PRIVACY POLICY
Last Updated August 1, 2023
Introduction
The following information will help you understand how we collect, use, share and safeguard your Personal Information. It also describes your choices regarding use, access, and correction of your Personal Information.
This Policy applies to information we collect:
- From visitors to any publicly available website or web-based applications owned by this site or any of its subsidiaries or affiliates (“Website(s)”)
- Through software applications made available for use on or through computers and mobile devices (“Apps”)
- In email, text, and other electronic messages between you and this site
- Through social media properties from which you access this Policy
- Through HTML-formatted email messages that link to this Policy
- From contacts at our clients and customers and/or contacts at prospective clients and customers
- From contacts for suppliers of goods and services to this company
- When you interact with our advertising and Apps on third party websites, if those advertisements and Apps include links to this Policy
- From any other individual about whom we obtain Personal Information in the provision of its goods and services to clients, customers, and the public
- Through any offline business interactions you may have with us (“Offline Interactions”)
Collectively, we refer to the bullets outlined above as the “Services.” By accessing our Services, you agree to this Policy. This Policy may change from time to time. Your continued use of Services after we make changes is deemed to be acceptance of those changes, so please check this Policy regularly for updates.
If you are a resident of those states with specific state privacy laws, please review the Additional Information Regarding Your State Privacy Rights below.
Information Relating to Minors
The nature of the Services is not intended for individuals under the age of 16. If we learn we have collected or received Personal Information from someone under age 16 without parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at privacy@deluxe.com
Information We Collect About You and How We Collect It:
“Personal Information” is information that relates to an identified or identifiable person, whether alone or in combination with other information.
We collect the following types of Personal Information:
- Identifiers (such as your contact information (name, alias, email address, postal address, phone number, driver’s license number, account name, social security number) or unique personal identifiers (wireless device ID, cookies, IP address, signature)) (“Identifiers”)
- Commercial information (such as transaction data, purchase history, signatures, or delivery information) (“Commercial Data”)
- Financial information (such as bank account information, routing numbers, and credit or debit card information, and other financial information, including credit report and salary data) (“Financial Data”)
- Internet or other network or device activity (such as browsing history, online search history, Website search history, browser type and language, operating system, or App usage) (“Internet Data”)
- Geolocation information (such as city, state and zip code associated to your IP address or derived through Wi-Fi triangulation; and, with your permission, in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices (“Geolocation Data”)
- Inference information about you (such as preferences, characteristics, attitudes, and behaviors) (“Inference Data”)
- Legally protected classifications (such as race, national origin, religion, age, gender or gender identity, military status, and marital status) (“Protected Data”)
- Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes) (“Profile Data”)
- Information that identifies or can be reasonable associated with you (“Associated Data”)
- Sensitive personal information (such as social security number; driver’s license number; account login; financial account; debit card or credit card number in combination with any required security or access code, password, or credentials; racial or ethnic origin; religious or philosophical beliefs; precise geolocation; contents of mail, email, and text messages; and union membership) (“Sensitive Personal Information”)
We may collect Personal Information from a variety of sources, including, sometimes automatically:
- Through our provision of Services, for example, when you request or use Services, sign up for a newsletter, register for a webinar, enter into a contractual relationship for Services, interact with us at an event, provide information in conjunction with Services, call our help desks, complete a survey, order or inquire about Services via phone or internet, visit any Website or network, use our online applications, send us communications, visit one of our physical locations, or automatically as you browse the internet.
-
From other sources, including:
- Publicly available databases
- Subscription based sources
- Court documents and filings
- Joint marketing and event sponsors
- Our clients and customers
- Counterparties in transactions or disputes
- Social media platforms
- Our service providers
- Entities to which we provide Services, which may include your employer
- Cookies, web beacons, pixels and similar tracking technologies
We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
Cookies, Web Beacons, and Other Tracking
For information on how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking, please see our Cookies Policy.
How We Use Information We Collect About You:
We collect or disclose Personal information for these legitimate business or commercial purposes:
- Performing Services, including management of business operations, maintaining or servicing accounts, providing customer service, sending administrative information to you, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, providing similar services, responding to inquiries and fulfilling requests (“Performing Services”)
- Auditing and reporting related to particular transactions and interactions, including online interactions you may have with us or others on our behalf, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing to verify that our internal processes function as intended and are compliant with legal, regulatory, and contractual requirements (“Auditing”)
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”)
- Detecting security incidents and cyberattacks, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”)
- Debugging to identify and repair errors that impair existing intended functionality (“Repairs”)
- Undertaking internal research for technological development and demonstration, including enhancing, improving, or modifying our current Services, and using data analysis to improve our Services (“Research and Development”)
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us and to maintain the safety, security, and integrity of our Services, Websites, databases or other technology assets and business (“Quality and Safety”)
- 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 is among the assets transferred (“M&A”)
- To advance our commercial or economic interests, including marketing our Services to you, determining the effectiveness of our promotional campaigns or by inducing you or another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”)
- To enforce our terms and conditions or legal or regulatory rights, comply with applicable laws and regulations which may include laws outside your country of residence, or to cooperate with public or government authorities and law enforcement (“Legal Interests”)
- For any other purpose with your consent
We may aggregate and/or anonymize Personal Information so it is no longer considered Personal Information. We do this to generate data for our use, which we may use and disclose for any purpose.
We collect the Personal Information and use it for legitimate business purposes as detailed in the following table:
How We Sell/Share and Disclose Your Information
The table below explains the categories of information that we may share with third parties and the categories of those parties:
| Third Parties with whom we share information and why | Categories of information shared |
|---|---|
| Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver Services to you, and enhance our products, services, and your customer experience, consistent with this Policy.Those businesses may also use your information for their own purposes, including marketing purposes. |
|
| Third Parties Aiding in our Provision of Services. We may share information we collect with third party vendors, service providers, and consultants that provide products or services as part of our Services to you. These third parties may only use your information as directed by us. |
|
| Third Parties for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. |
|
| Third Parties for Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity. |
|
| Third Parties for the Protection of our Websites, Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Websites and, our subsidiaries and affiliates, and their employees, contractors, and agents; to protect the security and safety of our users of the Websites or any product or service, including when we believe disclosure is necessary to prevent physical harm or financial loss. |
|
| Third Parties in Business Transfers. We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets. |
|
| Third-Party Online Advertisers and Ad Networks. We may use or rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Websites, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Websites to assist in delivering such ads. |
|
| Internet Services Providers. In connection with the provision of the Websites, we may share information with companies that provide internet services. |
|
| Data Analytics Providers. We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business. |
|
| Operating Systems and Platforms. We may share information with software companies that power your devices and companies that provide common tools or information for software or apps about software or app consumers. |
|
| List Rental or Data Broker Services. Where permitted by law, we may share or sell information with list rental or data broker services for such list rental or data broker services’ marketing or commercial purposes. |
|
Protection of Personal Information
We have implemented reasonable measures to secure Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Unfortunately, no transmission or storage system can be guaranteed 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at privacy@deluxe.com.
Choices, Access and Opt Out
You have choices regarding marketing-related communications. If you no longer want to receive marketing-related emails, you may opt out by following the unsubscribe instructions in any of our marketing emails or by contacting us at privacyprogramoffice@deluxe.com. Note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative and account messages, from which you cannot opt out.
If you would like to request to review, correct, update, suppress/delete, or object to or restrict processing of your Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, please email privacy@deluxe.com or call 877-861-8985 to leave a voicemail. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the Additional Information Regarding Your State Privacy Rights below for more information about the requests you may make under the CCPA.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note, however, that certain Personal Information may be exempt from requests pursuant to applicable data protection laws or other laws and regulations, such as for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
Data Retention
We retain personal information as long as necessary according to our enterprise records retention schedule. Retention period calculations are based upon the time the Personal Information is needed to satisfy the purposes described in this Policy, to comply with applicable laws, legal holds, and other legal obligations (including contractual obligations), operational requirements, and to fulfill your requests.
Third Party Services and Websites
The Websites, Apps, and Services may contain links to unaffiliated third parties. This Policy does not apply to such third party sites. When you click a link to visit a third party website, you will be subject to that website’s privacy practices. We encourage you to review the privacy and security practices of any linked third party website before providing any Personal Information on that website.
The inclusion of a link on this site or Services does not imply endorsement of the linked site by us or by our affiliates or subsidiaries.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with Apps or our social media.
Special Notification about Webinars
Webinars offered as a service to users of the Services (“Webinars”) are hosted by unaffiliated third party vendors, and not by us.
Our third party vendors require users to provide Personal Information to register for or attend Webinars. This Personal Information includes name and email address. Users seeking continuing education credit also may be asked to provide the appropriate identification number(s). Please note that this Personal Information is collected by our vendors and not by us. We encourage you to read the privacy statements of our vendors, which control how such vendors handle Personal Information provided by you to register for the Webinars.
Additionally, our third party vendors provide us with Personal Information about users of our Webinars. We use this Personal Information to track attendance, to facilitate future communication with such users, and for other purposes set forth in this Policy.
Cross Border Data Transfers
Your Personal Information may be stored and processed in any country where we conduct business or in which we engage service providers to support our operations. We may transfer Personal Information to jurisdictions as necessary for the purposes described above, including to jurisdictions that may not provide the same level of protection as your country of residence. By using our Services, you understand that your information will be transferred to the United States or to other countries in which we or our affiliates or subsidiaries may exist.
Do Not Sell or Share My Information
If you do not want us to sell or share your Personal Information with affiliated, unaffiliated, or non-agent third parties for promotional or targeted advertising purposes, you can opt-out by emailing privacy@deluxe.com. Please include your name, email address and/or mailing address, as well as a daytime telephone number.
Contact Information
To ask questions about this Policy and our privacy practices, contact us at:
Privacy Program Office
801 South Marquette Ave.
Minneapolis, MN 55402
PrivacyProgramOffice@deluxe.com.
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Additional Information Regarding Your State Privacy Rights
Certain states, including California, Colorado, Connecticut, Utah, and Virginia, require that we provide additional information regarding our privacy practices and your privacy rights. If you are a resident of those states, we provide you additional notices about our privacy practices and consumer rights relating to your information. This Policy does not apply to our employees, contractors, owners, directors, or officers where the Personal Information relates to their current, former, or potential role. Job applicants can review our Privacy Notice for Job Applicants for more information about the Personal Information we collect when you apply for a position with us.
In addition to the above-listed Personal Information categories, we have collected the following in the last 12 months:
Individual Rights and Requests
You may, subject to applicable law, make the following requests:
-
You may request that we disclose to you the following information:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information
- The business or commercial purpose for collecting Personal Information about you
- The categories of Personal Information about you that we disclosed, and the categories of third parties to whom we disclosed such Personal Information (if applicable)
- You may request that we correct inaccuracies in your Personal Information
- You may request that we delete Personal Information we collected from you
- You may request to receive the specific pieces of your Personal Information, including a copy in a portable format
Exercising Your Rights to Know, Delete, or Correct
To exercise your rights to know, delete, or correct described above, please submit a request by either:
Calling: 877-861-8985 or
Emailing: privacy@deluxe.com
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct information related to your Personal Information. You may only submit a request to know twice within a 12-month period. Your request to know, delete, or correct must:
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
-
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative
- For a request by an individual, we require a copy of a valid state-issued identification card, together with any email or physical address and a valid phone number belonging to the individual making the request
- For an authorized representative, we require a copy of the signed authorization from the individual on whose behalf the agent is acting demonstrating the agent’s ability to act on that person’s behalf, a valid power of attorney, court appointment document or the agent’s registration with the California Secretary of State. Once we receive a Personal Information request from an authorized agent, unless that agent has a power of attorney issued pursuant to California Probate Code Sections 4121 to 4130, we may contact the person to whom the request relates in order to, among other things, verify their identity, confirm the agent’s capacity to act on that person’s behalf, and if applicable, respond to or deliver information requested pursuant to the Personal Information request
- For a request related to a household, all members of the household must submit the request, and each must provide information sufficient for us to verify their identity. Typically, that will include, a copy of each household members’ valid state-issued identification card (or for minors under the age of 13, a signed consent of the minors’ parent or guardian), together with any email or physical address that may have been submitted to us and a valid phone number belonging to the individuals making the request. We may deny a request from a household if we cannot verify that the individual(s) making the request are part of the same household
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at the methods described above.
We endeavor to respond to your request (upon verification) within forty-five (45) calendar days of its receipt. If we require more time (up to ninety (90) calendar days total), we will inform you of the reason and extension period in writing. We will deliver our written response electronically, or by mail if you so choose.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request and your appeal options, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In some cases, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities
- Debug products to identify and repair errors that impair existing intended functionality
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Comply with applicable state, federal, and local laws.
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Nondiscrimination
Subject to applicable law, we may not discriminate against you because you exercise of any of the above rights, or any other rights under the state privacy laws, including by:
- Denying you goods or services
- Charging different prices or rates for goods or services, including using discounts or other benefits or imposing penalties
- Providing you a different level or quality of goods or services
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
California “Shine the Light” Disclosures
Residents of the State of California may ask us to provide them with a list of the types of Personal Information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us by either:
Calling: 877-861-8985 or
Emailing: privacy@deluxe.com
For all such requests, please indicate "CA Shine the Light" in the subject field of your request and include the name of the specific product or service with respect to which you are requesting the information. You must also include your full name, email address, street address, city, state, zip code, and phone number.