Privacy Policy | Insurity Payments LLC

This Privacy Policy discloses the privacy practices for Insurity Payments LLC, ("IPL"), a subsidiary of Insurity LLC ("Insurity"). This Privacy Policy applies to Personal Data collected through the IPL website and through other IPL online and offline channels in connection with our payments and money transmission services, including customer portals, merchant and partner onboarding, mobile applications, customer support interactions (email/phone/chat), events and webforms, APIs and SDKs, and other operational systems used to provide our services. Where we provide services as a money transmitter or payment processor, this Privacy Policy also covers Personal Data we receive from or process on behalf of our customers and their end users in order to operate those services.

This Privacy Policy explains:

What Personal Data is collected from you through the website, how it is used, and with whom it may be shared.
What choices are available to you regarding the use of your data.
The security procedures in place to protect the misuse of your information.
How you can correct any inaccuracies in the information.
Insurity's participation in the Data Privacy Framework.

"Personal Data," as used in this Privacy Policy, is information that allows a person to directly identify an individual, such as but not limited to name or email address, including information that we combine directly with such identifying information.

Notice: Information Collection, Use, and Sharing

IPL is the sole owner of the Personal Data collected on the IPL website. However, we may offer the opportunity to interact with certain third party sites or services ("Third Party Services"). Those Third Party Services may also collect certain Personal Data from you. Some of the Personal Data collected on such Third Party Services will be owned by the Third Party Services. You should consult the privacy policies of whatever Third Party Services you sign up for to understand how and whether they protect your Personal Data and what choices you may have regarding the information they collect.

IPL, for itself, collects Personal Data from you on forms or email that you voluntarily submit to us and also collects Personal Data based on your usage of the IPL website. This information is collected in order to enable us to better identify and serve our community of users and to respond better to their needs.

This Privacy Policy applies to Personal Data collected through the IPL website and through other IPL online and offline channels in connection with our payments and money transmission services, including customer portals, merchant and partner onboarding, mobile applications, customer support interactions (email/phone/chat), events and webforms, APIs and SDKs, and other operational systems used to provide our services. Where we provide services as a money transmitter or payment processor, this Privacy Policy also covers Personal Data we receive from or process on behalf of our customers and their end users in order to operate those services.

In addition, IPL also collects and stores certain information in order to answer your email and to measure your interest in the various sections of the IPL website. We will not sell or rent this information to anyone.

IPL also permits you to post information or upload content to the website or to a Third Party site. We will use information that you provide to us to respond to you, regarding the reason you contacted us, and to provide you with information about IPL, our events, materials and our other activities. We will not intentionally share your information with any unaffiliated third party outside of our organization, other than as necessary to fulfill your request, e.g. to respond to your emails or questions or to provide services to you. Generally, these third parties are required not to use your information other than to provide the services requested by IPL.

We may share your information with affiliated companies and our third party service providers in order to provide better service to you. We may also receive information from or about you from other sources like address, phone numbers or facsimile number. We may add this information to the information we have already collected from you via our website in order to serve you better.

We may passively collect information regarding your use of the IPL website by automated methods. The information that we collect with these automated methods may include, for example, your IP address, cookie information, browser type, system type, the content and pages that you access on our website, and the "referring URL" (i.e., the page from which you navigated to the our website). We use this information statistically to serve you and our other visitors better.

Our site does serve cookies. A cookie is a small file that is created to help visitors navigate about the site, and for use to track the traffic to and on our site. You may refuse the cookies but some functions may not work as well or at all. We or our third party service providers may also use other methods, including clear GIFs (also known as "web beacons") to determine which pages you visit. We also may include clear GIFs or other discreet tokens in some of our email messages in order to learn whether the messages are delivered and opened.

While IPL websites at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser. Look under the heading "Tools" (or similar heading) in your particular browser for information about controlling cookies. In most instances you can set your browser to notify you before you receive a cookie, giving you the option to decide whether to accept it or not. You can also generally set your browser to turn off cookies. Since cookies allow you to take advantage of some of our websites' features or features of our software products, we recommend that you leave them turned on. If you block, turn off or otherwise reject our cookies, some web pages may not display properly or you may not be able to use any website that require you to sign in.

Certain third party Third Party Services may also collect similar data. Please consult their privacy policies regarding their use of your information. Certain of these services collect data from you as part of the registration process, through your volunteering information when you interact with their services and by combining data with other information you have provided to such services at other times. These sites have privacy policies which are in addition to this Privacy Policy.

Certain of these Third Party Services permit you to adjust your user settings to permit certain choices by you about your Personal Data. These choices may be limited by the third party provider and the third party provider will typically not guarantee that once your information has been disclosed to them or posted to their website it can be removed from all locations where it may be stored. You should consult the respective privacy policies of these, advertising servers or advertising networks and Third Party Services. This Privacy Policy does not apply to such other advertisers or websites or Third Party Services.

If our organization or our assets are acquired by another organization, that organization will possess the information collected by us and we will endeavor to have it assume the rights and obligations regarding your information as described in this Privacy Policy.

We may disclose your information if we believe in good faith that such disclosure is necessary to:

comply with relevant laws or to respond to subpoenas or warrants served on us;
protect and defend the rights or property of IPL or users of our website;
take precautions against liability;
protect the rights, property, or safety, any individual, or the general public;
maintain and protect the security and integrity of our services or infrastructure;
protect ourselves and our services from fraudulent, abusive, or unlawful uses;
investigate and defend ourselves against third-party claims or allegations; or
assist government enforcement agencies.

Unless you ask us not to, we may contact you via email in the future to tell you about upcoming events, opportunities we think may interest you, new activities or changes to this website.

Your Access to and Control Over Information

You may opt out of any future marketing contacts from us by e-mail at any time by following the "opt out" or "SafeUnsubscribe" link at the bottom of our marketing emails to you.

Withdrawing Your Consent to Us Using Your Information

You may withdraw any consent you previously provided to us for the processing of your Personal Data by contacting us at support@insuritypayments.com or at the address provided at the bottom of this notice. As required by applicable law, we will apply your preferences going forward, within a reasonable amount of time. Even where you withdraw your consent, we may still process your Personal Data for limited purposes, for example, to give effect to your request or to safeguard our business. In some circumstances, withdrawing your consent to our use or disclosure of your Personal Data will mean that you cannot use some of our products or services.

Security

We have secured Personal Data only to the extent of the security systems provided by our third party hosting service. We have required that our third party hosting service use reasonable security measures to protect against the loss, misuse, and alteration of Personal Data. We take certain precautions to protect the information of registered users. Wherever we collect information that we deem is sensitive (such as account information), we enforce transmission layer security (TLS) to transmit that data from a user's computer to the servers of our third party hosting service providers' servers.

Although we make good faith efforts to maintain the security of such Personal Data, we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent unauthorized persons from illegally accessing or obtaining this information. We do not assume any liability to third parties for your use of our website or for information about others you include in your profile or contacts.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the IPL website or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our website. If a security systems breach occurs, IPL may post a notice on our homepage or elsewhere on our website and may send email to you at the email address you have provided to us.

Where We Store Your Information

We are a global organization and so the Personal Data that we process may be transferred to, and stored at, a destination other than the country in which the information was collected or provided (Personal Data is frequently transferred to the United States because that is where we are headquartered). Where we transfer your personal information outside the European Economic Area, we will ensure that your Personal Data is protected by appropriate safeguards as required by applicable data protection laws. These safeguards may include, in particular, the European Union General Data Protection Regulation (GDPR).

Your Personal Data may also be processed by our staff at any of our locations around the world or by the staff of our suppliers at any of their locations around the world. Such staff may be engaged in, among other things, the fulfillment of your request or the provision of support services. Your Personal Data may be stored on our servers or those of our third party service providers.

Your Choices

You may, at any time, update, correct, or delete certain categories of Personal Information that you have provided to the IPL website by notifying us in writing at support@insuritypayments.com. Your Personal Data may be retained in our backup files and archives for a reasonable period of time for legal purpose.

Registration

When you wish to receive information, download publications, enroll for a live or virtual event or request a trial, we may ask you to provide your name and business contact information, as well as other information in connection with your request. We use this information in connection with your request and to communicate with you. This information may, in most cases, also identify you when you visit our websites.

This information may, in most cases, also identify you when you visit our websites, use our mobile applications, interact with our APIs/SDKs, or complete merchant/partner onboarding. We may also ask you to register an ID, in which case you need to provide us with your name, email address, country location and other information if needed for the purpose for which you are asked to register. The ID serves to uniquely identify you when you visit our websites, have a request or use a product or service.

Registration with ID may allow you to customize and control your privacy settings. Certain products and services may require unique registration specifically for the purpose of providing these products or services. In such cases, registration details provided by you for a product or service will only be used for the specific purpose of providing you with that product or service.

Links to Other Sites

Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these other websites. Any Personal Data you provide on third-party sites or services is provided directly to that third party and is subject to that third party's policies governing privacy and security.

Retention

IPL will retain your Personal Data for as long as is required to fulfill the purposes for which the information is processed or for other valid reasons to retain your Personal Data (for example to comply with our legal obligations, resolve disputes, or enforce our agreements).

Your registration information will be retained for as long as your account or ID is active or as needed to provide you services. If you wish to request that we no longer use your registration information to provide you services, contact us at support@insuritypayments.com.

Lawful Basis for Processing

We rely on the following legal bases, under data protection laws, to process your Personal Data.

because the processing is necessary to perform a contract with you or take steps prior to entering into a contract with you;
where you have expressly consented to the use of your personal information, because we have obtained your consent (for example, if you consent to our sharing your personal information with a third party for marketing purposes);
because it is in our legitimate interests as a provider of an application to maintain, improve and promote our products and services;
when we have a legal obligation to process your personal information, including in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Conditions of Use and Revisions

If you choose to visit IPL's website, your visit and any dispute over privacy is subject to this Privacy Policy, as governed by the laws of the State of Connecticut, as applied to agreements entered into and to be performed entirely within Connecticut between Connecticut residents. The exclusive forum for any disputes arising out of or relating to this Agreement shall be the appropriate federal or state courts in Hartford County, State of Connecticut, USA.

Data Privacy Framework

Insurity complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce, and as subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Insurity has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

Insurity has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard to the processing of Personal Data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the Data Privacy Framework website. Pursuant to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Insurity maintains liability in cases of onward transfers of Personal Data to third parties.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Insurity commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Insurity at support@insuritypayments.com.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Insurity commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States.

If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

You may have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Insurity's DPF compliance not resolved by any of the above mechanisms. Please see the following link for more information: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

Insurity's DPF-compliant HR privacy policy can be found in its employee handbook, as applicable and accessible to Insurity LLC and IPL employees only.

Changes and Updates to This Privacy Policy

We may update this Privacy Policy without prior notice and will update the "effective date" at the bottom of the Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about our collection, use, and disclosure of Personal Data. Your continued use of the IPL website constitutes your agreement to this Privacy Policy and any updates.

Annual Review. IPL's Chief Information Security Officer (CISO), Chief Compliance Officer or another senior officer will review this Privacy Policy at least annually and update it as needed to reflect IPL's current data practices and applicable legal requirements (including those under New York's cybersecurity regulations for financial services).

Contacting Us

If you have questions about this Privacy Policy, please contact us at privacy@insurity.com.

You may also write to us at:

Insurity Payments LLC120 Huyshope AvenueHartford, CT 06106

For general inquiries, we can also be reached via e-mail at support@insuritypayments.com.