SurePay Finance, LLC is committed to protect your privacy and security of information we have concerning our clients and merchants. In order to make this Privacy Policy accessible, it is available on our website and wherever personally identifiable information (PII) may be requested. If you do not agree with the terms and conditions of our Privacy Policy in its entirety, you are not authorized to use or access the website or apply for any product/service available on the website. Please read this Policy carefully. Your continued use of our sites means that you understand and consent to the terms of this Policy.
WHAT IS COLLECTED
This policy is applicable to any information submitted or collected from you, including PII that you provide via forms, applications, surveys, and other online fields. This information can include:
- Name
- Street address
- Contact information
- Phone number
- Date of birth
- Driver license number
- Financial account details including bank account information and account balances
- Social Security Number (SSN)
- Employer Identification Number (EIN)
- Personal reference information
- Payment history
- Employment information
- Income information
- Information from identification documentation, such as your driver’s license or passport
In addition to the personal information that we may collect from you, we may also automatically gather and store non-personal information about your visit including the IP address from which you access our sites; browser information; computer operating system information; the date and time you access our sites; the pages, files, and links you visit; and the web address from which you linked to our sites.
We may collect this information from the devices and networks that you use to visit our sites in order to help improve the services we provide. We may use this information to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use or for other business purposes.
SurePay uses cookies and other tracking technology to monitor website performance. These other tracking technologies may include some combination of web beacons, clear GIFs, or pixel tags. Cookies and other tracking technology allow us to collect information, such as your browser type, the time you spend on our sites, the pages you visited, your language preferences, and other anonymous visit data. We may use this information to improve the quality of our sites.
SurePay may also contract with third-party companies that use cookies, web beacons, clear GIFs, pixel tags, and other tracking technology for our sites’ analytics and to advertise our products and services on unaffiliated websites and mobile apps. With our approval, these companies will have access to your information as needed to perform their functions, but they cannot use your information for any other purpose. These companies will not have access to information that can personally identify you.
Most web browsers are initially set up to accept cookies. Many web browsers also allow you to refuse cookies, but doing so may degrade your experience on our sites.
USE OF INFORMATION
Subject to applicable state and federal law, we may use your personal, demographic and profile information for marketing and promotional purposes, for editorial or feedback purposes, for statistical analysis and/or to assist us in improving our website. Collected information may be added to our databases to use in emails or postal mailings concerning upcoming events, new services and products, site updates and/or the status of online orders.
Should you decide to provide PII (including sensitive information), your information will be used in considering you for a SurePay account; will be shared with trusted third parties such as Affiliated Loan Providers, credit bureaus, and/or other financial service providers in accordance with applicable law; and PII (excluding sensitive information) will be used to market products and services that may be of interest to you. Information we collect may be added to our databases and used for future SMS text-messaging, telemarketing, emails and/or postal mailings concerning services, new products, updates, upcoming events, and/or the status of online orders and/or online credit.
SurePay reserves the right to release current or past customer information: (i) in the event that we believe the website is being used or has been used in violation of the Terms of Website Use and/or to commit unlawful acts; (ii) if we are sold, acquired or where we deem it necessary or appropriate; and (iii) when requested by governmental or quasi-governmental authorities conducting an investigation, hearing or the like and/or if the information is subpoenaed. By agreeing to this Privacy Policy, you hereby consent to the disclosure of any record or communication to any third party when SurePay in its sole discretion, determines the disclosure to be appropriate including, without limitation, sharing your email address with other third parties for suppression purposes in compliance with the requirements of the CAN-SPAM Act of 2003, as amended.
By submitting your information on the website, you agree to receive mobile marketing from us and our third party advertisers and marketers. This includes, but is not limited to text-message based marketing. In the event that your mobile telephone number is listed on state and/or federal do-not-call registries, we retain the right and you consent to allow us to contact you via text-message based marketing. Furthermore, registration and/or using the website, constitutes your acknowledgement that such registration constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”). Even in the event that your telephone number is listed on the Federal Trade Commission’s Do-Not-Call List, we retain the right and you consent to allow us to contact you via telemarketing in accordance with the Rule.
We may also employ other companies and/or individuals to carry out certain functions on our behalf, such as analyzing data, collecting unpaid account balances, sending electronic and direct mail, providing marketing analysis and removing duplicate information from customer lists. In order to perform their various functions for SurePay, these agents have access to our users’ personal information as necessary.
Through your use of this website and agreement with this Privacy Policy, you authorize us to use your sensitive information, such as your Social Security Number, to obtain other information about you from third-parties where such information was incompletely or improperly filled out on our registration form. Such third-parties include, but are not limited to, consumer credit bureaus, consumer reporting agencies and other outside parties as permitted or required by applicable laws. In order to determine you eligibility for credit, any and all information that we collect from you as part of your credit application, and from such third-parties, may be used.
Should you choose to provide sensitive information, such as your Social Security Number, your information may be used to determine your financial status. If such information is not provided, other information you provided for the purpose of verifying your eligibility for credit or for any other programs, offers or services, may be used. Once you qualify for credit, any specific financial information relating to the credit contract will be stored and utilized by your applicable lender pursuant to the terms of that lender’s Privacy Policy.
The information we collect is used to increase your service and experience on our sites. We may use your information for everyday business purposes including: to process your requests, transactions, applications, and inquiries; to verify your identity; to allow access to your online accounts; to recognize you when you return to our sites; to prevent fraud and increase security of our online services; and to comply with applicable legal requirements.
We reserve the right to contact you regarding changes to this Policy or any other policies or agreements relevant to your use of our sites.
COLLECTION AND USE OF BANK ACCOUNT INFORMATION
As part of our information collection process, we may detect additional bank accounts under the ownership of the consumer. We will consider these additional accounts to be part of the application process. By applying, you authorize us to search for and evaluate bank accounts under your ownership for this purpose.
HOW WE COLLECT INFORMATION
SurePay may utilize cookies in order to route, customize and track website users and behavior in order to determine appropriate marketing offers to target toward users. Certain areas of our website may only be accessed in conjunction with cookies and if you choose to disable cookies, this may prevent you from accessing that content.
SurePay may track information related to the email and web pages viewed by users, as well as the hyperlinks clicked by users while viewing our emails and the pages on our Website.
Log files may be used to track and monitor user activity on the website.
DATA SECURITY
SurePay uses security measures consistent with industry standards to protect your information collected through our sites. These measures include technical, procedural, monitoring, and tracking safeguards to protect your information from misuse, unauthorized access or disclosure, loss, alteration, or destruction. All collected information is stored in a secured environment. When we store and transmit sensitive information, that information is encrypted and is protected with SSL encryption software. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure, as a result, we cannot ensure or warrant the security of any information that you transmit to us, and you do so at your own risk.
Once we receive the transmission of your PII, we make all reasonable and customary efforts to ensure its security on our systems. Access to this information is strictly limited, and not accessible to the public. Certain employees are granted access to PII on an “as-required” basis. Employees not adhering to our policies are subject to disciplinary action. In compliance with applicable federal and state law, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your PII. You will be notified via email in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
OPT OUT
We use personal information to provide promotional offers sent via email to individuals. We may maintain separate email lists for different purposes. If you wish to end your email subscription from a particular list, follow the instructions which are given at the end of each email message to unsubscribe from the particular list. If you choose to not receive emails from us anymore, please send your request in writing via email to support@surepayfinance.com.
It is important to note that if you subsequently sign up at one of our other websites for other product or service offerings, you will need to again address any information sharing preferences that you had previously established through this website.
CHILDREN’S PRIVACY
SurePay does not knowingly contact or collect personal information from children under 13 years. SurePay’s sites are not designed or directed to solicit information of any kind from children under 13 years.
CHANGES TO THE PRIVACY POLICY
We reserve the right to change or update this Privacy Policy at any time by posting a clear and conspicuous notice on the website explaining that we have updated our Privacy Policy. If the manner in which we use PII changes, we will notify you by posting the changes on the website and sending you an email notification advising you of the changes, and providing you with the opportunity to opt-out of the provisions relating to the transfer of your PII. Other than where you opt-out, continued use of the website and/or acceptance of the email communications following notification of changes to this Privacy Policy will constitute your acceptance of any and all changes.
NOTICES
In the event that we need to contact you or send you a notification for any reason, we may notify you by means of a general notice on this site, electronic mail to your e-mail address on our records, or by written communication sent by first class mail to your address on our records.