Last Updated: April 3, 2024

At PrimePay, we appreciate your concerns about privacy and confidentiality. Our clients have trusted us with their payroll needs since 1986, and we strive to maintain a high level of integrity across our suite of services, including payroll, SyncHR, benefits administration and compliance services, and ProfitKeeper. In doing so, we want you to understand what information we collect from you (our customers, Website visitors and end users of PrimePay services), why we collect this information and how we protect your privacy, including some of the technological measures we take to protect your personal and business information.

This Privacy Policy also explains additional rights that you may have under international or state law. If you are a resident of California or a European Union member state or Switzerland, please make sure to review the applicable Consumer Privacy Statement, available below.

Please read this Privacy Policy carefully. By using and/or accessing our websites (collectively, the “Websites” or “Sites”), Apps and Services, you acknowledge and agree to the terms of this Privacy Policy.

Part I: GENERAL CONSUMER PRIVACY STATEMENT

Information Collection

With few exceptions, the information of yours that we collect or handle is information that you give us so that we can provide the services you desire from PrimePay, such as employee and payroll data. In addition, certain services may require us to request a standard credit report on your business from a credit reporting agency or specific credit references. In some instances you may contact PrimePay on our website, or PrimePay may contact you, as a result of a referral from a co-branded business partner who may supply us with limited contact information pursuant to a national program offering special benefits to you. In other cases, we may get your publicly available contact information from sources such as the Internet, professional or business organizations, or as a result of a personal referral from your accountant or bookkeeper, from another PrimePay client or from any other person. Finally, our website may retain certain personally identifiable or non-personal information from visitors to the site for internal maintenance and research purposes, which is discussed more fully below.

General Privacy Policy

Practically all of the services PrimePay provides you (our “client”) involve the handling or processing of your contact information, employee compensation, withholding and benefits data, and in many cases individual client and employee banking or health information that you or your employees disclose to us under a service or other agreement providing an obligation of confidentiality on PrimePay’s part. It is also possible that, during the course of performing our services, talking to you, visiting your offices, or receiving information or communications from you over the Internet, we may encounter other business, employee or employee dependent information relating to your business or your employees of a nature and under circumstances such that a reasonable person would understand such information to be proprietary or confidential. For purposes of this Statement we will refer to all of this information, collectively, as “Client Information.” We understand how sensitive this information is to you and are committed to protecting it and safeguarding your privacy.

Subject to the exceptions listed below, PrimePay will safeguard your Client Information with the same level of care and diligence with which we safeguard our own confidential information (which is never less than a reasonable level of care). All PrimePay employees are subject to a strict Confidentiality and Non-Disclosure Agreement and all understand that it can and will be strictly enforced. PrimePay is committed to handling your Client Information with high standards of information security (discussed below) and will take reasonable technical, physical and operational precautions to protect your data and other Client Information. PrimePay does not sell or rent your Client Information to third parties.

Client Information – Confidentiality Conditions

PrimePay’s undertaking to keep all of your Client Information confidential is subject to several standard legal and common sense exceptions. These are listed below:

• PrimePay may disclose Client Information to our own employees, affiliates, or service providers who have a need to know in order for PrimePay to provide the services you have asked us to provide or other PrimePay services that could benefit you or your business. All of these parties will be subject to confidentiality restrictions comparable to those in effect with our own employees.
• PrimePay will disclose Client Information when you authorize us to do so. For example: in order to provide our tax filing and payment service, you will have to provide us with a Power of Attorney authorizing us to sign your employment tax returns and speak to the taxing authority if the need arises.
• PrimePay will disclose Client Information when your consent to disclosure is implied by the nature of your request for services from us. For example: if you ask us to get you a quote on your worker’s compensation insurance, we will have to share certain Client Information with the insurance company and possibly a licensed broker.
• While not a standard business practice, PrimePay legally:
  • may disclose any information already lawfully in its possession without any obligation of confidentiality;
  • may disclose any information that is developed independently by PrimePay or procured from sources other than you without obligation of confidentiality;
  • may disclose any information that is publicly available when received by PrimePay, or which becomes publicly available through no fault of PrimePay; or
  • may disclose any information that you disclose to another without obligation of confidentiality;
• PrimePay may disclose Client Information in limited circumstances when in good faith we believe that disclosure is required under the law. For example: we may be required to disclose Client Information to cooperate with regulators or law enforcement authorities, to comply with a specific legal process such as a court order, subpoena, or search warrant, or to comply with a law enforcement request.

PrimePay, from time to time, may offer features or services that may be accessed directly by employees or participants that may require the use of their personal information, and they will be given a choice to consent to such use or opt out of the feature or service.  Similarly, in a few instances PrimePay may bundle services of potential value to you, the employer, that necessarily involve the disclosure of personal information of individuals and which may require you to notify each affected employee or participant of their right to opt-out of such disclosure.  In such instances, you will receive written notice of this responsibility and detailed instructions as to the required notice to be distributed.

Third Party Relationships

We have limited relationships with third parties to assist us in servicing you, for example, by making certain specialized knowledge bases available to our clients. These service providers are contractually required to maintain the confidentiality of the information we provide them.

Additionally, we have business partners that provide services, some of which are co-branded. We clearly identify partner services and sites. When you request any of these products or services or a quote or other information on them, you are permitting us to provide your contact or limited Client Information necessary to the partner to fulfill your request or to verify your participation in the partner’s special program or service involving PrimePay. Other than as discussed above, PrimePay does not sell, rent, share or disclose its clients’ identities to other parties for marketing or promotional purposes.

Web Technologies

We use, or may in the future use, a variety of technologies on our Website. Hits to our primepay.com portal or other PrimePay sites are tracked on our Web server only for purposes of managing our traffic and bandwidth usage, but are not linked to any name or personally identifiable login information.

On the other hand, if you choose to submit your sensitive payroll data via our Internet PrimePay Web interface, or through our SyncHR product, such data is only accepted on a secure, data-encrypted Web page behind a firewall, and your identity will necessarily be established both by secure login procedures as well as through “cookies” which identify your computer. For more information about cookies, see below.

When we track activity on any PrimePay Website, we collect information such as your IP address, browser type and version, and pages you view. We may also keep track of how you get to our sites and any links you click on to leave our sites. We do not track non-PrimePay URLs that you type into your browser and we do not track you across the Internet once you leave our sites.  We do not disclose your URL to other parties – this information is used for internal purposes only. We only use your Website activity to assist you by aiding security, by reducing the need to re-enter your data and by helping us to resolve technical support issues. We may also use this information to offer you a personalized Web experience or to tailor our offerings to you.

You control whether you receive PrimePay promotional materials and may always opt out by clicking on the icon or checkbox that indicates you do not want to receive any promotional materials.

To provide you with a seamless experience, we may occasionally use framing or provide links to non-PrimePay Websites. Though your browser may indicate you are at a PrimePay site, you may be on a partner’s site. Also, you may be on a PrimePay regional or specialized site created for certain customers or purposes. To determine which site you are on, right-click on the site and then select “properties.”

When visiting a partner’s Website or any non-PrimePay linked Website, you will be subject to the privacy policies in effect with respect to that site. PrimePay has no control over that Website’s security or privacy policies. If you have questions about a Website’s practices, please review that Website’s privacy policy.

Cookies.

Like many online services, we use cookies to collect certain information and provide a more personalized site experience. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers on our web site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

We use the following types of cookies for the purposes set out below:

Type of cookie	Purpose
Essential Cookies	These cookies are essential to provide you with our services and to enable you to use some of the features. For example, they help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow our web sites to remember choices you make when you use our services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our web sites or services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our web sites.
Analytics and Performance Cookies	These cookies are used to collect information about traffic to our web sites and how users use our services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our web sites, websites that referred them to our web site, the pages they visited on our web sites, what time of day they visited our web sites, whether they have visited our web sites  before, and other similar information. We use this information to help operate our web sites  and services more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites . We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Sites  and services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies You can find out more about how Google protects your data here: https://policies.google.com/privacy You can prevent the use of Google Analytics relating to your use of our web sites by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en-GB
Targeted and Advertising Cookies	These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show ads which may be relevant to your interests while you are on third party websites.
Social Media Cookies	These cookies are used when you share information using a social media sharing button or “like” button on the website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our web sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our web sites.

Analytics

We may use third-party analytics providers (like Google Analytics and Mixpanel) to help analyze how users use our web sites. These analytics providers use cookies and other technologies to collect information such as how often users use our web sites, what pages they visit, and what other websites they used prior to coming to our web site. We use the information we get from these providers only to improve our web sites and our services. They collect the IP address assigned to you on the date you visit our web sites, rather than your name or other personally identifying information. Although such services may set persistent cookies on your computer to identify you as a unique user the next time you visit our web sites, the cookie is designed to be used only by the service provider.

We use cookies to understand website and Internet usage and to improve or customize the content, offerings or advertisements on our web sites. We also may use cookies to help us offer you products, programs, or services that may be of interest to you and to deliver relevant advertising.

We, our third-party service providers, advertisers or our partners also may use cookies to manage and measure the performance of advertisements displayed on or delivered by us and/or other networks or websites. This also helps us, our service providers and partners provide more relevant advertising.

We, our third party service providers, advertiser or our partners may also use “web beacons” or clear.gifs, or similar technologies, which are small pieces of code placed on a web page, to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Automatic Data Collection

As is true of most websites, we gather certain information automatically. We may combine this automatically collected log information with other information that you provide us or that we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality and to analyze trends in the aggregate and to administer our Sites. The information we may collect by automated means includes:

• Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type);
• URLs that refer visitors to our websites;
• Dates and times of visits to our websites; and/or clickstream data
• Internet service provider;
• Referring/exit pages;
• The files viewed on our Sites (e.g., HTML pages, graphics, etc.)
• Language;
• Information on actions taken on our websites (such as page views and site navigation patterns);
• A general geographic location (such as country and city) from which a visitor accesses our websites or mobile applications; and
• Search terms that visitors use to reach our websites.

Linked Websites and Social Networks

Our websites may provide links to third-party sites for your convenience and information. PrimePay does not control linked websites, and we do not endorse or make any representations about third-party websites. Linked sites may have their own privacy policies, which you should review if you visit those sites. We are not responsible for the content of any sites not affiliated with PrimePay, any use of those sites, or those sites’ privacy practices.

We may also provide social media features on our Sites that enable you to share PrimePay information with your social networks and to interact with PrimePay on various social media websites. This includes social media features, such as the Facebook Like button and widgets, such as the Share this button or interactive mini-programs that run on our websites. Your use of these features may result in the collection or sharing of information about you. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. We encourage you to review the privacy policies and settings on the social media websites with which you interact to help you understand those website’s privacy practices.

Information Security

PrimePay understands the importance of maintaining the security and accuracy of your personal and payroll information. We utilize advanced industry accepted security practices, including digital certificates, encryption and passwords to protect your personal and payroll information. We employ technological means for the backup and recovery of client information, detection and prevention of viruses and malware and site monitoring. We maintain advanced firewalls and other computer hardware and software to protect against unauthorized access or alteration to client data. These measures implement reasonable physical, administrative and technical safeguards that help us to protect our Client Information from loss or from unauthorized access, use and disclosure.

Digital Certificates

Secure Sockets Layer (SSL) provides a method to verify that you are logging on to our server and not a site that is impersonating our server. Our server sends a digital certificate to your browser program before you log on with us. SSL lets you verify the identity of a server by viewing the site’s certificate. A certificate is a way of associating a public key to a name. You can verify that you are logged on to our server by viewing our certificate through your browser program.

Data Encryption

Once the server is authenticated via SSL, your browser and our server will establish a secret symmetric key. This symmetric key allows your browser and our server to exchange encrypted data and is valid for a single session only. If you log out and later come back to our Website, your browser and our server will negotiate a different symmetric key automatically.

Passwords

PrimePay provides for the creation of a unique username and password for each user in your organization that must be entered each time a user logs on. Please be aware that passwords can remain in your browser’s cache, which may allow access if your computer is left unattended.

A Further Word About Cookies

In addition to the cookie usage described above in relation to visits to PrimePay Websites generally, PrimePay issues a separate “session cookie” only to record encrypted authentication information for the duration of each specific session during which an authorized user is logged in. The session cookie does not include either the username or password of the user. PrimePay does not use cookies to store confidential user information.  Instead, an advanced security method utilizing encoded session IDs has been implemented. The session cookie lets a specific, authorized user move from page to page in the secure parts of PrimePay’s Website and stay identified by our system. Without the session cookie, each page would treat the user like a completely new visitor. The session cookie is a temporary file that gets erased when you log out or close your browser.

Timeouts

To provide additional protection, a timeout feature is used on selected parts of our website. This feature automatically logs you out of your account after an extended period of time.

Firewalls

PrimePay utilizes advanced hardware and software security systems including firewall, attack detection and anti-virus systems.

Physical Security

PrimePay utilizes secure monitored server hosting environments which feature redundant, high bandwidth internet connections from multiple providers, real-time network monitoring and management, 24/7 facilities access monitoring, environmental controls and redundant electricity. Non-H2O fire suppression systems are also utilized to protect the availability of PrimePay internet services.

Children Under 16 Years of Age

Our Services generally provide payroll and related compliance solutions. As such, our Websites are not intended for children under 16 years of age and we do not knowingly collect personal information from children under 16 years of age. If we learn that a user of our Site is under 16 years old, we will promptly delete any personal information that the individual has provided to us.

Personal Rights and Preferences

PrimePay respects your rights to access, correct, amend and erase your personal information or object to the processing of such data. To receive an accounting of the personal information held about you by PrimePay or exercise any other personal rights or preferences regarding your personal information, please contact us at the email address or physical address listed below.

PrimePay will respond to all requests as soon as reasonably possible and in accordance with applicable law and regulations.

How to Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@primepay.com. You also may write to:

PrimePay, LLC
 Attn: Information Security
 1487 Dunwoody Drive
 West Chester, PA 19380

You will receive confirmation of requested updates or deletions within 10 business days after request is made.

Changes to this Policy

We may update this Privacy Policy from time to time to comply with legal requirements or to align with a change in our personal information practices, so please check periodically to make sure you are aware of PrimePay’s most up to date privacy policies. If we make a substantial change to this Privacy Policy, such as a change to the processes by which we collect or use your personal information, we will attempt to notify you by email or by alerting you through our Websites.

PART II. CALIFORNIA CONSUMER PRIVACY STATEMENT

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), PrimePay is providing the following disclosure for residents in California, including consumers whose information we collect from them directly in signing up for our services and those who visit our Website. In addition to the information provided above, this disclosure further explains our collection and use of your data and rights that may be afforded to you under California law.

This disclosure does not apply to employees of our clients, whose information we are provided and maintain from your employer in performing services. If you have any questions regarding personal information provided to or maintained by PrimePay in this respect, please reach out directly to your employer.

As defined under the CCPA, Personal Information is “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

Your Rights in CA:

1. Right to Know.

Under California law, you have a right to know: (i) the categories of Personal Information we collect about you, (ii) the categories of sources from which we collect that information, (iii) the business or commercial purpose for collecting such information, and (iv) the categories of third parties with whom we share that information. Additionally, you have a right to request a disclosure of the specific pieces of Personal Information PrimePay has collected and/or maintained about you for the previous twelve (12) months.

Categories of Personal Data Collected & Disclosed

PrimePay may collect the following categories of Personal Information about you in your interactions with us:

Category A: Identifiers such as your name, alias, postal address, unique personal identifier, online identifier, Internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Category B: Personal information as defined in the California consumer records statute, such as your name, signature, social security number, address, etc.

Category C: Characteristics of protected classifications under California or federal law, such as sex, race, or age.

Category D: Commercial information, such as your purchase history and transaction information.

Category F: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interactions with our Website or applications.

Category G: Geolocation data.

Category H: Audio, electronic, visual, or similar information.

Category I: Professional or employment-related information.

Category J: Education information.

Category K: Inferences drawn from any information identified above to create a profile about you reflecting, among other, your preferences, characteristics, behavior and aptitudes.

Category L: Sensitive personal information, including your social security and other identification numbers, account log-in and credentials.

Sources of Personal Data

We collect Personal Information from you directly and indirectly through your interactions with us. For example, we may collect Personal Information when you complete forms or surveys requesting information regarding a product. We may also collect information indirectly, such as through your interactions with our Websites. 

In addition, we collect Personal Information from third party sources, such as clients and partners who may provide your information in connection with our service offerings or marketing opportunities.

Purposes for the Collection of Personal Data

We may collect your Personal Information in order to:

• Perform services: such as maintaining accounts, provide customer service, process payments, or verify customer information;
• Provide advertising and marketing services: including sending you promotional materials or other advertising items that you have or may be interested in;
• Development: to help maintain, develop, improve or enhance our products and services;
• Research: to conduct research regarding technological developments;
• Security detection: to detect security incidents, to the extent that such Personal Information is reasonably necessary and helpful in detecting such incidents;
• Marketing purposes: such as auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards and advertising relating to your current interaction with our websites.

Disclosure of Personal Data

PrimePay does not sell your Personal Information, however, we may disclose such information with certain third-parties either for a valid business purpose, in accordance with applicable law (e.g., law enforcement agencies when required), or with your consent.

Parties to whom we may disclose Personal Information include contractors, vendors and other authorized third-parties to provide specific services, such as support and marketing services. 

We also share cookies with third party analytics providers. For more information, please see the section entitled “Analytics” in the General Consumer Privacy Statement.

2. Right to Delete or Correct.

PrimePay retains your Personal Information until there is no longer a legitimate business purpose for maintaining such information, unless we are required to maintain that information longer by applicable law.

Under California law, you have a right to request that we delete any and all Personal Information that we have collected or maintain about you. If you make such a request, we will either (i) delete all Personal Information from our records and notify our service providers to delete any Personal Information maintained about you, or (ii) notify you that your request cannot be complied with and for what reason, such as because we need to maintain the information to perform the transacted for services or comply with applicable law.

3. Right to Correct Inaccurate Personal Information.

You have a right to request that PrimePay correct any inaccurate personal information collected or maintained by us. If you would like to update or correct such information, please contact us at one of the contact methods designated below.

4. Right to Non-Discrimination

If you choose to exercise any of these rights afforded to you, PrimePay shall not retaliate by any means including, but not limited to, denying goods or services, charging different prices for goods or services, or providing different service levels for goods or services. Exercising certain rights may prevent or inhibit your use or access to PrimePay’s Websites or services. 

5. Right to Opt Out of Sharing of Personal Information

You have a right to opt out of the sharing of your personal information with third parties. If you would like to update your cookie preferences or exercise this right, please contact us at one of the contact methods designated below.

How to exercise your rights.

To submit a request under this California Consumer Privacy Statement, please contact us at privacy@primepay.com, (610) 296-4500, or the mailing address listed above.

Part III: EUROPEAN UNION (“E.U.”), UNITED KINGDOM (“UK”), AND SWITZERLAND CONSUMER PRIVACY STATEMENT

What Role Does PrimePay Serve in Data Protection?

It is important to note that PrimePay acts both as a Data Controller and a Data Processor within the realm of data protection law compliance, including the European General Data Protection Regulation of 2018 (“GDPR”). As a Data Processor, PrimePay is responsible for safeguarding the data submitted to our services by or on behalf of our customers, including data regarding our client’s employees, as it flows through the suite of services that we offer to our customer, including our payroll processing, benefits administration, and other ancillary services (collectively the “PrimePay Services”).  The first part of this E.U., UK, and Switzerland Consumer Privacy Statement (the “EU, UK, and Swiss Consumer Privacy Statement”) describes how we deal with Data as a Data Processor.

As a Data Controller, PrimePay is responsible for safeguarding the data of visitors to our websites, including our public website – primepay.com – and related sites, as well as our customer solution websites, our customer support websites and other sites through which we communicate or deliver our services (the “Sites”), and all PrimePay Service Information (as defined below). The second section of this EU, UK, and Swiss Consumer Privacy Statement describes how we deal with Data as a Data Controller.

As used in this EU, UK, and Swiss Consumer Privacy Statement, “personal data” is defined as in the GDPR, and includes any information which, either alone or in combination with other information we hold about you, identifies you, including, for example, your name, postal address, email address and telephone number.

1. PrimePay as a Data Processor

PrimePay has entered into separate agreements with our customers to govern the delivery, access, and use of the PrimePay Services, including instructions for the processing of personal data on behalf of our customers.

PrimePay does collect information when acting as a service provider to its customers, however, PrimePay has no direct relationship with the individuals whose personal data it processes under the direction of our customers and our customers are responsible for making sure that your privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a client’s data processor, we will process your information, including any personal data, in accordance with the terms of our agreement with the applicable customer and the customer’s lawful instructions and the terms of this Privacy Policy shall not apply to such processing. As part of the service to our customers, PrimePay may operate a hosted version of the SyncHR HCM Cloud Platform for our customers to which the customer’s privacy policy applies. If you are an employee or contractor of one of our customers and would no longer like to be contacted by the employer that uses our service, please contact the employer that you interact with directly. Additionally, an individual who seeks access, or who seeks to correct, amend, or delete inaccurate data provided to PrimePay in performing the PrimePay Services to our customers should direct his query to PrimePay’s employer customer, the data controller.

In some cases, use of the PrimePay Services may allow you to interact with and receive services from other third-party processors (e.g. 401(k) administrators). These third-party services and the collection and use of your personal data by these third parties is governed by such third parties’ respective terms of service and privacy policies. You are responsible for reviewing these third-party terms and policies and you acknowledge that PrimePay is not responsible for the privacy practices of these third parties.

2. PrimePay as a Data Controller

When you contact us to request services through our Sites or to raise a customer service issue with PrimePay, you may provide us with relevant information such as, but not limited to, your contact information, the services you currently or would like to purchase from us, or your username related to the PrimePay Services (collectively “PrimePay Service Information”). You acknowledge that PrimePay Service Information does not include the personal information processed by PrimePay when serving as a Data Processor to its customers. This Privacy Policy does not apply to PrimePay employees.

Why Do We Need Personal Data? We need certain personal data in order to communicate with you, provide you with the services you request through our Sites, and to address any customer service inquiries you make to PrimePay.

Your Consent. By submitting personal data to PrimePay, you expressly consent to the collection, use and disclosure of your personal data in accordance with this EU, UK, and Swiss Consumer Privacy Statement and this Privacy Policy. We will process your personal data in accordance with applicable data protection and privacy laws. When you access our Sites, you hereby consent to the terms of this Privacy Policy. This consent provides us with a legal basis under applicable law to process your personal data. You maintain the right to withdraw such consent at any time.

Information We Collect.

PrimePay may collect information about you from various sources. Specifically, we may obtain information about you:

• On our Sites (e.g., when you request information, establish an account, or submit content to our Sites);
• When you call us, email us, or communicate with us through social media; and
• From our affiliates or subsidiaries, service providers, business partners, and other third parties.

The types of personal information we may obtain includes:

• Contact details (e.g., name, postal address, email address, and telephone number);
• Username and password for the account you may establish on our Sites;
• Photographs, videos, comments, and other content you submit to us;
• Information you provide by interacting with us through social media; and
• Other details that you may submit to us or that may be included in the information provided to us by third parties.

How We Use the Information We Collect When Acting as a Data Controller

When you use or communicate with us through the Site, we may use the information we obtain about you to:

• Register you on our Sites and manage and maintain your accounts on our Sites;
• Provide products or services you request;
• Understand your needs and interests and tailor our products and services to suit your personal interests and the manner in which visitors use our Sites, products, and services;
• Communicate with you about products, services, based on the general geographic location transmitted by your mobile device;
• Maintain a record of general transactions on our Sites;
• Respond to your questions and comments and provide customer support;
• Communicate with you through email, website, mobile applications and social media about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you;
• Enable you to communicate with us through our blogs, social networks, and other interactive media;
• Operate, evaluate, and improve our business and the products and services we offer;
• Analyze and enhance our marketing communications, and strategies (including by identifying when emails sent to you have been received and read);
• Analyze performance of our services and technology and to analyze trends and statistics regarding visitors’ use of our Sites, mobile applications, and social media assets, and the transactions visitors conduct on our Sites;
• Protect against fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
• Enforce our Terms of Use; and
• Comply with applicable legal requirements and industry standards and our policies.

We may combine the information we collect with publicly available information and information we receive from our affiliates, business partners, and other third parties which may include contact details (e.g., name, postal address, email address, and telephone number). We may use that combined information to enhance and personalize your experience with us, to communicate with you about products, services, and events that may be of interest to you, for promotional purposes, and for other purposes described in this EU, UK, and Swiss Consumer Privacy Statement or the Privacy Policy.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Information We Share

We do not sell or otherwise disclose personal information about you, except as described in this EU, UK, and Swiss Consumer Privacy Statement or the Privacy Policy.

We may share the personal information we collect with our affiliates, business partners, ad network vendors and their participants, and other third parties for the purposes described in this EU, UK, and Swiss Consumer Privacy Statement or the Privacy Policy, including to communicate with you about products and services, offers, events, and promotions that we believe may be of interest to you. We also may share personal information with our service providers who perform services or process information on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose information about you (i) if we are required to do so by law such as to comply with a subpoena or other legal process (such as a court order), (ii) in response to a request by law enforcement authorities, or (iii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

We reserve the right to transfer personal information we have about you in the event we sell, merge or transfer all or a portion of our business or assets, including pursuant to a bankruptcy or similar proceeding. Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this EU, UK, and Swiss Consumer Privacy Statement and our Privacy Policy. Following such a sale, merger, or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information. You will also be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Your Rights When PrimePay is Your Data Controller

If PrimePay is your Data Controller as described above and you wish to exercise any of the following rights, please contact us using the details below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA, UK, or Switzerland. Please note that your use of some of our Sites may be ineffective upon opt-out. Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our this EU, UK, and Swiss Consumer Privacy Statement or our Privacy Policy.

Access. You may access the information we hold about you at any time by contacting us directly.

Amend. You can also contact us to update or correct any inaccuracies in your personal data.

Move. Your personal data is portable – i.e., you to have the flexibility to move your data to other service providers as you wish.

Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

Data Retention

PrimePay will retain and use your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. The user account will remain active until responsible contracting company has either disabled the account or termination of service contract with PrimePay.

How We Protect Personal Information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide on our Sites against accidental unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Other personal information (not including payment card information) may be transferred unencrypted and involve (i) transmissions over various networks and (ii) changes to conform and adapt to technical requirements of connecting networks or devices. However, PrimePay will use commercially reasonable efforts, like secure socket layer (SSL), to encrypt information such as your login credentials during transmission.

You can find more information regarding PrimePay’s security measures to protect personal information in our Privacy Policy.

Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.

EU-U.S. Data Privacy Framework (DPF), UK Extension to the EU-U.S. DPF and Swiss – U.S. DPF

PrimePay participates in and has certified its compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. PrimePay is committed to subjecting all personal data received from EU member countries, the UK, and Switzerland, in reliance on the applicable DPF, to the Framework’s applicable Principles.  To learn more about the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF visit the Data Privacy Framework website. PrimePay is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. PrimePay complies with the Data Privacy Framework principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Data Privacy Framework, PrimePay is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, PrimePay may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, PrimePay commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Under certain conditions, more fully described on the Data Privacy Framework website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

How to Contact Us

If you have any questions or comments about this EU, UK, and Switzerland Consumer Privacy Statement, or if you would like us to update information we have about you or your preferences, please contact us by email at privacy@primepay.com. You also may write to:

PrimePay, LLC
Attn: Information Security
1487 Dunwoody Drive

West Chester, PA 19380

You will receive confirmation of requested updates or deletions within 10 business days after such request is made.