Effective Date: November 1, 2021
- Customers. Customers are our direct clients with whom we have contractual relationships and who use our Services to coordinate and receive payment from End Users (defined below).
- Prospective Customers. Prospective Customers are users with whom we have not entered into a contractual relationship and who may be accessing the Site to evaluate our offerings and determine whether to engage our Services.
- End Users. End Users are users with whom we have not entered into a contractual relationship and who access the Site or Services to make payments to Customers.
- Information We Collect. When you use the Site, we process certain types of Information, as described below.
- Personal Information. “Personal Information” means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information that we collect on the Site includes, but may not be limited to, first name, last name, e-mail address, phone number, IP address, and payment information. When you access or use the Services, you may provide Personal Information to us, such as when you request to receive information or support, submit a payment or other transaction through the Services.
Personal Information and Non-Personal Information are collectively referenced as “Information.”
- Geolocation Information. Prospective Customers may choose to allow us to access your location by granting the Site access to your location when prompted or through your device’s location services settings. You may change these settings on your device, but this may impact your use of and access to the Services.
- Third-Party Social Networking Service(s). If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Site, we may receive your Personal Information and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Site. Your decision to use a social networking service in connection with our Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.
Use of Information. We use Non-Personal Information collected by clickstream information collection, web pixels, and cookies to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the products, services, materials, and other content that we describe or make available through the Services, and otherwise help administer and improve the Services.
We may identify you from your Personal Information and merge or co-mingle Personal Information and Non-Personal Information. Except as otherwise stated, we may use Information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:
- To fulfill or meet the reason you provided the Personal Information. For example, if you share your name and contact information to ask a question about our Services, we will use that Personal Information to respond to your inquiry.
- To establish and secure accounts to use the Services, check on your account status, and to validate your username, e-mail, password, and/or other login credentials.
- To provide, support, personalize, and develop our Services, including without limitation, to conduct aggregate or research analysis and develop business intelligence that helps us to enhance, improve, evaluate, operate, protect, make informed decisions about, and report on the performance of our Services.
- To communicate information and promotional materials to you, where you have not expressed a preference otherwise, and to send you information and updates about the Services.
- To notify you of any changes to relevant agreements, policies, or other terms, and to enforce such terms.
- To work with our service providers, who perform certain business functions or services on our behalf.
- To prevent or investigate fraud, or for risk management purposes, and to help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
- To comply with legal obligations, court orders, or in order to exercise any legal claim or to defend against any legal claim.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.
- As otherwise described to you when collecting your Personal Information.
In addition, we may use third‐party e‐mail providers to deliver communications to you. This is an opt-in e-mail program. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link.
We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and Services. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services.
- How We Share Information. We may share Personal Information with the following parties:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. While we may seek to require such third parties to follow appropriate privacy policies and to prohibit them from using your Personal Information except for the express purpose for which it is provided, you agree that we do not bear any responsibility for any actions or policies of third parties.
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
- Pursuant to your express consent.
- Information Security. We take reasonable steps online and offline to safeguard the Personal Information that you provide to us. OpenWallet’s online portal is certified as a Level 1 Service Provider, this being the highest security level available.
- We have several levels of security built into the system for our Customers. This includes the following security services:
- Cryptography and Encryption of sensitive information inside payment system;
- Quarterly scans of payment system performed by Qualified Security Assessor;
- Annual Audit performed by Qualified Security Assessor;
- Completion of Level 1 PCI Compliance Assessment;
- Encryption of card details, preventing card information from being exposed once transaction is complete;
- Secure receipts exposing only last 4 digits of card number; and
- Enforcing security-code confirmation every 30 days for merchant log-ins.
It is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee or warrant the security of your Personal Information, or any other information, transmitted to or through our Site or Services or otherwise provided to us, and we cannot be responsible for the theft, destruction, or inadvertent disclosure of such information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Service(s). Any transmission of information is at your own risk.
- If you have any questions about security on our Services, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach, notify us immediately via email at support@OpenWalletusa.com. If our security system is breached, we will notify you of the breach to the extent required under applicable law.
- Children’s Privacy. We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Information from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
- Your California Privacy Rights. California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to firstname.lastname@example.org. For more information regarding your privacy rights as a California resident, please see our Privacy Notice for California Residents.
|Mailing address||Fresh Start Funding LLC DBA OpenWallet
Attn: Website Inquiry
1805 N Scottsdale Road
Tempe, AZ 85281