Payce Privacy Policy

Effective Date: May 7, 2020

The Services, as defined in the Terms of Use, are provided by Payce, LLC ("Payce," "Company," "we," or "us") as a convenience to consumers and are governed by the Terms of Use. Prior to accessing the Services, you must confirm that you agree with the terms set forth in this policy as well as the Terms of Use.

Payce understands that your privacy is very important to you. Payce has created this privacy policy, which explains what information we typically collect, how we use that information, and how we protect your privacy.

Visitors to our website or mobile application remain anonymous unless they register for the Services or otherwise elect to disclose their identity to us. We collect certain limited information about visitors, such as their IP address (a numeric address assigned automatically to computers when they access the Internet). Our Services are not directed at individuals under 18 years of age.

CONTROLLER

Payce is the controller and responsible for your personal data.

INFORMATION WE COLLECT

We may have collected the following categories of personal information from consumers within the last 12 months:

Categories of Personal Information	Examples of Specific Types of Personal Information Collected	Collected
A. Identifiers	Name, postal address, email address, telephone number, account numbers.	Yes
B. Personal Information categories	Bank routing and account number, credit card number, debit card number, or bill account number.	Yes
C. Commercial information	Records of cash back rewards earned through participating reward program merchants.	Yes
D. Internet or other electronic network activity information	IP address, user agent, and offer click history.	Yes
E. Inferences drawn from any of the information identified above	Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

A cookie is a small piece of data sent from a website and stored on your computer by your web browser. The file is added once you agree to store cookies on your computer or device, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow sites to respond to you as an individual. The website can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

This website collects cookies and may use cookies for reasons including, but not limited to:

Analyze our web traffic using an analytics package.
Identify if you are signed-in to the Website.
Test content on the Website.
Store information about your preferences.
Recognize when you return to the Website.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the website.

HOW WE COLLECT YOUR INFORMATION

We collect nonpublic personal information about you in order to administer our business, process your rewards, understand your needs, and provide you with products and services. We collection most of this personal information directly from users of our Services for whom we provide services to through the website. We obtain nonpublic personal information about you from the following sources:

Information such as your name, email address, zip code, password, and payment account details provided by an entity to which you provide express approval to provide such information upon enrollment;
Information, such as your name, email address, telephone number, zip code, password, credit and bank debit card numbers, and payment account details you provide to us when registering for the Services or when updating your profile;
Information about eligible transactions with participating merchants that earn cash back, such as amount of transactions;
Information we receive from other sources, such as your registered payment account;
Responses to customer surveys;
Communications with our customer service team;
Technical, and Transactional Data from Affiliate Networks and retailers featured on the Site from time to time;
From other third parties with your consent.

You also may give us permission to access your information in other services. For example, you may log in with your Facebook account. This will allow us to obtain information from that account. The information we get from that service often depends on your settings or their privacy policies, so be sure to check what those are.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies. As you navigate our website, we may collect usage data, profile data and marketing and communications data as specified by you from time to time.

HOW WE USE YOUR INFORMATION

We use your Personal Information to provide you the features and functionality of the service to ensure that you have a safe, high-performance experience when using the service. We may also use your information:

To present our site and its contents to you.
To provide you with information, products or services that you request from us.
To develop, offer, deliver and improve our products and services.
To offer products and services of participating merchants.
To track eligible purchases from participating merchants.
To calculate, award, and track earned cash back.
To process transactions on your behalf.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
To notify you about changes to our site or any products or services we offer or provide through it.
To allow you to participate in interactive features on our site.
To process and deliver contest entries and cash back rewards.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
To fulfill legal and regulatory requirements.
To confirm a Qualifying Purchase or return to match transactions to confirm whether you qualify for an Offer.
To confirm a specific transaction with a participating merchant; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction.
We may provide participating merchants and/or Third-Party Service Providers (third parties, including ValueDynamx, Inc. that enable us to provide the Payce® Program) aggregated and anonymized information relating specifically to linked card activity solely to allow participating merchants and Third-Party Service Providers to assess the results of their campaign.
Create a record of the transaction data and thereafter maintain and use data in connection with operating the Program.
Conduct analysis for the improvement and optimization of Program.
We may provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.
To transfer Payce Rewards balances to named beneficiaries.

When you use our services, we may automatically record your account transactions, transaction location, and computer or access device.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

If you have linked a credit or debit card in Payce, please review the Terms of Use to learn more about transaction monitoring, data collection, use, and sharing practices in connection with the program. You may opt-out of transaction monitoring on the credit and debit card(s) you have linked by logging into Paycepays.com, selecting "Manage Cards" and deleting your linked card.

Notwithstanding anything to the contrary in the Terms and Conditions or Privacy Policy, where you have agreed to receive card-linked offers, Payce and ValueDynamx, Inc. will use transaction information solely as follows:

We may use Transaction Data:

to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for a statement credit or an offer;
to share with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred or [cash back] should be awarded; for example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing or disputed transaction;
to provide participating merchants aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants to assess the results of their campaign;
to create a record of the transaction data and thereafter maintain and use data in connection with operating the program;
to conduct analysis for the improvement and optimization of the program; and
to provide information in order to respond to a request from government authority or a payment organization involved in a transaction with you or a merchant.

HOW WE SHARE YOUR INFORMATION

Payce may share personally identifiable information it collects with its employees who need to know that information to service your account. Except as provided below, Payce does not share or disclose any personally identifiable information to any company or marketing group external to Payce. Payce may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, process rewards distributions, provide customer service, or as otherwise authorized by law. We may store Personal Information in locations outside the direct control of Payce (for instance, on servers or databases co-located with hosting providers).

Reasons we can share your personal information	Does Payce share?	Can you limit this sharing?
For our everyday business purposes - such as to service your account, process rewards distributions, provide customer service or respond to court orders and legal investigations	Yes	No
For our marketing purposes - to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	We do not share
For our affiliates' everyday business purposes - such as information about your transactions and experiences	Yes	No

Definitions:

Affiliates are companies related by common ownership or control. They can be financial and non-financial companies.

Nonaffiliates are companies not related by common ownership or control. They can be financial and non-financial companies.

Joint marketing is a formal agreement between nonaffiliated financial companies that together market financial products or services to you. Payce does not jointly market.

Further, Payce may disclose personally identifiable information:

(i) Third party service providers (which may include Company affiliates) to operate our Services,
(ii) To another entity with which Payce enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase,
(iii) To a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, Payce, where appropriate,
(iv) To a third party if determined by Payce in its sole judgment that such disclosure is appropriate to protect the life, health, or property of Payce or any other person or entity, all in compliance with applicable law,
(v) Financial institutions that allow us to distribute your rewards to your payment account, and partner with us to develop new offerings for you,
(vi) Clients of Payce for whom we provide private-label rewards programs to you on their behalf through the Services (“Clients”),
(vii) To conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to Payce.
(viii) To third parties as authorized or designated by you.

Except as necessary for Payce to provide the services, information, or products requested by a website user, or except for the disclosures identified in the preceding paragraphs, the user may opt out of having his or her personally identifiable information, which has been voluntarily provided to Payce through or from its website, prospectively retained by Payce, used by Payce for secondary purposes, or disclosed by Payce to third parties

Payce may disclose certain information about you without identifying you as an individual to third parties. We do this for purposes such as analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing content.

SALE OF PERSONAL INFORMATION

We do not sell and will not sell your personal information.

ACCESSING CORRECTING AND MAINTAINING YOUR INFORMATION

You may update your personal information in your profile associated with the Services. If you are unable to update your profile, contact us using the contact us link on the website or mobile application. We reserve the right to not accommodate a request to change information if we believe the change would violate any law or legal requirement, create a security risk, or cause the information to be incorrect.

COMMUNICATIONS FROM US

We will send you regular servicing emails detailing your earnings and rewards distributions through the Services. We may also send you information on new offers and earning opportunities through the program. Out of respect for your privacy, we present the option not to receive these types of communications. You may elect to unsubscribe from promotional emails by selecting the unsubscribe link in the footer of any promotional email and may unsubscribe from servicing emails by contacting us at payce@rewards.support.

THIRD-PARTY MARKETING

As referred to above, we may share your contact or identity data with certain third parties e.g. sub-processors to facilitate the delivery of marketing emails to you and social media publishers, in order to ensure our marketing is targeted at and relevant to Payce members.

CONFIDENTIALITY AND SECURITY

We restrict access to nonpublic personally identifiable information about you to those employees who need the information to perform a specific job. We only store the nickname and last four digits of your credit and card information. We maintain industry standard physical, electronic, and procedural safeguards to encrypt, secure, and protect your information from unauthorized access by third parties.

Payce has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. We employ internal and external system safeguards designed to protect confidentiality and security of personal information.

The confidentiality of any communication or material transmitted to or from Payce via the website or via e-mail cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the website's content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to confirm and adapt to technical requirements of connecting networks or devices.

We will collect the IP Address of all visitors to the Payce website for internal security and other proprietary purposes. We do not release this data outside of our corporate team nor utilize the data other than for internal purposes.

However, the internet is never 100% secure. We cannot guarantee the use of the site will be totally safe. If you have reason to believe that your interactions with the website are no longer secure, please contact us immediately.

YOUR CHOICES

Payce offers you certain choices in connection with the personal data it collects from you, including:

Your Payce Account: You may review, update and correct your contact information, including your telephone number and email address, after logging in to the website or app.

Your Choice to Decline Cookies: You may adjust your browser settings to decline cookies if you do not want to accept Payce cookies. However, declining cookies may affect proper operation of Payce's website and will not allow you to earn cash back from online merchants, who rely on cookies to identify your eligibility to earn rewards.

You may decline to submit personally identifiable information through the Service, in which case Payce may not be able to provide certain services to you. You can review and correct the information about you that Payce keeps on file by contacting us as described below.

California Residents - Your Legal Rights

The right to access personal information - You have the right to request access to your personal information that we collected about you, subject to certain exceptions.
The right to request deletion of personal information - You have the right to request that we delete your personal information, however, state and federal law may prohibit us from deleting personal information, which Payce will disclose to you.
The right to non-discrimination - We will not discriminate against you if you exercise any of these rights.
The right to an authorized agent - You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent's name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion).
Opt out of sale of information -
If you wish to exercise any of these rights, please contact Payce by doing one of the following:
1. Submit online to payce@rewards.support;
2. By mailing a request to: P.O. Box 42104, Cincinnati, Ohio 45242
If you choose to contact directly by [email/phone/in writing], you will need to provide us with:
- Enough information to identify you [e.g., your full name, address and one other account detail]; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person's behalf.

HOW LONG IS INFORMATION RETAINED

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

LINKS TO OTHER WEBSITES

The Services may feature links to third party websites that offer goods, services or information. When you click on one of these links, you will leave our website or mobile application and will no longer be subject to this policy. We are not responsible for the information collection practices of the other websites that you visit and urge you to review their privacy policies before you provide them with any personally identifiable information. Third party sites may collect and use information about you in a way that is different from this policy.

CHILDREN UNDER THE AGE OF 13

The Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the website or mobile application. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through the Services, make any purchases through the Services, use any of the interactive or public comment features of the Services, or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13, we will delete that information. Further, if you believe that a minor in your care has provided us with information, please contact us and we will remove that information.

CHANGES TO THIS POLICY

We may add to, delete from, or otherwise change the terms of this Privacy Policy from time to time by posting a notice of the change (or an amended Privacy Policy) on the website and the mobile application. If required by law, we will send you a notice of the change by a method that we select and that complies with applicable state and federal laws. Such methods could include email, postal mail and/or posting on this website. Your continued use of our website or any service following such notification will constitute evidence of your agreement to the revised Policy.

If you have any questions about our privacy policy or our data security practices, contact us using the contact us link in the Services.