Privacy Statement Effective: October 1, 2019
1. OUR COMMITMENT TO PRIVACY
i3 Verticals, LLC (“i3 Verticals” “we” “our”) is the owner and operator of the Burton Portal (“Burton Portal”) found at www.i3verticals.com/burton-portal. Our family of companies and the products and services offered represent tech-enabled payments solutions for a wide variety of industries. We and our affiliate companies are committed to protecting any personally identifiable information collected while providing those services. We have adopted this Privacy Statement to explain what personally identifiable information may be collected on the Burton Portal, how we use this personally identifiable information, and under what circumstances we may disclose the personally identifiable information to third parties. This Privacy Statement applies to all visitors to the Burton Portal and anyone else who accesses or uses our products and services. WHEN YOU ACCESS THE BURTON PORTAL, YOU AGREE TO THIS PRIVACY STATEMENT. IF YOU DO NOT AGREE TO THIS PRIVACY STATEMENT, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING THE BURTON PORTAL.
2. THE PERSONALLY IDENTIFIABLE INFORMATION WE COLLECT
i3 Verticals is the sole owner of the personally identifiable information collected on the Burton Portal. We will not sell, share, or rent this personally identifiable information to others in ways differently than we have disclosed in this statement. We collect personally identifiable information from our users at several different points on the Burton Portal. Examples of the types of personally identifiable information collected are:
- Web address
- IP address
- Email address
- Phone Number
- Device type
- Merchant or other Customer identification
- Payment transaction personally identifiable information
- Financial and credit card personally identifiable information
- Technical personally identifiable information
In addition to the Burton Portal, we may collect personally identifiable information about you from the following sources:
- Personally identifiable information we receive from you on applications or other forms
- Personally identifiable information about your transactions with us, our affiliates and others
- Personally identifiable information we receive from third parties, including consumer-reporting agencies, fraud monitoring providers, commercial databases or know your customer providers (KYC)
We also automatically collect certain personally identifiable information when you visit the Burton Portal, such as the following:
- Log data: Our servers automatically record personally identifiable information when you access the Burton Portal, the type of browser you are using and its settings, the third party website you visited immediately prior to accessing the Burton Portal, the operating system you are using, the domain name of your internet service provider, the search terms you use on the Burton Portal, the specific pages of the Burton Portal you visit, and the duration of your visits.
- Cookie data: Like many websites, we use “cookies” to obtain certain types of personally identifiable information when your web browser accesses the Burton Portal. “Cookies” are small text files that we transfer to your computer’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you, such as recognizing you as a frequent user of the Burton Portal. We may use “session cookies” (cookies that last until you close your browser) or “persistent cookies” (cookies that last until you or your browser delete them). Examples of the personally identifiable information we collect and analyze from cookies include your activity on the Burton Portal, including the URL you come from and go to next (whether this URL is on our site or not).
If the Burton Portal contains link through to third party websites, those processes may involve the placement of third party cookies on your machine or device. Please be aware that we do not control these third party websites or any of the content contained on those websites, including the third-party cookies used for these purposes. The inclusion of links to third party websites in no way constitutes an endorsement by us of such websites’ content, actions, or policies.
Experience data: We collect other personally identifiable information that is voluntarily provided by you from time to time if you respond to surveys, polls or questionnaires, and/or website registration forms. Such personally identifiable information may include personal preferences, opinions and experiences with our products and services, and may be provided anonymously.
3. USE OF PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU
We use the personally identifiable information we collect in a variety of ways that are appropriate, based on legitimate interests or as authorized by applicable law, which may include:
- Analyzing website traffic, which allows us to improve the design and content of the Burton Portal
- Legal, regulatory or law enforcement purposes, including compliance with local and national laws (including card brand rules and requests from law enforcement and regulatory authorities); enforcing our legal rights and satisfying our legal obligations, including, without limitation, any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others; conducting our own due diligence checks, preventing, detecting and prosecuting fraud or crime or to assist others in doing so; assisting in investigation by third-party vendors, financial organizations or third parties of suspected criminal activity; assessing financial and insurance risks; notifying you about important changes or developments to the Burton Portal or our services, recovering debt or in relation to your insolvency, including tracing your whereabouts; identifying and monitoring for fraud; maintaining internal recordkeeping and reporting; preparing and furnishing compilations and analyses as well as other reports of aggregated and anonymized personally identifiable information; checking your personal or business credit status/profile and identity; and recording and tracking details of your transactions or your customer’s transactions
- Evaluating credit risk, including conducting our own due diligence checks; checking your personal or business credit status/profile and identity; recording and tracking details of your transactions or your customer’s transactions; maintain internal recordkeeping and reporting; identifying and monitoring for fraud; assessing financial and insurance risks; mitigating personally identifiable information security, sector or credit risk; and commercial purposes, such as trend analysis and the use of data analytics to obtain learnings and insight around cardholder transaction patterns and usage
- Fraud monitoring, including monitoring merchant or other customer transactions in an effort to detect and prevent fraud; maintaining internal recordkeeping and reporting; preparing and furnishing compilations and analyses as well as other reports of aggregated and anonymized personally identifiable information; and providing or developing more innovative and effective fraud monitoring services for our merchants or other customers
- Security, including conducting our own due diligence checks; administering the Burton Portal and services for internal operations, including troubleshooting; keeping the Burton Portal and services safe and secure; maintaining internal recordkeeping and reporting; identifying and monitoring for fraud; and mitigating personally identifiable information security, sector or credit risk
- Marketing, including marketing or market research; performing analysis and comparisons; maintaining internal recordkeeping and reporting; improving and developing our business; providing personally identifiable information about the Burton Portal and services you requested, purchased or which may be of interest to you; providing or developing more innovative and effective services for our partners, merchants or other customers; communicating with you; creating promotional materials, social media site integration and interaction; notifying you about important changes or developments to the Burton Portal and services; improving the Burton Portal and services, and ensuring content is presented in effective way; allowing you to participate in interactive features of the Burton Portal
- Product development, including providing or developing the Burton Portal and services to be more innovative, user friendly and effective; maintaining internal recordkeeping and reporting; preparing and furnishing compilations and analyses as well as other reports of aggregated and anonymized personally identifiable information
- Customer Service/Account Management, including enabling you to contact us; providing training; authorizing and establishing commercial user and merchant accounts; maintain internal recordkeeping and reporting; enabling you to upload and/or store personally identifiable information; obtaining your views on the Burton Portal and services; allowing you to participate in interactive features of the Burton Portal; responding to any inquires by you; providing the Burton Portal and services to you and your business; subscribing you to our services; registering your use of services where applicable, processing your application for services; and notifying you about important changes or developments to the Burton Portal or services
- Operations, including IT, security and analytics services
- Risk Management, including fraud mitigation and management, authentication and acceptance
- Transaction Processing, including compliance monitoring, card brand operations, disputes/chargebacks, capturing payments, settlement, gateway services, pre-paid card processing and program management and authorization
We may respond to concerns and questions you have sent to our email address, and may send you promotions and news about the services you use or other products and services we think may be of interest to you.
4. HOW AND WHEN WE SHARE PERSONALLY IDENTIFIABLE INFORMATION
Before we share your personally identifiable information, we ensure there are adequate safeguards in place to protect the processing of that data. Except where permitted, we do not sell, rent, share or otherwise disclose your personally identifiable information to third parties for the third party’s commercial purposes or disclose personally identifiable information that could identify you personally to anyone, except as described in this Privacy Statement.
We may disclose your personally identifiable information to third parties for the following purposes:
- Legal or regulatory purposes, including when required or permitted to do so by law or regulations, including for tax purposes or to comply with financial services regulations; in the course of litigation; when following requests from governmental or public authorities; and when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others
- Business purposes, including improving and developing our business, business partners, suppliers and sub-contractors for the performance of any contract we may enter into with them or you, transferring personally identifiable information and/or assets in the event of a merger, acquisition, sale, bankruptcy filing, or other corporate restructuring (if we or substantially all of our assets are acquired by a third party, in which case personally identifiable information held by it about its customers will be one of the transferred assets); and if we sell or buy any business or assets, in which case we may disclose your personally identifiable information to the prospective seller or buyer of such business or assets
- Suppliers who assist us with the provision of its services, including fulfilling or processing application forms, processing payments; managing credit, security, sector and fraud risk, market research and survey activities
- Email communications. If you send us an email with questions or comments, we may use your email address to respond to your questions or comments, and we may save your questions or comments for future reference. We may email you when you inquire about our business or our family of companies or our Services or when you consent to being contacted by email for a particular purpose. You may unsubscribe from receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of any marketing emails we send, or by emailing us as provided in the Contact Us section below. For security reasons, we do not recommend that you send personal personally identifiable information, such as passwords, social security numbers, or bank account personally identifiable information, to us by email.
- Transfer of Assets. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personally identifiable information we have about you will be transferred to and used by this acquiring entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personally identifiable information may be considered an asset of ours and as such may be sold or transferred to third parties
- Legal Necessity. Notwithstanding anything herein to the contrary, we reserve the right to disclose any personally identifiable information about you if we are required to do so by law, with respect to copyright and other intellectual property infringement claims, or if we believe that such action is necessary to fulfill a government request; conform with the requirements of the law or legal process; protect or defend our legal rights or property, the Burton Portal, or other members of our family of companies; or in an emergency to protect the health and safety of the users of the Burton Portal or the general public.
5. CALIFORNIA DO NOT TRACK DISCLOSURES
Certain browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether or not that reflects your preference. Providing DNT Notice is often touted as a means to ensure that cookies, web beacons and similar technology are not used for preference based advertising purposes – that is, to restrict the collection of personally identifiable information your online activities for advertising purposes. Since we do not engage in targeted advertising, we do not track your online activity while on the Burton Portal for those purposes and do not have processes in place for you to submit any preference regarding tracking.
6. YOUR CALIFORNIA PRIVACY RIGHTS:
Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information, as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the personally identifiable information in writing at: i3 Verticals, LLC, 40 Burton Hills Road, Suite 415, Nashville, TN 37215.
7. OUR COMMITMENT TO SECURITY
We value your confidence and have implemented administrative, technological and physical security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the personally identifiable information under our control. We cannot, however, guarantee or warrant the security of any personally identifiable information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information. We recommend that you take steps to protect the privacy and security of your personal and payment personally identifiable information and your activity while using the Internet. Where we have has given you (or where you have chosen) a password or access code enabling you to access certain parts of the Burton Portal, you are responsible for keeping this password and/or access code confidential. You should not share your password or access code with anyone and you should use all reasonable methods to ensure that there is no unauthorized use. You therefore authorize us to act upon instructions and personally identifiable information received from any person that enters your user ID and password and you agree to be fully responsible for all use and any actions that may take place during the use of your account. You also agree to promptly notify us of any personally identifiable information you have provided which has changed.
8. CHILDREN UNDER 13
We have no way of distinguishing the age of individuals who access the Burton Portal. The features, programs, promotions and other aspects of the Burton Portal requiring the submission of personally identifiable information are not intended for children. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us please contact us at [email protected] A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof, and also we carry out the same Privacy Statement.
9. REVISIONS TO OUR PRIVACY STATEMENT
This Privacy Statement is effective as of the date stated above. We reserve the right to revise this Statement or any part of it from time to time. We will post a new or revised Statement to the Burton Portal, and we suggest you review our Privacy Statement periodically when accessing the Burton Portal.
10. CONTACT PERSONALLY IDENTIFIABLE INFORMATION
You may contact us at [email protected] if you have questions or comments about our Privacy Statement.