Privacy Notice
DigiPass Pay – U.S. Privacy Notice
Last Revised: December 31, 2019
DigiPass Pay U.S. Privacy Notice
We at DigiPass LLC, along with our subsidiaries and affiliates (collectively, “DigiPass”)respect your concerns about privacy. This DigiPass Pay U.S. Privacy Notice describes how we collect, share and use your personal information in connection with the DigiPass Pay mobile app. In this U.S. Privacy Notice, we describe the types of personal information we collect, how we may use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the steps we take to safeguard the information and tell you how to contact us if you have any questions about our privacy practices.
Information We Obtain
We may obtain the following information about you:
Your name (and any prior names) and contact information (such as email address, telephone number, and current and former billing and shipping addresses);
Your banking information (for processing payments)
The banking and contact information of your bank.
DigiPass Account information (including your DigiPass Account profile, ID and DigiPass Account settings);
Device information (such as IP address, MAC address, device model, IMEI number, operating system version, advertising identifiers (including Google Ad ID), device settings (including language and lock settings), device status information (including connections with other devices), mobile network operator, mobile country code, app usage information and other device identifiers);
Third-party device, app, service or program identifiers when you choose to connect such devices, apps, services or programs to DigiPass Pay (such as merchant loyalty program membership numbers connected to the DigiPass Pay Deals or Coupons features);
DigiPass Pay usage data (such as the number of payment cards registered on DigiPass Pay, DigiPass Pay Deals and Coupons viewed or redeemed, and use of DigiPass Rewards);
Information about transactions completed through DigiPass Pay (such as the name and location of the merchant completing the transaction and transaction amount); and
Location information associated with your device, including (1) the precise geolocation of your device if you consent to the collection of this data and (2) information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use DigiPass Pay.
We may obtain certain information about you from other DigiPass products or services with which you have shared your information. For example, if you choose to save your payment card information with DigiPass we may save this information to your DigiPass Pay account, to be used in connection with transactions you make.
We also may collect other information about you and your use of DigiPass Pay in ways that we describe to you at the time of collection or otherwise with your consent.
Third-Party Web Analytics Services
Through DigiPass Pay, we may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services.We may use third-party analytics services on DigiPass Pay. The service providers that administer these analytics services help us to analyze your use of DigiPass Pay and improve DigiPass Pay. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of DigiPass Pay, help administer DigiPass Pay and diagnose technical issues.
Online Tracking and Interest-Based Advertising
Through DigiPass Pay, we may collect information about your online activities over time and across DigiPass apps, websites and other online services, to provide you with advertising about products and services tailored to your individual interests. Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
How We Use the Information We Obtain
We may use the information we obtain to:
Provide and operate the DigiPass Pay service and user experience;
Identify and authenticate you so that you may use DigiPass Pay;
Respond to your requests and inquiries;
Keep you informed about DigiPass Pay and participating third-party features, services, deals, promotions and application updates;
Improve and customize your experience with DigiPass Pay, such as by delivering notifications, communications, content, alerts, offers, promotions, marketing information and advertisements that are tailored to your interests and the manner in which you interact with DigiPass Pay and other DigiPass or participating third-party products and services;
Operate, evaluate and improve our business (including developing new products and services, enhancing and improving DigiPass Pay, managing our communications, analyzing DigiPass Pay and our customer base, conducting market research, aggregating and anonymizing data and performing data analytics, and performing accounting, auditing and other internal functions);
Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
Comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this U.S. Privacy Notice, the DigiPass Privacy Policy for the U.S.and the DigiPass Pay Terms and Conditions.
Through DigiPass Pay, we may collect personal information that you provide through other DigiPass devices, apps and online features and services, including your cross-platform and cross-device online activities. We also may obtain information about your interactions with and use of third-party services with which you choose to connect through DigiPass Pay. We may combine information we obtain about you for the purposes described above. We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection or otherwise with your consent.
Information Sharing
We may share certain parts of your personal information:
With banks to help for authentication and fraud prevention purposes;
With our affiliates;
With our service providers who perform services for us (such as to help operate and improve DigiPass Pay, to help us detect fraud and secure our networks, to facilitate customer service and to send you promotional and marketing communications and information). We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements;
With financial services companies, to facilitate interactions with your bank via DigiPass Pay; and
With trusted business partners, who may use your information to provide you with services you request, make predictions about your interests and may provide you with promotional materials, advertisements and other materials. For example, in connection with our money transfer and prepaid card features, we share your personal information with our banking partners that provide these features.
DigiPass Pay, our affiliates , and our third-party service providers also may disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation); or (7) otherwise with your consent.
Links to Third-Party Websites, Devices, Apps and Features
DigiPass Pay may provide the ability to access other websites, devices, apps, features, programs, products and services (e.g., gift cards or third-party merchant loyalty programs), which may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app, feature, program, product or service is not owned or controlled by us, we are not responsible for its content, any use of the website, device, app, feature, program, product or service or the privacy practices of the operator of the website, device, app, feature, program, product or service.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through DigiPass Pay against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Children’s Personal Information
DigiPass Pay is designed for a general audience and is not directed to children. DigiPass Pay does not knowingly collect or solicit personal information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will promptly delete that information. If you believe that a child under age 13 may have provided us with personal information, please contact us as specified in the Contact Us section of this U.S. Privacy Notice.
Updates To This U.S. Privacy Notice
This U.S. Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices with respect to DigiPass Pay. We will indicate at the top of the Notice when it was most recently updated.