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Copyright © 2010 Finsphere Corporation | Patents Pending | All rights reserved.
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Finsphere Privacy Policy
Finsphere Corporation (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our Site, located at http://www.Pinpoint-fraud.com/. Capitalized terms not defined in this Privacy Policy have the meaning given in our Terms of Use, located at http://www.pinpoint-fraud.com/terms-conditions.
We encourage you to review this Privacy Policy carefully.
We welcome your comments or questions regarding this Privacy Policy. Please contact us at the following email address: OfficeOfPrivacy@pinpoint-fraud.com (see section 10 below for additional contact information).
1. User Consent. By submitting Personal Data through our Site or Services (as defined in the Terms of Use), you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Data in accordance with this Privacy Policy. 2. A Note About Children. We do not intentionally gather Personal Data about visitors who are under the age of 13. 3. A Note to Users Outside of the United States. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States and/or the United Kingdom, where laws regarding processing of Personal Data may be less stringent than the laws in your country. We adhere to the United States-European Union Data Protection Safe Harbor Principles and the United States-Swiss Data Protection Safe Harbor Principles, which can be located at http://www.export.gov/safeharbor. 4. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below. (a) Personal Data You Provide to Us. (i) Your Requests. In order to provide the Services, we collect your first name, last name, email, company, title (optional), mobile phone details, country of residence, and postal or zip code. (ii) Company Accounts and Services. We collect your first, middle and last name, e-mail, home postal code and home country, mobile phone number, username and password when you create an Company Account (as defined in the Terms of Use). When you order Services on our Site, we will provide a link to a third party billing provider (“Third Party Billing Provider”) who will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. Our Third Party Billing Provider is required to be compliant with the Payment Card Industry Data Security Standards. (iii) Phones and Location Information. When you add a Phone (as defined in the Terms of Use) to the Service, we will collect information regarding the Phone, including the number, Carrier (as defined in the Terms of Use), and device information. We may collect from your Carrier the GPS and/or cell site location of your Phone to provide you the Service. You expressly consent to your Carrier’s release and disclosure of your location data to the Company for the provision of the Service. You also consent to the Company using your location data to provide the Service. You acknowledge that the Service’s accuracy can vary depending on your location (i.e., whether you are in a city vs. country location). You acknowledge that the Company has the right to suspend or terminate the Service. (iv) Third Party Accounts. When you add a Third Party Account (as defined in the Terms of Use) to the Service, we will collect your Access Credentials (as defined in the Terms of Use) and other relevant information necessary to enable our Service to access that Third Party Account and your data contained within that Third Party Account. We will only use your Access Credentials to access your Third Party Accounts to the extent necessary to provide the Services to you. You hereby (1) expressly consent to our use of your Access Credentials on your behalf for such purpose; (2) designate and appoint Company as your agent and attorney-in-fact, to act on your behalf to use your Access Credentials and to do all other lawful acts on your behalf for such purpose, with the same legal force and effect as if done by you. We will protect your Access Credentials in accordance with the security provisions in this Privacy Policy. (v) Other. If you provide us feedback or contact us via e-mail (e.g.in response to a request for customer feedback question posted on our Site), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply, and any information that you submit to us. When you participate in one of our surveys, we may collect additional profile information. We may also collect Personal Data, such as at other points in our Site that state that Personal Data is being collected. (b) Personal Data Collected via Technology. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect Personal Data from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We may also use Cookies (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit our Site or access your Company Account on our network. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas of our Site may not work properly. 5. Use of Your Data (a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Company uses your Personal Data in the following ways: (1) to facilitate the creation of and secure your Company Account on our network; (2) identify you as a user in our system; (3) provide improved administration of our Site and Services; (4) improve the quality of experience when you interact with our Site and Services; (5) send you a welcome text message and/or e-mail to verify ownership of the Phone and/or e-mail address provided when your Company Account was created; (6) send you administrative text messages and/or e-mail notifications, such as security or support and maintenance advisories; (7) send you Service related text messages and e-mails; (8) respond to your inquiries related to customer service or other requests; (9) to provide you with hardcopy or electronic newsletters, or surveys; (10) to send upgrades and special offers related to our Services and for other marketing or promotional purposes of Company; and (11) to make telephone calls and/or send text messages and/or emails to you, from time to time, as a part of secondary fraud protection or to solicit your feedback. (b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. Company reserves the right to use and disclose Anonymous Data to third party companies at its discretion. 6. Disclosure of Your Personal Data (a) Disclosure to Service Providers. We do not sell, trade, or rent the Personal Data collected from our Services to other entities. We may share your Personal Data with third party service providers (including our Third Party Billing Provider) to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of Company Accounts; or to provide technical support. These third party service providers are contractually required not to use your Personal Data other than to provide the services requested by Company and to use industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. You expressly consent to the sharing of your Personal Data with our contractors and other service providers for the sole purpose of providing services to you. (b) Affiliates. We may share some or all of your Personal Data with a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to comply with the terms of this Privacy Policy. If another company or entity acquires our company or our assets, we may disclose your personal data to that company or entity. (c) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on Company; or (b) protect or defend the rights or property of Company or users of the Services. 7. Third Party Websites. Our provision of a link to any other website or location, is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our Site and go to another site. During this process, another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. 8. Your Choices Regarding Your Personal Data (a) Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data. (i) We will periodically send you free newsletters and e-mails that directly promote the use of our Site or the purchase of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you notice of any updates to our Terms of Use or Privacy Policy and emails regarding the Service you ordered. (ii) We may send you text messages to your Phone to provide you the Services. When you receive text messages from us, you may indicate a preference to stop receiving further text messages from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the text message you receive or by contacting us directly (please see contact information below). You expressly consent to the Company sending you Service related communications as text messages to your Phone as described above. You agree that you are solely responsible for any and all fees billed to your Phone as a result of these text messages. (b) Changes to Personal Data. You may change any of your Personal Data in your Company Account by logging into your Company Account and editing your profile within your Company Account or by sending an e-mail to us at the e-mail address set forth below, after which we will make changes to your Personal Data in accordance with your e-mail instructions. You may request deletion of your Personal Data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. 9. Security of Your Personal Data. (a) Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Without limiting the generality of the foregoing, Company employs the following security procedures: (i) We require you to enter a password to access your Company Account information. Please do not disclose your Company Account password to unauthorized people. (ii) We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Company Accounts and systems from unauthorized access. (iii) Our servers are in a secure facility. Access requires multiple levels of authentication, including biometrics recognition procedures. Security personnel monitor the system 7 days a week, 24 hours a day. (iv) Our databases are protected from general employee access both physically and logically. We encrypt your Company Account password so that your password cannot be recovered, even by us. All data on backup drives and tapes is encrypted. (v) We enforce physical access controls to our buildings. (vi) No employee is permitted to put any sensitive content on any insecure machine (i.e., nothing can be taken from the database and put on an insecure laptop). (vii) We have been verified by Verisign for its use of Extended Validation (EV) SSL encryption technologies and audited by TRUSTe for its privacy practices. In addition, we test the Site daily for any failure points that would allow hacking. (viii) However, it is important to understand that these precautions apply only to our Site and systems. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites. (b) Despite these measures, you should know that Company cannot fully eliminate security risks associated with Personal Data and mistakes may happen. (c) You acknowledge that Company is not a financial institution that provides financial products or services to consumers and therefore Company is not subject to the Gramm-Leach-Bliley Act. 10. TRUSTe (a) Company is a Participant in the TRUSTe Privacy Seal Program. TRUSTe is an independent organization whose mission is to advance privacy and trust in the networked world. This privacy statement covers the Web site http://www.Pinpoint-fraud.com/. As this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices monitored for compliance by TRUSTe. If you have questions or concerns regarding this statement, you should first contact us at OfficeOfPrivacy@pinpoint-fraud.com. If you do not receive acknowledgment of your inquiry, or if your inquiry has not been satisfactorily addressed, you should then contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with the Web site to resolve your concerns.
11. Contact Information. Company welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following address or email address: You can submit e-mails to: OfficeOfPrivacy@pinpoint-fraud.com
You may also contact us by mail at: Finsphere Corporation 505 106th Ave NE Suite 200 Bellevue, WA 98004
12. Dispute Resolution. If you believe that Company has not adhered to this Privacy Policy, please contact Company at the contact information provided above. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and Company are unable to reach a resolution to the dispute, you and Company will settle the dispute under either European Data Protection Authorities, Swiss Data Protection Authorities, the Better Business Bureau (BBB) EU Safe Harbor Dispute Resolution Procedure, or in accordance with applicable law. 13. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision in accordance with the Terms of Use. Changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Company Account with us. Continued use of our Site or Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes. This Privacy Policy was last revised on 10 January 2012. |