We respect your privacy, and take great care to safeguard information in our possession. Your preferences for use of your information are our highest priority. Smart Technologies & Services USA LLC and its affiliates (collectively “Smart ExpressPay”, “Site”, “we” and “us”) respect your privacy. We offer services that enable platforms and merchants to run businesses, and to safely conduct online payment transactions.
Smart ExpressPay does not share customer information (including email addresses) with any third party unless it is necessary to provide you with products or services available from Smart ExpressPay. Any third-party companies we use to provide you with products or services are required to keep your information secure and confidential. We may also disclose information when you tell us to do so, to identify or contact you, to protect your rights or the rights of Smart ExpressPayor as required or permitted by law.
We restrict access to your information to only those individuals who need to provide you with our products or services. If you have any other questions or concerns regarding how Smart ExpressPay manages, accesses or uses your personal information, please write to us at our address at the end of this document or call us via our listed numbers.
As a customer of Smart ExpressPay, your trust is our most important asset. We take the protection and proper use of your personal information seriously and are committed to protecting your personal information in our possession. In order to preserve your trust, we want you to understand what personal information we may collect from you, how we use such information, and the choices you have regarding our use of this information.
In this policy, “personal information” means any information by which you can be identified, located or contacted, such as your name (first and last), address (city, town), email address, or telephone number.
Types of Information We Collect
We collect personal information when communicating or interacting with you through our Sites. Some examples include:
We may also collect personal information about you from other third parties, such as demographic firms, to make our future service and marketing efforts more efficient and personalized for you. We may combine all information we collect and we may disclose this information within our corporate family of companies or our service providers. When you visit our websites we may also gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses or other device identifiers, browser information, Internet Service Provider (ISP), operating system, location, date/time stamp and clickstream data.
If you are a Site User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number).
If you are a Customer, when you make payments or conduct transactions through a Site User’s website or application, we will receive your transaction information. Depending on how the Site User implements our Services, we may receive this information directly from you, or from the Site User or third parties. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The Site User will determine the payment methods that it enables you to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Site User. When you make a transaction, we may also receive your name, email, billing or shipping address and in some cases your transaction history to authenticate you.
When we conduct fraud monitoring, prevention, detection, and financial compliance activities, we will receive Personal Data from you and about you from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the Site User’s website or the application that collects information.
How We Use Your Information
We use the personal information that we and our service providers collect to conduct our business and to provide you with the best possible products, services and experience. We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.
We may collect and use your information to provide you products and services, notify you of product recalls or safety issues, process and respond to your application for current or future career opportunities, process membership requests when you apply or otherwise administer your participation in our programs, to respond to your comments, questions or complaints, determine your satisfaction with our programs and service, to personalize your experiences, if you ask us to, send you marketing communications and other information you have chosen to receive regarding our products, services, marketing or special events. We also use your personal information for our everyday business purposes such as security, payment processing, analytics, operations, fraud detection and prevention, reporting, making back-ups and legal compliance.
How We Share Your Information
We do not sell or rent Personal Data to marketers or unaffiliated third parties. We share Personal Data with other Site entities in order to provide our Services and for internal administration purposes.
To best serve you, we may share your personal information with other members of the Smart ExpressPay family of companies and with service providers that provide support services to us or that help us market our products and services, administer our programs, operations, fulfill your requests, surveys, contests, sweepstakes and product reviews, or provide you with membership information. Service providers, third parties who perform services on our behalf, are contractually restricted from using your information in any manner other than in helping us to provide you with the products and services available. We may also, in certain instances, disclose your personal information when we have reason to believe that it is necessary to identify you, contact you, to advise you of a product recall, detect and protect you or us from fraud, manage information security or bring legal action to protect your rights or the rights of Smart ExpressPay (and affiliates) or others. We may also disclose your personal information when you ask us to do so or when we believe it is required or permitted by law.
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Smart ExpressPay, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
Cookies, Web Beacons, and Other Similar Technologies
We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.
When you visit our website, we may use both a session and a persistent cookie. This Smart ExpressPay-placed cookie may contain information (such as a unique user ID) that is used to track your usage of our website and in some cases, your email address. Your email address and name are only saved in this Smart ExpressPay-placed cookie if you register with us. A web beacon allows us to capture certain additional types of information about a visitor’s actions on a web site, such as a visitor’s cookie number, the time, date, duration and number of page views, a description of the page where the Web beacon is placed, and details about any items that were purchased.
We may use Flash Cookies (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed on a computer using Adobe Flash technology that may be built into your computer or downloaded by you to your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, personalize and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience, play games and perform surveys. They help us improve our sites by measuring which areas are of greatest interest to customers. We do not use Flash cookies for marketing or behavioral targeting purposes. Flash cookies are different from browser cookies and the cookie management tools provided by your browser will not remove Flash cookies.Learn how to manage privacy and storage settings for Flash cookies. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.
Third-Party Advertising Partners
We use third-party service providers to serve advertisements (banners or links) on our behalf across the Internet.
Our third party advertising partners may use information about your visits to other websites to target advertisements for products and services available from Smart ExpressPay.
In the future we may partner with more companies to provide interest-based advertising, both on and off SmartExpressPay.com. If this occurs, you may opt-out of the partner ads by clicking on the ad and setting your opt-out. To learn more or to opt-out of receiving interest-based advertising generally, please visit Network Advertising Initiative.
Social Media Interactions
Smart ExpressPay invites you to socialize and share your prizes with your friends using Social Media tools such as Facebook, Twitter, Tumblr, Pinterest and Instagram. If you choose to use these tools, you may be sharing certain profile elements, including your comments. This sharing is subject to each social media program’s privacy policies. We also use Facebook Social Plugins to allow Facebook to share information and friends’ activities with its members while they are on our website. For example, Social Plugins allow Facebook to show you and your friends’ “Likes” on our product pages if you are logged into Facebook while shopping at SmartExpressPay.com. Smart ExpressPaydoes not receive or control any of the content from Facebook Social Plugins. To remove a previously-given Facebook “Like” through Smart ExpressPay, place your cursor in the “grayed out” Like button and click on the “X” that appears. This removes the “Like” from your Facebook Page, as well as from Smart ExpressPay’s websites. You can also delete comments made while at SmartExpressPay.com from your Facebook Page.
You may research more information about Facebook Social Plugins and other social media tools.
Links to Other Websites and Services
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
Browser Do Not Track Signals
Although our websites currently do not have a mechanism to recognize the various web browser Do Not Track signals, we do offer our customers choices to manage their preferences that are provided in the previous sections above. To learn more about browser tracking signals and Do Not Track please visit www.allaboutdnt.org
We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of personal information transmitted to us using this website. To help guard your information, our website uses Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only Smart ExpressPay is able to decode your information. Please note that email is not encrypted and is not considered to be a secure means of transmitting credit card information.
To be sure your connection is secure, look at the bottom status bar of your browser window. If you see an unbroken key or a closed lock (depending on your browser) the SSL is active and your information is secure. Most browsers offer additional security alerts as well.
We also ask customers to carefully review their accounts and immediately report any unexpected activity to Smart ExpressPay and their issuing bank or credit card company. Additionally, we are asking all our customers to take measures to help protect personal information in their online accounts, including the following:
Fraud Alerts: Protecting Your Personal Information
You may come in contact with websites, emails or texts that try to lure you into providing personal information with an offer such as a Smart ExpressPay. Smart ExpressPay does not sponsor these offers nor are we affiliated with the promotion originators. We take these matters, and the protection of our customers’ sensitive information, very seriously. View our Fraud Alerts page.
Smart ExpressPay will never knowingly request or collect personal information from any person under 13 years of age without prior verifiable parental consent. If you are under 13 years old please do not provide your information on our website.
If we become aware that an individual is under the age of 13 and has submitted any information to Smart ExpressPay for any purpose without prior verifiable parental consent, we will delete his or her information from our files.
Data Processing and Storage
Smart ExpressPay and its third party service providers may process or store your personal information outside of Jamaica and other countries. In accordance with the laws of those countries, in certain circumstances your personal information may be accessible by foreign law enforcement, regulatory bodies or other authorities. For more information of our use of foreign service providers please contact us as described below.
We respect your need to be able to access and update the personal information that you have provided to us. If you have registered online, you may access and update your personal information at any time by logging into your account.
Residents of California in the United States
This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).
To submit a request to exercise any of the rights described above, you may contact us at firstname.lastname@example.org. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required. If you are a Customer of a Site User, please direct your requests directly to the Site User with whom you shared your personal information.Last updated: February 1, 2020