In order to offer some of
Glowpay.com ’s services and reduce fraud,
Glowpay.com (“
Glowpay.com ” or “we”) may ask you to provide us information
about yourself and your credit card and/or bank account. This
Privacy Policy describes the information we collect and how we
use that information.
Glowpay.com takes the privacy of your personal information very seriously
and will use your information only in accordance with the terms
of this Privacy Policy. We will not sell or rent your personally
identifiable information or a list of our customers to third parties.
However, as described in more detail in Part C below, there are
limited circumstances in which some of your information will be
shared with third parties, under strict restrictions, so it is
important for you to review this Privacy Policy. This Privacy
Policy applies to all services that are hosted on the
Glowpay.com website, whether
Glowpay.com (or its subsidiaries or its affiliates) offers the services.
By accepting the Privacy Policy and Terms of Use in registration,
you expressly consent to our use and disclosure of your personal
information in the manner described in this Privacy Policy. This
Privacy Policy is incorporated into and subject to the terms of
the
Glowpay.com Terms of Use.
Your personal information will be stored and processed on our
computers in the United States. The laws on holding personal data
in the United States may be less stringent than the laws of your
country, but
Glowpay.com will hold and transmit your personal information in a safe, confidential
and secure environment. If you object to your personal information
being transferred or used as described in this Privacy Policy,
please do not register for the
Glowpay.com service.
Notification of Changes
This policy may be revised over time as new features are added
to the
Glowpay.com service or as we incorporate suggestions from our customers. If
we are going to use or disclose your personally identifiable information
in a manner materially different from that stated at the time
we collected the information, you will have a choice as to whether
or not we use or disclose your information in this new manner.
Any material changes will be effective only after we provide you
by e-mail with at least 30 days’ notice of the amended Privacy
Policy (if you have closed your
Glowpay.com account, you will not be contacted to notify you of the amended
Policy and your personal information will not be used or disclosed
in this new manner).
We will post the amended Privacy Policy prominently on our website
so that you can always review what information we gather, how
we might use that information, and whether we will disclose it
to anyone. Please check the
Glowpay.com website at
http://www.glowpay.com at any time for the most current version of our Privacy Policy.
Pages on the
Glowpay.com website may include links to third party websites.
Glowpay.com is not responsible for their operations, including but not limited
to their information practices. Their privacy statements govern
those sites. Users submitting information to or through these
third party websites should review the privacy statement of these
sites before providing them with personally identifiable information.
Required Information
To open a
Glowpay.com account, you must provide your name, company name (if any), address,
phone number, home page (if any), and e-mail address. In order
to make payments through
Glowpay.com , you must provide credit card, debit card or bank account information.
We may also ask you to choose different security questions to
answer. This required information may be necessary for us to process
transactions, issue a new password if you forget or lose your
password, protect you against credit card fraud and checking account
fraud, and to contact you should the need arise in administering
your account.
In order to comply with the Bank Secrecy Act, we will also require
your SSN or TIN if you send or receive certain high-value transactions
or high overall payment volumes through
Glowpay.com . If you choose to register or apply for certain optional features
or products offered through the
Glowpay.com websites, you will be required to provide additional information
to establish that you qualify for such features or products.
Transaction Information
When you use
Glowpay.com to send money to someone else or request money from someone else,
we ask you to provide information related to each transaction,
including the amount of the transaction and the e-mail address
of the third party. We retain this information for each of your
transactions through
Glowpay.com . We also collect the Internet address (IP address) of the computer
or device you use to access your
Glowpay.com account, in order to help detect possible instances of unauthorized
transactions.
Information About You From Third Parties
In order to protect all our customers against potential fraud,
we verify with third parties the information you provide. In the
course of such verification, we receive personally identifiable
information about you from such services. In particular, if you
register a credit card or debit card with
Glowpay.com , we may use card authorization and fraud screening services to
verify that your card information and address matches the information
that you supplied to
Glowpay.com , and that the card has not been reported as lost or stolen.
If you send or receive high overall payment volumes through
Glowpay.com , in some circumstances we may conduct a background check on your
business by obtaining information about you and your business
from a credit bureau or a business information service. If you
incur a debt to
Glowpay.com , we will generally conduct a credit check on you by obtaining
additional information about you from a credit bureau, to the
extent permitted by law.
Glowpay.com , at its sole discretion, also reserves the right periodically
to retrieve and review a business or consumer credit report for
any account, and reserves the right to close an account based
on information obtained during this credit review process.
Additional Verification
If we cannot verify the information that you provide, or if you
request a withdrawal by check to an address other than your verified
credit card billing address, we may ask you to send us additional
information (such as your drivers’ license, credit card
statement, and/or a recent utility bill or other information linking
you to the applicable address), or to answer additional questions
online to help verify your information.
Website Traffic Information
Because of the way that Internet communication standards work,
when you arrive at or leave the
Glowpay.com website, we automatically receive the Internet address of the
site that you came from or are going to. We also collect information
on which pages of our website you visit while you are on the
Glowpay.com site, the type of browser you use and the times you access our
website. We may use this information only to try to understand
our customers’ preferences better and to manage the load
on our servers, so as to improve our service and your experience
with
Glowpay.com . We do not track the websites that you visit before or after
you leave the
Glowpay.com site.
Our Use of “Cookies”
“Cookies” are small files of data that reside on your
computer and allow us to recognize you as a
Glowpay.com customer if you return to the
Glowpay.com site using the same computer and browser. We send a “session
cookie” to your computer if and when you log in to your
Glowpay.com account by entering your e-mail address and password. These cookies
allow us to recognize you if you visit multiple pages in our site
during the same session, so that you don’t need to re-enter
your password multiple times. Once you log out or close your browser,
these session cookies expire and no longer have any effect.
We also use longer-lasting cookies to display your e-mail address
on our sign-in form, so that you don’t have to retype the
e-mail address each time when you log in to your
Glowpay.com account. In addition, we use cookies to process our referral program,
described in Section C below. We may share cookie information
regarding whether or not a certain user is already registered
with
Glowpay.com with certain merchants with whom we have an official co-marketing
relationship.
Customer Service Correspondence
If you send us correspondence, we may retain such information
in the records of your account. We may also retain customer service
correspondence and other correspondence from
Glowpay.com to you. We may retain these records in order to measure and improve
our customer service, and to investigate potential fraud and violations
of our Terms of Use. We may, over time, delete these records if
permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we may offer optional questionnaires and surveys
to our users for such purposes as collecting demographic information
or assessing users’ interests and needs. The use of the
information collected will be explained in detail in the survey
itself. If we collect personally identifiable information from
our users in these questionnaires and surveys, the users will
be given notice of how the information will be used prior to their
participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to, or requests a payment
from, an individual who is not a registered member of
Glowpay.com , we will retain the information that the member submits to us,
including, for example, the other party’s email address
and/or name, for the benefit of the member who is attempting to
contact the non-member, so that the member can see a complete
record of his or her transactions, including uncompleted transactions.
Although this information is stored indefinitely, we will not
market to the non-member in any way at any time. Additionally,
these non-members have the same rights to access and correct information
about themselves (assuming that their email addresses were correct
enough to reach them) as anyone else who uses
Glowpay.com .
Internal Uses
We collect, store and process your personal information on servers
located in the United States. We use the information we collect
about you in order to provide our services and process your transactions,
to provide customer service, to determine your eligibility to
receive offers for special features or products, and to improve
our products and services. At your option (as indicated in your
Glowpay.com user settings), we use the information you provide to access specific
third party services on your behalf and perform the actions that
you request us to perform.
We give access to individually identifiable information about
our users only to those employees who require it to fulfill customer
service requests.
Disclosure to Other
Glowpay.com Customers
If you are a registered
Glowpay.com user, your name, e-mail address, date of sign-up, and other information
may be displayed to other
Glowpay.com customers whom you have paid or who are attempting to pay you
through
Glowpay.com . Your credit card number, bank account and other financial information
will never be revealed to anyone whom you have paid or who has
paid you through
Glowpay.com , except if we are required to do so pursuant to a subpoena or
other legal process.
If you are buying goods or services and paying through
Glowpay.com , the seller of the goods or services may request that you provide
a mailing address that
Glowpay.com has confirmed as matching the billing address in the credit card
system. You do not have to provide this information. If you do
not provide the information, however, the seller may choose not
to accept your
Glowpay.com payment and not to complete the transaction.
Glowpay.com may also disclose to other
Glowpay.com customers the number of payments you have received from Verified
Glowpay.com customers (as defined in the Terms of Use on the
http://www.glowpay.com site), or other aggregate measures that provide an indication
of your reputation with other
Glowpay.com customers.
Disclosure to Third Parties Other Than
Glowpay.com Customers
Glowpay.com will not sell or rent any of your personally identifiable information
to third parties.
Glowpay.com will not share any of your personally identifiable information
with third parties except in the limited circumstances described
below, or with your express permission (and to other
Glowpay.com customers as described above). These third parties are limited
by law or by contract from using the information for secondary
purposes beyond the purposes for which the information is shared.
We share information with companies that help us process the transactions
you request and protect our customers’ transactions from
fraud, such as sharing your credit card number with a service
that screens for lost and stolen card numbers. See “Information
About You From Third Parties” in Section B above. Additionally,
if you go into a negative balance and owe us money, we may share
information with processing companies including collection agencies.
We disclose the information we collect, as described in Section
B above, to companies that perform marketing services on our behalf
or to other financial institutions with whom we have joint marketing
agreements. These companies may be subject to confidentiality
agreements with us and other legal restrictions that prohibit
using the information except to market the specified
Glowpay.com -related products or services, unless you have affirmatively agreed
or given your prior permission for other uses.
We disclose information that we in good faith believe is appropriate
to cooperate in investigations of fraud or other illegal activity,
or to conduct investigations of violations of our Terms of Use.
Specifically, this means that if we conduct a fraud investigation
and conclude that one side has engaged in deceptive practices,
we can give that person or entity’s contact information
(but not bank account or credit card information) to victims who
request it.
We disclose information in response to a subpoena, warrant, court
order, levy, attachment, order of a court-appointed receiver or
other comparable legal process, including subpoenas from private
parties in a civil action.
If a user signs up for a co-branded version of
Glowpay.com through links on our co-branded partner’s website,
Glowpay.com will share with the co-branded partner that user’s name,
e-mail address and physical address in order to provide enhanced
integration between
Glowpay.com ’s services and the services of our co-branded partner.
If a user does not want his or her information shared with
Glowpay.com ’s co-branded partner, he or she should not use this aspect
of the site.
We disclose information to your agent or legal representative
(such as the holder of a power of attorney that you grant, or
a guardian appointed for you).
We share aggregated statistical data with our business partners
or for public relations. For example, we may disclose that a specific
percentage of our users live in British Columbia. However, this
aggregated information is not tied to personally identifiable
information.
As with any other business, it is possible that
Glowpay.com in the future could merge with or be acquired by another company.
If such an acquisition occurs, the successor company would have
access to the information maintained by
Glowpay.com , including customer account information, but would continue to
be bound by this Privacy Policy unless an until it is amended
as described in Section A above.
We share your information with our parent, subsidiaries and joint
ventures to help coordinate the services we provide to you, enforce
our terms and conditions, and promote trust and safety.
Our Contacts with
Glowpay.com Customers
We communicate with users on a regular basis via e-mail to provide
requested services, and we also communicate by phone to resolve
customer complaints or investigate suspicious transactions. We
use your e-mail address to confirm your opening of a
Glowpay.com account, to send you notice of payments that you send or receive
through
Glowpay.com (including referral payments described below), to send information
about important changes to our products and services, and to send
notices and other disclosures required by law. Generally, users
cannot opt out of these communications, but they will be primarily
informational in nature rather than promotional.
We also may use your e-mail address to send you other types of
communications that you can control, including tips, newsletters,
customer surveys and notice of special third-party promotions.
You can choose whether to receive some, all or none of these communications
when you complete the registration process, or at any time thereafter,
by logging in to your account on the
Glowpay.com website and changing your user preferences. You can also change
your choices at any time through the same procedure.
In connection with independent audits of our financial statements
and operations, auditors may seek to contact a sample of our customers
to confirm that our records are accurate. However, these auditors
cannot use personally identifiable information for any secondary
purposes.
Internet Address Information
We use IP addresses, browser types and access times to analyze
trends, administer the site, improve site performance and gather
broad demographic information for aggregate use.
Your Use of Information and Our Services
In order to facilitate the transactions between
Glowpay.com members, our service allows you limited access other users’
contact information. As a seller you may have access to the User
ID, email address and other contact information of the purchaser,
and as a purchaser you may have access to the User ID, email address
and other contact information of the seller.
By entering into our Terms of Use, you agree that, with respect
to other users’ personally identifiable information that
you obtain through the site or through an
Glowpay.com -related communication or
Glowpay.com -facilitated transaction, you will only use this information for:
(a)
http://www.glowpay.com -related communications that are not unsolicited commercial
messages, (b) using services offered through
Glowpay.com , and (c) any other purpose that such user expressly agrees to
after adequate disclosure of the purpose(s).
In all cases, you must provide users with the opportunity to remove
themselves from your database and review any information you have
collected about them. In addition, under no circumstances, except
as defined in this Section, can you disclose personally identifiable
information about another
http://www.glowpay.com user to any third party without our consent and the consent
of such other user after adequate disclosure. Note that law enforcement
personnel and other rights holders are given different rights
with respect to information they access.
http://www.glowpay.com does not tolerate unsolicited commercial e-mail or “spam.”
Therefore, without limiting the foregoing, you may not add a
http://www.glowpay.com user to your mail list (e-mail or physical mail) without
their express consent after adequate disclosure, even if said
user has previously made a purchase from you. Our anti-spam policy
is strictly enforced. To report
http://www.glowpay.com -related spam to
http://www.glowpay.com , please contact us at
.
Information Security
http://www.glowpay.com handles your customer information with high standards of
information security. We restrict access to your personally identifiable
information to employees who need to know that information in
order to provide products or services to you. We maintain physical,
electronic and procedural safeguards that comply with federal
regulations to guard your nonpublic personal information.
The security of your
http://www.glowpay.com account also relies on your protection of your
http://www.glowpay.com password. You should not share your
http://www.glowpay.com password with anyone.
http://www.glowpay.com representatives will never ask you for your password, so
any e-mail or other communication requesting your password should
be treated as unauthorized and suspicious. If you do share your
http://www.glowpay.com password with a third party for any reason, including because
the third party has promised to provide you additional services
such as account aggregation, the third party will have access
to your account and your personal information, and you may be
responsible for actions taken using your password. If you believe
someone else has obtained access to your password, please change
it immediately by logging in to your account at
http://www.glowpay.com and changing your user settings, and also contact us right
away as described in Section F below.
You can review the personal information you provided
us and make any desired changes to such information, or to the
settings for your
http://www.glowpay.com account, at any time by logging in to your account on the
http://www.glowpay.com ">
http://www.glowpay.com website and changing your user preferences. You can also
close your account through the
http://www.glowpay.com website. If you close your
http://www.glowpay.com account, we will mark your account in our database as “Closed,”
but will keep your account information in our database. This is
necessary in order to deter fraud, by ensuring that persons who
try to commit fraud will not be able to avoid detection simply
by closing their account and opening a new account. However, if
you close your account, your personally identifiable information
will not be used by us for any further purposes, nor sold or shared
with third parties, except as necessary to prevent fraud and assist
law enforcement, or as required by law.