This Privacy Policy describes how Modern Treasury Corp. and our affiliates (collectively "Modern Treasury," "we", “us” or "our") handle personal information that we collect through our websites and other digital properties that link to this Privacy Policy (collectively, the “Site”), receive our marketing communications, or engage with us on our social networks (collectively, the “Service”).

Table of Contents

Personal information we collect
How we use your personal information
Third-party payment processing
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us

Personal Information we collect

Information you provide to us. “Personal Information” means any information that relates to an identified or identifiable individual. Personal information you may provide to us through the Service or otherwise, includes:

• Contact data, such as your first and last name, email address, billing and mailing addresses, phone number, professional title, and organizational affiliation.
• Account data, such as your username and password that you set to establish an online account with us, registration code, preferences, and any other information that you add to your account profile.
• Identity and financial data, such as a national identification number (e.g., social security number where permitted, tax identification number, passport number), state or local identification number (e.g., driver’s license, passport, or state ID number), an image of the relevant identification card, and any other information required to comply with “Know Your Customer” laws (e.g. beneficial owner identities and addresses, incorporation details, financial references, and financial statements).
• Third-party account and transactional data needed to provide the Service to you and complete your payments on or through the Service (such as third-party account login information, bank account login information, payment card information, bank account numbers, and other transaction information).
• Marketing data, such as your preferences for receiving communications about our products, services, and details about how you engage with our communications.
• Communications that we exchange, including when you contact us with questions or feedback, through social media, or otherwise. 
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise described at the time of collection.

Third party sources. We may combine Personal Information we receive from you with Personal Information we obtain from other sources, such as:

• Our clients, such as the organizations using our Service when they provide us information about their payees, which may include first and last name, email address, billing and mailing addresses, phone number, bank account number and payment history.
• Data providers, such as information services and data licensors, that provide identity verification and other information.
• Public sources, such as social media platforms, publications, consumer reporting agencies, public databases, and news sites.
• Business partners, such as joint marketing partners.
• Marketing partners, such as companies that have entered into joint marketing relationships or other joint ventures with us.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, your activity over time on our sites and other online services, and your interactions with our marketing communications such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Like many online services, we use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.
• Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Application programming interfaces, or APIs, which are used to interface our Service with third party services that allow us and our third party service providers or advertising partners to collect and share user data.

How we use your Personal Information

We use your Personal Information for the following purposes or as otherwise described at the time we collect it:

Service delivery. We use your Personal Information to:

• provide, operate and improve the Service and our business;
• verify your identity in compliance with “Know Your Customer” laws and establish and maintain your account on the Service;
• send you invoices for the Service and collect on any overdue balance;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your Personal Information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from Personal Information we collect. We make Personal Information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising. We and our third party advertising partners may collect and use your Personal Information for marketing and advertising purposes:

• Direct marketing. We may send you Modern Treasury-related or other direct marketing communications as permitted by law, including by email and mail. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We may contract with third-party advertising and social media companies to display ads on our Service and other online services. These companies may use cookies and similar technologies to collect information about you (including the data described in the automatic data collection section above) over time across our Service and other online services and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising in the Advertising choices section below.

Third party payment processing

We may use a third party payment processors (each a “Payment Processor”) to process payment of your Fees for our services. The applicable Payment Processor for your transaction may be displayed to you at the time you initiate a payment transaction. To simplify the payment process, we save the last four digits of your credit card, the expiration date of your credit card, the credit card type, your first and last name, your billing address, and a token identifier to match your information to your full credit card number, which is stored by the applicable Payment Processor. We do not store your full credit card number or your CVV2 number (the 3 to 4 digit security code on your card). We do not have access to your full credit card number stored by the applicable Payment Processor. For more information on how payments are handled, and to understand the data security and privacy protections afforded to such information, please refer to the privacy policy on the applicable Payment Processor’s website.

How we share your Personal Information

We may share your Personal Information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and other affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as information technology, hosting, customer relationship management and support, payment processing, email delivery, advertising, marketing, and website analytics).

Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use customer lists that we share with them to deliver ads on their platforms on our behalf to those customers and similar users.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees. Acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Modern Treasury or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your choices

You have the following choices with respect to your Personal Information.

Access or update your information. If you have registered for an account with us, you may review and update certain account information from your account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at [EMAIL]. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use third-party vendors, such as Google Analytics, to help us understand user activity on the Sites. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Advertising choices. You can limit use of your information for interest-based advertising by:

• Browser settings. Blocking third party cookies in your browser settings.
• Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies. 
• Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
• Google: https://adssettings.google.com/
• Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:
• Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance: https://optout.aboutads.info/.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device from which you wish to opt-out.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect Personal Information to provide certain services. If you do not provide the information we identify as mandatory, we may not be able to provide those services.

Third party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not 

Other sites and services

The Service may contain links to websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or other online services that are not associated with us. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.

International data transfer

Modern Treasury operates in the United States and provides the Service to customers located in the United States. If you are accessing the Service from outside the United States, your Personal Information may be transferred to, stored, or processed in the United States and maintained on computers or servers located outside of your state, province, country, or other jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Some information may also be stored locally on devices you use to interact with the Service. By accessing the Service, you understand and consent to the transfer of your information to the United States and to those third parties with whom we share it as described in this Privacy Policy. Modern Treasury does not represent or warrant that the Service, or any part thereof, is appropriate or available for use in any particular geographic location. If you choose to access or use the Service, you do so at your own risk, and you are responsible for complying with all local laws, rules, and regulations applicable in your jurisdiction. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Service.

With respect to European Economic Area (“EEA”) and the United Kingdom (“UK”), if our customers use the Service such that they are providing or collecting information from EEA or UK residents, we are acting as a data processor and storing Personal Information on behalf of those customers. If you are located in the EEA or UK and use our Service, your Personal Information is processed by us and transferred to our servers and the servers of our service providers located in the United States. In order to ensure that your information is protected when transferred out of the EEA or UK, we rely on data processing agreements, EU Standard Contractual Clauses, as well as agreements with our various third-party service providers that may process your information on our behalf. When we process Personal Information for the purposes and to pursue the legitimate business interests set forth in this Privacy Policy, we do so where we believe the nature of the processing, the information being processed, and the technical and organizational measures employed to protect that information can help mitigate the risks to the data subject. However, though we undertake to preserve the confidentiality of all information provided to us, we cannot be responsible for ensuring the security, accuracy, or privacy of your data once it leaves our environments.

If you are located in the EEA or UK, you have certain rights under applicable law with respect to your Personal Information, including the right to request access to, correct, amend, delete, port to another service provider, or object to certain uses of your Personal Information. Upon request, we will provide you with information about whether or not we hold any of your Personal Information. To the extent required by law, we provide you with (i) reasonable access to the Personal Information you provide to us, (ii) the ability to review, correct and delete such Personal Information, (iii) the right to data portability, and (iv) the ability to restrict or object to our processing of Personal Information we have collected about you. If you believe that any of the Personal Information that you have submitted through the Service is no longer accurate, or you wish to make any updates or changes, or rights requests, you may do so by emailing us at legal@moderntreasury.com. We will use reasonable efforts to comply with your request as soon as reasonably practicable. However, we reserve the right to use any information previously obtained to verify your identity or take other actions that we believe are appropriate and lawful. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are impractical, or for which access is not otherwise required by local law. We may also need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed from such locations.

If you have a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may submit a complaint to the data protection regulator in your jurisdiction. We would, however, appreciate the opportunity to address your concerns in advance, and would ask that you direct the inquiry first to us at legal@moderntreasury.com.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected Personal Information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

Modern Treasury Corp.
315 Montgomery St.
10th Floor
San Francisco, CA 94104
Attn: Legal