Glacier Payments Inc. (“we” or “us or “our”) is committed to
protecting the privacy of our users. This Privacy Policy outlines what data we process, how we do that, how
it is used, how we safeguard it, and what your rights are. This Privacy Policy applies to the data we
obtain from you when you use the Site and when you use the products, services,
tools, and functionality offered or made available by us, whether online
(including the Site), in person, or when you otherwise interact with us (herein
collectively referred to as the “Services”). The “Site” shall mean all websites, devices, and applications that we
operate, the pages within each such websites, devices and applications, and
equivalent, mirror, replacement, substitute or backup such websites, devices
and applications, and pages that are associated with each such websites,
devices, and applications. By signing up for, accessing, or using our Services
or by accessing our Site, you accept this Privacy Policy and consent to our collection,
use, and disclosure of your Personal Data as described in this Privacy Policy.
This Privacy Policy only covers our data collection, maintenance, and
processing.
What information do we collect?
We collect two types of information from you, Personal Data
and Technical Data (as defined below). Although we do not normally use
Technical Data to identify individuals, sometimes individuals can be recognized
from it, either alone or when combined or linked with Personal Data. In such
situations, Technical Data can also be considered to be Personal Data under
applicable laws, and we will treat the combined data as Personal Data. We may
collect and process, for example, the following Personal Data: (i) name and
contact details; (ii) e-mail address; (iii) phone number; (iv) date of birth
(v) Social Security Number, (vi) invoicing and billing information; (vii)
business and financial data, including but not limited to credit histories,
credit scores, transaction history, and credit rates; and (viii) other Personal
Data that you provide to us. The specific kind of Personal Data collected will
depend on how you use the Services. Some of the Personal Data is received
directly from you during your use of the Site or at the point of registration
for the Services or otherwise at the beginning of and during your use of the
Services, and the rest is based on the data you provide to us that is
processed.
The Services use several web analytics services to compile
Technical Data and reports on visitor usage and to help us improve our Services
(“Technical Data”). Technical Data we gather in connection with the use of our
Services may include, for example, the following data: (a) your IP address; (b)
browser type and version; (c) preferred language; (d) geographic location using
IP address or the GPS, wireless, or Bluetooth technology on your device; (e)
operating system and computer platform; (f) the full Uniform Resource Locator
(URL) clickstream to, through, and from our Services, including date and time;
(g) products or services you viewed or searched for while using our Services;
(h) areas of our Services you have visited; and (i) historical data regarding
your use of our Services.
What do we use your information for?
There are several purposes for our collection, maintenance,
and processing of Personal Data. We collect, maintain, and process Personal
Data to perform our contractual obligations to you and to comply with any legal
obligations. Furthermore, we collect, maintain, and process Personal Data to
run, maintain, and develop our business. We also use or process Personal Data
and Technical Data for some or all of the following purposes:
Quality of Services:
We may process information regarding the use of the Services
to improve the quality of our Services (e.g. by analyzing any trends in the use
of our Services). When possible, we will do this using only aggregated,
non-personally identifiable data. Personal Data may also be used for research
and analysis purposes in order to improve our Services.
Provide Services:
We collect, maintain and process Personal Data in the first
place to be able to offer the Services to you and to run, maintain, and develop
our business, including providing Personal Data to affiliates and third party
providers necessary to provide the Services. In some cases, Personal Data may
be collected, maintained, and processed in order to carry out our contractual
obligations to you. Further, if you contact our customer service, we will use
the information that you provide for answering questions and solving possible
issues.
Communication:
We may collect, maintain and process Personal Data for the
purpose of contacting you regarding our Services and to inform you of changes
in our Services.
Functionality of Services:
Provided the following are done in full compliance with this
Privacy Policy, applicable laws, rules, and regulations, we may (a) process,
analyze, and manage data to provide the Services to you; and (b) use data to
analyze, develop, and improve the Services.
Share Information:
We may share information with third parties that is not
personally identifying, such as aggregated or anonymized data that does not
identify you or our third parties, in our discretion, where not prohibited by
law.
Compliance:
We may share Personal Data in response to a subpoena or
similar investigative demand, court order, requests for cooperation from a law
enforcement agency, self-regulatory body, or other governmental agency to
establish or exercise our legal rights, to defend against legal claims, or as
we reasonably believe is required by law. In such cases, we may raise or waive any legal objection or right
available to us.
Prevent Illegal Activities:
We may share Personal Data when we believe that disclosure
is appropriate in order to investigate, prevent, or take action regarding any
actual or suspected illegal activity or other wrongdoing, to protect and defend
the rights, property, or safety of our business, our users, our employees, or
others or to enforce any of our agreements or policies.
How do we protect your information?
We will take all reasonable and appropriate security
measures to protect the Personal Data we store and process from unauthorized
access or unauthorized alteration, disclosure or destruction. We maintain all
Personal Data collected through industry standard safe mechanisms. We use
administrative, organizational, technical, and physical safeguards to protect
the Personal Data we collect and process. Our security controls are designed to
maintain an appropriate level of data confidentiality, integrity, and availability.
If a security breach occurs despite our security measures that is likely to
have negative effects to your privacy, we will inform you and other affected
parties, as well as relevant authorities when required by applicable data
protection laws, about the breach as soon as reasonably possible. We use
appropriate security measures to keep your Personal Data safe; however, we
cannot guarantee that your Personal Data will always remain secure. We encourage you to disclose any suspected
security vulnerabilities or bugs to us at [email protected]. After
a transaction, your private information (credit cards, social security numbers,
financials, etc.) will be kept on file for more than 60 days in order to comply
with our banking partners’ requirements.
Do we use cookies?
Yes. Cookies are small files that a site or its service
provider transfers to your computers hard drive through your internet browser
(if you allow) that enables the sites or service providers systems to recognize
your browser and capture and remember certain information. We use cookies to understand and save your
preferences for future visits, keep track of advertisements and compile
aggregate data about site traffic and site interaction so that we can offer
better site experiences and tools in the future. Please note that some parts of our Services
may not function properly if use of cookies are refused. If you wish to op-out of cookies, you can use
Clym.io tool located at https://clym.io/blog/introducing-widget-layouts-for-website-compliance.
Further, our Services may not respond to Do-Not-Track requests or headers from
some or all browsers.
Do we disclose any information to outside parties?
We do not share Personal Data with third parties outside of
our organization other than in connection with the performance of the Services,
including, without limitation, with third party providers for the Services,
unless one of the following circumstances applies:
Consent:
We may share Personal Data with third parties outside of our
organization when we have your explicit consent to do so. You have the right to
withdraw this consent at all times.
Necessity:
To the extent that third parties need access to Personal
Data to perform the Services, we have taken appropriate contractual and
organizational measures to ensure that Personal Data is maintained and
processed exclusively for the purposes specified in this Privacy Policy and in
accordance with all applicable laws and regulations.
Service Providers:
We may share Personal Data to authorized service providers
who perform services for us (including data storage, sales, marketing and
customer support services). Our agreements with our service providers include
commitments that the service providers agree to limit their use of Personal
Data and to comply with privacy and security standards at least as stringent as
the terms of this Privacy Policy. Please bear in mind that if you provide
Personal Data directly to a third party, such as through a link on our website,
the processing is typically based on their policies and standards.
Legal:
We may share Personal Data with third parties outside of our
organization if we have a good-faith belief that access to and use of the
Personal Data is reasonably necessary to: (i) meet any applicable law,
regulation, and/or court order; (ii) detect, prevent, or otherwise address
fraud, security or technical issues; and/or (iii) protect the interests,
properties or safety of our customers or the public in accordance with the law.
When possible, we will you about such transfer and processing.
Any Other Legitimate Reason:
If we are involved in a merger, acquisition or asset sale,
we may transfer Personal Data to the third party involved; however, we will
continue to ensure the confidentiality of all Personal Data. We will give
notice to you when your Personal Data is transferred or becomes subject to a
different privacy policy as soon as reasonably possible.
What are your rights concerning your Personal Data?
We will handle your requests and rights in accordance with
applicable law. This means there may be
legal reasons why we cannot fulfill all requests. We may need to request specific information
from you to help confirm your identify and ensure your right to access your
Personal Data (or to exercise any of your other rights). This is a security measure to ensure that
your Personal Data is not disclosed to any person who has no right to receive
it. We may also contact you to ask you
for further information in relation to your request to speed up our response
time.
Withdraw Consent:
In case the collection, maintenance, or processing of
Personal Data is based on your consent, you may withdraw your consent at any
time. Withdrawing your consent may lead to fewer possibilities to use the
Services or the complete termination of our Services.
Correction:
You have the right to have incorrect, imprecise, incomplete,
outdated, or unnecessary Personal Data we have stored about you corrected or
completed.
Objection:
You may object to certain use of Personal Data if such
information is collected, maintained, or processed for other purposes than
purposes necessary for the performance of our Services to you or for compliance
with a legal obligation. You may also object to any further collection,
maintenance, or processing of Personal Data after previously giving consent. If
you object to the further collection, maintenance, or processing of Personal
Data, this may lead to fewer possibilities to use the Services or the complete
termination of our Services.
Access:
We offer you access to your Personal Data that we maintained
or processed. This means that you may contact us, and we will inform you what
Personal Data we maintain and the purposes such Personal Data is used for.
Portability:
You have the right to receive your Personal Data from us in
a structured and commonly used format and to independently transmit that
information to a third party.
Deletion:
You may also ask us to delete your Personal Data from our
systems. We will comply with such request, unless we have a legitimate ground
to not delete the information. We may not immediately be able to delete all
residual copies from our servers and backup systems after the active Personal
Data has been deleted. Such copies shall be deleted as soon as reasonably
possible.
Restriction:
You may request us to restrict certain maintenance or
processing of Personal Data, but this may however lead to fewer possibilities
to use our Services or the complete termination of our Services.
The above-mentioned rights may be used by sending a letter
or an e-mail to us at the addresses set out below, including the following
information: the full name, company name (if applicable), address, e-mail
address, and a phone number. We may request the provision of additional
information necessary to confirm your identity. We may reject requests that are
unreasonably repetitive, excessive, or manifestly unfounded. If you consider
our collection, maintenance, or processing of Personal Data to be inconsistent
with the applicable data protection laws, you may lodge a complaint with the
local supervisory authority for data protection.
California Online Privacy Protection Act Compliance
We are required by the California Consumer Privacy Act of
2018 (“CCPS”) to provide this CCPS Notice to California residents to explain
how we collect, use, and share their Personal Data, and the rights and choices
we offer California residents regarding our handling of their Personal Data. This CCPA Notice applies only to California
residents whose interactions with us are limited to:
1. Visiting
our Site;
2. Signing
up for email alerts;
3. Commenting
on or contributing to our blogs;
4. Establishing
an account that does not include financial products or services; or
5. Applying
for our job openings on our websites (however, note that the CCPA limits some
of the privacy rights for job applicants).
This CCPA Notice does not apply to the Personal Data we
collect, use, or disclose about consumers who initiate or complete the process
of applying for financial products or services. This is because this information is subject is subject to the federal
Gramm-Leach-Billey Act (“GLBA”) and implementing regulations of the California
Financial Information Privacy Act (“FIPA”), or representatives of businesses
that seek to obtain our products or services, or to provide products or
services to us. We do not sell personal
information. As explained in this
Privacy Policy, we use cookies and other tracking technologies to analyze
website traffic and facilitate advertising.
The below provides California residents the right to know
the categories of Personal Data collected and whether we disclosed your
Personal Data for business purposes in the proceeding twelve (12) months:
Privacy Practices:
We do not sell Personal Data. As explained in our Privacy Policy, we use
cookies and other tracking technologies to analyze website traffic and
facilitate advertising. Please note that
we may also disclose Personal Data as described in this Privacy Policy.
Privacy Rights:
The CCPA grants individuals the following rights:
1. Information
and Access. You can request information
about how we have collected, used, and shared your Personal Data during the
past 12 months. You can also request a copy of the Personal Data that we
maintain about you.
2. Deletion. You can ask us to delete the Personal Data
that we collected or maintained about you. Please note that the CCPA limits these rights by, for example,
prohibiting us from providing certain sensitive information in response to an
access request and limiting the circumstances in which we must comply with a
deletion request. We will respond to
requests for information and access only to the extent we are able to associate
with a reasonable effort the information we maintain with the identifying details
you provide in your request. If we deny
your request, we will communicate our decision to you. You are entitled to exercise the rights
described above free from discrimination. To request access to or deletion of Personal Data please contact us at
[email protected].
3. Opt-Out. You may request us to stop sharing your
Personal Data (“op-out”, including via a user-enabled global privacy
control). We cannot share your Personal
Data after we receive your opt-out request unless you later authorize us to do
so again.
4. Non-discrimination. We cannot deny you the Services, charge you a
different price, or provide a different level or quality of the Services just
because you exercised your rights under the CCPA. However, if you refuse to provide your
Personal Data to us or ask us to delete or stop sharing your Personal Data, and
that Personal Data or the sharing of the Personal Data is necessary for us to
provide you with the Services, we may not be able to complete that portion of
the Services or the Services in its entirety.
5. Correction. You have the right to ask us to correct any
inaccurate information that we may have about you.
6. Limit. You can direct us to only use your sensitive
Personal Data (i.e. your social security number, financial account information,
your precise geolocation data, or your genetic data) for limited purposes, such
as providing you with the Services.
7. Identity
verification. The CCPA requires us to
verify the identity of the individual submitting a request to access or delete
Personal Data before providing a substantive response to the request. We will ask you to verify your identity when
you submit a request.
8. Authorized
Agents. California residents can empower
an “authorized agent” to submit a request on their behalf. We will require the authorized agent to have
a written authorization confirming that authority.
Viriginia, Colorado, Connecticut, and Utah
In addition to your rights set forth in this Privacy Policy,
residents of Virginia, Colorado, Connecticut, and Utah have the right to
opt-out of the sharing of Personal Data. Residents of Virginia, Colorado and Connecticut also have the right to
appeal any decision made by us concerning the use of your Personal Data.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA
(Children’s Online Privacy Protection Act), we do not collect any information
from anyone under 13 years of age. Our website, products and services are all
directed to people who are at least 13 years old or older. If we learn we have
collected such information, we will delete such information. To notify us that we might have any
information from or about a person under the age of 18, please contact us at [email protected].
Changes to our Privacy Policy
We reserve the right to modify or amend this Privacy Policy
at any time and for any reason. If we make any changes, we will notify you by
posting it on our Site. We encourage you to frequently check this page for any
changes to stay informed about how we are helping to protect the information we
collect. By using our Services, you
acknowledge and agree that it is your responsibility to review this Privacy
Policy periodically and become aware of any modifications. If there are material changes to this Privacy
Policy, we will notify you more directly by email or means of a notice on the
home page prior to the change becoming effective. We encourage you to review
our Privacy Policy periodically to stay informed about our information
practices and the ways you can help protect your privacy. Your continued access
or use of our website and Services following a change means you consent to the
collection, maintenance, use and disclosure of your Personal Data as set out in
this Privacy Policy.
Contacting Us
If there are any questions regarding this Privacy Policy,
you may contact us at [email protected]
