Effective Date: December 30, 2019
This Fintwist Solutions Digital Privacy Statement (“Privacy Statement”) applies to information that Comdata on behalf of itself and its corporate affiliates (collectively “Comdata,” “we” or “us”) collects on fintwistsolutions.com, and the Fintwist Solutions mobile application made publicly available by Comdata, Comdata-branded social media pages, digital advertising campaigns, and any other websites, applications and digital Sites which expressly reference or link to this Privacy Statement (each a “Site” and collectively, the “Sites”). By using a Site, you agree to the terms and conditions of this Privacy Statement.
Your privacy is important to us. This Privacy Statement describes the information we collect, why we collect it, and what we do with the information we collect from or about you through the Sites. This Privacy Statement does not apply to third-party websites and other websites and applications that do not link to or reference this Privacy Statement and does not apply to information collected from you offline. Additional information about our privacy and security practices may be found on our Sites and within Frequently Asked Questions (FAQs) we may publish from time to time on a Site. This additional information is provided as a resource and the terms and conditions of this Privacy Statement control in the event of a conflict.
The Sites are intended for persons currently residing in the U.S. who have reached the age of majority in their states. You are not authorized to access and use the Sites if you are located outside the U.S.
The Site is not directed to or intended for use by children under the age of 13. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act (COPPA), Comdata does not direct its website or provide any online service that would knowingly collect personal information from children under the age of 13. For more information about the Children’s Online Privacy Protection Act (COPPA) please refer to the FTC’s website at http://www.business.ftc.gov/privacy-and-security/children%27s-privacy.
If you do not agree with any part of this Privacy Statement, you may not use any of our Sites.
How We Define Personal Information
For purposes of this Privacy Statement, “Personal Information” means any information you provide us on a Site that personally identifies you. For example, Personal Information includes your name, postal address, telephone, fax and mobile numbers, email address, Social Security number, login credentials, and account numbers. Personal Information also includes information that does not directly identify you but when combined with other information identifies (or can be used to identify) you.
How We Collect and Use Your Personal Information
How we collect information from you depends on how and why you use the Sites. Comdata may collect information in the following ways:
When You Give Comdata Information: When you create an account online, we may ask you for Personal Information such as your name, email address, telephone number, Social Security Number, date of birth, or other government-issued identification number, and payment card number and associated security code. Certain parts of the Sites require users to provide contact information (such as name and e-mail address), demographic information (such as ZIP code), financial information (such as account numbers and payment card numbers) and other similar information. If you sign up for emails about Comdata’ latest news and new products, we collect the email address that you give us. We also collect feedback, questions and information that you provide to us for customer support.
When You Use the Sites: We collect information about how and when you use the Sites including:
Through Server Logs: A server log is a list of the activities that a server performs. Comdata’s servers automatically collect and store in server logs, your search queries, Internet Protocol (IP) address, the date and time of your request and referral URL, and certain cookies that identify your browser or Comdata account.
From Your Computer or Mobile Device: We collect information about your computer, tablet or mobile telephone (“Device”), such as model, operating system version, mobile network information, telephone number, internet service provider and similar identifiers. We may associate your Device information with your account. We may collect and store information (including Personal Information) on your Device through browser web storage (including HTML 5) and web application data caches.
We may collect data about the location of the Device that you use to access the Sites (“Location Data”) using IP address, GPS, cellular towers and other information from your mobile service provider, Bluetooth address, Wi-Fi access points, and information made available by you or others that indicates your current or prior location, such as geotag information in photographs. We may use Location Data to provide information on proximity to nearest in-network ATM, to assist in verifying your identity, and as an indicator of suspicious activity or fraud. How we collect Location Data depends on whether you use a mobile application (“App”) or website to access the Sites. Certain Sites may collect Location Data even when you are not actively using the Sites. If you do not want us to collect Location Data from your mobile Device, please turn off the location services in your Device settings.
Through Mobile Applications: We may from time to time offer Apps that collect information about your use of and interaction with the App, such as your Device’s operating system, browser type, domain and other system settings, search queries, the country and time zone in which your Device is located, metadata, and other information associated with files stored on your Device.
From Other Sources: Comdata collects information about you from third parties:
When you Connect with Social Media through the Sites: The Sites link to social media platforms through “plug-ins” (e.g., Facebook, Twitter, Instagram and LinkedIn buttons). When you access social media from one of our Sites the social media platform may receive Personal Information about you. Once on a social media platform, whether on a Comdata or Comdata affiliate-branded page or not, the social media platform’s privacy policies and practices apply to the collection and use of your data collected during your time on their platform. When you are logged into your social media account and access the Sites, we may (depending on your settings) automatically receive information (including Personal Information) from the social media platform. Comdata collects and uses this information for the purposes described in this Privacy Statement or at the time the information is collected; however, Comdata does not currently use or store any Personal Information received from any social media platform.
From Third Parties: Comdata may from time to time supplement the information that we collect from you with information from third parties. We may combine the third-party information with information that we already have from or about you.
Through Service Providers: Third parties that assist us with our business operations also collect and use information (including Personal Information) through the Sites and also may share the collected information with us. For example, our service providers collect and share information with us to analyze the performance of the Sites and to detect and prevent fraud. You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose to Fleetcor and its third-party service providers your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, solely to verify your identity and prevent fraud for the duration of the business relationship.
Comdata uses your Personal Information as described in this Privacy Statement and for any other purpose that we disclose when we collect your Personal Information.
Comdata uses Personal Information to:
How We Share Personal Information
We may share Personal Information collected through the Sites as follows:
Affiliates: Comdata shares Personal Information within Comdata’s corporate family for the affiliates’ everyday business purposes and as required or permitted by law.
Service Providers: Comdata shares information with Comdata’s third-party service providers that help us operate the Sites, provide Comdata products and personalize your experience on the Sites. We also may share information with other service providers that help us with payment card processing, sending emails, order fulfillment, conducting advertising, providing customer service or product support, industry benchmarking, consumer analysis, market research, and administering promotions.
Corporate Transactions: Comdata may share and transfer Personal Information if Comdata is involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control by Comdata or any affiliated company (in each case, whether in whole or in part).
Comdata never publicly discloses any Personal Information related to financial or payment activities or any government identification numbers. Comdata also does not allow unauthorized publishing or disclosure of any user’s non-public contacts. We also never share Personal Information with third parties for their marketing purposes.
How We Protect and Store Information
Comdata takes precautions intended to help protect your personal and financial information that we collect and store. We employ controls that follow widely recognized security policies, standards, and regulations and align with industry-standard best practices. However, you are responsible for using appropriate security measures to protect your information and for refraining from sending sensitive data to us over unsecure means.
For your protection, Comdata maintains authentication procedures to protect your personal information and account. You are responsible for maintaining the security of your account credentials and other authentication data or means involved in obtaining access to password-protected or secure areas of the Sites. Comdata will treat access to the Sites through your account credentials as having been authorized by you. If you suspect a website is pretending to be a Comdata website, do not provide personal information and instead contact us directly by calling 800-266-3282 or using the contact information below. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Sites without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
We retain information for as long as necessary to fulfill the purposes for which you provided the information, to comply with legal obligations, to resolve disputes, to enforce agreements, and similar essential purposes.
Other Information We Collect
We collect information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as demographic information, browser information, information collected through cookies, pixel tags and other technologies, other information provided by you such as your date of birth or household income, and aggregated and de-identified data.
How We Use Data Collection Tools
Cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Tools”) help Comdata automatically collect information about you when you use the Sites.
Web Beacons: A web beacon (also called a pixel tag or clear GIF) is computer code that communicates information from your Device to a server. Some of our content and emails may contain embedded web beacons that allow a server to read certain types of information from your Device, allow us to count the number of people who have viewed content, to know when you opened an email message, and the IP address of your Device. Web beacons help us develop statistical information to provide better and more personalized content.
Cookies: Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your Device, such as user settings, browsing history and activities conducted while using the Sites.
Comdata uses the following types of cookies:
Data Collection Tools record how long you spend on various pages on Sites, which pages you view, your search queries, the products you viewed, error and performance reports, your IP address, your browser type, time zone and language settings, and operating system. Data Collection Tools also help us with fraud prevention and detection.
Comdata also uses analytics services, such as Google Analytics, to collect information. Generally, analytics services do not identify individual users. Many analytics services allow you to opt out of data collection. For example, to learn more about Google Analytics practices and to opt out, visit www.google.com/settings/ads or download the Google Analytics opt-out browser add-on athttps://tools.google.com/dlpage/gaoptout.
Your Control of Data Collection Technology: Some web and mobile browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is stored in your browser. If you set your browser to refuse to accept cookies, you may not be able to use certain features of the Sites, access some of our online Sites, or apply for a credit card. You also may be able to reject use of mobile device identifiers by activating the appropriate setting on your Device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all products or features available through the Sites.
How We Respond to Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals a website that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Comdata, do not respond to DNT signals.
Third Party Sites and Services
Comdata may provide links to websites operated by unrelated third parties, such as companies that provide Sites for us or special offers. Please note that when you navigate to the website of an unrelated third party, this Privacy Statement no longer applies. This Privacy Statement does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating any site or service to which the Sites link. In addition, we are not responsible for the information collection, usage, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, or any other third-party app provider, social media platform provider, operating system provider, device manufacturer, or wireless service provider, including with respect to any personal information you disclose to other organizations through or in connection with the Sites. We encourage you to read the privacy policies of every website or service that you visit to understand how your Personal Information is processed.
How Can I Correct or Delete My Personal Information?
If you would like to correct or delete Personal Information, please update your information accordingly at www.fintwistsolutions.com, or by using the Fintwist mobile app, or by calling 1- 888-265-8228. Comdata reserves the right to request that you provide information that will enable Comdata to confirm that you have the authority to correct or delete the Personal Information that you want corrected or deleted. Comdata will use reasonable efforts to correct your Personal Information but may not be able to correct or delete Personal Information shared with third parties.
Notice to California Residents
California Code Section 1798.83 permits individual California residents to opt-out of Comdata’ disclosure of Personal Information to third parties for their direct marketing purposes. Comdata currently does not disclose Personal Information to third parties for their direct marketing purposes.
Effective January 1, 2020, the California Consumer Privacy Act (CCPA) permits consumers who are California residents to (a) ask a covered business which categories or pieces of personal information it collects and how the information is used; (b) request deletion of the information; and (c) opt out of the sale of such information, if applicable. The CCPA sets forth certain exceptions to these general provisions, including for personal information collected, processed, sold or disclosed by financial institutions pursuant to specified federal law, for personal information provided in the context of certain business to business transactions, and when we are required to retain information to comply with other laws. To contact us with questions about our compliance with the CCPA, call1- 888-265-8228 or write to: Comdata Prepaid Customer Service, 5301 Maryland Way, Brentwood, TN 37027. Please note, consumers will not receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA.
Changes to this Privacy Statement
The Effective Date of this Privacy Statement is set forth at the top of this webpage. We reserve the right to change this Privacy Statement as business needs require. If we make material changes to the way we use Personal Information, we post a notice about the changes prominently on the Sites in advance so that you have an opportunity to discontinue your use of the Sites. Your continued use of the Sites after the Effective Date constitutes your acceptance of the amended Privacy Statement. The amended Privacy Statement supersedes all previous versions.
How to Contact Us
If at any time you have questions about the Comdata Digital Privacy Statement, please contact us at 1-888-265-8228 or by mail to Comdata at Comdata Prepaid Customer Service, 5301 Maryland Way, Brentwood, TN 37027.
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