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Privacy Policy

ComCard, Inc. (“ComCard,” “we,” “us,” or “our”) is committed to respecting the privacy rights and concerns of all ComCard users, whether on our website where this Privacy Policy is posted (the “Site”), through use of our corporate cards (the “Cards”), or through other services, such as our mobile app (collectively the “Services”).  We have established and implemented this Privacy Policy to inform visitors to the Site and users of the Services how we use and protect the information we collect through the Services. By accessing the Site, using our Cards, or using any Services, you consent to ComCard collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy.  This Privacy Policy is effective as of the date set forth above and is only applicable to the Services and not to any other website that you may be able to access from the Services which may have its own data collection and use practices and policies.

1. Information we collect

1.1 Types of Identifying Personal Information We Collect

Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access the Site generally.  However, you may be required to submit personal information to access the Services.

The personal information we process depends on the products you use and how you access them. We process information when you directly interact with ComCard in the following ways:

When you open an account, we collect the following information from you:

  • contact information such as name, email address, mailing address, phone number;

  • billing information such as credit card number, and billing address;

  • financial information such as bank or brokerage account number;

  • Tax ID number or Social security number;

  • Driver’s license number or identification card number;

  • Information related to your business, including the business’s legal name, address, Employer Identification Number (EIN), and certain individuals who have an ownership interest in your business;

  • Unique identifiers such as username, account number, and password;

  • Birthdate; and

  • Profile photo (when submitted).

We also collect and store your:

  • Order and transaction history, including your: payment method, amount, purchase date, purchase location, and any information that may be provided to us by the merchant.

  • Any information you choose to enter into the Services (through our chat support services, emails, postings, etc.)

We also collect information about you through our financial partners, identity verification services, and other third-party service providers.  This information is used to: comply with our regulatory and reporting obligations; to underwrite your account; and to conduct fraud monitoring, prevention, and detection.

1.2 Types of Non-Identifying Information We Collect

When you visit the Site, we collect non-personal information such as your browser type and when and from what location you access the Services.  This information may be aggregated to measure the number of visits, average time spent, page views, geolocation, and other statistics about users of the Services.  We also may use this data to monitor the Services’ performance and to make the Services easier and more convenient to use.

We may also collect general information resulting from your use of the Services, including your preferences and other tendencies.  This may include anonymous “traffic data” or tracking information provided by the website’s host or similar provider of such information (i.e., Google Analytics or Salesforce Analytics) that does not personally identify you, but may be helpful for marketing purposes or for improving the services we offer.  Analytics is the process of collecting, analyzing, and reporting aggregate data. This information may include which pages visitors visit, how long visitors may stay on a particular page, and where visitors are located. It may also provide information about what browser, network, or device is used to visit our Site. 

In addition, when you use our Site, we may log your anonymous IP addresses, a unique identifier for your computer or other access devices. This helps us diagnose problems with our server, to administer our Site, or to display the content according to your preferences.

1.3 Collection of Information by Third-Parties

Through the Services, you may be able to link to or otherwise utilize technology, software and services owned and controlled by third parties (“Third-Party Services”).  You may be permitted or required to submit personal information to access Third-Party Services. Such use of Third-Party Services and submission of information through Third-Party Services will be subject to such applicable third party’s terms of use, terms of service, privacy policy and/or practices. You agree to look solely to the applicable third party and not to ComCard to enforce your rights in relation thereto.  When you have clicked on a third-party logo or URL displayed on the Site or accessible through the Services which links you to any Third-Party Services, our Privacy Policy and Terms of Use no longer applies and you must read the terms of use, terms of service and privacy policy of the third party, or contact the third-party directly, to see how your personal information will be handled on their website.

1.4 Do Not Track

ComCard does not honor the request of “do not track” signals sent by your browser when you visit the Site.  Additionally, ComCard does not collect user information about your online activities over time and across different websites or authorize third parties to do so. 

1.5 Cookies

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive.  Like many websites, we employ cookies in certain areas of the Site to allow us to provide information to make your online experience more convenient.  For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are on subsequent visits, speeding up or enhancing your experience of the Services by, for instance, tailoring content to you. Cookies may also be used to keep track of your login name and password.  While ComCard may use cookies to track your visit to the Site, this information does not identify you personally and you remain anonymous, even if you have previously submitted personal information to ComCard through the Site or otherwise. You may still access the Services if you set your browser not to accept cookies.

Third parties whose websites are accessible through links on the Site may also use their own cookies when you link to their site or service.  ComCard does not control these third parties’ use of cookies and cannot guarantee that they will uphold the same privacy standards as ComCard.  ComCard expressly disclaims any and all liability related to the collection, use or disclosure of information by third parties. You should review the privacy policies of any third-party websites that you visit through a link from the Site to understand how these third parties use cookies and the information they collect through cookies.  Most cookies are “session cookies” which means that they are automatically deleted at the end of each session. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it. 

1.6 Children’s Privacy

We do not knowingly collect personal information from children under 16, or allow them to create an account for the Services.  We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience at all times.

2. How We Use Your Information

The personal information you provide to us will allow us to communicate with you and provide the Services to you, depending on the aspects of the Services for which you register.  We primarily use the personal information you provide and any general information we receive from you to provide the following:

  • Determine eligibility;

  • Create and manage your account;

  • Calculate and provide rewards, and manage our fully integrated loyalty system;

  • Communicate with you (by phone, text, email, or chat);

  • Process transactions;

  • For billing purposes;

  • To personalize your customer experience;

  • Provide customer service, troubleshoot; whether it’s responding to a request or following up on an order;

  • Improve our services and the interactions you have with us;

  • Monitor, prevent, and detect fraud or unauthorized activity;

  • For our business purposes, such as to facilitate reporting, analyze performance, or create/respond to audits;

  • Market products and services that may be of interest to you-- for instance, we may add you to our email list and newsletter; and

  • Comply with and enforce applicable legal requirements, relevant industry standards and our policies.

We keep track of your interactions with us, including but not limited to your activity within the Services. Except as set forth in this Privacy Policy, or unless we have your consent, we will not share your personal information with any person or entity other than those affiliated with us, entities acting on our behalf, and relevant third parties such as those needed to collect and maintain our servers and perform technology and related services.

We may use your personal information with non-personal information that we have collected in a manner such that the end-product does not personally identify you or any other user of the Services. We may make your personal information non-personally identifiable by either combining it with information about other users (aggregating your personal information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the Services (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies any Services users.

To better target advertisements, improve, and market our products and services, and for other promotional purposes, we may reasonably transform personal information into de-identified information removing or masking the information that could be used to identify you and by aggregating or combining de-identified data with other information.  If you don’t want us to use your data in an anonymized or aggregated form, contact us.

3. How We Share Your Information

We share the personal information we collect from you for the following reasons:

  • Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce our Terms of Use for the Services, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Services, or (iv) such action is appropriate to protect the rights, property or safety of ComCard, its employees, users of the Services or others.

  • Services Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. For example, we utilize payment processors.  Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

  • Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of ComCard’s assets, user information, including personal information collected from you through your use of the Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the Site.

Advertising. We may use third parties to send advertisements on our behalf.  We may only share a very limited set of personal information required to deliver our advertisements to you (such as an email address to deliver the message to you), and we do not permit third parties to use or share your personal information to advertise unaffiliated products or services to you.  These third parties may also use cookies or similar tracking tools to identify you through your browser usage. While you may disable these tools in your browser settings, you may still receive non-targeted advertisements we sent as part of a general marketing campaign.

  • Financial and business partners. We share personal information to facilitate the services we provide to you with our business and financial partners.

    • Card issuing partners.  ComCard partners with banks to issue cards to you.  ComCard owns and controls the transaction data and other personal information we share with the card-issuing partners.  We share the personal information you provide with your application for a ComCard Account with our card-issuing partners to comply with our contractual obligations and to facilitate compliance with their and our regulatory obligations.  Our card issuing partners do not sell or use your personal information or use any related data to market or to develop products and services, or for any other purpose not authorized by us.

    • Credit reporting agencies.  We share your business information with credit reporting agencies to verify information about your business and to report on your business’s performance, which in some cases may contain personal information.

    • Card network partners.  Mastercard separately processes information related to your use of your cards.  For more information on how Mastercard handles your personal information, please visit Mastercard’s Global Privacy Notice, which can be found here: https://www.mastercard.us/en-us/about-mastercard/what-we-do/privacy.html.

    • Partnerships and referrals.  We share personal information to facilitate referral partnerships.  For example, if you were referred to us through an organization, we may provide confirmation to that organization that your business opened a ComCard Account with us, and information relating to your ComCard Account activity solely for the purpose of calculating any referral fees we owe related to the referral.

  • Loyalty Management. We share personal information with merchants who participate in our loyalty system (“Loyalty Partners”).  These Loyalty Partners use this information to provide services and rewards to you. You cannot opt-out of the sharing of this information.  Information shared with our Loyalty Partners includes:

    • Company name;

    • Company information, such as your: business type, location, and number of employees; and

    • Transaction information, including your: average monthly spending at similar merchant locations, average transaction size, and quarterly monthly spending tier at similar merchant locations, location of transactions (grouped by city).  We do not share exact transaction amounts, only averages and ranges. 

We may also use your depersonalized personal information to provide analyses of our users in the aggregate (including Analytical Data subject to the terms of this Privacy Policy) to prospective partners and other third parties. 

4. Your Rights and Choices Regarding Your Information

  • Electronic Communications.  If you no longer want to receive our newsletter, emails or other marketing communications, you may unsubscribe by following the “unsubscribe” link at the bottom of our emails or by contacting us. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account.

  • Updates.  You can review and update your personal information in your account settings at any time by logging in to your account.

  • Closing Your Account.  You can cancel your Cards at any time per the terms set out in our Terms of Use. Upon cancellation, you will permanently lose access to the Cards, your personal information, and data associated with the account.  However, personal information or de-identified information associated with your business may be retained where required to comply with the law or our contractual obligations.

5. How We Store and Safeguard Your Information

We care about protecting your information, so we employ physical, technical, and administrative safeguards designed to help keep it safe, including encryption and techniques to reduce the ability to identify an individual in some cases.  We partner with third-parties, like Very Good Security, to ensure that Data collected is segmented, aliased, and stored in secure vaults until needed.

We are PCI compliant.  PCI DSS stands for Payment Card Industry Data Security Standard, which sets the requirements for organizations and sellers to safely and securely accept, store, process, and transmit credit card transactions to prevent fraud and data breaches.  In addition, our third-party service providers are also PCI compliant.  

Unfortunately, no data transmission over the Internet or other network can be guaranteed to be 100% secure. We cannot and do not guarantee the security of any information you transmit on or through our websites or a mobile app (if available).  

Please contact us immediately if you believe that your personal information or any other confidential information that you have provided to us is no longer secure or has been lost or stolen.

When you communicate with customer service via email or chat, we ask that you not share sensitive information via these communication channels.  When you register for Services, you will need to set up a password to access your information on our site. If you want to change your password, click on “Sign In” from any page on the website, and you can access, correct, or update your choices and settings from within your account.  Note that we don’t ask customers to confirm account or credit card details by email – if you receive an email claiming to be from us and asking for this information, do not respond.

6. Changes to this Privacy Policy

We may change this Privacy Policy from time to time.  Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business.  We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your account and cease the use of our Services.

7. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us.

Сall us if you have questions

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ComCard card is issued by Sutton Bank, Member FDIC, pursuant to license by Mastercard International. Terms and conditions apply. See the ComCard Platform Agreement for details.