Privacy Policy

Effective Date: September 18, 2024

This Privacy Policy has been compiled to assist you (“you,” “your,” or “User”) to understand how InfoPay, Inc. (“we,” “our,” or “us”), which provides the IDStrong services, and our affiliates and subsidiaries, collect, use, and disclose your personal information.

This Privacy Policy describes our practices in connection with information that we collect through your use of the IDStrong website and the associated products, services, information, and materials offered herein (the “Site”).

Depending on where you live, you may be entitled to certain individual rights with respect to some or all of your personal information. Please see the Notice of Privacy Rights for Residents of Certain U.S. States section of our Privacy Policy for more information related to privacy rights that may be applicable to you.

By accessing, browsing, or otherwise using the Site, you acknowledge and consent to our collection, use and disclosure of personal information as set forth in this Privacy Policy. PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOUR USE OF THE SITE CONSTITUTES YOUR CONSENT TO THIS PRIVACY POLICY. DO NOT USE THE SITES IF YOU ARE UNWILLING OR UNABLE TO CONSENT TO THIS PRIVACY POLICY.

This Privacy Policy applies only to your use of the Site. We may revise this Privacy Policy at any time and such revision shall be posted here and accessible via this link: https://www.idstrong.com/privacy. Any revision and/or addition to this Privacy Policy shall become effective and binding on you when you continue to use the Site on or after the effective date of such revision and/or addition.

1. Information Collection

When you use the Services, we may collect the following categories of personal information about you, which are described in more detail below. All of the information listed below is hereinafter referred to as "Information."

Categories of Information We Collect	Examples	How We Use Your Information
Individual identifiers	Name Email address Physical billing address Phone number Business name Demographic information you choose to provide such as age or date of birth	To operate and improve the Services and products and content therein To create and maintain an account for you to allow you to purchase and use the services we make available on the Services To provide you with information, products, or services that you request from us, or that may be of interest to you To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies. (Because this information may be important to your use of the Services, you may not opt out of receiving these communications.) To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners To comply with our Terms To comply with any applicable laws and regulations and respond to lawful requests For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent
Payment and transaction information	Credit card number Name CVV code Date of expiration	To create and maintain an account for you to allow you to purchase and use the services we make available on the Services For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent
Communications with us, preferences, and other Information you provide to us	Messages, opinions, and feedback that you provide us Your user preferences (such as in receiving updates or marketing information) Other Information that you share with us when you contact us directly (such as for customer support services)	To operate and improve the services and products and content therein To provide you with information, products, or services that you request from us, or that may be of interest to you To respond to your comments, inquiries and questions and provide customer services To deliver a more personalized experience based on your preferences For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted out of receiving such communications For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent
Additional Information	Additional Information as otherwise described to you at the point of collection or pursuant to your consent	To operate and improve the services and products and content therein For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent
Information we may automatically collect about you	IP address Date and time of your visit or use of our Services Domain server from which you are using our Services Type of computer, web browsers, search engine used, operating system, or platform you use Data identifying the web pages you visited prior to and after visiting our website or use of our Services Your movement and activity within the website, which is aggregated with other information Geographic data such as country or region Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”)	To operate and improve the services and products and content therein To provide you with information, products, or services that you request from us, or that may be of interest to you To understand and analyze information related to the number and type of visitors that browse and use the Services To maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services For analytics for business purposes and business intelligence For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent
Information we receive from third parties	Information appearing in publicly available records that matches user searches	To operate and improve the services and products and content on our platforms

2. Cookies and Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications.

A. Cookies

The Site uses “cookies.” We may store information about you using the cookies on our Site. A cookie (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. We use cookies to improve your site experience, to assess content usage, to distinguish you from other users of our site and to support the marketing of our services.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. You can also visit our Cookie Notice, available at https://members.idstrong.com/cookieInfo. Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

B. Web Beacons

Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Site uses retargeting pixels from Google. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

C. Analytics

Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Site, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.

D. Mobile Application Technologies

If you access Site through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt out of these online tracking technologies by submitting a request here.

3. Information Sharing or Disclosure

We may share and/or disclose your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Site, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Site.
Business Transfers. Your Information may be transferred, sold, or otherwise conveyed to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates.
De-Identified or Aggregated Data. We may share your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked, or otherwise not identifiable.
Data obtained through SMS/Text Messaging (short code program) will not be shared with any third-parties for the purpose of marketing.
With Your Consent.. We may share Information consistent with this Privacy Policy with your consent.

4. Protecting Your Personal Information

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Site and safeguard your information. However, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us so that necessary measures can quickly be taken.

5. Geographic Location of Data Storage and Processing

The Sites are operated in the United States. Please be aware that the Site collects Information and process and store that Information in databases located in the United States. By visiting the Site and submitting any personal Information you consent to the transfer of such personal Information to the United States. If you are visiting the Site from a country outside the United States, you should be aware that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Site and submitting any personally identifiable Information, you consent to the transfer of such personally identifiable Information to the United States.

6. The Length of Time that Your Information is Kept by Us

We will retain your Information for as long as needed to provide you Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

7. Your Choices

A. Notification Opt-In. Throughout the Site, we provide you with the opportunity to opt-in to receive marketing communications from us as well as from our subsidiaries, marketing partners, advertisers, and other third parties we may partner with. We may offer these notifications via email, via browser notifications, or both. You may opt-out of receiving these communications as described below.
B. Notification Opt-Out. If you no longer wish to receive marketing or promotional communications from us, you may:
- Respond to the emails that we send out with your request for removal or
- Click the “unsubscribe” link (where available).
Please be aware that there may be a delay between our receipt of your request and our being able to update our lists. Thank you for your patience in this regard.

Note that you may not be able to opt out of certain administrative emails that are important to your use of the Sites, such as information about updates to our Privacy Policy or Terms of Use or correspondence related to specific requests that you have made to us.
C. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:
- You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices
- You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info
- You can opt-out of having your activity on our Site made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

8. Third-Party Links on the Sites

Occasionally, at our discretion, we may link to third party sites or content on the Sites. We may do this for the convenience of you and other users of the Sites, but we do not have control over the operation of these third-party websites. This Privacy Policy only applies to Information collected by our Site. The third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of linked sites. We are not responsible for the privacy and security practices of those other websites or the Information they may collect (which may include IP address).

9. Notice of Privacy Rights for Residents of Certain U.S. States

Residents of certain U.S. states may have rights and choices regarding their personal information. To the extent any data protection law applies to our collection of your personal information, this supplemental section of our Privacy Policy outlines the individual rights you may be entitled to and how to exercise those rights.

Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.

Right to Know and Access. You may have the right to request that we confirm whether we process your personal information, and to request information about our collection and use of your personal information, including whether we sell or share your personal information. You also have the right to request access to personal information we may process about you.
Right to Data Portability. Where the processing is carried out by automated means, and subject to certain exceptions, you may have the right to request and obtain a copy of your personal information that you previously provided to us in a portable format. In addition, to the extent technically feasible, you may have the right to obtain your personal information in a readily usable format that allows you to transmit the personal information to another data controller without hindrance.
Right to Request Correction of Inaccurate Personal Information. To the extent that we may maintain inaccurate personal information, you may have the right to request that we correct such inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Request Deletion. You may have the right to request that we delete certain personal information or records provided by or obtained about you, with certain exceptions and limitations as allowed under law.
Right to Opt Out of the Sale and Sharing of Personal Information. You may have the right to opt out of the processing of your personal information for the purpose of selling or sharing your personal information to third parties. We do not sell or share your personal information.
Right to Opt-Out of the Use of Personal Information for Targeted Advertising and Profiling. You may have the right to opt out of the processing of your personal information for purposes of targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not use your Information for targeted advertising or profiling purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to request that we limit the ways we use and disclose your sensitive personal information to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or as authorized by law.
Right to Non-Discrimination. You may have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or Services, charging different prices or rates for goods or Services, or providing a different level of quality of goods and Services. However, we may offer a different price, rate, level, quality, or selection of goods or Services, including offering goods or Services for no fee, if you have exercised your right to opt-out.
Right to Disclosure of Third-Parties. You may have a right to know the categories and names/addresses of third parties that we have disclosed your personal information to under this Policy.
Right to Disclosure of Direct Marketers. You may have a right to know the categories and names/addresses of third parties that have received personal information for their direct marketing purposes upon simple request, and free of charge.
Right to Appeal. You may have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeal request via the information in the How to Contact Us section below or using the Your Privacy Choices form. Within the certain timeframe of receipt of your appeal, as proscribed by the applicable law we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Attorney General or another authority which we will help you identify.

To learn more about whether you are guaranteed certain rights, or to submit a request to exercise your rights, please contact us using any of the methods in the How to Contact Us section or using the Your Privacy Choices form.

10. Exercising Your Data Subject Rights

To the extent a state privacy law applies to your Information, you may exercise applicable rights by submitting a verifiable consumer request to us via the methods described below. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. Only you or your authorized agent may make a verifiable consumer request related to your Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above). You may also make a verifiable consumer request on behalf of your minor child.

Email us: privacy@idstrong.com
Call IDStrong: (800) 470-7489
Write us:
IDStrong.com
InfoPay, Inc.
227 Lewis Wharf
Boston, MA 02110
Visit: Your Privacy Choices

11. Do Not Track Signals

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

12. Children’s Information

The Site is not intended for use by persons under the age of 18. We do not knowingly solicit, collect, maintain, or disclose any personal Information from children under the age of 18. If we become aware that a user is under eighteen (18) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

13. Difficulty Accessing Our Privacy Policy

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

14. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

15. Contact Us

If there are any questions regarding this Privacy Policy you may contact us using the information below:

Email us: privacy@idstrong.com
Call us: (800) 470-7489

Write us:
IDStrong.com
InfoPay, Inc.
227 Lewis Wharf
Boston, MA 02110