Policy published: 10 April, 2017
Last updated: 09 February, 2018
Scope and Consent
Collection of Personal Information
We collect the following types of personal information in order to provide you with the use of Cifron Services, and to help us personalize and improve your experience.
Information we collect automatically
Information you provide to us.
We may collect and store any information you provide us when you use Cifron Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding Cifron Services.
When you use Cifron Services, we also collect information about your transactions and your activities. In addition, if you open a Cifron account or use Cifron Services, we may collect the following types of information:
- - Contact information, such as your name, address, phone, email and other similar information;
- - Financial information, such as the full bank account numbers and/or credit card numbers that you link to your Cifron account or give us when you use Cifron Services;
- - Detailed personal information such as your date of birth or national ID number.
We may also collect information from or about you from other sources, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with members of the Cifron corporate family or other companies (subject to their privacy policies and applicable law), and from other accounts we have reasons to believe you control (whether in part or in whole). Additionally, for quality and training purposes or for its own protection, Cifron may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with Cifron, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Information from other sources.
We may also obtain information about you from third parties such as credit bureaus and identity verification services.
Authentication and Fraud Detection.
In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with Cifron Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.
Using Your Mobile Device.
When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's settings menu. If you have questions about how to disable your devices location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
How We Use the Personal Information We Collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:
- - provide Cifron Services and customer support;
- - process transactions and send notices about your transactions;
- - verify your identity, including during account creation and password reset processes;
- - resolve disputes, collect fees, and troubleshoot problems;
- - manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
- - detect, prevent or remediate violations of policies or applicable user agreements;
- - improve the Cifron Services by customizing your user experience;
- - measure the performance of the Cifron Services and improve their content and layout;
- - manage and protect our information technology infrastructure;
- - provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on your communication preferences;
- - contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by our User Agreement;
- - perform creditworthiness and solvency checks, and compare information for accuracy and verify it with third parties.
We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about Cifron Services and the services of our corporate family. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and you consent to receive, autodialed or prerecorded calls and text messages. Where applicable and permitted by law, you may decline to receive certain communications.
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize Cifron Services, content, and advertising.
When you access our website or use Cifron Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively "Cookies"). We use these technologies to:
- - recognize you as a customer;
- - customize Cifron Services, content, and advertising;
- - measure promotional effectiveness;
- - help ensure that your account security is not compromised;
- - mitigate risk and prevent fraud;
- - to promote trust and safety across our sites and Cifron Services.
You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and Cifron Services.
How We Protect and Store Personal Information
We store and process your personal information on our computers in North America, Asia, Europe and elsewhere in the world where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls.
How We Share Personal Information with Other Cifron Users
When transacting with others, we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. To facilitate dispute resolution, we may provide a buyer with the seller’s address so that goods can be returned to the seller. The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is against our policies and constitutes a violation of our User Agreement.
We work with third parties, including merchants, to enable them to accept or send payments from or to you using Cifron. In doing so, a third party may share information about you with us, such as your email address or mobile phone number, to inform you that a payment has been sent to you or when you attempt to pay a merchant or third party. We use this information to confirm that you are a Cifron customer and that Cifron as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a Cifron customer with a third party, we will do so.
Please note that merchants, sellers, and users you buy from or contract with have their own privacy policies, and although Cifron User Agreement does not allow the other transacting party to use this information for anything other than providing Cifron Services, Cifron is not responsible for their actions, including their information protection practices.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using Cifron, or with the third parties that offer or use Cifron Services, except with your expressed permission or if we are required to do so to comply with credit card rules, a subpoena, or other legal process.
How We Share Personal Information with Other Third Parties
We may share your personal information with:
- - Financial institutions that we partner with to jointly create and offer a product. These financial institutions may only use this information to market Cifron-related products, unless you have given consent for other uses;
- - Credit bureaus and collection agencies to report account information, as permitted by law;
- - Banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you meet their criteria which includes having Cifron close your Account due to your breach of Cifron User Agreement);
- - Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Cifron or one of its affiliates; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.
- - Fraud Prevention and Risk Management;
- - Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional);
- - Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements;
- - Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit;
- - Other third parties with your consent or direction to do so.
Other unaffiliated third parties, for the following purposes:
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.
Cross Border Transfers of Personal Information
Cifron is committed to adequately protecting your personal information regardless of where the data resides and to providing appropriate protection for your personal information where such data is transferred across borders.
How You Can Access or Change Your Personal Information
You can review and edit your personal information at any time by logging into your account and reviewing your account settings and profile. You can also close your account through the Cifron website. If you close your Cifron account, we will mark your account in our database as "Closed," but may retain personal information from your account for a certain period of time to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce our User Agreement, or take other actions as required or permitted by law.
DISCLAIMER AND LIMITATION OF LIABILITY
How You Can Contact Us about Privacy Questions