REAL-TIME TRANSFERS PRIVACY POLICY

CheckFreePay Digital Payment Service Privacy Policy

The Digital Disbursements Payment Service is provided by CheckFreePay Corporation and CheckFreePay Corporation of New York, each a wholly owned subsidiary of Fiserv, Inc.

1. Introduction. This Privacy Policy describes the types of “Personal Information” (information that is identifiable to a particular person) that is collected (directly or through service providers) in connection with the Digital Disbursements Payment Service (the “Service”) offered through app.instant.co  (the “Site”), and how that Personal Information is used, shared and protected.  Some of this information is required by U.S. federal law or other law.  For residents of the State of New York, CheckFreePay Corporation of New York is the operator of the Service.  For residents elsewhere, CheckFreePay Corporation is the operator of the Service.  In this Policy, “CheckFreePay” or “we” or “us” refers to the operator applicable to you.  Both CheckFreePay Corporation of New York and CheckFreePay Corporation are wholly owned subsidiaries of Fiserv, Inc.

2. Eligibility. The Service is offered only to individual residents of the United States who can form legally binding contracts under applicable law. Without limiting the foregoing, the Service is not offered to minors.  Other restrictions and eligibility requirements apply as described in the Digital Disbursements Payment Service Terms of Use or other disclosures on the Site.  We do not knowingly collect any Personal Information from or about individuals under 18 years of age.   Please do not submit such information to us, and as a parent or legal guardian, please do not allow your children to submit personal information without your permission.  By using the Site and/or the Service, you represent that you meet these requirements and that you agree to the terms of this Privacy Policy.

3. Scope. CheckFreePay offers other products and services, some of which are available through other organizations such as banks, credit unions, brokerage firms, and Internet portals.  This Privacy Policy applies only to the Digital Disbursements Personal Payment Service offered at the Site (via browser or the Mobiliti mobile app, for which you received additional privacy disclosures).  Other CheckFreePay products and services offered through other websites or organizations may be governed by different terms.  For more details on what your rights and obligations are when using the Service offered on the Site, please also refer to the Digital Disbursements Payment Service Terms of Use and other notices and disclosures you may be provided regarding the Service.

4. Cookies, Browser Information and Related Issues.

a. When you visit the Site, we may receive certain standard information that your browser sends to every website you visit, such as the originating IP address, browser type and language, access times and referring website addresses, and other such information.  This data may be used, among other uses, to improve the operation of the Site and to improve the security of the Site and Service by assisting in “authenticating” who you are when you access the Site or Service, particularly if you register for the Service and are issued or create a username and password.  We may also receive additional technical data about the device being used to access the Site (“Device Data”) (such as device IDs, device models, operating system version, application types and versions, browser type, language, and plug-ins, originating IP address, and time zone and geolocation information).  Device Data may be used as part of Fiserv’s security controls to uniquely identify the device, authenticate the user when accessing the Site, and shared (along with information about any fraudulent transactions using the device) with one or more third party service providers, which will compare and add the Device Data and fraud data to a database of similar device and fraud information in order to identify and block access to the Site by devices associated with fraudulent or abusive activity.  We will not share with service providers any information that personally identifies the user of the device.

b. We may also receive additional information about your visit to the Site, including the pages you view, the links you click and other actions you take in connection with the Site and the Service.  This data may be used, among other uses, to improve the operation of the Site and the Service.

c. Like most websites, the Site also uses “cookies”, which are small data files placed on your computer or other device by the web server when you visit the Site.  Most such cookies are “session” cookies that are only used for a specific period during which you are on the Site, but a few are “persistent” cookies that stay on your hard drive and are read by the web server when you return to the Site (unless you erase them).  The Site uses cookies to recognize your device and to store your preferences and other information on your device in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content on your later visits to the Site.  These cookies may be linked to Personal Information about you, such as your email address.  Cookies cannot and will not be used to deliver or run programs on your computer.  Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer.  However, if you choose to decline cookies, you may not be able to sign in or use other interactive features of the Site that depend on cookies.

d. You may encounter our cookies or pixel tags on websites that we do not control.  For example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie or pixel tag placed by the web page or application.

e. Web beacons: Our Web pages contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients.  This allows us to gauge the effectiveness of our customer communications and marketing campaigns.

f. Widgets: Our Web site may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site.  These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly.  Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site.  Your interactions with these Features are governed by the privacy policy of the company providing it.

g. Targeted Ads: We may partner with third party ad networks to either display advertising on our Web site or to manage our advertising on other sites.  Our ad network partners use cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising.  You will continue to receive generic ads.

h. Tracking: With respect to personally identifiable information about an individual consumer’s online activities over time and across different Web sites or online services when a consumer uses this Site, except as required by law: (1) parties other than the operator of this Site are not permitted to collect such information, and (2) the operator of this Site does not collect such information (except any such information that is reasonably necessary to process and document user transactions, such as payment history).  Therefore, this Site has no need to respond and does not respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of such information.

5. What Types of Personal Information We May Collect. In addition to the types of information described in section 4 above, we may also collect Personal Information about you.  This information may include:

a. Social Security number, date of birth, name, postal address, email address, telephone number, and other information that we can use to contact you, verify your identity, and manage risks, such as information maintained about you by identity verification services and consumer reporting agencies, including credit bureaus;

b. bank account information (checking, money market or other direct deposit account, credit card account, or debit card account, including any required routing information), including account numbers and transaction history, for accounts that you designate for sending or receiving payments, fees, debits and credits for the Service;

c. name, email address and telephone number that you provide us for other persons to whom you would like to send payments;

d. username, password, secret questions and secret answers for resetting passwords, and other authentication credentialing used to verify that only authorized users access the Service;

e. payment and other transaction information; and

f. any Personal Information that you may enter in response to surveys or into information blocks on the Site such as “personal message blocks”.

6. How We May Collect Personal Information About You. We may collect Personal Information about you from the following sources:

a. Enrollment applications, survey responses, and other electronic or paper forms that you fill out in connection with the Service;

b. Your use of the Site and the Service (such as when you initiate a Payment Instruction), and your interactions with customer care, including information you enter or speak, and information transmitted by your computer, cell phones and other devices you use to connect to the Site or the Service; and

c. We also collect Personal Information about you from others, such as individuals and financial institutions using the Service, credit bureaus, Affiliates or other companies (such as identity verification services and consumer reporting agencies).

7. How We May Share Personal Information About You. We share Personal Information about you only as permitted by law.   For Personal Information that is nonpublic and that we collect in connection with a financial service, U.S. federal law permits us to share the information only for the purposes shown in the following table:

Reasons we can share your Personal Information Does CheckFree Pay share? Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your accounts, respond to court orders and legal investigations, and report to credit bureaus Yes No

For our marketing purposes – to offer our products and services to you;

Yes No

For Joint Marketing with other financial companies;

No We Do Not Share

For our Affiliates’ everyday business purposes (information about your transactions and experiences);

Yes No

For our Affiliates’ everyday business purposes (information about your creditworthiness);

No We Do Not Share

For our Affiliates to market to you;

No We Do Not Share

For Nonaffiliates to market to you

No We Do Not Share

In order to process your transactions, we may share a small amount of Personal Information about you to an entity identified in your Payment Instructions, including your name, email address, telephone number and anything you type into the “message” field.

We may share certain Personal Information about you (including with a third party service providers, which will compare and add the Device Data and fraud data to a database of similar device and fraud information in order to identify and block access to the Site by devices associated with fraudulent or abusive activity.  We will not share with service providers any information that personally identifies the user of the device.

Identity and Location Verification: You authorize CheckFreePay to share your mobile subscriber details with a third party provider which will request your mobile carrier to use your mobile subscriber details for verifying your identity.  Those details may include name, billing address, email, and phone number.  This information may also include location information, if available.

8. How We May Use Personal Information About You. We use Personal Information about you only as permitted by law, including but not limited to the following purposes:

a. To complete transactions and render services authorized by you;

b. Other everyday business purposes, such as to maintain your ability to access the Service, to authenticate you when you log in, to send you information about the Service, to effect, administer and enforce transactions, to perform fraud screening, to prevent actual or potential fraud and unauthorized transactions, to verify your identity, to determine your transaction limits, to perform collections, to comply with laws, regulations, court orders and lawful instructions from government agencies, to protect the personal safety of subscribers or the public, to prevent and defend claims, to resolve disputes, to troubleshoot problems, to enforce our Service Terms of Use, to protect our rights and property, and to customize, measure, and improve the Service and the content and layout of the Site including pattern recognition, modeling, enhancement and improvement, system analysis, and Service performance analysis; and

c. For marketing purposes – to offer products and services to you, although you may opt-out of receiving commercial email marketing messages from us by following the opt-out processes described in those messages.

9. Other Important Information.

Vermont:

Under Vermont law, we will not share information we collect about Vermont residents with companies outside of our Affiliates, unless the law allows.  We will not share information about your creditworthiness with our Affiliates except with your consent, but we may share information about our transactions or experiences with you with our Affiliates without your consent.

California:

Under California law, we will not share information we collect about you with Nonaffiliates, unless the law allows.  For example, we may share information with your consent, to service your accounts, or to provide rewards or benefits you are entitled to.  We will limit sharing among our Affiliates to the extent required by California law.

10. Definitions.

a. Affiliates: Companies related by common ownership or control.  They can be financial or nonfinancial companies.  Our Affiliates include members of the Fiserv, Inc. corporate family including, CashEdge, Inc. and Fiserv Solutions, Inc.

b. Nonaffiliates: Companies not related by common ownership or control.  They can be financial or nonfinancial companies.

c. Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

11. Access to Information About You. You may review and update the Personal Information maintained about you in the “Settings” section of the Site at any time to ensure that it is accurate and up-to-date.

12. How We Protect Personal Information About You. To protect Personal Information about you from unauthorized access and use, we maintain physical, electronic, and procedural safeguards, including but not limited to security measures that comply with applicable federal and state laws.  We also require our service providers and business partners to whom we disclose the information to do the same.

13. Amendments. CheckFreePay may amend this Privacy Policy at any time by posting a revised version on the Site.  The revised version will be effective immediately at the time it is posted, unless a delayed effective date is expressly stated therein.  You may (in our discretion) also be provided with an email notification of such amendments.  You may (in our discretion) be required to affirmatively acknowledge or accept the revised Privacy Policy in order to continue using the Service.  Any use of the Service after a notice of change (whether by Site posting, email, or express acknowledgment or acceptance) will constitute your express agreement to such changes.  If we make any change in how we use Personal Information about you we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective.

14. Protection for Former Customers. When you are no longer our customer or using the Service, we continue to protect, use, and share Personal Information about you as described in this notice and as required by law, including but not limited to for risk management, regulatory compliance, and audit purposes.

15. Links to Other Web Sites. Our Site includes links to other Web sites whose privacy practices may differ from ours.  If you submit Personal Information to any of those sites, your information is governed by their privacy statements.  We encourage you to carefully read the privacy statement of any Web site you visit.

16. Contacting Us. If you have any questions about this Privacy Policy, you may contact us at the postal address or email address below:

In writing:  CheckFreePay Corporation
ATTN:  Privacy Management
2900 Westside Parkway
Alpharetta, GA 30004
E-mail:  privacy@customercenter.net