MineralTree Privacy Notice

MineralTree, Inc., a Global Payments company (“MineralTree,” “we,” “us”), respects your concerns about privacy. In this Privacy Notice, we describe how we collect and process personal information about users of our websites, blogs, social media pages, and other online media. We also describe how we collect and process personal information about our prospects and customers, about the end users of our solutions, and about internet users and other individuals for cybersecurity and threat assessment purposes.

Please note that if you do not fall within any of those categories, this Notice does not apply to you. For example, MineralTree provides solutions that improve and automate key financial processes for businesses, and our business customers use those solutions to collect and process personal information about their own contacts, such as the individuals to whom they owe payments for services. If you are an individual whose personal information was collected and processed by one of our business customers using one of our solutions, and you have questions about that business’s privacy practices, you should refer to that business’s privacy notice or contact that business directly.

This Notice covers the following topics:

• Personal Information We Collect
• Data Anonymization and Aggregation
• Sources of Personal Information
• How We Use the Personal Information We Obtain
• Our Processing of Sensitive Personal Information
• How We Share the Personal Information We Collect
• Cookies and Other Tracking Technologies
• External Links
• Our Relationship with Affiliate Companies (Including Sharing and Cross-Border Transfers)
• Our Commitment to Data Security
• Login Details and Your Responsibility
• Managing Your Preferences
• Your Legal Rights
• UK & EU Resident Rights
• Information for California Residents
• Children
• Changes & Updates
• Choice of Law
• Arbitration
• Contact Us

Personal Information We Collect

We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so. Subject to your consent if required by law, we may collect the following categories of personal information:

• Identifiers, including your name and contact details such as telephone number, employment information, and email address;
• Sensitive Personal Information, limited to any username and password you may use to log in to our website or our solutions (see “Login Details and Your Responsibility” below) and any payment information you may provide to us in connection with your use of our solutions;
• Commercial Information, including information about your business and about your preferences regarding our solutions and related services, or our partners’ and affiliates’ solutions and related services, which may be of interest to you (see “Managing Your Preferences” below);
• Internet/Electronic Activity Information, including information we collect automatically from all visitors to our websites, such as IP address, browser type, operating system and referral page; information about your use of our solutions; and information collected through the use of cookies and other tracking technologies, to the extent you have not disabled them;
• Geolocation Information, including your physical address (if you provide it to us), as well as location information derived from other data, such as IP address; and
• Records of Communications we have with you, including any information that you provide to us through web forms, through our solutions, through email, or otherwise, as well as recorded calls, subject to your consent if required by law.

Data Anonymization and Aggregation

Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data, for example, for statistical analysis (including analysis of trends), to carry out actuarial work, to tailor products and services, and to conduct risk assessments and analyses of costs and charges in relation to our products and services. We may share anonymized or aggregated data with our global affiliates and with other third parties., and this Notice does not restrict our use or sharing of any non-personal, summarized, derived, anonymized or aggregated information.

Sources of Personal Information

Information that you provide to us:  We collect personal information that you provide to us when you contact us, set up an account with us, use our solutions, or otherwise interact with us.  For example, if you use a web form to request information from us, we may ask for your name, contact information, and information about your business.  Providing us with personal information about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of our solutions and services.

Information collected from third parties:  We collect personal information about you from third parties in the course of providing our services to you.  For example, we may collect Identifiers and Commercial Information from a referral partner or other third-party in order to contact you about the services we provide. We may also receive business-related information about you from third-party companies that supplement our business customer records with firmographic and professional information.

Information collected through technology:  When you visit our websites, use our solutions, or interact with an email we send to you, we may collect certain information automatically, including your account or device identifier and usage information such as the pages that you visit, the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our services.  You have the ability to express your preference regarding some of the ways we collect information through technology in some of our services (see “Cookies and Other Tracking Technologies” for more information).

How We Use the Personal Information We Obtain

Subject to your consent if required by law, we may use your personal information for the following business and commercial purposes:

• To provide services to you;
• To contact you regarding any inquiry you make or to fulfill a request, such as, for example, a request for information about our solutions and services;
• To contact you if you have signed up for e-newsletters or any other updates, communications or publications;
• To verify or maintain the quality and safety of our solutions and services and to improve, upgrade, or enhance our services;
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute individuals responsible for that activity;
• To enable internal record keeping and administration of records;
• To personalize your experience when you use our website, solutions or services;
• To track information about our interactions with you, including, but not limited to, counting advertising impressions to unique visitors and verifying positioning and quality of advertising impressions;
• To send you direct marketing material, subject to your consent if required by applicable law (see “Managing Your Preferences” below); and
• To comply with applicable laws and regulations.

We retain personal information in an identifiable format only for as long as is necessary to complete the legitimate business or legal purposes for which we collected it. The specific retention period can therefore vary depending on the nature of your relationship with us. In many cases, the retention period will correspond to the period for which you have an account or other type of business relationship with us, plus a defined period after that relationship ends, determined by our regulatory requirements.

Our Processing of Sensitive Personal Information

“Sensitive Personal Information” includes personal information defined as sensitive under any applicable privacy and data protection laws. It can include account log-in information, as well as payment account information. When we collect Sensitive Personal Information about you, we will limit our use and disclosure of that information to what is necessary to provide the information, offer the solution, or perform the service requested by you, unless we are required to do otherwise under applicable laws. In addition, we may process Sensitive Personal Information to detect and prevent security incidents or fraud, to ensure the physical safety of natural persons, for short-term transient uses (when consistent with the purpose for which the information was collected), and to verify or maintain the quality or safety of any solutions that we offer or services that we perform.

Under some privacy and data protection laws, you may have the right to limit the processing of your sensitive personal information.  You can find more information about your rights in other sections of this Notice including any applicable section directed at residents of the state or country in which you reside.

How We Share the Personal Information We Collect

We are a Global Payments company, meaning we are a part of a multinational family of businesses headquartered in the United States, with affiliates in countries around the world. Your personal information may therefore be disclosed to recipients within our organization who are located outside of your country, including to our affiliates (see “Our Relationship with Affiliate Companies” below).

For each category of personal information we collect, we may share such information in the manner and for the purposes described below:

• With companies engaged to help us run our business, subject to your consent if required by law. These types of companies may include resellers and distributors of our solutions; service providers retained to perform functions on our behalf or to provide services to us, including (without limitation) legal, accounting, audit, consulting and other professional service providers; and providers of other services related to our business. Portions of our services may be provided by organizations with which MineralTree has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as necessary for their service delivery and for no other purpose;
• With third parties with whom you have a relationship, such as a financial institution or independent sales organization who referred you to MineralTree for services;
• With logistics service providers to enable the delivery of packages to individuals;
• With other third parties with whom you direct us to your personal information, subject to your specific consent for such data sharing;
• With regulators including state and federal agencies, card payment networks, issuing banks and other parties required to enable compliance with laws, regulations and industry standards related to transaction processing and in order to obtain commercial and credit information to establish, maintain or renew a customer’s contract(s), as may be required to provide any of the services for which a customer has subscribed, or to comply with the rules and regulations of any credit or debit card payment network or otherwise in accordance with this Notice;
• In response to a court order or a request for cooperation from a regulatory, law enforcement or other government agency; to establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
• When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend the rights, property or safety of MineralTree, its customers, staff, suppliers or others; and
• To purchasers and, subject to local legal requirements, prospective purchasers in the event that MineralTree and/or its global affiliate companies (as applicable) disposes of, or considers the disposition of, any of its/their business or assets.

We do not sell your personal information to third parties for monetary compensation, and we do not share your personal information with third parties for cross-context behavioral advertising.

Cookies and Other Tracking Technologies

We use cookies and similar tracking technologies to help us retain information about your use of our websites.  Using cookies, we collect information like country location, language preference and other settings. Cookies can also help us to operate our websites more efficiently, remember you for future visits, and enhance your user experience by providing real-time tools such as user guides and chatbots

The cookies and tracking technologies that we may use within our websites fall into the following categories:

Strictly Necessary. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you, such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the websites.

Performance. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our websites. They help us to know which pages are the most and least popular and to see how visitors move around the websites. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our website, and we will not be able to monitor its performance.

Functionality. These cookies enable the websites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some of these services may not function properly.

Targeting. These cookies may be set through our websites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other websites.  They work by uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

How to Delete or Block Cookies and Other Tracking Technologies

On some websites, when technically feasible, we will enable tools to help you make choices about cookies and other tracking technologies. You may also delete or block cookies at any time by changing your browser settings. You can click “Help” in the toolbar of your browser for instruction or review the cookie management guide produced by the Interactive Advertising Bureau available at www.allaboutcookies.org. If you delete or block cookies, some features of the websites may not function properly.

External Links

MineralTree may provide links on our websites and within our solutions to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or the products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our websites and to read the privacy statements of each and every website that collects personal information. This Notice applies solely to information collected by us. You should read any other applicable privacy and cookies notices carefully before accessing and using such other websites.

Our Relationship with Affiliate Companies (Including Sharing and Cross-Border Transfers)

Subject to your consent if required by applicable law, we may appoint an affiliate company to process personal information in a service provider role. We will remain responsible for that company’s processing of your personal information pursuant to applicable data privacy laws.

Because our affiliate companies are located around the globe, your personal information may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence.

We take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, are carefully managed to protect your privacy rights and interests and limited to countries which are recognized as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights.

Our Commitment to Data Security

We maintain administrative, technical and physical safeguards designed to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.

Please remember that communications over the internet, such as emails, are not secure.  We seek to keep secure all confidential information and personal information submitted to us. However, like all website operators, we cannot guarantee the security of any data transmitted through the internet.

Login Details and Your Responsibility

If you use our solutions, we will collect and process your personal information as necessary to set up and administer an account for you. It is your responsibility to protect the login credentials that we provide to you from compromise, and you are required to adhere to the security procedures we establish in the documentation we provide you as part of the services.

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of our global affiliates and third parties. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, we may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.

We will take steps to ensure that any direct marketing from us will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in email, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

Your Legal Rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have the right to:

• Know whether we process your personal information;
• Know how your personal information is used;
• Access, request and receive the personal information we have collected in a portable manner;
• Object to having your personal information sold or shared; and
• Request that we delete your personal data.

For some users, we have additional disclosures in the sections of this Notice directed at users based on where they reside.  You may contact us using the information in the “Contact Us” section of this Notice for additional information about how to exercise your rights.

UK and EU resident rights

Information for California Residents

If you are a California resident, this section applies to you, in addition to the rest of the Notice.

California Shine the Light

If you are a resident of California, you may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the information provided in the “Contact Us” section of this Notice.

Categories of Personal Information We Collect and Our Purposes for Collection and Use

You can find a list of the categories of personal information that we collect in the “Personal Information We Collect” section above. For details regarding the sources from which we obtain personal information, please see the “Sources of Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “How We Use the Personal Information We Obtain” section above.

Categories of Personal Information Disclosed and Categories of Recipients

Our disclosures of personal information are described in the “How We Share the Personal Information We Collect” section above. To further clarify the content of that section, we disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

We share Identifiers with: service providers, affiliates, and third-party partners.

• We share Commercial Information with: service providers, affiliates, and third-party partners.
• We share Geolocation Information with: service providers, affiliates, and third-party partners.
• We share Payment Information with: service providers who enable the processing of payments and third party partners such as the applicable card schemes.
• We share Internet/Electronic Activity Information with: service providers and third-party partners.

As a California resident, you have rights with regard to your personal information. You can contact us using the information provide in the “Contact Us” section of this Notice with regard to the following rights: