Billing Soutions, Inc. (“BSI”) PRIVACY POLICY

BSI takes your privacy seriously. Please read the following to learn more about our privacy policy.

This policy covers how BSI treats personal information that BSI collects and receives through the BSI Services as BSI Services is defined in the BSI Terms and Conditions. Personal information is information about you or your customer/client that is personally identifiable, and that may not otherwise publicly available, like your name, address, email address, phone number, financial institution account numbers, and employers.

This privacy policy only applies to BSI.

This policy only applies to BSI, and not to any other person or entity, including, but not limited to any government entity, financial institutions, employers, and/or other third parties found on or through the BSI Services.

INFORMATION COLLECTION AND USE

General

BSI receives Personal information when you register with BSI, when you use BSI Services, and sometimes when you visit BSI Services. As part of BSI Services, BSI may also receive personal information about you or your customer/client from government entities, financial institutions, employers, and/or other third parties who participate in BSI Services. BSI may combine information about you or your customer/client that it has with information about you or your customer/client it obtains from government entities, financial institutions, employers, and/or other third parties who participate in BSI Services.

When you register with BSI and use the BSI Services, you and your customer/clients are not anonymous to BSI. BSI maintains information about your or your customer/client’s transactions with us and with government entities, financial institutions, employers, and/or other third parties who participate in BSI Services. BSI automatically receives and records information from your computer and browser, including your IP address, BSI cookie information, software and hardware attributes, and the page you request.

BSI uses information for the following general purposes: to customize the content you see, fulfill your requests for BSI Services, improve BSI Services, contact you, conduct research, and provide reporting for internal and external clients. BSI may also possess and deliver your and/or your customer/client information, and information you provide and/or request, to fulfill requests and requirements of you, your customer/client, and/or requestors, persons or entities authorized by you or your customer/clients, including, without limitation informing you of, and putting information in your account with BSI. Such persons may include, but not be limited to, lenders, employers and/or mortgage processors.

INFORMATION SHARING AND DISCLOSURE

BSI does not rent, sell, or share personal information about you with other people or non-affiliated companies except (i) to provide products or services you and/or your customers/clients have requested, (ii) as noted above, to facilitate the sharing of information to persons or entities you and/or your customers/clients have authorized, and/or (iii) under the following circumstances:

· We provide the information to trusted partners who work on behalf of or with BSI under confidentiality agreements. These partners may use your and/or your customer/client’s personal information to help BSI communicate with you. However, these partners do not have any independent right to share this information.

· We use the information to respond to subpoenas, court orders, or legal/regulatory process, or to establish or exercise our legal rights or defend against legal/regulatory claims.

· We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to property and/or the physical safety of any person, violations of BSI’s Terms and Conditions, or as otherwise required by law.

· We transfer information about you and/or your customers/clients if BSI is acquired by or merged with another company.

COOKIES

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site's computers and stored on your computer's hard drive.

BSI may set and access BSI cookies on your computer. BSI uses its own cookies for a number of purposes, including, but not limited to: (i) access your information when you "sign in" so we can provide you with customized content or remember the last page you visited, (ii) keep track of preferences you specify while you are using BSI Services, (iii) provide general internal and customer analytics, (iv) conduct research to improve BSI Services, (v) support security measures such as requiring re-logging into a BSI Service after a certain amount of time has elapsed, and (vi) assist in identifying possible fraudulent activities.

BSI lets government entities, financial institutions, employers, and/or other third parties who participate in BSI Services set and access their cookies on your computer. Other companies' use of their cookies is subject to their own privacy policies, not this one. Other companies do not have access to BSI's cookies.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.). If you reject all cookies, you will not be able to use BSI Services that require you to "sign in," and you may not be able to take full advantage of all offerings. However, many BSI Services do not require that you accept cookies. BSI refreshes cookie information for a registered BSI user each and every time a registered BSI User logs into BSI on whichever computer or device you are using at that time. Accordingly, previously deleting your cookies may not be effective. Instead, you should contact BSI at clientservices@bankvod.com to implement this.

WEB BEACONS

Web pages may contain an electronic file called a web beacon, that allows a web site to count users who have visited that page or to access certain cookies. BSI uses web beacons in the following ways:

· to count users and to recognize users by accessing BSI cookies.

· to personalize your experience when you visit BSI web sites.

· to conduct research on behalf of certain partners on their web sites and also for auditing purposes.

· to report anonymous individual and/or aggregate information about users of BSI Services to our partners. Aggregate information may include demographic and usage information. No personally identifiable information about you is shared with partners from this research. When conducting research that collects personal information, BSI's practice is to require partners to disclose the presence of web beacons in their privacy policies and state what choices are available to users regarding the collection and use of this information. You may choose to opt-out of BSI using this information by emailing BSI at clientservices@bankvod.com. (Note: This opt-out applies to a specific browser rather than a specific user. Therefore you will have to opt-out separately from each computer or browser that you use).

· to include web beacons in HTML-formatted email messages (messages that include graphics) that BSI, or its agents, send in order to determine which email messages were opened and to note whether a message was acted upon.

In general, any file served as part of a web page can act as a web beacon. BSI may also include web beacons from third parties’ and affiliates’ pages served by BSI so that BSI’s partners may receive auditing, research and reporting.

GENERAL

You can opt out of receiving marketing communications from BSI by following instructions contained in the messages you receive.

We reserve the right to send you certain communications relating to the BSI Services, such as service announcements, administrative messages and the BSI Newsletter, if any, that are considered part of the BSI Services you receive, without offering you the opportunity to opt out of receiving them.

In order to provide BSI Services, BSI collects and stores information from user account registration and site usage. BSI’s policy is to de-identify user log file data within 90 days of collection, with limited exceptions to fight fraud, secure systems, and meet legal obligations.

In addition,

· When you register with BSI or submit information to BSI, a temporary copy of that information is routinely made to prevent accidental loss of your information through a computer malfunction or human error.

· BSI keeps your account information active in our user registration databases in order to provide immediate access to your personalization preferences each time you visit BSI.

·         If you ask BSI at clientservices@bankvod.com to delete your BSI account, in most cases your account will be deactivated and then deleted from our user registration database in approximately 90 days. This delay is necessary to discourage users from engaging in fraudulent activity.

·         Please note that any information that we have copied may remain in back-up storage for some period of time after your deletion request. This may be the case even though no account information remains in our active user databases.

Also,

· The BSI computers that send your web pages process and store information every day create records called “log files”. Log files are used for analysis, research, auditing, and other purposes. After this information has been used, it is stored and is inaccessible. Until the information is stored, your BSI ID may remain in our active server log files.

· BSI uses a multi-step process to replace, truncate, or delete identifiers in order to de-identify data. However, BSI stores this data in an identifiable form for up to 90 days for most log file data. There are certain exceptions to this policy. BSI will store a limited amount of log file data in identifiable form for up to 6 months for select log file systems involved in product/service and financial fraud detection and abuse management. There are also exceptions for legal obligations.

CONFIDENTIALITY AND SECURITY

Except as to what is otherwise set forth in this Privacy Policy, we limit access to personal information about you to employees or contractors of BSI who we believe reasonably need to come into contact with that information to provide BSI products or services to you or in order to do their jobs.

We have safeguards that protect personal information about you.

CHANGES TO THIS PRIVACY POLICY

BSI may update this policy. We will notify you about significant changes in the way we treat personal information by placing a prominent notice on our site or by updating this Privacy Policy.  On a regular basis, please check this Privacy Policy.  

If you have questions or suggestions, please contact us at: clientservices@bankvod.com.

This Privacy Policy was last updated and is effective as of November 11, 2014.