Updated and Effective as of January 21, 2020
How you can contact us about privacy questions
Scope and consent
Collection of Personal Information
We may collect the following types of personal information in order to provide you with the use of Quadpay Services, and to help us personalize and improve your and others’ experience.
Information we collect automatically:
Information you provide to us
We may collect and store any information you provide us when you use Quadpay Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding Quadpay Services.
When you use Quadpay Services, we also may collect information about your transactions and your activities, such as records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. In addition, if you open a Quadpay account or use Quadpay Services, we may collect the following types of information:
- Contact information, such as your name, address, phone, email and other similar information.
- Financial information, such as information about your current employer and your employment history and the full bank account numbers and/or credit card numbers that you link to your Quadpay account or give us when you use Quadpay Services.
- Detailed personal information such as your date of birth or Social Security Number.
- Biometric information, such as information about your physiological, biological and behavioral characteristics.
- We may also collect information from or about you other than through your use of the Quadpay Services, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with members of the Quadpay corporate family or other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole). Additionally, for quality and training purposes or for its own protection, Quadpay may monitor or record its telephone conversations with you or anyone acting on your behalf, subject to applicable law. By communicating with Quadpay, unless otherwise provided by applicable law, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Information from other sources
When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
How we use the personal information we collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience with the Quadpay Services. We may use your personal information to:
- provide Quadpay Services and customer support;
- communicate with you, respond to your requests, and send information to you; including communications regarding our site or Quadpay Services, updates and/or any changes to our site or Quadpay Services;
- process transactions and send notices about your transactions;
- verify your identity, including during account creation and password reset processes;
- resolve disputes, collect fees, and troubleshoot problems;
- manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
- detect, prevent or remediate violations of policies or applicable user agreements;
- improve the Quadpay Services by customizing your user experience;
- measure, analyze and gain insights into the performance of the Quadpay Services and maintain or improve their content, design, delivery and layout;
- manage and protect our information technology infrastructure;
- provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;
- contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our User Agreement;
- perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties;
- other business or operational purposes compatible with the context in which the personal information was collected;
- prevent fraud and other illegal activities;
- comply with applicable law;
- defend our legal rights.
We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about Quadpay Services and the services of our corporate family. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. To reach you as efficiently as possible, we may contact you via phone, and may use autodialed or prerecorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your personal information with information we collect from other companies and use it to improve and personalize Quadpay Services, content, and advertising delivered to you and other users. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by logging into your account and going to the Notifications section and updating your preferences, or by following the directions that may be provided within the communication or advertisement.
We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.
When you access our website or use Quadpay Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, e-tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We use these technologies to recognize you as a customer; customize Quadpay Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and Quadpay Services.
You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and Quadpay Services.
Do Not Track
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to DNT signals. We do, however, provide you notice of the tracking by advertisers and other third parties in our Privacy and Cookies policies.
How we protect and store personal information
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers, and information access authorization controls.
How we share personal information with merchants
When transacting with merchants of goods and services (“Merchants”), we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction.
We do not share your bank account information or card account information with any Merchants.
We work with third parties, including Merchants, to enable them to accept or send payments from or to you using Quadpay. In doing so, a third party may share information about you with us, such as your email address or mobile phone number. We use this information to confirm that you are a Quadpay customer and that Quadpay as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a Quadpay customer with a third party, we will do so.
Please note that Merchants and other third parties from whom you buy or with whom you contract will have their own privacy policies, and although Quadpay’s user agreement does not allow the other transacting party to use any personal information we give them for anything other than providing Quadpay’s Services, Quadpay is not responsible for their actions, including their information protection practices.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using Quadpay, or with the third parties that offer or use Quadpay Services, except with your express permission or if we are required to do so to comply with applicable credit card association rules, a subpoena, or other legal process.
How we share personal information with other third parties
We may share personal information with:
- Members of the Quadpay corporate family, to help detect and prevent potentially illegal acts and violations of our and their policies, and to guide decisions about their products, services, and communications. Members of our corporate family will use this information to send you marketing communications only if you have requested their services.
- Financial institutions that we partner with to jointly create and offer a product. These financial institutions may only use this information to market Quadpay-related products, unless you have given consent for other uses.
- Credit bureaus and collection agencies to report account information, as permitted or required by law.
- Banking partners as required by credit card association rules for inclusion on their list of terminated merchants.
- Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Quadpay or one of its affiliates; when we need to do so to comply with law or credit card association rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
- Other unaffiliated third parties, for the following purposes:
- Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk.
- Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).
- Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements.
- Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
- Other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.
If you open a Quadpay account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a Quadpay website) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with personal information. Quadpay is not responsible for the content or information practices of such third parties.
How you can access or change your personal information
Opt out notice
As a Quadpay customer you have the right to opt out of Quadpay’s sharing of your ‘nonpublic personal information’ with nonaffiliated third parties. You may limit the sharing of your information, to the extent it may be so limited, by accessing your account and profile and reviewing/updating your settings.
Children’s online privacy protection act
We comply with the requirements of the Children’s Online Privacy Protection Act. We do not knowingly or intentionally collect or sell personal information from children under the age of 16. Our website, products and services are directed to individuals who are at least 16 years of age or older.
If you learn that your child has provided us with personal information without your consent, you may contact us as set forth herein. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
Provisions applicable to California consumers
California consumer privacy act
The California Consumer Privacy Act (“CCPA”) provides natural persons who are California residents (“California Consumers”) users of our Services with the right to receive, in connection with their use of our Services, certain disclosures regarding our collection, use, sharing and processing of certain personal information, as well as the right to know/access, delete and limit sharing of this personal information. To the extent that we collect such personal information subject to the CCPA, that information, our practices, and your rights are set forth below. Under the CCPA, “personal information” is defined as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household,” and we use that meaning in this section. We do not sell personal information of California Consumers, as such terms are used in the CCPA.
Collection of personal information
California Consumers have the right to receive notice of the categories of personal information we collect regarding our California Consumers and the purposes for which those categories of personal information will be used. Please refer to the section above titled “Collection of Personal Information” for a description of the categories of personal information we collect regarding California Consumers, and the section above titled “HOW WE USE THE PERSONAL INFORMATION WE COLLECT” for a description of the purposes for which those categories of personal information may be used.
Third parties with whome personal information is shared
Quadpay shares California Consumers’ personal information with third parties as described in the above sections titled “How We Share Personal Information with Merchants” and “HOW WE SHARE PERSONAL INFORMATION WITH OTHER THIRD PARTIES”.
In the preceding 12 months, we have disclosed the following categories of personal information about consumers for business purposes:
- Personal Identifiers. We share this information with our Service Providers to allow them to perform services on behalf of Quadpay. We may also share this information with our business partners so that they may provide California Consumers with information about products and services that may be of interest to such persons.
- Internet or Other Electronic Network Activity Information. We share with or allow third parties to utilize cookies for marketing or advertising customized to users’ interests or needs.
Right to know/access information
California Consumers have the right to request that we disclose to them the categories of personal information we have collected about them, the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share the personal information, the specific pieces of personal information we have collected about them. California Consumers may request this information twice in a 12-month period. To protect our customers’ personal information, we are required to verify the requestor’s identity before we can act on any such request.
Right to request deletion of personal infromation
California Consumers have the right to request that Quadpay and our Service Providers delete any personal information about them that we have collected. To protect our customers’ personal information, we are required to verify the requestor’s identity before we can act on any such request. The right of deletion may be subject to superseding law.
Right to equal service
Quadpay will not discriminate against California Consumers on the basis of the exercise or non-exercise of any rights hereunder, including, but not limited to, by:
- Denying goods or services on such basis;
- Charging differing prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, on such basis;
- Providing differing levels of quality of goods or services on such basis; or
- Suggesting that California Consumers will receive a different price or rate for goods or services or a different level or quality of goods or services.
California Consumers can submit “verifiable consumer requests” (as such term is used in the CCPA) regarding the privacy of their personal information through their account with us, by sending an email to [email protected] Quadpay must be able to verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request (or is the parent or legal guardian of such minor California Consumer, or is a person authorized by such a California Consumer to act on such California Consumer’s behalf). Making a verifiable consumer request does not require you to create an account with us; however, if you are our customer, then by signing in to your account to submit such a request, you will be able to automatically verify your identity, which will result in faster processing of your request. Otherwise, we will only use personal information provided in such a request to verify the requestor’s identity. We reserve the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is suspect or fraudulent.