Privacy Policy

Last Updated: August 1, 2014

This Privacy Policy ("Policy") applies to the website operated by Varinode, Inc. ("Company", "we" or "us"), including all subpages and successor pages (collectively referred to as the "Website"), and also applies to all software and services that we offer, including the varinode API and checkout solution that may be available on a third-party website, or other services that we offer (collectively referred to as the "Services").

This Policy does not apply to any website, product or service of any third-party company even if the website links to (or is linked from) our Website. The Company does not operate or control those websites, products or services. Please always review the privacy practices of a third-party before deciding to provide any information.

By using our Website or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, delete all cookies from your browser cache after visiting our Website and do not visit or use our Website or Services. Your continued use of our Website or Services signifies your acceptance of this Policy.

1. Information Collection and Use
   We collect information in three ways: (1) when you provide it directly to us, (2) when we obtain verification information about you through our Services (e.g. information entered and passed through our API), and (3) passively through technology such as "cookies". The types of information that we collect and our use of that information will depend on whether you are a Website Visitor, Test User, API User, or Live User, as described below.
   Personal Information
   The term "Personal Information", as used in this Policy, refers to any information that can be used to identify a specific person, or any anonymous information (e.g., IP Address) that is linked to a specific person. Personal information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
   Cookies and Web Server Logs
   Similar to many commercial websites, we utilize "cookies" and other technologies to collect non-personally-identifiable information from our Website and from other websites that use the varinode API. "Cookies" are a feature of web browser software that allows web servers to recognize the computer used to access a website. Cookies store information accessed through your browser to streamline activities on related web sites, and make the online experience easier and more personalized. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent at a site. We use cookie data to measure web traffic and usage activity on our Website for purposes of improving and enhancing the functionality of our Website, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our website and the websites of publishers that use the varinode API. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages on our Website and also across other websites or applications that have integrated the varinode API. Log files are used to monitor, measure, analyze, improve, and troubleshoot our Services. You can choose to disable cookies for our Website but this may limit your ability to use our Website and Services.
   In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technology to identify the fact that you have visited our Website or seen one of our advertisements, and we may provide that information to one or more third party advertising networks. The information we provide may include the time and date of your visit to our website, pages viewed, links clicked and other non-personally identifying information. Those advertising networks may recognize the web beacon or cookie associated with your visit to our Website when you visit other websites on which they serve advertising, and they may make decisions about the advertisements you see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage you to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to "opt out" of the behavioral advertising delivered by member companies. Additional information on that program can be found here.
   Website Visitors
   To simply browse our Website, you are not required to provide any Personal Information. However, we may gather non-personally-identifiable information, as described directly above, just for the purposes of monitoring and improving our Website and Services. We will not share this information with third parties except as a necessary part of providing our Website and Services, nor will we use it to target any advertisements to you.
   API Users
   When you use the varinode API on a publisher website or App to store your credentials, we will gather, hash, and store the information you disclosed. We will use this information to complete purchases that you choose to make on merchant websites or applications, but only with your permission. We may also share your contact information, but not your card information, with merchants and/or publishers as part of your purchases. We will not share this information with other third parties except as a necessary part of providing our Website and Services. You should carefully review merchants' privacy policies to better understand how each uses your information.
   Clients/Publishers
   To gain full access to our Website and Services, you must have a formal client relationship with varinode. When you are given access to our services, we collect Personal Information when you voluntarily provide it to us, such as the following:
   1. Your name, company name, location, email address, and phone number, and account password, to set up your account
   2. Your business and personal tax, social security, or other government-issued identification or identification numbers, as well as your date of birth, to verify your identity for underwriting purposes
   3. Your bank account information, to settle funds for your transactions
   4. Your IP addresses, devices, and locations used to access the API, which will be linked to your account for fraud detection/prevention purposes
   With your consent, we may also collect additional Personal Information in other ways including emails, surveys, and other forms of communication. Once you begin using the Service, we will keep records of your transactions and collect information of your other activities related to our Services.
   Children's Online Privacy Protection Act
   Our Website and Services are directed to the general public. We do not knowingly collect information from children under 13 years of age or have any reasonable grounds for believing that children under the age of 13 are accessing our Website or using our Services. If we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us.

2. Sharing and Disclosure of Information

   We may share your Personal Information with trusted third parties who are integral to the operation of our Website and Services, including but not limited to retail merchants, financial institutions, payment processors, verification services and credit bureaus, as well as any third parties that you have directly authorized to receive your Personal Information. We may store your Personal Information in locations outside the direct control of the Company, for instance, on servers or databases co-located with hosting providers.

   We may disclose your Personal Information to law enforcement, government officials, or other third parties if: (i) we are compelled to do so by subpoena, court order or other legal process, (ii) we must do so to comply with laws, statutes, rules or regulations, including credit card rules, (iii) we believe in good faith that the disclosure is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Service.

   We will only disclose your Personal Information in response to such a request if we believe in good faith that doing so is necessary to comply with applicable law or a legal obligation to which we are bound. If we receive such a request, we will make best efforts to give you prompt notice, so that you may contest it if you choose. We won’t provide you such notice if we determine in good faith that either (a) we are not permitted to provide it under applicable law, or (b) that doing so would result in an imminent risk of death, serious physical injury or significant property loss or damage to varinode or a third party.

   In the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, any information in our possession may be transferred to our successor or assign.

3. Choice and Data Retention

   We are required to collect certain Personal Information to confirm your identity and comply with our obligations. If you elect to not provide Personal Information in optional fields it may limit your ability to use our Services.

   If you wish to opt out of having cookies set on your browser, the only way to ensure that this happens is to manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. For more information, refer to your browser's technical information. You may also consider visiting aboutcookies.org, which provides helpful information about cookies. Note that disabling cookies on your browser prevents varinode from tracking your activities in relation to our Website and Services. However, it may also disable many of the features available through our Websites and Services. We therefore recommend that you leave cookies enabled.

4. Changes and Notifications

   We reserve the right, in our sole and absolute discretion, to make changes to this Policy from time to time. Please review this Policy periodically to check for updates. If any changes are material and/or retroactive, we may provide additional notice and/or an opportunity to "opt-in," as appropriate under the circumstances.

   We will provide you with disclosures and alerts regarding this Policy by posting them on our Website and/or by notifying our Clients.

5. Feedback
   If you have any questions or suggestions about this Privacy Policy or any of our privacy-related practices, please contact us.