Last modified: 2/22/2021

Introduction

This Privacy Policy ("Policy") explains how ConnectPayUSA, LLC [and our subsidiaries and affiliates] (collectively, "ConnectPay," "we" or "us") collect, use and share information about you when you access or use our website (including the mobile version of our site and related apps) (the “Website”) or other online services (collectively "Services"), We may supply different or additional notices of our information practices specific to certain programs or activities, in which case this Policy will not apply. For purposes of this Policy, personal information and similar terms are defined under applicable privacy laws.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@connectpayusa.com.

Information We Collect About You and How We Collect It

Information Collected Directly from You.

We collect personal information and other data from you when you submit it to us or a third party acting on our behalf. The information collected directly from you depends upon how you use the Services. For example:

• Registration Information: When you create an account, we collect your e-mail address, username and password. If you provide it to us, we may also collect additional information from you (both personal and employment information), including your name, birthday, physical address, zip code/post code, phone number, gender, user image, social security number, financial, bank account, geolocation data, employee identification numbers, other tax, medical and beneficiary information, to provide the Services.
• Purchase Information: If you make a purchase on our Website, we will collect the order-related information, including billing and shipping addresses. We will also ask that you provide your payment information (credit card, debit card, or other payment method) at the point of purchase, but we do not directly collect that information. Instead, that information is passed on to our payment processors, or if you use any third party payment services, directly to them. Purchase Information may also be used in returns.
• Marketing,, Newsletter, and Notifications Information: If you join our marketing and/or newsletter e-mail list, we will collect your e-mail address, and when we send related e-mails to you, we (or our vendors working on our behalf) will collect information such as your reaction to our marketing or newsletter, whether you open or share our e-mails, how long you engage with them, and whether you click the links in the e-mails. If you download our mobile application, you may collect your cell phone number and related contact information if you elect to receive notifications or text message updates. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
• ConnectPay Interaction Information: When you contact our customer service agents by e-mail, chat, phone, Social Media or via contact forms we provide for that purpose, we will collect (and you expressly consent to our doing so) any personal details and other content that you provide to us, which may include, without limitation, your name, e-mail address, postal address, IP address, geolocation data, and if you contact us via Social Media, your social media handle, your profile photo and any other publicly available information. We may maintain copies of your customer service correspondences. If you request us to perform additional services on your behalf we may collect and maintain your personal information for those purposes as well. We my collect your search queries on the Website. We may collect your information in responses to surveys. If you report any issues regarding the Website we may also collect information from you.
• Promotions: If you participate in a Prize Promotion, we may collect and process your name, social media handle, address, e-mail address, phone number, image, photograph, voice, statements, and/or other information, such as the prize you have won.
• Information About Others: You may provide us with information about your beneficiaries. Subscribers (used herein to refer to any person or entity that has entered into a paid contract for services with ConnectPay, for example the Subscriber is often an employer) using this service may, directly and/or through third parties at the Subscribers’ direction, provide us with information about you, including Registration Information (other than your account log in information). Subscribers may also provide us with information regarding your employment history or creditworthiness.

Information From Other Sources.

As detailed in the “Information About Others” section above, we may receive information pertaining to you from the Subscribers and/or third parties acting on their behalf. We may also receive information from third parties pertaining to your employment history or creditworthiness. We may collect information from governmental entities, including Federal, State, and local tax authorities for tax purposes. We may also receive information about you from governmental/law enforcment entities, financial institutions and others through our Anti-Money Laundering and Know Your Client compliance obligations, including but not limited to ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions

We may collect additional information from Third Party data suppliers who enhance our files and help us better understand our contacts and potential customers. We also receive other analytics and metrics information provided by our partners for advertising regarding your browsing behaviors.

We may combine information we receive from other sources with information we have collected directly from you.

Information Automatically Collected When You Use our Services.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your device and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking) and across devices.

The information we collect automatically is only statistical data and does not include personal information, [but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies.
• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit ConnectPay, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may use other similar technologies as well.

Third-party Automated Collection

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services, and across different devices. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We and our service providers use anonymous identifiers such as cookies and other technologies to collect and store certain types of information (e.g. click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) whenever you interact with us or third-parties that use our services.

We also allow third-party companies (e.g., Google) to place tags on our Website. The tags may collect information from your interactions on the Website.

We do not control these third parties’ tracking technologies or how they may be used. Our Privacy Policy does not cover these third party companies. Please contact these third party companies (e.g., Google) directly for more information about their privacy policy and your choices regarding the tags and the information collected by the tags.

Biometrics – Collection, Transmission, Retention and Destruction

Biometric Collection

Depending on how you and the Subscriber use the Services, the Subscriber may enter into a contract with ConnectPay to lease Swipeclock biometric timekeeping equipment. The biometric equipment if used will scan a fingerprint and convert it into a template. Some laws require that individuals (such as employees and others) are provided with notice of the use of regulated biometrics in timekeeping, and to obtain consent. ConnectPay requires the Subscribers to bear the responsibility of providing compliant notice and collecting compliant consent for use of the biometric timekeeping equipment, including consent for the transfer of the biometrics to any third parties and vendors needed to support the service, such as ConnectPay and Swipeclock.  Subscribers must also comply with all other applicable law requirements pertaining to the biometrics, including but not limited to retention schedules, security, lawful use of biometric data, and so forth.

If regulated biometric information is collected from you, it would be collected, stored and/or used for purposes of timekeeping, security and fraud prevention.

Biometric Transmission, Security and Storage

Following biometric collection, the resulting templates are stored in the timekeeping device, and are also transmitted for storage on a database hosted by either the customer, SwipeClock or a third-party web hosting service. ConnectPay requires that reasonable care be used for transmission of biometrics to storage on any ConnectPay-hosted, Swipeclock or third-party database. ConnectPay provides secure transmission and storage for biometrics, which use reasonable standards of care within ConnectPay’s industry, and which are the same as the manner in which other confidential and sensitive information is transmitted and stored. ConnectPay does not sell, lease, trade, or otherwise profit from biometrics. ConnectPay at no point stores or has access to the fingerprints or templates.

Biometric Destruction/Retention Schedule

Biometric templates are and remain the property of the Subscriber, which is responsible for biometric template destruction when the biometric template is no longer needed, or within (1) year from the Subscribers last contact with you, whichever is first.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, for the following purposes:

• Presenting our Services and Website and its contents to you.
• Providing you with information, products, or services that you or the Subscriber request from us.
• Fulfilling any other purpose for which you or the Subscriber provide it.
• Carrying out our obligations and enforce our rights arising from any contracts entered into between you or the Subscriber and us, including for billing and collection.
• Notifying you about changes to our Website or any products or services we offer or provide through it.
• Allowing you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information or for which you consent.
• Fulfilling orders and requests for products, services, or information.
• Processing refunds, returns, and exchanges.
• Tracking and confirming orders.
• Delivering products.
• Marketing and advertising products and services, including interest-based advertising.
• Conducting research and analysis.
• Preventing and identifying fraud and other illegal activity.
• Engaging in internal uses such as data analytics with the purpose of enhancing existing and creating new products and services.
• Complying with and enforcing applicable legal requirements, contractual obligations (including our contractual obligations with you), relevant industry standards, and our policies.
• Administering our programs, sweepstakes, contests, promotions, or surveys and provide appropriate notifications.
• Communicating with you about special offers, events, or new products or services that may be of interest to you, or to send newsletters, text messages and mobile push notifications about the Services.
• Customizing and enhancing the Website, your experience on the Website and advertising.
• Notifying you regarding security, privacy, and administrative issues.
• Managing our business.
• Providing you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• Maintaining the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• Testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• Responding to law enforcement requests or other legal processes, and as required by applicable law, court order, or governmental regulations.
• Facilitate customer requested Services, transactions, investments, distributions and benefits.
• Comply with legal, reporting and regulatory requirements. This includes, but is not limited to Anti-Money Laundering and Know Your Client compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions
• Detect fraud or theft to protect our business and customer information.
• Facilitate applicant tracking and recruitment.
• Anonymizing, deidentifying and/or aggregating data.
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

Disclosure of Your Information

We may also be required to share client data with applicable government entities (for example, the IRS, state unemployment agencies, state income agencies, tax authorities, workers compensation auditors, 401k administrators and other similar entities) or as otherwise required by law.

We may disclose aggregated information about our users, and information that does not identify any individual or otherwise does not constitute personal information as defined by applicable law, without restriction as permitted by applicable law.

ConnectPay does not sell your personal information for monetary consideration. We may combine or share information among past, current and future ConnectPay companies, including affiliates and subsidiaries. We may also disclose personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business and marketing.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ConnectPay's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ConnectPay about our Website users is among the assets transferred.
• To fulfill the purpose for which you or the Subscriber (and/or any third parties at the direction of the Subscriber) provide it.
• For any other purpose disclosed by us when you or the Subscriber (and/or any third parties at the direction of the Subscriber) provided the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request. These regulatory disclosure obligations include but are not limited to Anti-Money Laundering and Know Your Client disclosures discussed above.
• To enforce or apply our agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ConnectPay, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices

There are available mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. 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. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Google Analytics: One of the third party services we use for advertising purposes is Google Analytics. Information about how Google Analytics uses data and what representations Google makes regarding your choices with this data can be found at google.com/policies/privacy/partners/.
• Promotional Offers and Notifications from ConnectPay. If you do not wish to receive promotional e-mails from us, email us at privacy@connectpayusa.com to opt-out. You also have the ability to unsubscribe from promotional e-mails via the unsubscribe link included in each promotional e-mail. If you are a US resident and have signed up for our marketing text message program, you can opt out by replying “STOP” to the last marketing text message you received from us. You may also log into your account to disable text messages. We make every effort to promptly process all unsubscribe requests; however, this may take a few days. If you unsubscribe from receiving promotional e-mails or text messages, we may still send you transactional e-mails or text messages about your account or any services you have requested or receive from us (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices, responses to your communications, purchase-related communications if you made a purchase, etc.). We may send you push notifications from time-to-time. If you no longer wish to receive these types of communications, you turn them off at the device level.
• Correcting Your Information. You may log into your account to personal information in your account, such as certain items of Registration Information.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Your California Privacy Rights

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to privacy@connectpayusa.com. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the contact information specified in this section.

Nevada Residents

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address: privacy@connectpayusa.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Data Security

We have implemented appropriate measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Links to Other Websites
The Website may allow links to various other Websites. ConnectPay assumes no responsibility for the information practices of sites you are able to access through the Website. These links to other sites do not imply affiliation or endorsement of a linked site. You should review the privacy policies for these third parties.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

ConnectPay, LLC
10 Lincoln Road
Suite 110
Foxborough, MA 02035

Or email us at:
privacy@connectpayusa.com