Privacy Policy

Information Disclosure

Corporate Spending Innovations and its affiliates (“CSI”) is committed to safeguarding your privacy. This privacy policy summarizes how we meet our privacy commitments to you. We believe it is important to understand how CSI keeps your information private and secure.

CSI will not knowingly disclose to any third party your credit card number without your prior consent, except to the extent necessary or appropriate to comply with applicable laws or in legal proceedings where such information is relevant or where CSI believes in good faith that the law requires such disclosure.

CSI uses its best efforts to protect your personal information. However, CSI is not responsible or liable for the acquisition of your personal information by third parties without CSI’s knowledge and CSI has no control over anything that occurs on servers not controlled by CSI. The Website may have links to other sites not controlled by CSI and CSI warrants no level of privacy protection from or by those other sites.

Data We Collect
The following types of Personally Identifiable Information (“PII”) may be collected, stored, and used by CSI:

  • information about your computer including your IP address, geographical location, browser type and version, and operating system;
  • information about your visits to and use of this website including the referral source, length of visit, page views, and website navigation paths;
  • information, such as your email address, that you enter when you register with our website;
  • information that you enter when you create a profile on our website—for example, your user name, and password;
  • information that you enter while using the services on our website;
  • information that is generated while using our website, including when, how often, and under what circumstances you use it;
  • information relating to any services you use, or transactions you make through our website, which includes your name and credit card details;
  • information contained in any communications that you send to us by email or through our website, including its communication content and metadata;
  • any other personal information that you send to us.

Purposes
CSI may collect, use and disclose your PII for the following purposes:
To provide and administer products and services you request, and to disclose the information for any purpose related to the provision of requested products and services;

  • For internal business purposes, including solving technical problems, calculating usage statistics, product development, and content improvement;
  • To provide customer support;
  • To compare information for accuracy and verify it with third parties;
  • To collect fees or debts owed to us;
  • To manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger;
  • To protect us, yourself and others from fraud and error, to prevent potentially prohibited or illegal activities, and enforce our website Terms of Use and Customer Terms of Service; and to comply with legal and regulatory requirements.

These collections, uses and disclosures listed above are a reasonably necessary part of your relationship with CSI. CSI may also collect, use and disclose your PII to offer additional or alternate products and services to you.

We may disclose your PII to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your PII to any member of our group of companies (this means our subsidiaries and our affiliates) as reasonably necessary for the purposes set out in this policy.

Communications
In the event that you communicate any information, feedback, data, questions, comments, suggestions or other items to CSI regarding CSI, this Website and its contents, or the services offered on this Website, any such communication shall be deemed not to be confidential and shall become the property of CSI. CSI shall be free to reproduce, use, disclose and distribute such communication to others, without limitation. CSI shall also have the unrestricted right to use any ideas, concepts, know-how, software, documentation, diagrams, drawings, schematics or techniques contained in your communication in any manner and for any purpose whatsoever including, but not limited to, developing, and marketing products or providing services.

Internet Use Considerations
We have implemented measures designed to secure your PII from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Your password should not be shared.

The transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your PII, we cannot guarantee the security of your PII transmitted through our Website. Any transmission of PII is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Mobile Applications
CSI’s Mobile Payments Application (“Application”) is governed by this Privacy Policy. This Notice applies to any PII or other information that we may collect through the Application.

Collection of Personal Information/Ability to Opt Out of Further Contacts
We collect information you provide when applying on the Website or that you share through the Website. CSI will not collect PII indiscriminately but will limit collection of PII to that which is reasonable and necessary or as authorized by law.

When you apply through the Website or update your account information, we may collect the following types of information:

  • Contact information: name, address, phone number, email, job title, and other similar identifiers.
  • Business information: name of business, tax identification, authorized officers, and description of services.
  • Financial information: financial institution and account numbers.

We may also collect information concerning you, including, but not limited to, the kind of service you are seeking from CSI. Our web server collects and stores the following general information about you such as the date and time you access our Website and the name and version of your device or web browser software you are using. This information is collected automatically. It is used to help us improve our website by tabulating the number of visitors to our website in terms of new users, origin of referrers, popularity of pages, amount of use, and types of errors, and to make the website more useful to you. Occasionally, we may provide data to third parties concerning the number of visitors to our websites. This data will not contain PII.

We may use “cookies,” “web beacons” or scripts to store and track your use of the Website. These tools are used to remind us of who you are in order to deliver you better service. By disabling these tools or not accepting cookies, you may not be able to access all parts of the Website.

In the event you elect not to receive any future contacts from CSI, we will endeavor to remove your name from all of our contact lists; however, this does not include information which may have been shared with a third party and is no longer in the control of CSI. For U.S. citizens, we shall have no liability under this Privacy Policy and the Terms of Use for our failure to remove your name from all our contact lists. If you have questions, you should direct them to privacy@corporatespending.com.

Cookies
Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

International Data Transfers

  • PII that we collect may be stored, processed in, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.
  • Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: The United States of America and Canada.
  • You expressly agree to the transfers of personal information described in this Section.

Your Rights
You may instruct us to provide you with access to any PII we hold about you; provision of such information will be subject to the following:

  • the payment of a reasonable fee to the extent allowed by law; and
  • the supply of appropriate evidence of your identity.

We may withhold PII that you request to the extent permitted by law.

Legal Protection
We reserve the right to disclose your PII, as required, to comply with the law, applicable regulations, governmental and quasi-governmental requests, judicial proceedings, court orders, or legal process, and will establish or exercise our legal rights and defend against legal claims at our discretion. We will share, without notice to you, all information we possess in response to court orders, subpoenas and to comply with government investigations. At our discretion we will share information to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Website’s Terms of Use or as otherwise required by law.

Third-Party Internet Sites
This Privacy Policy is applicable only to CSI’s Website or any affiliate or related websites and does not apply to any third-party internet sites or to other companies or persons. The Website may contain links to, and media and other content from, other internet sites. In addition, such third-party media and content may also contain external links. CSI cannot and does not guarantee the privacy policies and practices of any third party. CSI does not control, operate, or endorse any information, products, or services of any third-party internet sites that may be reached through links from the Website. The use of any personal information provided by you to such a third-party will be governed by that party’s privacy policy, as applicable. If you are unsure whether an internet site is controlled, affiliated, or managed by CSI, you should review the privacy policy at each linked website to determine how that site treats your personal information.

Retaining Personal Information

  • This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal information.
  • PII that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  • Without prejudice to this Section, we will usually delete personal data within 30 days.
  • Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing PII:
    • to the extent that we are required to do so by law or any regulatory agency;
    • if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    • in order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Protecting Children
This Website is intended for a general audience. You must be at least 18 years old to use this web site. We do not knowingly collect, use, or disclose personal information about visitors under 18 years of age. If you are under 18 years of age, you may not use the services offered on our web site unless they are used with the consent, permission and supervision of your parents or guardians.

YOUR DATA PROTECTION RIGHTS
Please be advised that in case you allow CSI to collect and process certain personal data from you, you may have the following rights:

  • Right of Access. You may have the right to obtain from us confirmation as to whether personal data concerning you is processed, and, where that is the case, you have the right to request and get access to that personal data.
  • Right to Rectification. You may have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.
  • Right to Erasure (“Right to be Forgotten”). In certain cases, you may have the right to obtain from us the erasure of your personal data.
  • Right to Restriction of Processing. You may have the right to obtain from us restriction of processing, applicable for a certain period and/or for certain situations.
  • Right to Data Portability. You may have the right to receive from us in a structured format your personal data and you have the right to (let) transmit such personal data to another controller.
  • Right to Object. In certain cases, you may have the right to object to processing of your personal data, including with regards to profiling. You have the right to object at further processing of your personal data in so far as such data have been collected for direct marketing purposes.
  • Right to be Not Subject to Automated Individual Decision-Making. You may have the right to not be subject to a decision based solely on automated processing

Policy Changes
CSI may change this Privacy Policy from time to time in our sole discretion. We will provide notice by, at a minimum, updating this posting. Periodically, you should review this Privacy Policy carefully. By using the Website, you acknowledge and agree to CSI’s collection and sharing of your PII according to the terms of the then current Privacy Policy. If, at any time, you have questions or concerns about CSI’s privacy commitment, please feel free to contact us at privacy@corporatespending.com.

Updated July 2018