Collection of Personal Information

 
In order to offer you the best possible experience using the Services, Solutran may collect the following information:

1. Information You Provide to Solutran

   
    
   The types of Personal Information you provide may include name, address, telephone number, e-mail address, and other unique information. You may also provide bank account, payment card and other financial information, and transaction information including when and where transactions occur, the identities of transacting parties, a description of the transactions, the payment or transfer amounts, billing information, and the devices and payment methods used to complete transactions.
   
   Solutran may collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information collected may include location information, device information, information about how you use the Services, and information provided to you by customers.
   
   

2. Information Provided to Solutran by Third Parties

   
   
   Solutran may combine the information it collects from you with information about you that Solutran receives from other sources in order to provide you with a better experience and to improve the quality of the Services. Depending on your use of the Services, Solutran may collect information about you from third parties and publicly available sources to verify your identity and for any fraud detection process, collection procedures, or as may otherwise be required by applicable law.
   
   

3. Direct Communication with Solutran

   
   
   When you send e-mail or other communications to Solutran, Solutran may retain those communications in order to process your inquiries, respond to your requests and improve the Services. Solutran may also collect any other information that you voluntarily provide related to the Services.
   
   

4. Cookies and Other Usage Information

    
   
   In addition to the information you provide, the Services uses “cookie” technology to enhance and personalize your experience with the Services. Cookies, web beacons, or similar technologies are small pieces of data that Solutran stores on your computer or device. Certain cookies Solutran uses last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer. These “cookies” help Solutran to: (1) improve and customize Services content and offerings; (2) authenticate you when you use the Services; (3) remember your Services preferences and registration information; and (4) measure and research, via statistics and data collection, the effectiveness of the Services offerings and e-mail communications. By using the Services, you permit us to collect and use your information from activity on devices you use in accordance with this Privacy Notice.
    
   Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set. You may disable your cookie information by adjusting the settings preferences on your personal computer or mobile device at any time. Keep in mind that cookies do not identify a specific user and are not used to collect any Personal Information.
    
   The Services may also use automated data collection tools to collect standard information about your Internet access, such as your browser type and language, access times, and the address of the website from which you arrived at any Solutran site. It may also collect information such as your Internet Protocol address, the website pages on the Services that you view, the links that you click, your use of e-mails sent to you from us (such as when you open the e-mail or click on a link in the e-mail).
   

No Information From Children Under Age 13

 
The Services are not directed at children under the age of 13. If Solutran learns that it has collected any Personal Information from a child under the age of 13, Solutran will promptly delete that information. If you believe Solutran has collected Personal Information from a child under the age of 13, please write to Solutran at the address provided above.
 

Personal Information Use

 
Solutran may use your Personal Information for any of the following purposes: (1) to provide the Services to you, including the display of personalized content, offers and advertising; (2) to process or record payment transactions or money transfers; (3) to display your historical transaction information; (4) to investigate, detect, prevent or report fraud, misrepresentations, security incidents, or other potentially prohibited or illegal acts; (5) to enforce the General Terms of Service; (6) to verify your identity; (7) to help address problems with and the functioning of the Services; (8) to monitor and conduct internal reviews of the Services; (9) to help Solutran better understand and improve the use of the Services, and to develop new services; (10) to protect the security and integrity of the Services; (11) to comply with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process; (12) to contact you, if necessary or at your request; and (13) to fulfill any other purpose disclosed to you in connection with the Services.
 
IN ADDITION TO THE FOREGOING, BY USING THE SERVICES AND AGREEING TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE DIRECTING SOLUTRAN TO SHARE YOUR PERSONAL INFORMATION AND OTHER INDIVIDUALLY IDENTIFIABLE INFORMATION, INCLUDING INFORMATION SOLUTRAN OBTAINS FROM ITS RETAIL PARTNERS ABOUT YOUR PURCHASING ACTIVITY, WITH THE COMPANY OR ORGANIZATION THAT IS RESPONSIBLE FOR FUNDING THE PROGRAM THROUGH WHICH YOU MAY RECEIVE ACCESS TO CERTAIN SERVICES.
 

Personal Information Sharing

 
Solutran may share your Personal Information with other parties in the following circumstances:

• If Solutran has your consent.
• As explicitly directed by you in the “Personal Information Use” section above;
• To provide information with other users of the Services with whom you interact through your own use of the Services;
• To provide, maintain, and improve the Services, including providing information to service providers who access information about you to perform services on Solutran's behalf, as well as financial institutions, payment networks, payment card associations, and other entities in connection with the Services;
• If Solutran determines that there has been a violation of Services policies;
• To enforce or comply with the General Terms of Service referenced herein or other applicable agreements or policies;
• If Solutran has reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with Solutran's rights or property, other users of the Services or anyone else that could be harmed by such activities;
• To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and/or
• To provide information to a company that acquires, is acquired by or is merged with Solutran.

In the general course of business, Solutran will not share your Personal Information with any individual or entity without first obtaining your express consent, except that Solutran may share your Personal Information with (i) the company, organization, entity or other body responsible for providing or overseeing the benefits or other programs you are receiving through the Services, or (ii) any third party necessary to carry out Solutran's obligations to such company, organization, entity or other body.

Non-Personal Information Sharing

 
Solutran may share aggregated and anonymized information that does not specifically identify you or any individual user of the Services within Solutran, its related companies and other third parties.

Data Retention and Disposal

 
In accordance with our data retention policies, and unless a longer retention period is required by applicable law, Solutran will retain your information for as long as you continue to have an account with us or access the Services. Solutran may also retain your information for an additional period of time after you no longer have an account with us or cease to use the Services to resolve any outstanding issues or queries that may arise in relation to your account and use of the Services, and for historical and archiving purposes. This retention period is subject to Solutran's review and modification as necessary to comply with applicable law and at the direction of the company, organization, entity or other body responsible for providing or overseeing the benefits or other programs, or otherwise involved in the administration of such benefits or programs, through the Services.

After the applicable retention period, and in accordance with Solutran's data retention policies, Solutran will dispose of all data in a manner that ensures the information cannot be reconstructed into a usable format.
 

Access to Your Personal Information

 
Depending on your location, and in accordance with applicable laws, you may have the right to request through the contact information above that Solutran disclose certain information to you about its collection and use of your Personal Information over the past 12 months. Once Solutran receives and confirms your verifiable consumer request, and to the extent required by applicable law, Solutran will disclose to you:

• The categories of Personal Information Solutran collected about you.
• The categories of sources for the Personal Information Solutran collected about you.
• Solutran's business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom Solutran shared that Personal Information.
• The specific pieces of Personal Information Solutran collected about you (also called a data portability request).
• If Solutran sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

You may also have rights to access the Personal Information and data held by the company, organization, entity or other body responsible for providing or overseeing the benefits or other programs you are receiving through the Services. Any requests for access to your Personal Rights held by any governmental agencies must be directed to that entity.

California Resident Privacy Rights

 
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. You may find more information about your rights as a California resident by visiting: https://oag.ca.gov/privacy/privacy-laws.
 

Privacy Policy Changes

 
Solutran may amend the Privacy Policy at any time by posting the revised version here or communicating it to you through the Services. The revised version will be effective as of the time it is posted. The most current version will supersede all previous versions. Your continued use of the Services after any revision means that you accept the updated Privacy Policy.
 

ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Additional Privacy Notice for California Residents (“California Privacy Notice”) supplements and is incorporated into the information contained in Solutran's Privacy Policy above. This California Privacy Notice applies only to only those individuals who access or use the Services and who reside in the State of California. This California Privacy Notice is adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.
 

Solutran has collected the following categories of Personal Information from its consumers who reside in California within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Solutran obtains the categories of Personal Information listed above from the following categories of sources:

• Directly or Indirectly from you. For example, from forms you submit to us or from observing your actions on our website.
• Directly or Indirectly from our clients. For example, from information provided to us by our clients related to the services for which Solutran is engage or through information we collect from our clients in the course of performing the services for which Solutran is engaged.
• Directly or Indirectly from activity using any of the Services. For example, from website or mobile app usage or cookies and other details collected automatically.

Personal Information Use

 
Solutran may use your Personal Information for any of the following business purposes: (1) to provide the Services to you, including the display of personalized content, offers and advertising; (2) to process or record payment transactions or money transfers; (3) to display your historical transaction information; (4) to investigate, detect, prevent or report fraud, misrepresentations, security incidents, or other potentially prohibited or illegal acts; (5) to enforce the General Terms of Service; (6) to verify your identity; (7) to help address problems with and the functioning of the Services; (8) to monitor and conduct internal reviews of the Services; (9) to help Solutran better understand and improve the use of the Services, and to develop new services; (10) to protect the security and integrity of the Services; (11) to comply with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process; (12) as described to you when collecting your personal information or as otherwise set forth in the CCPA; (13) to contact you, if necessary or at your request; and (14) to fulfill any other purpose disclosed to you in connection with the Services.

Personal Information Sharing

 
Solutran may disclose your Personal Information with other third-parties for a business purpose. When Solutran discloses Personal Information for a business purpose, it enters a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. If a third-party purchaser of your Personal Information wants to resell such Personal Information, the third-party purchaser is required by law to provide you with explicit notice and an opportunity to opt-out of further sales.

In the preceding twelve (12) months, Solutran has not disclosed or sold any Personal Information covered under the CCPA for a business purpose.

California Resident Rights and Choices Under the CCPA

 
The CCPA provides California residents who are consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Non-Discrimination

 
Solutran will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Solutran will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to This California Privacy Notice

 
Solutran may amend the California Privacy Notice at any time by posting the revised version here or communicating it to you through the Services. The revised version will be effective as of the time it is posted. The most current version will supersede all previous versions. Your continued use of the Services after any revision means that you accept the updated California Privacy Notice.

Contact Information

 
If you have any questions or comments about this California Privacy Notice, the ways in which Solutran collects and uses your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us via our website or the address first listed above.