Privacy Policy

CINCHKEY INC. PRIVACY POLICY
Effective Date: November 30, 2016

SCOPE

Cinchkey Inc. respects and is committed to protecting the privacy of our users including Merchants, customers and others who visit our website. This Privacy Policy (this “Policy”) explains what information Cinchkey, Inc. and our affiliates and subsidiaries (collectively referred to as “Cinchkey,” “we,” “us” and “our”) may collect about you via our website and through our program and services (collectively, “Services”) and how we use, share and protect that information.


CONSENT

When you submit business and personal information (as applicable) to apply for our Services and each time you use our Services, you are indicating your acknowledgement and consent to the collection, use and disclosure of information about you collected through our Services (either directly or through access to third party websites where your information is stored) as set forth in this Policy. We may revise this Policy without advance notice to you but we will let you know of any changes by posting a revised Policy on our website with a new effective date. If you do not accept the terms outlined in this Policy or a revised Policy, please do not use our Services.


WHAT INFORMATION WE COLLECT

We collect business and personal information (as applicable) that you provide while using our Services. Based on your use of our Services, we may collect the following information:

From individuals:

• your name

• your email address

• your date of birth

• your address and telephone number

• your social security number

• your bank account and credit card account

• credentials for and information from third party sites

From businesses:

• your business name

• your business email address

• your business address and telephone number

• your business EIN

• credentials for and information from third party sites

• your customer information

• your bank account and credit card account

• general information about your business, including information related to how you receive and process payments from your customers, banking information, vendor information, and other information we may obtain from time to time during our relationship with you


INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive information about you from third parties, such as credit bureaus, identity verification services and other public records or websites, and third-party sites you provide us access to. For example, if you access a third-party connection or log-in through our website, or otherwise link an account to the website, that third party may pass certain information about you and your use of its service to us. This information could include an access token necessary to access that service, any information that you have permitted the third party to share with us and any information that you have made public in connection with that service. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking them to our website. You may also unlink your third-party account from our website by adjusting your settings on the third party service. If you unlink your third party account, we will remove the information collected about you in connection with that service.


HOW WE COLLECT INFORMATION

We collect information about you:

• from you, when you register or apply on our website; use our website; from your transactions, including purchases and payments; and from your communications with us including email, text message and telephone;

• from third parties such as credit bureaus, identity verification services and other public records or websites; and

• from third parties which hold your account(s) that you give us access to.


WHY WE COLLECT INFORMATION

We may use and disclose your information that is collected through our Services in accordance with applicable law, where appropriate, which uses may include:

• providing and managing Services you have requested;

• verifying your identity and authenticating you;

• creating customer and Merchant profiles on our website;

• protecting against fraud or security threats, and otherwise managing risks;

• communicating with you regarding services that may be of interest;

• evaluating and improving our website and other offerings;

• tailoring our Services and otherwise enhancing the customer and Merchant experience;

• satisfying legal or regulatory requirements or law enforcement requests; and

• as permitted by applicable law.


WHAT INFORMATION WE MAY SHARE WITH THIRD PARTIES

We may use and disclose your information that is collected through our Services to run our everyday business and in accordance with applicable law. We do not share, sell, rent or trade your personal information with any third party other than as described below. We may share your information with:

• Merchants who are registered with the Site, not including payment account information;

• Other website visitors limited to describe publically available information, comments you post, campaign funding activity;

• Agents and service providers who help us with parts of our business operations, such as fraud prevention, servicing activities, payment processing, marketing and technology services;

• Law enforcement, government officials, or other third parties as required by law and when we believe that such disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, regulatory request or other legal process; and

• Other third parties but only if you consent or direct us to do so.


HOW WE PROTECT YOUR INFORMATION AND USE COOKIES

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects and other tracking technologies for various purposes, such as fraud prevention and monitoring our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online Services.

To help operate our website, enhance your experience and collect information about online activity, we may place small data files on your computer or other device. These data files may be in the form of cookies, pixel tags, local shared objects or other similar technologies. Cookies and similar technologies enable us to personalize our website and Services for you. These technologies may allow us to store and manage your preferences and settings, measure and analyze how you use our website and the effectiveness of our communications, offer services and help us improve our services and security.

• “Cookies” are small amounts of data a website can send to a visitor’s web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our online Services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies, but doing so may degrade your experience with our online Services.

• Clear GIFs, pixel tags or web beacons—which are typically one-pixel, transparent images located on a webpage or in an email or other message—or similar technologies may be used on our website and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online Services. These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement.

• Local shared objects, sometimes referred to as “flash cookies,” may be stored on your hard drive using a media player or other software installed on your device. Local shared objects are similar to cookies in terms of their operation but may not be managed in your browser in the same way. For more information on managing local shared objects, click https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Most browsers provide you with the ability to block, delete or disable these technologies. If you choose to reject cookies or similar technologies, some Services may not be available or some functionality may be limited or unavailable. Please review your browser’s help pages for assistance with changing your settings.


LINKS TO OR FROM OTHER WEBSITES AND SERVICES

Our website may contain links to other sites that we do not own or operate (“third-party websites”). When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked third-party website before providing any information on that website.


“DO NOT TRACK” SIGNALS

We do not respond to “do not track” signals from your browser at this time. To learn more about how “do not track” works, click https://allaboutdnt.com.


SECURITY SAFEGUARDS

We use security controls to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your personal and business information in our custody or control.


CHILDREN’S PRIVACY

We do not knowingly solicit from, and the Services are not intended for, children under 13 years old, and children should not provide personal information online. If a parent or guardian becomes aware that his or her child has provided us with information, he or she should contact us. We will delete such information from our files.


HOW YOU CAN CONTACT US

If you have questions or concerns regarding this Policy, please contact:

Cinchkey Inc.
7 World Trade Center, 10th Floor,
250 Greenwich St.
New York, NY 10007
support@cinchkey.com