TaliPay Privacy Policy

About this Policy

This Privacy Policy (the “Privacy Policy” or “Policy”) describes the information collection, use and disclosure practices of TaliPay, Inc. and its affiliates (collectively, “TaliPay”, the “Company”, “we”, “us”, or “our”) as related to information about identifiable individuals (“you”, “your” or “Users”) that is regulated by applicable privacy laws who visit, use or otherwise interact with our websites (“Sites”), or any application, webpage, email, text message, or online ad under our control (“Our Services” or “TaliPay Services”). This Privacy Policy applies to current and former individuals and their relationships with us relating to the products and services that you may request or receive from us through Our Services.

For purposes of this Privacy Policy, an affiliate is a company that is related by common control or ownership (e.g. companies in the same corporate family), including non-financial companies, and information includes personal data obtained in connection with Our Services.

Your privacy is important to us, and we are strongly committed to making our practices regarding your personal data more transparent and fairer. Please read this Privacy Policy carefully and make sure that you fully understand and agree to it.

This Privacy Policy should be read in conjunction with and forms part of our Terms of Service (“Terms of Service”).

Policy Changes

From time to time, but at least annually, the Privacy Policy will be reviewed to ensure it is up to date. As a result of this review, the Policy may be revised or supplemented. We will let our Users know about changes to the Policy by posting such changes on our Sites.

Data Collection

We may collect technical data, profile data, content, and other data from you, your organization, or other third-party sources.

We collect various types of personal data regarding our Users. Such Personal Data is typically collected and generated through your interaction with us or our Sites, through automatic means, or directly from you, from other Users, or from other third-parties.

Specifically, we collect the following categories of information which may contain personal information:

1. Data automatically collected or generated: When you visit, interact with, or use our Sites or the TaliPay Services, we may collect, record or generate certain technical data about you. We do so either independently or with the help of our Service Providers, including through the use of “cookies” and other tracking technologies (as detailed in Cookies and Tracking Technologies below);
2. Such Personal Data may consist of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device data (like type, operating system, mobile device id, browser version, locale, and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on such device and the recorded activity (sessions, clicks, and other interactions) of Users in connection with the TaliPay Services. In addition, phone calls (e.g. with our customer success or product consultants) may be automatically recorded, tracked and analyzed, for purposes including analytics, service, operations, and business quality control and improvements, and record-keeping purposes;
3. User Data received from you: When you contact us or sign up for TaliPay Services and create your individual profile (“User Profile”), you may provide us with Personal Data. This includes your name, workplace, and position, contact details (such as email, phone, and address), account login details (email address and passwords which are automatically hashed), as well as any other data you choose to provide when you use the TaliPay Services, contact us, or interact with others via our Sites. For example, you may connect your Google account when you sign up or log in to the TaliPay Services, and thereby provide us with your name, email address, image, and other details listed on your profile there. You may also provide us with your profile photo, location, time-zone, skills, device, general location, and activity logs and data; as well as your preferences, characteristics, and objectives for using the TaliPay Services;
4. Identification Information: Supplemental documentation may be required by TaliPay to verify the identity of a customer’s or a prospective customer’s directors, officers, or owners (who may be customer’s Users), such as a copy of a government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address. This includes any additional data you choose to provide to us directly through our Know Your Customer (“KYC”) process to comply with legal, regulatory, and other compliance-related requirements. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply to it.
5. You may also send us a “Contact Us” or support requests, or provide us with feedback, reviews, or answers to surveys or promotions, including by submitting an online form on our Sites or social media channels, by posting on any of our online public forums or communities, by sending an email to any of our designated addresses, or any other form of communication. Such data may include details on a problem you are experiencing, contact information and any other documentation, screen recording, screenshots, or other information;
6. Our Users may provide us with additional User Data such as their billing details, business needs, and preferences;
7. Payment information: Payee username, email address, physical addresses, phone number, social security numbers or tax identification numbers, bank account numbers, SWIFT codes, and payment preferences. Supplemental documentation may be required by the Users, such as a copy of payee User’s government-issued identification card, voided check, personal bank statements or other documentation serving as proof of identity or valid address. This includes any additional data you choose to provide to us directly, provided to us by the relevant User, banks, payment processing services, your representative, or that we may require in order to properly process your payment and in order to comply with legal, regulatory, and other compliance-related requirements. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply to it;
8. User Data containing Personal Data: Users may choose to upload or submit to the TaliPay Services User Data which includes Personal Data about other individuals (e.g., by uploading the User’s client or employee directories in order for us to contact, invite or subscribe them as Users to the TaliPay Services). Any Personal Data which is included in User Data will only be processed by TaliPay on behalf of the User which uploads it in accordance with any Data Processing Agreement or other agreements with such User, and this Privacy Policy. To the extent that such User Data contains Personal Data about other individuals, the User represents to us that they have obtained any required consent from such other individuals to provide such Personal Data to us;
9. Personal Data received from other third parties: We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar, or promotion that we sponsor or participate in, we may receive your Personal Data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details, and professional experience, preferences, and interests) from our business partners or Service Providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn;
10. Data concerning service integrations: If, when using the TaliPay Services, you or your employees or agents choose to integrate your account on a third-party service (and such service is supported by the TaliPay Services), we will connect and integrate that third-party service to ours. The third-party provider of this integration may receive certain relevant data about or from your account (including User Data), or share certain relevant data from your account on their service with the TaliPay Services, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them). If you do not wish your Personal Data to be shared with such third-party service(s), please notify your account administrator;
11. Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and the TaliPay Services. Analytics tools collect data such as how often Users visit or use the Sites or the TaliPay Services, which pages they visit and when, and which website, ad, or email message brought them there;

(collectively, “Personal Data” or “Personal Information”).

Data Uses

We collect your Personal Information required to provide and improve Our Services; responding to your queries; identification, account creation and management; security measures, fraud prevention and investigation; account servicing; analytics; marketing and sales purposes; to comply with applicable laws and regulations; and to support our legitimate interests.

We use Personal Data as necessary for the performance of the TaliPay Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving the TaliPay Services, e.g. in understanding how the TaliPay Services are used and how our marketing campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling the TaliPay Services to you and others; providing customer service and technical support; and protecting and securing our Users, ourselves and the TaliPay Services.

Specifically, we use Personal Data for the following purposes:

1. To facilitate, operate, and provide the TaliPay Services;
2. To authenticate the identity of our Users, and to allow them to access the TaliPay Services;
3. To provide our Users with assistance and support;
4. To gain a better understanding of how Users evaluate, use, and interact with the TaliPay Services, and how we could improve their User experience, and continually improving our products, offerings, and the overall performance of the TaliPay Services;
5. To facilitate and optimize our marketing campaigns, ad management, and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using the TaliPay Services and thereby increasing your engagement and overall satisfaction with the TaliPay Services. This includes contextual, behavioral, and interests-based advertising based on the User’s activity, preferences, or other data available to us or to our business partners;
6. To contact our Users (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Communications below);
7. To facilitate, sponsor and offer certain events, contests, and promotions;
8. To publish your feedback and submissions to our public forums and blogs;
9. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity;
10. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data which we or our business partners may use to provide and improve our respective services, or for any other purpose;
11. To market, promote and drive engagement with Our Services. We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you;
12. To comply with applicable laws and regulations;
13. To protect our legitimate business interests and legal rights. Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business; and
14. To use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote Our Services, with your explicit permission.

In respect of Personal Data we obtain from Google OAuth API Scopes, which is used in our integration with certain Google services (the “Integrated Google Services”), our use of such Personal Data and any aggregated or anonymized data that is derived from such Personal Data (the “Restricted Personal Data”) is limited to the following:

1. Facilitating, operating, supporting, providing, and improving the Integrated Google Service;
2. Troubleshooting or security purposes (such as investigating a bug or abuse);
3. Compliance with applicable law and regulations;
4. For our internal operations, provided that the Restricted Personal Data (including derivations thereof) have been aggregated and anonymized;
5. Transfer of the Restricted Personal Data to third parties: (1) in accordance with this Privacy Policy, solely to the extent necessary to provide or improve the Integrated Google Services; (2) to comply with applicable laws and regulations; and (3) in connection with any change in control, including by means of merger, acquisition or purchase of substantially all of TaliPay’s assets; or
6. In accordance with your express consent.

Our use of Restricted Personal Data, and our transfer of Restricted Personal Data to any third party, will adhere to Google’s Limited Use Requirements.

Data Sharing

Your information will be used and disclosed for the purposes of complying with the law and to provide you with, or enhance, Our Services.

Legal Compliance

We may disclose your Personal Information for legal compliance under exceptional circumstances, including but not limited to:

• When we are required or authorized by law to do so (e.g. in response to a summon or a subpoena, search warrant, court order or similar requirement);
• To investigate or prevent potential fraud, loss or harm;
• When you have consented to the disclosure; and
• To establish or collect amounts owed to us;

Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of the TaliPay Services.

Service Providers

We may also disclose your information to third-party service providers engaged to support Our Services. We may engage selected third-party companies and individuals to perform services complementary to our own in order to provide Our Services to you (“Service Providers”). Such Service Providers include hosting and server co-location services, communications, and content delivery networks, data and cybersecurity services, billing and payment processing services, customer support providers, identification verification providers, fraud detection and prevention services, web analytics, email distribution, and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, email, voicemails, support and customer relationship management systems, and our legal and financial advisors.

Depending on each of their specific roles and purposes in facilitating and enhancing the TaliPay Services, Service Providers may have access to your Personal Data. Service Providers may only use your Personal Data for such limited purposes as determined in our agreements with them. Our Service Providers are not authorized by us to use or disclose your Personal Information except as necessary to perform services on our behalf or comply with legal requirements. If you do not wish us to provide your personal information to such service providers, we may be unable to provide you with Our Services or adequately respond to your query.

Our Service Providers shall be deemed as ‘Data Processors’ in circumstances where TaliPay assumes the role of ‘Data Controller’; and where TaliPay acts as the Data Processor for our User, the Service Provider shall be deemed our ‘Sub-Processor’ (as further described in Data Controller/Processor section below).

When our Service Providers contact you in order to offer or promote the TaliPay Services, they may additionally interest you in their own services. Should you decide to engage in such activities with our Service Providers, any such engagement is beyond the scope of TaliPay’s Terms of Service and Privacy Policy and will therefore be governed solely by the Service Provider’s Terms and Privacy Policy.

We use international Service Providers to process and/or store personal information for us. Please note that personal information in the custody of these service providers may be subject to access by the law enforcement authorities of those jurisdictions in which the service providers are located.

We may also, from time to time collect and share summarized, combined, generic, aggregated, and/or anonymized information derived from Personal Information with our Service Providers and trusted partners for any of the purposes outlined in this Privacy Policy. In doing so, we will take steps such that the summarized, combined, generic, aggregated, and/or anonymized information cannot be identifiable to you or to any person.

Account Administrators

We may share your Personal Data with the User owning the account to which you are subscribed as a User (including data and communications concerning your User Profile). In such cases, sharing such Personal Data means that the account’s administrators may access it on behalf of the account owner, and will be able to monitor, process, and analyze your Personal Data. This includes instances where you may contact us for help in resolving an issue specific to a team of which you are a member (and which is managed by the same User).

If you register or access the TaliPay Services using an email address at a domain that is owned by your employer or organization, and another team within such organization wishes to establish an account on the Site, certain information about you including your name, profile picture, contact info and general use of your account may become accessible to that User’s administrator and Users, and may still be accessed, copied, and processed by the account owner. Your User profile and User Data will also be made available to all the authorized Users who can view the same User accounts as you. TaliPay is not responsible for and does not control any further disclosure, use, or monitoring by or on behalf of the User who controls such a User account. Please contact your organization or refer to your administrator’s organizational policies for more information.

TaliPay Subsidiaries and Affiliated Companies

We may share Personal Data internally within our group, for the purposes described in this Privacy Policy. In addition, should TaliPay or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via email or prominent notice on the TaliPay Services.

Cookies and Tracking Technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics, and personalization purposes.

Our Sites and the TaliPay Services (including some of our Service Providers) utilize “cookies”, anonymous identifiers, container tags, and other technologies in order for us to provide the TaliPay Services and ensure that they perform properly, to analyze your performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by a User.

The following describes different categories of cookies and how we might use them on our Sites and within our Services:

Required Cookies

These cookies are necessary for the functionality of our Sites, and include session cookies needed to transmit authentication and security cookies. These cookies cannot be opted out of, as they are required for website functionality.

Functional Cookies

These cookies assist us with enhancing the function and performance of our Sites, including capturing analytics of website traffic, assisting with market research, and providing non-targeted advertising.

Google Analytics

We use Google Analytics to collect information to maintain and improve the use of our Sites and Our Services. Google Analytics collects information such as how often Users visit Our Services, which pages Users visit when they do so, and which other sites Users used prior to coming to our Services. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. For more information about Google Analytics and opt-out options, review Google Analytics’s Terms of Service and the Google Privacy Policy.

Opting Out

You can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please bear in mind that disabling cookies may complicate or even prevent you from using Our Services. You may choose to decline cookies if your browser permits but doing so may affect your use of the website and your ability to access certain features of the website or engage in transactions through the website.

Communications

We engage in service and promotional communications, through email, phone, SMS/Text, and notifications.

TaliPay Services Communications

We may contact you with important information regarding the TaliPay Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to the TaliPay Services, billing issues, service changes, log-in attempts or password reset notices, etc. account owners, and other Users on the same account, may also send you notifications, messages, and other updates regarding their or your use of the TaliPay Services. You can control your communications and notifications settings from your User Profile settings. However, you will not be able to opt-out of receiving certain service communications that are integral to your use (like password resets or billing notices).

Promotional Communications

We may also notify you about new features, additional offerings, events, and special opportunities, or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile, or email), through the TaliPay Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify TaliPay at any time by sending an email to [email protected], changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

Data Security Procedures

We maintain commercially reasonable physical, technical, and procedural safeguards to guard Personal Information. We limit the access of Personal Information to those employees, Service Providers, and agents who assist us in providing Our Services. We also require third-parties to whom we disclose Personal Information to adhere to this Privacy Policy and to establish Personal Information security procedures.

You also play an important role in protecting your Personal Information. Your password and security codes are private, and you should not share them with anyone. We will never ask you for your password, or the security code that is sent to you by SMS text message or e-mail when you log into your account. Keep your passwords, and other account details confidential and do not share them with others.

Due to the nature of internet communications and evolving technologies, we cannot ensure that Personal Information we collect, store or transfer online will remain free from loss, interception or alteration and TaliPay and its service providers shall have no liability for any loss, interception or alteration of personal information.

Your Access to Personal Information

You can access your account details at any time by logging into your account online. Subject to any exceptions prescribed by law, you can access and correct your Personal Information and challenge the accuracy and completeness of the information we have about you. We may deny access when required or authorized by law. For example, we may deny access when granting access would have an unreasonable impact on other people’s privacy or when necessary to protect our confidential commercial information and the requested Personal Information cannot be severed from the balance of the record in which it is contained. If we deny your request for access to, or refuse a request to correct, information, we will explain why.

Data Location

We may store your Personal Data in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs (as necessary for the performance of the TaliPay Services or for supporting and exercising our legitimate interests); and in accordance with our legal obligations.

Your Personal Data may be maintained, processed, and stored by us and our Service Providers in multiple locations, including in the United States of America, Canada, and other jurisdictions, as reasonably necessary for the proper performance and delivery of the TaliPay Services, or as may be required by law.

While privacy laws may vary between jurisdictions, TaliPay and its Service Providers are each committed to protecting Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention

Unless you specifically ask us to delete your Personal Information, we keep your Personal Information for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with the TaliPay Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes, whichever is longer.

Except as required by applicable law or any express agreement with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you.

If you no longer wish to use Our Services, you may request the account that you have created to use Our Services be closed by contacting [email protected]. You can also request that we delete or remove your Personal Information from our records by contacting [email protected].

Subject to our requirements for continued retention of your Personal Information (e.g., for auditing purposes) or to fulfill our legal obligations, we will make every reasonable effort to honor your request.

Even if you submit a deletion request, we may be required to maintain your personal information for as long as necessary to:

• comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);
• to exercise, establish or defend legal claims; and/or
• to protect against fraudulent or abusive activity on Our Services.

There may be occasions where we are unable to fully delete, anonymize, or de-identify your Personal Information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your Personal Information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

Data Subject Rights

Individuals have rights concerning their Personal Data. You may exercise your rights by contacting us or your account administrator.

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your Personal Data held with TaliPay, or to restrict or object to Personal Data processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by email at [email protected].

Please note that once you contact us by email, we may instruct you on how to fulfill your request independently through your User Profile settings; or may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will then be retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with this Policy.

If you would like to make any requests or queries regarding Personal Data we process on your account owner’s behalf, please contact the account’s administrator directly. For example, if you are a User who wishes to access, correct, or delete data processed by TaliPay on behalf of an account manager, please direct your request to the relevant account manager or administrator (who is the “Data Controller” of such data – see Data Controller/Processor below).

Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes the data on behalf of the Data Controller (or business). Below we explain how these roles apply to the TaliPay Services, to the extent that such laws and regulations apply.

TaliPay is the “Data Controller” of its Users’ Personal Data, as well as User Data consisting of profile and contact details, as well as usage, preferences, engagement, and analytics data. With respect to such User Data, we assume the responsibilities of Data Controller (solely to the extent applicable under the law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “Data Processor”.

If any of our Users upload or submit customer data or other content to the TaliPay Services which includes Personal Data (e.g., by submitting their own clients’ contact details to one of their User boards), such data will only be processed by TaliPay on behalf of that User, who is the owner of the relevant account, along with all other User Data processed on such User’s behalf.

In such instances, the User operating the account shall be deemed the “Data Controller” of such Personal Data, and TaliPay will process such data on the User’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our Terms of Service, our Data Processing Agreement with such User (to the extent applicable) and other commercial agreements. TaliPay’s Service Providers shall act as designated Sub-Processors in these instances. The User supplying such Personal Data will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to data subject rights requests concerning the data they control).

Additional Notices

The examples contained in this Privacy Policy are illustrations only and are not intended to be all-inclusive. If you decide to terminate your account, or if we close or suspend your account, we will continue to adhere to the privacy policies and practices described in this Privacy Policy to the extent we retain Personal Information about you.

We may amend this Privacy Policy from time to time. Your continued use of Our Services following a change to this Privacy Policy means that you provide your consent to the collection, use and disclosure of your Personal Information as set out in the updated Privacy Policy. Please check back periodically for updates.

Our website and Our Services are not intended to solicit information of any kind from individuals under the majority in their jurisdiction of residence (“Minors” or “Minor”) without the required consent from their parents/guardians. If we become aware of any Personal Information we possess that may belong to a Minor, we will immediately obtain parental consent or delete this Personal Information from our servers. If you are a parent/guardian and you suspect that your child may have submitted Personal Information to us, please contact us at the contact information below.

We may provide links to third-party sites. We encourage you to pay attention when you leave the TaliPay Services for websites or applications of third parties and to read the privacy policies of each and every website and service you visit. You should review their privacy policy and other terms and conditions, as they may be different from ours, and TaliPay is not responsible for the privacy, accuracy, reliability or security of third-party sites. This Privacy Policy applies only to the TaliPay Services.

Contact Us

If you have any questions, concerns or complaints about this Policy, please contact us by emailing us at [email protected]. We will respond to your request or investigate your concern as quickly as we can.

If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending personal or confidential information to us.

Additional State Disclosures

Vermont

We will not share personal information with non-affiliates except for our own marketing purposes, our everyday business purposes, with your consent or as permitted by law.

Nevada

In accordance with state law, we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone number: 702-486-3132; email: [email protected].

California

This Privacy Policy describes personal information we generally collect, use and disclose about California residents. We will not share personal information with non-affiliates except for our own marketing purposes, our everyday business purposes, with your consent or as permitted by law. We do not sell California residents’ personal information. The California Consumer Privacy Act (CCPA) permits California residents to (a) ask which categories and pieces of personal information it collects and how the information is used; (b) request deletion of the information; and (c) opt out of the sale of such information, if applicable. These provisions of the CCPA do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law. To contact us with questions about our compliance with the CCPA submit an e-mail request to [email protected] with the. We may ask that you provide certain information to verify your identity. We will respond to your request in accordance with the CCPA and if we deny your request, we will provide an explanation. You may designate an authorized agent to make a request under the CCPA on your behalf if the authorized agent is a person or business registered with the Secretary of the State of California and you sign a written declaration that you authorize the agent to act on your behalf. Please include a certified copy of your written declaration authorizing the agent to act on your behalf with your CCPA e-mail inquiry. You may not be discriminated against because you exercise your rights under the CCPA in violation of Cal. Civ. Code §1798.125.