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Onbe Privacy Policy

Last updated 23th March 2020

PURPOSE

This Privacy Notice describes how Onbe (“we”, “our”, or “us” ) manages the personal data we collect about users of our Web sites and mobile applications, as well as the personal data we collect in providing our products and services or when individuals communicate with us about our Web sites, mobile apps, products or services. It explains (1) what personal data we collect, (2) how we use the personal data we collect, (3) how long we hold the data, (4) what and with whom we share it with, (5) how to control your privacy options with Onbe, (6) what are your rights, and (7) certain other privacy information.

For more information on how we manage personal data for participants in our payment programs, please follow the following links for the Privacy Policies of daVinci Payments and North Lane Technologies.

WHAT DATA WE COLLECT ABOUT YOU 

Onbe may collect Personal Data, for example through the use of our products, accessing our websites or when you contact customer service. Personal Data may include the following, as applicable: 

HOW WE USE YOUR DATA 

We collect Personal Data about you in order to operate and to support our services and products only. We may use this Personal Data to: 

We may also use your Personal Data in other instances with your consentor as allowed or required by law. 

HOW LONG WE HOLD YOUR DATA 

We may hold Personal Data as long as required or relevant for the practices described in this Privacy Notice or as otherwise applicable by law. Actual hold periods differ depending on the type of services and products. The principles we use to determine the holding periods include the following: 

For more information on how long we will retain your personal information, please see the Privacy Policy of daVinci Payments and North Lane Technologies.

WHAT AND WITH WHOM WE SHARE 

We do not share your Personal Information with third-parties for joint marketing purposes or so they can market to you, without your prior express consent. We may share your Personal Data: 

HOW TO CONTROL YOUR PRIVACY OPTIONS  

You can update your account profile online or by email. We maintain electronic records of your Personal Data for the purposes described in this Privacy Notice. You will be able to access and edit your Personal Data on the website listed on the back of the card. Otherwise, you may contact us at the e-mail address listed at the bottom of this Notice. Your right to access, correct or delete your Personal Data indicated in our records is subject to applicable law including our right to retain documentation of our compliance with applicable legal requirements and technology limitations. We may take reasonable steps to confirm your identity before giving access or making modifications to your Personal Data. 

If we receive data from other sources, we may direct you to contact those sources. Please note that we are not responsible for permitting you to review, or for updating or deleting personal data that you provide to those sources or any other third-party. 

WE USE BROWSER INFORMATION 

We may use cookies, browser data, and location information, to uniquely recognize your computer or device and the pages you see on our website. We use tracking tools to: 

For more information, please read our Cookie Policy. 

You can adjust cookies and tracking tools on our Website. Your web browser may give you the ability to adjust cookies. How you do so depends on the type of cookie. Certain web browsers can be set to clear past and reject future cookies. If you block cookies on your browser, certain features of our website may not work. Additionally, if you limit or delete cookies, not all of the tracking activities we have defined here will stop. The choices you make are both browser and device specific. For more information on cookies and how to manage them, visit http://www.allaboutcookies.org/ 

WHAT ARE YOUR RIGHTS UNDER DATA PRIVACY LAWS 

When you provide us with your Personal Data it is only used for the purposes of providing products and services as described in this Privacy Notice. You have the option to opt-out of certain uses and disclosures of your Personal Data as outlined in this Notice. If you would like to opt-out of these uses or disclosures of your Personal Data, you may contact us at the email address listed at the bottom of this Notice. 

California Residents

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. Effective January 1,2020, under the California Consumer Privacy Act (CCPA), residents of California have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. California residents may also opt out of the sale of such information, if applicable. These provisions of the CCPA do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law. 

To contact us with questions about our compliance with the CCPA, or exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by either: 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. 

You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Please note, consumers will not be subject to discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. 

EU & UK RESIDENTS 

All personal information of EU/UK residents will be handled by Onbe’s affiliate, daVinci Payments. If you have any questions regarding General Data Protection Regulation (“GDPR”), Privacy Shield Certification, Model Contract Clauses or Dispute Resolution, please see the daVinci Privacy Policy here

OTHER PRIVACY INFORMATION 

We process your Personal Data, on specific legal grounds. We do so with your consent, to fulfill the contractual requirements we have with you, comply with our legal responsibilities, or as needed to deliver our services and products and for other legitimate business interests for the purposes described in this Privacy Notice. 

We protect your Personal Data. We implement security policies, processes and technical security solutions to protect Personal Data which includes various network safeguards, logging and alerting. In order to perform certain obligations, our authorized employees and service providers will need access to your Personal Data. We contractually require our service providers to protect your Personal Data. 

Data storage and transfers. We store Personal Data in the United States. When we transfer your Personal Data to service providers or third parties as outlined in this Privacy Notice, we rely on contractual clauses to administer the transfer of that Personal Data and uphold those entities to protecting the data as described in this Privacy Notice or as required by law. 

Our Services are not intended for children. Our Services are meant for adults and are not for children. We do not intentionally collect Personal Data from children under 13 without authorization from apparent or legal guardian. If you think your child under 13 has sent us data, you can contact us at:

Our Services may link to third-party services that we do not manage. If you click a link to a third-party website, you will be taken to sites that we do not control. This Privacy Notice does not apply to the privacy practices of those websites. Please read the privacy notice of those websites. We are not liable for these third-party practices. 

This Privacy Notice may be updated at any time. We may change our Privacy Notice from time to time. We may inform you of any changes to our Privacy Notice as required by law. Please check this website periodically for updates. This Privacy Notice was last modified in March, 2021. 

To contact us, if you have additional questions, concerns or wish to file a complaint regarding your Personal Data, you may e-mail our Data Protection Officer at compliance@onbe.com.  We are committed to resolving any questions you may have. 

YOU CAN OPT-OUT OF BEHAVIORAL ADVERTISING

https://app.adroll.com/optout

The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. To opt out of having your online behavior collected for behavioral advertising purposes as provided by our third vendors, click here.

The Digital Advertising Alliance also offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising. To exercise choice for companies participating in this tool, download the AppChoices app here.