BILLING SOUTIONS, INC. d/b/a BankVOD (“BankVOD”) PRIVACY POLICY

BankVOD takes privacy seriously. Please read the following to learn about our privacy policy.

This policy covers how BankVOD treats personal information that BankVOD collects and receives through the BankVOD Services as BankVOD Services is defined in the BankVOD Terms and Conditions located at https://www.bankvod.com/terms_and_conditions.htm, or such other location as we may designate.

Important Definitions:

Only businesses are BankVOD users.  Consumers are NOT BankVOD users.  In this policy “user” means a user (which is business, not a consumer) who enrolls with and uses BankVOD Services.  A “visitor” is someone who is casually on a BankVOD website, but does not enroll and use BankVOD Services.

Personal information is information about our user’s or our user’s customers/clients, or visitors that is personally identifiable, and that may not otherwise publicly available, like a name, address, email address, phone number, financial institution account numbers, and employers (“Personal Information”).

This privacy policy only applies to BankVOD.

This policy only applies to BankVOD, 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 BankVOD Services.  Please go to the website of that particular person or entity to view their privacy policy.

INFORMATION COLLECTION AND USE

General

BankVOD receives Personal Information when a business user enrolls with BankVOD and uses BankVOD Services, and sometimes when a visitor or a user is causally on a BankVOD website.

As part of BankVOD Services, BankVOD may also receive or pass through Personal Information about a BankVOD user’s customers/clients from government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services. BankVOD may combine information about a BankVOD user’s customer/client that it has with information about a user’s customer/client it obtains from government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services.  BankVOD strives to receive Personal Information from established, reputable sources in the government and private sectors. In support of this, BankVOD takes reasonable steps to assess the reputation and reliability of its private sector data sources before incorporating Personal Information from the source into its products and services. BankVOD also strives to obtain assurances from its data suppliers that they have the legal right to license or provide the data to BankVOD.\BankVOD maintains information about a user’s transactions with us and if applicable, a user’s customer’s / client’s, dealings with government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services or pass through information through BankVOD.

BankVOD automatically receives and records information from a user’s or visitor’s computer and browser, including IP address, BankVOD cookie information, software and hardware attributes, and the page(s) a user or visitor requested.

BankVOD uses information it receives for the following general purposes: to customize the content a user or visitor sees, to fulfill a user’s requests for BankVOD Services, improve BankVOD Services, to contact a user, conduct research, and provide reporting for internal and external clients. BankVOD may also possess and deliver a user’s customer/client information, and information a user provides and/or requests, to fulfill requests and requirements of a user, a user’s customer/client, and/or requestors, persons or entities authorized by a user or a user’s customer/clients, including, without limitation informing a user of, and putting information in a user’s account with BankVOD. Such foregoing persons or entities may include, but not be limited to, lenders, employers and/or mortgage processors.

INFORMATION SHARING AND DISCLOSURE

BankVOD does not share Personal Information with other people or non-affiliated companies except (i) to provide products or services a user and a user’s customers/clients have requested, (ii) as noted above, to facilitate the sharing of information to persons or entities a user and a user’s customers/clients have authorized, and/or (iii) under the following circumstances:

· We provide information to trusted partners who work on behalf of or with BankVOD under confidentiality agreements. These partners may use information to help BankVOD communicate with users or visitors. 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/statutory/regulatory process, or to establish or exercise our legal rights or defend against legal 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 BankVOD’s Terms and Conditions, or as otherwise required by law.

· We transfer information about users, users’ customers/clients, and visitors, if BankVOD is acquired by or merged with another company.

CALIFORNIA CONSUMERS PROTECTION ACT (CCPA) AND SIMILAR LAWS/RULES.

 

The California Consumers Protection Act (CCPA) requires under certain circumstances consumers to receive notification as to where their information resides and that it be deleted.  BankVOD is not subject to the California Consumers Protection Act (CCPA).  Notwithstanding, if required by the CCPA or similar law, rule or regulation, a user shall be in compliance with the CCPA and any other similar law, rule or regulation, including, without limitation, if required by law, permitting consumers to receive notification as to where their information resides and that it be deleted.  If it is necessary in this regard, in relation to the CCPA or any similar law, rule or regulation, for a user to contact BankVOD, a user should do so at [email protected], and BankVOD shall respond as required by law.

 

If you are a consumer or customer or client of a user of BankVOD Services, and feel you have rights under the CCPA or similar laws, rules, or regulation, please contact that user of BankVOD directly.  BankVOD has no consumer customers.       

 

COOKIES

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

BankVOD may set and access BankVOD cookies on a user’s or visitor’s computer. BankVOD uses its own cookies for a number of purposes, including, but not limited to: (i) providing a user or visitor  with customized content or to remember the last page visited, (ii)  accessing a user’s information when a user "signs in",  (iii) keeping track of preferences a user specified while using BankVOD Services, (iv) provide general internal and customer analytics, (iv) conducting research to improve BankVOD Services, (vi) supporting security measures such as requiring re-logging into a BankVOD Service after a certain amount of time has elapsed, and (vii) assisting in identifying possible fraudulent activities.

BankVOD lets government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services, or pass information through BankVOD, to set and access their cookies on a user’s computer.  Other companies' use of their cookies is subject to their own privacy policies, not this one, and their privacy policies should be consulted. Other companies do not have access to BankVOD's cookies.

As a user or visitor, you can configure your browser to accept all cookies, reject all cookies, or be notified 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 a user rejects all cookies, a user may not be able to use BankVOD Services and a user may not be able to take full advantage of all offerings. However, many BankVOD Services do not require that a user accept cookies. BankVOD refreshes cookie information for a registered BankVOD user each and every time a registered BankVOD user logs into BankVOD on whichever computer or device a user is using at that time. Accordingly, a user previously deleting cookies may not be effective.  Instead, a user should contact BankVOD at [email protected] to implement this.

WEB BEACONS

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

· to count visitors and users and to recognize visitors and users by accessing BankVOD cookies.

· to personalize visitor and visitor experience when BankVOD web sites are accessed.

· 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 BankVOD Services to our partners. Aggregate information may include demographic and usage information. No personally identifiable information about users is shared with partners from this research. When conducting research that collects personal information, BankVOD'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. A user may choose to prospectively opt-out of BankVOD using this information by emailing BankVOD at [email protected]. (Note: This opt-out applies to a specific browser rather than a specific user. Therefore a user will have to opt-out separately from each computer or browser that a user uses).

· to include web beacons in HTML-formatted email messages (messages that include graphics) that BankVOD, 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. BankVOD may also include web beacons from third parties’ and affiliates’ pages served by BankVOD so that BankVOD’s partners may receive auditing, research and reporting.

GENERAL

A user can opt out of receiving marketing communications from BankVOD by following instructions contained in the messages you receive.

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

In order to provide BankVOD Services, BankVOD collects and stores information from user account registration and site usage. BankVOD’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 a user registers with BankVOD or submits information to BankVOD, a temporary copy of that information is routinely made to prevent accidental loss of that user’s information through a computer malfunction or human error.

· BankVOD keeps a user’s account information active in our user registration databases in order to provide immediate access to that user of their personalization preferences each time a user uses BankVOD Services.

·         If a user asks BankVOD at [email protected] to delete their BankVOD account, in most cases the account will be deactivated and then deleted from BankVOD’s 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 BankVOD has copied may remain in back-up storage for some period of time after a user’s deletion request. This may be the case even though no account information remains in our active user databases.

Also,

· The BankVOD computers that send web pages, and 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, a user’s BankVOD ID may remain in BankVOD’s active server log files.

· BankVOD uses a multi-step process to replace, truncate, or delete identifiers in order to de-identify data. However, BankVOD stores this data in an identifiable form for up to 90 days for most log file data. There are certain exceptions to this policy. BankVOD will store a limited amount of log file data in identifiable form for up to 6 months for select log file systems involved in products/services and for 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 BankVOD who we believe reasonably need to come into contact with that information to provide BankVOD products or services to users or in order to do their jobs.

We have safeguards that protect personal information about you.

NO CHILDREN / MINORS

BankVOD Services are not for children / minors, and any person under the age of 18 is prohibited from accessing or using BankVOD Services.

ADDITIONAL CALIFORNIA PROTECTION

If you are a California resident you may have certain rights under California Civil Code Section 1798.83 that permits applicable individuals to request information regarding disclosure, if any, of their personal information to third parties for the third parties’ direct marketing purposes.  BankVOD does not disclose personal information for marketing purposes, whether to third parties or otherwise.     

BANKVOD SERVICES ARE LIMITED TO THE UNITED STATES

BankVOD Services are limited to the United States and to residents of the United States.  BankVOD servers and all BANKVOD operations are located in the United States.    

 

CHANGES TO THIS PRIVACY POLICY

BankVOD 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: [email protected].

This Privacy Policy was last updated October 17, 2023.