustain; and In connection with a sale or business transaction.
Please note that we may also use and disclose information about you that is not personally identifiable for any purpose, except where we are required to do otherwise under applicable law. For example, we may publish reports showing general payment card usage trends. These reports do not contain any Personal Information.
We want to inform you that whenever you visit our Service, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
Cookies are files with small amount of data that is commonly used an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive.
Our website uses these “cookies” to collection information and to improve our Service. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of our Service.
We may employ third-party companies and individuals due to the following reasons:
To facilitate our Service;
- To provide the Service on our behalf;
- To perform Service-related services; or
- To assist us in analyzing how our Service is used.
We want to inform our Service users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
Links to Other Sites
Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
Access and Correction
You have the right to request access or make corrections to any of your Personal Information. To do so, please contact us at email@example.com or 949-481-2700. We will respond to your request consistent with applicable law. Where permitted by law, we may charge you a reasonable fee for access.
Mobile Terms of Service
- When you opt-in to the service, we will send you an SMS message to confirm your secure validation pin, authorization and receipt for all opted-in users.
- You can cancel the SMS service at any time. Just text “STOP” to 38207. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
- If at any time you forget what keywords are supported, just text “HELP” to 38207. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe.
- We are able to deliver messages to the following mobile phone carriers: Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). ***Carriers are not liable for delayed or undelivered messages***
- As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive 2 messages per transaction. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. For all questions about the services provided by this short code, you can send an email to firstname.lastname@example.org.