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

1.      INTRODUCTION

This Privacy Policy describes the privacy practices of Billing Solutions, Inc. d/b/a BankVOD ("BankVOD" or “we”, “us” and/or “our”) with respect to personal information we collect in providing BankVOD Services (as defined in the BankVOD Terms and Conditions located at https://www.bankvod.com/terms_and_conditions.htm (our “Terms and Conditions”) or such other location as we may designate).  Please take the time to read this Privacy Policy, including but not limited to Section 2 (“Important Context”) below, and let us know if you have any questions or concerns. This Privacy Policy may be revised periodically, and any such revisions will be reflected by a new “last updated” date at the end of this Privacy Policy. Please revisit this page to stay aware of any changes.

2.      IMPORTANT CONTEXT

 

·        This privacy policy only applies to BankVOD’s privacy practices, not to the practices of other persons or entities. 

 

o   Background Regarding BankVOD Services: The BankVOD Services consist of BankVOD providing a variety of verification and similar services in and for a variety of contexts and users.  We collect certain personal information to perform the relevant BankVOD Service (e.g., information necessary to initiate a requested verification), along with a consent to disclose such personal information to certain relevant parties to whom such disclosure is necessary for us to provide the relevant BankVOD Service (e.g., disclosure to a financial institution from whom a verification is sought). In most cases, we collect this personal information indirectly – that is, not directly from the individual consumer who is the subject of the verification or other request, but from a business that has a relationship with such consumer (e.g., employer, mortgage broker, etc.) – and we refer to such businesses here and in our Terms and Conditions as “Business Users.”  In some cases, we instead collect this personal information directly from the individual consumer who is the subject of the verification or other request, and we refer to such individuals here and in our Terms and Conditions as “Individual Users.”

 

o   Limited Scope of This Privacy Policy: While this Privacy Policy describes BankVOD’s privacy practices with respect to all BankVOD Services, it does not govern and we are not responsible for either: (i) the privacy practices of Business Users (for example, if you wish to learn more about your employer’s or mortgage broker’s privacy practices, you would need to consult their privacy policies or contact them for more information); or (ii) the privacy practices of persons or entities to whom we are authorized to disclose personal information in performing requested BankVOD Services (for example, if you wish to learn more about the privacy practices of a bank that is verifying your account information, you would need to consult such bank’s privacy policies or contact them for more information).  Put differently, this Privacy Policy applies to BankVOD only, and not to any other person or entity, including, but not limited to, any government entities, 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.

 

·        This Privacy Policy only applies to personal information.  This Privacy Policy applies only to personal information, by which we mean information that is not publicly available and that identifies, relates to, describes, or is reasonably capable of being associated with or linked to a particular consumer or household (“Personal Information”).  This Privacy Policy does not apply to publicly available information or to anonymized, deidentified or aggregated information.

 

·        “Users” vs. “Visitors”.  As used in this Privacy Policy: a “user” means a user who enrolls with and uses BankVOD Services and generally means both Individual Users and Business Users unless the context clearly indicates otherwise; a “visitor” is someone who is casually on a BankVOD website, but does not enroll and use BankVOD Services; and “you” or “your” generally means both users and visitors unless the context clearly indicates otherwise.

 

3.      Our Collection and Use of Personal Information

BankVOD collects Personal Information when a 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, or a user’s customers/clients, from government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services.

BankVOD may combine Personal Information about a BankVOD user, or a user’s customer/client, with information about that user, or that user’s customer/client, that it obtains from government entities, financial institutions, employers, and/or other third parties who participate in BankVOD Services.  

BankVOD strives to collect 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 BankVOD and if applicable, a user’s, and 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 collects 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. For additional information regarding cookies and web beacons that we may use to collect such information, please refer to Section 5 (“Cookies”) and Section 6 (“Web Beacons”) below.

BankVOD uses Personal Information it collects for the following general purposes: to customize the content a user or visitor sees, to fulfill a user’s requests for BankVOD Services, to improve BankVOD Services, to contact a user, to conduct research, to provide reporting for internal and external clients, and as necessary to comply with applicable laws. BankVOD may also possess and deliver a user’s or 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.

4.      Our Sharing and Disclosure of Personal Information

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

· We provide information to trusted service providers and 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, to an affiliated company or if BankVOD is acquired by or merged with another company.

5.      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 for present use.  Instead, a user should contact BankVOD at [email protected] to implement this.

6.      Web Beacons

Web pages may contain an electronic file called a web beacon that allows a web site to (a) count visitors or users who have visited that page, or (b) access certain cookies. BankVOD uses web beacons for a number of purposes, including, but not limited to: (i) to count visitors and users and to recognize visitors and users by accessing BankVOD cookies, (ii) to personalize visitor and visitor experience when BankVOD web sites are accessed, (iii) to conduct research on behalf of certain partners on their web sites and also for auditing purposes, (iv) 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, and (v) to report anonymous individual and/or aggregate information about users of BankVOD Services to our partners.

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).

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.

7.      Retention and Deletion of Personal Information

BankVOD reserves the right to retain your Personal Information for so long as necessary or relevant to our legitimate operations, in accordance with applicable laws, and taking into account, among other considerations, the specific nature of the BankVOD Services.  We also desire to be transparent about our retention and deletion practices, and while these practices necessarily evolve, the below description reflects our practices as of the “last updated” date below.

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.

8.      Your Choices and Rights

 

a.      Opting Out of Marketing Communications

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, and changes in terms, if any, that are considered part of the BankVOD Services users receive, without offering users the opportunity to opt out of receiving them.

b.      Rights under Certain Privacy Laws

Certain states’ privacy laws provide their residents with rights regarding covered businesses’ use of their Personal Information (sometimes referred to as “personal data”).  Examples of such laws, to which we may or may not, and your Personal Information may or may not, be subject, include, but are not limited to, the California Consumer Privacy Act, Colorado Privacy Act, Connecticut Personal Data Privacy and Online Monitoring Act, Montana Consumer Data Privacy Act, Oregon Consumer Privacy Act, Texas Data Privacy and Security Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act (and given the frequency with which such laws are passed, we do not guarantee that the foregoing list is at all times up-to-date, but it should be interpreted as including any laws applicable to our business and to your Personal Information) (collectively, “Privacy Laws”).

Regardless of your state of residence, you can currently contact us at any time using the contact information listed in the last section of this Privacy Policy to request we do any of the following: (i) erase or delete all or some of your Personal Information; (ii) change, update, or correct your Personal Information; (iii) restrict how we use all or some of your Personal Information; (iv) access your Personal Information and, where applicable and feasible, request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what Personal Information we collect, use, disclose or sell (if any).

We do not guarantee that we will fulfill your request (in part because we may have no obligation to do so under applicable Privacy Laws – for example, because your Personal Information is not subject to any such laws, or because even if it is covered by such a law, that law does not grant you the right you are seeking to assert). However, we will consider and respond to any such requests promptly and otherwise in accordance with applicable Privacy Laws. Furthermore, if you choose to exercise your privacy rights or make the above requests, we will not treat you in a discriminatory way, nor will you receive a lesser degree of service from us.

In order to help ensure that your Personal Information is not disclosed to any person who does not have the right to receive it, and to help ensure your Personal Information is not mistakenly deleted or changed, we will attempt to verify that you are the subject of the Personal Information that your request concerns.

In many cases, our response may necessarily require the involvement of, and you may wish to contact directly, the relevant Business User through whom we received your Personal Information. Depending on the nature of the request, our response may simply recommend that you contact such Business User directly.

c.       Additional California Rights

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 to third parties for marketing purposes.     

9.      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.

10.    INFORMATION PROVIDED BY BANKVOD SERVICES IS LIMITED TO RESIDENTS OF, AND BUSINESSES LOCATED IN, THE UNITED STATES.

Information provided by BankVOD Services is limited to residents of, and businesses located in, the United States.  BankVOD servers and all BankVOD operations are located in the United States.    

11.    How to Contact Us

If you have questions or suggestions, please contact us at: [email protected].

This Privacy Policy was last updated June 11, 2024.