TrialPay Privacy Notice

Effective: May 24, 2018

TrialPay is committed to protecting the privacy and security of your Personal Information. The information you share with us allows us to provide the best experience with our products and services. We have a dedicated Global Privacy Program that protects all the Personal Information we collect and helps ensure that Personal Information is handled properly worldwide. Please read below to learn how we collect, use and disclose Personal Information.

This Privacy Notice explains the privacy practices of TrialPay and those Affiliates1 whose websites, platforms or services link to it. Some of our platforms and services may have different privacy notices. Please read the posted website privacy notice on each site to understand how we use your Personal Information.

In some places, this Privacy Notice is supplemented with additional information that may be required by law. Please see below for links to additional information provided for certain countries such as for the European Economic Area (EEA).

Personal Information is any information that we can use to identify, locate or contact you. It also includes other information that may be associated with your Personal Information, such as demographic data. We may collect the following types of Personal Information:

We may collect information from you, or someone acting on your behalf, when you interact with the Services. For example, you provide information to us when you:

  • Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone number, email address or other addresses that allow us to send you messages.
  • Relationship Information that helps us do business with you, such as information about the financial institution or other entity that issued your payment card, shopping and payment preferences, services you use, and similar information that can help us understand you and offer you personalized content and offers. We may also enhance our files with demographic data about you or your household, such as census records that tell us about the average ages or incomes in a certain neighborhood.
  • Card Transaction Data about your purchases or other transactions using your payment cards, such as your payment card number, the location of the transaction, the time and date of the transaction, enhanced transaction information, and the amount of the transaction.
  • Information about your Interactions with us, such as data collected when you:
    • Use our products, services, websites or apps (including information collected using Cookies and Other Data Collection Technologies described below),
    • Communicate with us, such as if you contact our customer service centers (including recordings of calls for quality, and training purposes),
    • Participate in promotions or programs,
    • Opt-in or out of marketing or offers, and other activities.

We collect Personal Information from you and from other sources.

  • In many cases, we collect Personal Information directly from you. You may choose to share Personal Information with us when you register on our websites, participate in a promotion, or sign up to receive messages from us. We also collect Personal Information from you when you contact us, such as for customer service purposes, to report a lost or stolen card, or interact with us online.
  • We receive Personal Information (including Card Transaction Data) from our clients as well as from your payment card issuer, merchants, acquirers, payment processors, service providers, and other third parties. For example, we may collect Personal Information from third party digital wallets and online merchants when you make an online purchase.
  • We may collect information from publicly-available sources, such as social media sites, when permitted by the site’s terms of service. For example, if you communicate with us using Facebook or Twitter, we may receive additional information about your from your profile. We may also obtain information from third party data suppliers who help us enhance our records.
  • We collect information about your interactions with us when you visit our websites, engage with our online advertisements, or call us. For example, when you use our websites or mobile apps, we and our service providers may collect information by setting and accessing cookies and using similar tracking technologies on your computer or device, as described in the Cookies and Other Data Collection Technologies section below. We treat this information as Personal Information when it is associated with other data elements that allow us to identify, locate or contact you.

We may use your Personal Information to:

  • Enable your payment card transactions, including for related purposes, such as authentication, fraud prevention, and dispute resolution,
  • Operate our products and services (such as authorization, clearing, and settlement of transactions, payment processing, dispute resolution, and tokenization),
  • Provide you with the products, content or services you request from us or a third party, including for related purposes such as determining eligibility, sending service messages and for customer service and account management, including (for example) to provide you with our offers and other partner promotions when you enroll in those programs,
  • Provide you with additional information that may be of interest, such as news and announcements, financial planning information and financial literacy messages,
  • Where appropriate, provide you with marketing communications for products and services from us and our partners, including personalized offers and content based on your interactions with us and usage of our products,
  • Generate anonymized and aggregated datasets, which can be used for modeling, reporting, and analytics, such as to analyze payment, transaction or similar trends,
  • Administer surveys, support loyalty programs, sweepstakes, contests and other events such as to identify qualifying transactions and selecting winners,
  • Understand how you use our products, content and services, for analytics and product development purposes, developing new products and services and (where appropriate) to personalize offers that we make to you, and
  • Manage our everyday business needs, such as for our internal account management, client reporting, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance.

Please note that we may also use and disclose information about you that is not personally identifiable. For example, we may publish reports and provide products that contain non-personally identifiable statistical data, such as reports showing general payment card usage trends. These reports do not contain any Personal Information.

In some countries, Visa enhances Card Transaction Data and uses it to generate anonymized and aggregated consumer spending and marketing reports and other data products that enable companies to improve their marketing efforts. These solutions help companies identify consumers that they can target. For example, a marketing report may show that consumers in one ZIP code tend to spend more at auto parts stores than consumers in other ZIP codes. These products also help companies determine the effectiveness of their marketing campaigns.

Visa’s marketing solutions do not contain any Personal Information, but they do allow companies to enhance their own consumer files with intelligence to support targeted marketing.

If you do not want us to use your Card Transaction Data in Visa marketing solutions, click here to learn about how you can opt out.

We disclose your Personal Information as follows:

  • We may share your Personal Information with the financial institution (or other entity) that issued your payment card (or other payment mechanism) and with merchants, other financial institutions and third parties as needed to process transactions, for risk and fraud management, to provide services to such entities, and for similar purposes (such as investigating and resolving disputed charges) and to comply with applicable law.
  • We may share your Personal Information with our Affiliates, which may only use your Personal Information for the purposes listed herein.
  • We may share your Personal Information with our service providers, who are bound by law or contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.
  • We may share your Personal Information with merchants and other partners through our partnerships, co-branded or promotional programs or websites, but only to the extent you have a relationship with such partner or you authorize the sharing. For example, if you sign up to receive offers from retail or travel partners through us, we may share your Personal Information with those partners as needed to provide promotions and marketing communications, to validate referrals, measure success of such promotions, or operate the programs. We may share your Personal Information with other partners, but only if we have your consent.
  • We also disclose Personal Information where permitted by law, such as when needed to affect the sale or transfer of business assets, to enforce our rights, including our Terms of Use or Service, protect our property, or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the United States and other countries where we operate.

When you visit our website, use our mobile applications, or engage with our online ads or email communications, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Notice describes how we use that information when we associate it with your Personal Information.

Cookies

When you visit our websites, we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.  Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud.

In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage, this could affect the features, availability, and functionality of our websites.

Flash Cookies

We may use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation.

We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain content and product features.

Pixel Tags and Web Beacons

Pixel tags and web beacons are tiny graphic images and small blocks of code placed on website pages, ads, or in our emails that allow us to determine whether you have performed a specific action. When you access these pages, or when you open an email, the pixel tags and web beacons let us know you have accessed the web page or opened the email. These tools allow us to measure response to our communications and improve our web pages and promotions.

Server Logs and Other Technologies

We collect many different types of information from server logs and other technologies. For example, we collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to us and the website you visit after you leave our site. These tools help us better user experience and deliver our services.

Device Information

We may use device-related information to authenticate users. For example, we may use your IP address, browser information, or other data provided by your browser or device to identify the device being used to access the our service. We may also use these device-related techniques for associating you with different devices that you may use to access our content, including for fraud-protection purposes and to better target advertising.

We have relationships with third party advertising companies that place advertisements on and perform tracking and reporting functions for our website and other websites. Although we do not share any Personal Information with these third party advertising companies, they may place cookies on your computer when you visit our website or other websites so that they can display targeted advertisements to you. However, this Privacy Notice does not cover the collection methods or use of the information collected by these companies.

For more information about third party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org. To opt out of being targeted by many third party advertising companies by visiting www.networkadvertising.org/consumer/opt_out.asp

On some our websites, you may see an AdChoices icon, which may appear on certain targeted ads. You may click on this AdChoices icon to learn more information about the collection and use of your information or to opt-out of such collection in the future. Please note that the opt-out is linked to your browser, so if you use different browsers or different devices, you will need to opt-out on each one. Even if you opt-out, you may still receive ads that are not customized for you. To learn more about the Digital Advertising Alliance Consumer Choice tool, please visit http://optout.aboutads.info.

Additional information from the third party advertising companies that we work with:

  • Adobe Marketing Cloud: If you would like more information on how to remove yourself from the tracking and reporting functions performed for this website by Adobe Marketing Cloud, please visit the Opt-Out page at http://www.adobe.com/privacy/marketing-cloud.html.
  • Google: For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/.

Although our websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer our customers choices to manage their cookie preferences as described in the previous section. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/

Our websites may enable you to interact with us and others via social media platforms, such as Facebook, Twitter, Pinterest and Instagram. For example, some of our websites and applications allow you to sign in using social media platform credentials. We may also collect information from publicly-available sources, such as social media sites, as permitted by the site’s terms of service. Please read the social media platform’s privacy statement to understand your privacy and data sharing choices.

We may display interest-based ads to you when you are using platforms such as Facebook and Google when you engage with us as described herein. These platforms allow us to personalize the ads that we display to you. We do not share any of your Personal Information with these platforms for ad-targeting, although we may convert your email address into a unique number that can be matched by the platform with its user to allow delivery of the advertising.  Additionally, although we do not provide any Personal Information to these platforms, they may gain insights about individuals who respond to the ads we serve.

We offer mobile applications that in some cases allow you to access your account, interact with us online and receive other information via your smartphone. All Personal Information collected by us via our mobile applications that link to this Privacy Notice are handled in accordance with the terms of this Privacy Notice.

When you download our mobile applications, you may choose to allow us to obtain your precise location from your mobile device. We use this information to deliver personalized content to you and for analytics purposes. We may also offer automatic (or "push") notifications. We will provide push notifications only to those individuals who opt-in to receive such notifications from us. You do not have to provide location information to us or enable push notifications to use any of our mobile apps. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

We offer you different choices about how we communicate with you and use your information.

  • You can limit the information you provide to us. Participation in promotions and programs is voluntary.
  • You can limit the communications that we send to you. To opt-out of marketing emails, simply click the link labeled “unsubscribe” at the bottom of any marketing email we send you. To revoke permissions that you may have given to send text messages, text STOP in response to any message.
  • Please note that even if you opt-out of marketing emails, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you activity confirmations or fraud alerts.
  • You can opt-out of having your Card Transaction Data used by us to generate certain anonymized and aggregated marketing products. If you do not want us to use your Card Transaction Data to create these products, click here to learn about how you can opt-out.

In addition to these choices, we respect the rights you may have under any applicable privacy laws. If you have any questions about your choices or if you need any assistance with opting-out, please see the contact us section below.

If you have an online account with us, you can log into your account to access and update your Personal Information. You can also contact us to update the information you have provided to us. Additionally, we comply with all applicable laws regarding access and correction. If you need assistance accessing or updating your Personal Information, please see the contact us section below.

We are based in the United States and operate a global network with Affiliates and service providers located around the world. As a result, your Personal Information may be transferred to, stored at or processed in other countries, including the United States, Singapore, Australia, and United Kingdom, and other countries, which may not have equivalent privacy or data protection laws. However, regardless of where your Personal Information is transferred, we will protect it in accordance with this Privacy Notice and applicable law.

We use physical, technical, organizational, and administrative safeguards to help protect your Personal Information from unauthorized access or loss. For example, we use technology like encryption to protect sensitive Personal Information (such as your account number) during transmission. We will retain your Personal Information for as long as the information is needed for the purposes listed above and for any additional period that may be required or permitted by law.

This Privacy Notice only addresses the use and disclosure of information by us and our Affiliates. If you have signed up for services through your card issuer or another third party, or if you are interacting with us through a social media platform or other site, you should read the privacy notice given to you by that company or site owner. If you are participating in our offers or promotions, please also read the privacy notices provided by our partners. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

If you have applied for employment with us, the Personal Information submitted with your job application will be used only for recruitment and other customary human resources purposes including any required government reporting and recordkeeping obligations. For more information, please contact us using the information provided under the contact us section below.

Our websites and applications are not directed to children under 16 and we do not knowingly collect any Personal Information directly from children under 16. We have websites that enable parents and teachers to help children learn about managing money and credit. We encourage parents and teachers to spend time online with children and to monitor their online activities.

We may also receive Personal Information about children from their parents or guardians or from merchants, such as when children are authorized users of payment cards. If you believe that we are processing information pertaining to a child inappropriately, please contact us using the information provided under the contact us section below so that we may investigate and restrict the data.

From time to time, we may update this Privacy Notice to reflect new or different privacy practices. We will place a notice online when we make material changes to this the Privacy Notice. Additionally, if the changes will materially affect the way we use or disclose previously-collected Personal Information, we will notify you about the change.

If you have questions or comments about our privacy practices, or would like help exercising your rights in accordance with this Privacy Notice, please

  • Email us: privacy@visa.com
  • Mail us a letter:

    Visa Global Privacy Office
    900 Metro Center Blvd.
    Foster City, CA, 94404
    USA


Important Information for:

Argentina

The data owner shall have access right at no cost and at time intervals of at least six months, unless there is a legitimate interest according to article 14, section 3 of Law No. 25.326

The National Data Protection Department (Dirección Nacional de Protección de Datos Personales), Supervisor Agency under Law No. 25.326, has the authority receive claims related to personal data protection regulations violations.

You can contact the National Data Protection Department at:

Sarmiento 1118, 5º piso (C1041AAX)

Tel. 4383-8510/12/13/15

Australia

We are providing the following supplemental information for individuals whose personal information is collected or held by us or any of its Affiliates at a time when the collecting or holding entity has an 'Australian link' within the meaning of the Australian Privacy Law.

Where you are such an individual, you may make a complaint to us about a breach of the Australian Privacy Principles by using the contract details in Part 18 of the Visa Privacy Notice.  We will investigate your complaint and endeavour to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Australian Information Commissioner.

Canada

Consent

We collect, uses and discloses Personal Information for the purposes identified in the Privacy Notice, and for any additional purposes, as required by law, with notice to you and your express or implied consent.

Opting Out of Third Party Advertising

You may be able to take advantage of the tool developed by the Digital Advertising Alliance of Canada to opt out of third party advertising. Where available, this tool provides a list of parties that may target advertisements based on your online web-browsing activities and the ability to opt out of their use of your information for that purpose. To access the tool, visit https://youradchoices.ca/.

European Economic Area (EEA)

We are providing this supplemental privacy notice to give individuals in the European Economic Area (EEA) the additional information required by the EU General Data Protection Regulation. These provisions, together with the statements in the Privacy Notice above explain our practices with regard to EEA personal data.

Information about Us

TrialPay is an Affiliate of Visa, Inc. This information is being provided by us and our Affiliates:

Visa Inc.
900 Metro Center Boulevard
Foster City, CA 94404
USA

We are based in the United States. Our representative in the EEA is:

Visa Europe Limited
1 Sheldon Square
London, W2 6TT
Registration Number: Z8657396

You can contact the Visa Global Privacy Office by emailing privacy@visa.com or writing to us at:

Visa Global Privacy Office
900 Metro Center Boulevard
Foster City, CA 94404
USA

The Purposes and Legal Basis for Processing, including Legitimate Interests

Our Privacy Notice explains the reasons why we process your Personal Information (as defined in our Privacy Notice). We only process Personal Information when we have a legal basis for the processing, as follows:

  • To fulfill a contract with you, or as needed to fulfill a contract between you and a merchant or between you and the financial institution or other entity that issued your card, where we are providing payment services or acting as a data processor,
  • For closely-related purposes, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance,
  • With your consent (or provided you have not objected, or opted-out, as may be appropriate under applicable law), to provide you with marketing communications, or,
  • To comply with the laws that are applicable to us around the world

We may also process your Personal Information for the purposes of our own legitimate interests or for the legitimate interests of others, provided that processing does not and shall not outweigh your rights and freedoms. In particular, we will process your Personal Information as needed to:

  • Protect you, us or others from threats (such as security threats or fraud),
  • Enable or administer our business, such as for quality control, consolidated reporting, and customer service,
  • Manage corporate transactions, such as mergers or acquisitions, and
  • Understand and improve our business or customer relationships generally.

Automated Decision-Making and Profiling

We use profiling and analytics to understand how individuals use their payment cards and other products, for product development purposes and business intelligence purposes. These analytics help us understand and improve our products and better serve our clients and consumers. We also use analytics for security and anti-fraud purposes, such as to identify unauthorized use of payment cards.

We will not make automated-decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.

When You are Required to Provide Personal Information to Us

You are not required by law to provide any Personal Information to us. For example, you always decide whether to participate in our promotions or to use our services. You are required to provide certain Personal Information to enable us to enter into a contract with you so that you can use our products and services or participate in promotions. Our registration forms indicate which data elements are required for our contracts.

When we provide payment processing services or acts as a data processor, we receive your Personal Information from third parties as needed to provide services or operate the payment network.

Your Rights

You have choices about how we use your Personal Information. You always have the right to object to our marketing communications. You can also object to having your Personal Information used to create anonymized and aggregated marketing reports. Please click here to learn more about how to exercise these choices and other choices.

We also respects the rights of EEA residents to access, correct and request erasure or restriction of their Personal Information as required by law. Where we are a data controller, this means:

  • You generally have a right to know if we are storing your Personal Information. If we are, you have the right to request that we provide you with a copy of that Personal Information, or in some cases, provide the information to another data controller. If your information is incorrect or incomplete, you have the right to ask us to update it.
  • You have the right to object to our processing of your Personal Information. If we are processing your Personal Information based on your consent, you have the right to withdraw your consent at any time.
  • You may also ask us to delete or restrict your Personal Information.
    To exercise these rights, please contact us via email to privacy@visa.com or write to the Global Privacy Office at the address above and a member of our Privacy Team will assist you. Please understand that we may need to verify your identity before we can process your request.

If we are processing your Personal Information as a data processor, we will refer you to our client (such as to your payment card issuer) for assistance with these requests. We support our clients in responding to requests as required by law.

If you believe that we have processed your Personal Information in violation of applicable law, you may also file a complaint with our Data Protection Officer, who can be reached by contacting the Visa Global Privacy Office, or with a supervisory authority.

International Transfers

As noted in the Privacy Notice, your Personal Information may be transferred to, stored at or processed in the United States, Singapore, Australia and other countries that may not have equivalent privacy or data protection laws.

We generally use approved Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the European Economic Area or Switzerland, but we may also make transfers to recipients with approved Binding Corporate Rules or to recipients in the United States who have certified to the EU-US and/or Swiss-US Privacy Shield Framework.

Please contact us via email to privacy@visa.com if you would like more information about cross-border transfers or to obtain a copy of the Standard Contractual Clauses.

Data Retention

We will retain your Personal Information for as long as the information is needed for the purposes set forth above and for any additional period that may be required or permitted by law. The length of time your Personal Information is retained depends on the purpose(s) for which it was collected, how its used, and the requirements to comply with applicable laws. You may request that we delete your Personal Information by contacting us via email to privacy@visa.com or writing to the Global Privacy Office at the address above. If we do not have a legal basis for retaining your information, we will delete it as required by applicable law.

U.S. - Social Security Number Policy and Sensitive Personal Information Statement

We collect U.S. Social Security numbers and other sensitive Personal Information in the ordinary course of its business. We have implemented reasonable technical, physical and administrative safeguards to help protect sensitive personal information from unlawful use and unauthorized disclosure. All of our workers are required to follow these established safeguards, which include the following:

  • Access to sensitive personal information is limited to those workers and service providers who have a need to access the information to perform tasks for us. Sensitive Personal Information is only disclosed to third parties in accordance with our established privacy and security policy.
  • We will only disclose sensitive Personal Information (1) to those service providers, auditors, advisors and/or successors in interest who are legally or contractually obligated to protect them, or (2) as required or permitted by law.

If you have any questions, please contact us at privacy@visa.com.

U.S. - Your California Privacy Rights

California Civil Code Section 1798 allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of Personal Information with third parties for direct marketing purposes. We do not share any California consumer Personal Information with third parties for marketing purposes without consent.

California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us at privacy@visa.com or by writing to:

Visa Global Privacy Office
900 Metro Center Boulevard
Foster City, CA 94494
USA

Version 7.0 (May 24, 2018)