08 01 2023
This privacy statement explains how and why Radium Payments collects, stores, uses, and shares personal data when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices.
“Personal data” in this statement means information about you, including your identity, finances, and online behavior.
“Radium” in this statement means 423 Enterprises, LLC, DBA "Radium" or "Radium Payments.” This privacy statement only applies to the services offered by Radium.
YOUR PRIVACY RIGHTS AND CHOICES
When it comes to how your personal data is collected, stored, used, and shared, you have rights and choices.
UNDERSTANDING YOUR RIGHTS
You have the right to request a copy of the personal data we’ve collected about you in the past 12 months. You also have the right to ask us to delete your personal data we have collected about you. If you want to see or delete your personal data, contact Radium at firstname.lastname@example.org. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.
If you request to see or delete your personal data, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request.
If you want to delete your personal data, you have choices:
Log in to your account and delete information you previously added. Contact us via email (email@example.com) and request that we delete specific information
CLOSE YOUR ACCOUNT
If you close your account or request that we delete personal data, we still need to keep some personal data so we can:
· Complete a transaction, provide goods or services you requested, or comply with our promises to you in the User Agreement or other contract you have with us (i.e., Radium retains profile photos for ease of identification of previous transactions because such photos are considered public and therefore are not able to be removed)
· Detect and prevent malicious, fraudulent, or illegal activity
· Protect your (or another person’s) legal rights, including the right to free speech
· Manage our internal business processes that are reasonably related to your expectations when using our services
· Comply with federal and state laws
Depending on where you live and what type of account you use, you may have different rights and choices for managing your personal data.
UNDERSTANDING YOUR CHOICES
You can control how personal data is collected or shared, as well as how we communicate with you. Here are some of the ways you can customize your choices.
CHOOSE HOW WE COLLECT PERSONAL DATA
You may choose to limit the personal data you provide when our app or services request it. To help make choices that are right for you, it’s important to understand that personal data helps us provide a richer, more personalized experience for you. Also, some personal data is required for our services to function at all.
For example, if you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you.
Radium provides its services with the support of it payment provider partner. Some of the information provided through the Radium platform is passed directly to our payment provider including all banking details as well as unique identifiers such as Social Security Numbers. This information is not collected nor stored by Radium. Radium does, however, collect personal details for the purpose of identification such as a user’s full name, phone number, and email address.
Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional and some are necessary for you to manage your accounts with us. We use email, push notifications on your mobile device, and even paper mail depending on the situation and your preferences.
For those who subscribe to our emails, you can click the unsubscribe link in a marketing email or turn off our app notifications on your device. You can also change your account’s notification settings or the notification preferences on your device.
You won’t be able to opt out of messages that are considered necessary for you to manage your account, such as receipts and emails that alert you to changes in your account’s status that require your attention. You may be able to decide how we send those messages, such as by email, text message, or a notification on your mobile device.
THE PERSONAL DATA WE COLLECT
We may collect your personal data when you register for or use our services, such as when you create an account, link your bank account, or make a payment, or make a purchase on a merchant’s website.
If you use our services without creating or logging into an account, we’ll still collect personal data, which may include your payment information, device information, and location. When you use our services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or if you create an account at a later date.
Here are the kinds of personal data that we or our partners may collect when you create an account or use our services:
1. Information that identifies you, for example:
· First and last name
· Phone number
· IP address
· Information collected from cookies or other tracking technologies
2. Records and financial information may be collected by Radium’s payment provider partner through the Radium application and is not shared with nor stored by Radium, for example:
· Social Security Number or Government-issued identification
· Bank account and routing numbers
· Credit and debit card information
· Financial information
3. Personal characteristics, for example:
· National origin
· Military status
4. Commercial information, for example:
· Online shopping cart information
· Purchase history
5. Internet or network activity, for example:
· Interactions with our services or sites
· Shopping history
6. Geolocation data, for example:
· Global Positioning System (GPS) information when you give us permission through your device settings
· IP-based geolocation
7. Audio, electronic, visual, or similar information, for example:
· Call recordings when you talk to customer service
· Photo IDs and profile pictures you provide
8. Professional or employment information, for example:
· Business information, contact emails and phone numbers
· Tax IDs
9. Information we infer based on your personal data, for example:
· Fraud and risk assessments
· Personalization preferences
WHERE PERSONAL DATA COMES FROM
We and/or our payment provider may collect personal information about you from various sources, for example from:
· Our payment partners, such as card networks and payment provider
· Financial institutions, such as banks
· Credit bureaus
· Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services
We do not knowingly collect personal information from people who are not allowed to use our sites and services, such as children under the age of 18. Contact firstname.lastname@example.org if you believe that we’ve mistakenly collected personal data from someone not allowed to use our services. We’ll delete it immediately, unless we’re legally required to keep it.
HOW WE USE TRACKING TECHNOLOGIES LIKE COOKIES
You can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.
Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.
WHY WE COLLECT PERSONAL DATA
We collect personal data for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal data include:
· Run our sites and provide better services. For example, to help you send or request money, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date.
· Manage and improve our business. For example, we do user research to improve our apps’ performance and abilities. We also monitor and analyze our website to help ensure it works as expected.
· Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants, such as eBay, Inc.
· Send you marketing information about our products and services. We may use personal data to market about our partners, such as merchants. We use personal data to better understand and cater to your interests.
· Personalize your experience when you use our sites and services, as well as other third-party sites and services. In this case, we might use tracking technologies like cookies. Send you locally relevant options, but only if you agree to let us track your location. If you do, this can help us enhance the security of our sites and services, and customize our services by using the right language and personalizing content such as ads and search results.
· Make it easy for you to find and connect with others. For instance, if you let us access your contacts, we can suggest connections with people you may know.
· Contact you when you need us, such as answering a question you sent to our support team.
· Comply with laws and enforce our agreements with you and other people who use our services.
HOW AND WHY WE SHARE PERSONAL DATA
We do not sell your personal data. However, we may share personal data across our services and with other members of the Radium corporate family. Sometimes we share the personal data we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations.
We may share personal data with:
· Other members of the Radium corporate family
· Service providers that help us with processing payments, marketing, research, compliance, audits, corporate governance, communications, and security
· Card networks and payment providers
· Financial institutions, such as banks we partner with
· Credit reporting and collections agencies
· Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires Radium or members of our corporate family to respond
· People involved in a transaction, such as other users or merchants and their service providers.
· Third parties that you asked us to connect with, such as other financial or social media apps. If you want us to stop sharing information with a third party, disconnect your account from that third party.
· Other third parties to:
· Comply with laws
· Investigate or enforce violations of our user agreement
· Facilitate a merger, purchase, or sale of part or all of our business
· Comply with card association rules
· To prevent physical harm or illegal activity
HOW WE PROTECT YOUR PERSONAL DATA
Helping to keep your personal data safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority.
To protect your personal data, we use technical, physical, and administrative security measures that include:
· Data encryption
While we protect our systems and services, you’re responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date.
If your account is closed, we may keep your personal data and other information as required by law and according to our data retention policy. If we do, we’ll continue to handle it as we describe in this statement.
HOW THIS STATEMENT CHANGES OVER TIME
We’ll make changes to this privacy statement from time to time. This helps us stay up to date with changes to our business and the most current laws. After a new version is published, we’ll collect, store, use, and protect your personal data as we outline in that revised statement.
If the new version reduces your rights or increases your responsibilities, we’ll post it on the Policy Updates or Privacy Statement page of our website at least 21 days before it becomes effective.
We may notify you about these changes through email or other communications.
If you have questions about this privacy statement or your personal data, contact us so we can help.
To talk about your Radium account email us at email@example.com.
CALIFORNIA PRIVACY RIGHTS
If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:
Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
· the categories and specific pieces of personal information we have collected about you;
· the categories of sources from which we collected the personal information;
· the business or commercial purpose for which we collected the personal information;
· the categories of third parties with whom we shared the personal information; and
· the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may contact Radium either via email to firstname.lastname@example.org or contact us via postal mail, proper postage prepaid, at:
Radium, Attn: Your California Privacy Rights
805 S. Wayne Street, Arlington, VA 22204.
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail).
All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.