Privacy Policy

We know that having trust and confidence in the companies you do business with is important to you. We are dedicated to protecting your privacy and handling your information in a secure and confidential manner. This Privacy Policy explains how we use your non-public personal information and to whom it is disclosed. We reserve the right to change this privacy policy from time to time in a manner consistent with applicable privacy laws.

We believe that you have a right to know how we will utilize the personal information you provide to us. This Privacy Policy applies to our use and handling of the information of all of our current and former customers. If you are a former customer, we maintain the confidentiality of your information as if you were still a customer.

Use of Information

We request information from you for our own legitimate business purposes and not for the benefit of any non-affiliated party. Therefore, we will not release your information to non-affiliated parties except: (1) as necessary for us to provide the product or service you have requested of us; or (2) as permitted by law. We may also use the information we collect to help us provide the products and services you request and to develop new products and services that we think will interest you and your customers. In addition, we may use the information to provide reports to our customers concerning their activities on our system. We may keep a record of your communications

with us to help solve any issues you might be facing. We may use your email address to inform you about our services. We will ask for your consent before using information for a purpose other than those that are set out in this privacy policy. We will only disclose your Personal Information when you direct or give us permission, when we are required by law to do so, or when we suspect fraudulent or criminal activities. We also may disclose your Personal Information when otherwise permitted by applicable privacy laws such as, for example, when disclosure is needed to enforce our rights arising out of any agreement, transaction or relationship with you.

Confidentiality and Security

We will make our best effort to ensure that no unauthorized parties have access to any of your information. To keep your information strictly confidential, we protect it with physical and electronic safeguards, and we abide by applicable federal security standards. We regularly review our processes and keep abreast of new technology. We do not allow anyone to have access to information unless we authorize them to do so. They must sign an agreement not to use or disclose your information without authorization. In addition, we require all

outside firms and contractors we hire to help us with any part of our business, including servicing and data processing, and all companies with which we enter into joint marketing agreements, to maintain the confidentiality of your information in accordance with this Privacy Policy and to comply with all applicable laws. We may, however, report your information to government regulators and law enforcement agencies, as permitted or required by law in connection with a fraud investigation or in response to a subpoena or legal process.

Types of Information we Collect

We collect information from the following sources:
Orders you or your representatives transact on our systems
Orders we transact on our systems on behalf of you or your customers
Your historical order information maintained on our computer systems
We may also collect information about online activity on our websites, in order to make them more usable. We do not collect information in this manner that identifies you or your customers as an individual without your knowledge. We may collect device-specific information (such as your hardware model, operating system version, and unique device identifiers). We may associate your device identifiers with your account(s).

Sharing Information with Non-Affiliates

We do not share information with non-affiliated companies unless you have given us permission to do so or unless it is necessary to maintain or service your business. We may use certain non-affiliated companies to perform services on our behalf and at our direction to help us communicate with you, or to help us offer or provide you with products or services in connection with your business. In these circumstances, we have written agreements that require the parties with whom

we are sharing your personal information to keep it safe and confidential and to use it only for the purposes we specify. When entering into an agreement to provide services to any financial institution we contractually agree that customers’ personal information will not be sold. Nor will we share that information with any other party including our affiliates for purposes that are not related to providing services to you or your customers.

We Do Not Sell Your Information

We do not permit list-brokers, mail-order businesses, telemarketers, or other marketing companies to contact you or your customers to promote their products or services, and we do not sell, lend, or give out your information for this purpose.