Privacy Policy

Effective Date: July 11, 2023

This Privacy Policy has been compiled to assist you (“you,” “your,” or “User”) to understand how InfoPay, Inc. (“we,” “our,” or “us”), which provides the IDStrong services, and our affiliates and subsidiaries, collect, use, and disclose your personal information.

This Privacy Policy describes our practices in connection with information that we collect through your use of the IDStrong website and the associated products, services, information, and materials offered herein (the “Site”).

If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you may be entitled to certain individual rights under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020 (“CPRA”)) (collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), or Utah Consumer Privacy Act (“UCPA”). Please see the Notice to Certain Residents of Data Subject Rights Section of our Privacy Policy for your rights and how to exercise them for users located in California, Virginia, Colorado, Connecticut, and Utah only.

By accessing, browsing, or otherwise using the Site, you acknowledge and consent to our collection, use and disclosure of personal information as set forth in this Privacy Policy. PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOUR USE OF THE SITE CONSTITUTES YOUR CONSENT TO THIS PRIVACY POLICY. DO NOT USE THE SITES IF YOU ARE UNWILLING OR UNABLE TO CONSENT TO THIS PRIVACY POLICY.

This Privacy Policy applies only to your use of the Site and was last updated as of July 11, 2023 . We may revise this Privacy Policy at any time and such revision shall be posted here and accessible via this link: https://www.idstrong.com/privacy. Any revision and/or addition to this Privacy Policy shall become effective and binding on you when you continue to use the Site on or after the effective date of such revision and/or addition.

1. The Personal Information We Collect

When you use the Site, we may collect the following categories of information about you, which are described in more detail below: (A) information you choose to provide to us; (B) sensitive information; (C) information we receive from third parties; and (D) information we may automatically collect. All of the information listed in (A)-(D) above are detailed below, and hereinafter referred to as “Information.”

A. Information You Choose to Provide to Us

When using the Site, you may choose to provide us with certain Information, including:

  • Individual identifiers such as your name, email address, and other contact information, as well as the name and other related information of an individual other than yourself who you have the legal authority to provide to us to use for the services provided via the Site;
  • Payment and transactional information such as services purchased. Note that we use third party payment processors to facilitate your payments and do not store your payment information;
  • Communications with us, preferences, and other Information you provide to us such as any messages, opinions and feedback that you provide to us, your user preferences (such as in receiving updates or marketing information), and other Information that you share with us when you contact us directly (such as for customer support services); and
  • Additional information as otherwise described to you at the point of collection or pursuant to your consent.

B. Sensitive Personal Information

We may process the following categories of sensitive personal Information when you use our Site:

  • Social security number;
  • Passport number; and/or
  • Driver’s license number.

C. Information Collected from Third Parties

  • We may collect additional Information about you from third-party websites, social media platforms and/or sources providing publicly available information to help us provide services to you, help prevent fraud, and for marketing and advertising purposes. Such third parties include Credit reporting agencies and financial institutions (used for purposes such as identity theft protection services);
  • Public sources (such as The Dark Web to alert you to potential misuse of your data, and Data Broker sites allowing you to remove your data at your discretion, and other sources for purposes such as to identify prospective customers or alert customers to potential fraud).

We are not responsible for the privacy practices of websites or applications that are operated or owned by third parties, even if they are linked from and/or through our Site. The information practices of such third-party websites or applications are governed by the privacy policies of those third-party websites or applications.

D. Information We Collect Automatically

We may now or in the future use tools, including third-party analytical software, to collect automatically certain data about the computer or other device you use to reach our Sites, without any active submission of information from you, such as:

  • Type of computer, web browsers, search engine used, operating system, or platform you use;
  • Data identifying the web pages you visited prior to and after visiting our website or use of our Site;
  • Your movement and activity within the website, which is aggregated with other Information; and
  • Mobile device Information, including the type of device you use, operating system version, and the device identifier (or “UDID”);
  • IP address (i.e., a number that is automatically assigned to your device or computer used to access the Site, and allows us to identify your device or computer) and Internet service provider;
  • Mobile phone carrier; and
  • Location data such as country or region. This Information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. All of this Information belongs to us, and we use it to improve effectiveness, content, layout and/or operation of our Site. You can remove certain cookies by following the directions in your Internet browser’s “help” file (see below). If you disable cookies, your ability to use areas of the Site may be limited. Additional information regarding the technologies we use, including cookies, is available in Section 3 below.

2. How We Use Your Personal Information

We use and process your Information for things that may include, but are not limited to, the following:

  • To provide you with information, products, or services that you request from us, or that may be of interest to you;
  • To verify your identity;
  • To maintain, improve, customize, or administer the Site, perform business analyses, or other internal purposes to improve the quality of our business, the Site, resolve technical problems, or improve security or develop other products and services;
  • To communicate with third parties as necessary to provide the Site, such as identification verification companies, consumer reporting agencies, credit bureaus, payment validation companies, law enforcement agencies, or others.
  • For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
  • To respond to your comments, inquiries and questions and provide customer services.
  • To comply with our Terms & Conditions;
  • For analytics for business purposes and business intelligence;
  • To comply with any applicable laws and regulations and respond to lawful requests; and/or
  • For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

3. Cookies and Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications.

A. Cookies

The Site uses “cookies.” We may store information about you using the cookies on our Site. A cookie (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. We use cookies to improve your site experience, to assess content usage, to distinguish you from other users of our site and to support the marketing of our services.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. You can also visit our Cookie Notice, available at https://members.idstrong.com/cookieInfo. Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

B. Web Beacons

Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf. Our Site uses retargeting pixels from Google. We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

C. Analytics

Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Site, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.

D. Mobile Application Technologies

If you access Site through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt out of these online tracking technologies by submitting a request here.

4. Information Sharing or Disclosure

We may share and/or disclose your Information as set forth in the Privacy Policy and in the following circumstances:

  • Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Site, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.
  • Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Site.
  • Business Transfers. Your Information may be transferred, sold, or otherwise conveyed to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
  • Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates.
  • De-Identified or Aggregated Data. We may share your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked, or otherwise not identifiable.
  • Data obtained through SMS/Text Messaging (short code program) will not be shared with any third-parties for the purpose of marketing.
  • With Your Consent.. We may share Information consistent with this Privacy Policy with your consent.

5. Protecting Your Personal Information

We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Site and safeguard your information. However, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us so that necessary measures can quickly be taken.

6. Geographic Location of Data Storage and Processing

The Sites are operated in the United States. Please be aware that the Site collects Information and process and store that Information in databases located in the United States. By visiting the Site and submitting any personal Information you consent to the transfer of such personal Information to the United States. If you are visiting the Site from a country outside the United States, you should be aware that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Site and submitting any personally identifiable Information, you consent to the transfer of such personally identifiable Information to the United States.

7. The Length of Time that Your Information is Kept by Us

We will retain your Information for as long as needed to provide you Site, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

8. Your Choices

  • A. Notification Opt-In. Throughout the Site, we provide you with the opportunity to opt-in to receive marketing communications from us as well as from our subsidiaries, marketing partners, advertisers, and other third parties we may partner with. We may offer these notifications via email, via browser notifications, or both. You may opt-out of receiving these communications as described below.
  • B. Notification Opt-Out. If you no longer wish to receive marketing or promotional communications from us, you may:
    • Respond to the emails that we send out with your request for removal or
    • Click the “unsubscribe” link (where available).

    Please be aware that there may be a delay between our receipt of your request and our being able to update our lists. Thank you for your patience in this regard.

    Note that you may not be able to opt out of certain administrative emails that are important to your use of the Sites, such as information about updates to our Privacy Policy or Terms of Use or correspondence related to specific requests that you have made to us.

  • C. Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may also review the following links:

9. Third-Party Links on the Sites

Occasionally, at our discretion, we may link to third party sites or content on the Sites. We may do this for the convenience of you and other users of the Sites, but we do not have control over the operation of these third-party websites. This Privacy Policy only applies to Information collected by our Site. The third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of linked sites. We are not responsible for the privacy and security practices of those other websites or the Information they may collect (which may include IP address).

10. Notice to Certain Residents of Data Subject Rights

A. Notice to California Residents

To the extent any California data privacy law applies to the collection of your personal information, this supplemental section of our Privacy Policy outlines the rights that California residents may have, and how they can exercise those rights. This notice applies solely to California residents. We provide the supplemental selection below to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning when used below.

1. Your Rights under CCPA

  • Right to Know and Access Specific Information. You have the right to request that we disclose certain information to you about our collection and use of your Information over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:

    • The categories of Information we collected about you, and whether we sell or share your information to third parties.
    • The specific pieces of Information we hold about you.
    • The categories of personal information sold within the last 12 (twelve) months.
    • The categories of sources from which Information about you is collected.
    • Our business or commercial purpose for collecting, selling, or sharing your Information.
    • The categories of third parties with whom your Information is sold, shared, or disclosed for a business purpose.

    You have the right to request that the Information described above be provided to you in a portable and readily useable format, to the extent technically feasible ("data portability").

  • Deletion Request Rights. You have the right to request that we delete the Information that we collected from you, subject to certain exceptions. To the extent that we can delete your Information, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Information, unless an exception applies.

  • Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your personal Information.

  • Sale and Sharing of Personal Information and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

    • Sale of your Information.
    • Sharing of your Information for cross-context behavioral advertising.
  • The use of online tracking technologies may be considered a "sale" or "sharing" under California law. To the extent that these online tracking technologies are deemed to be a "sale" or "sharing" under California law, you may opt-out of these online tracking technologies by submitting a request here.

  • Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the ways we use and disclose your sensitive personal Information (as defined by CCPA) to uses which are necessary for us to perform the Services, or deliver the goods reasonably expected by you, or and as authorized by law.

  • Right to Non-Discrimination. You have a right to not be discriminated against on the Sites or in the quality of services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or services to you, charge different rates for goods or services, provide a different level quality of goods or services, or suggest that we would treat you differently because of your data subject request activity.

  • Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received personal Information for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Information is being Sold or Shared or under the CCPA twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.

3. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

B. Notice to Virginia Residents

To the extent any Virginia data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Virginia residents and how to exercise those rights and applies solely to Virginia residents. We provide the supplemental section below to comply with the Virginia Consumer Data Protection Act ("VCDPA") and any terms defined in the VCDPA have the same meaning when used below.

1. Your Rights under VCDPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

    • Disclose whether we are processing your Information.
    • Provide you with access to your Information.

    Where the processing is carried out by automated means, and subject to certain exceptions, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance.

  • Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate Information, you have the right to request that we correct such inaccurate Information taking into account the nature of the Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your Information.

  • Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.

  • Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

    • Targeted advertising.
    • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request via the information in the Contact Us section below. Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Virginia Office of the Attorney General by:

  • Right to Non-Discrimination. You have a right to not be discriminated against on the Sites or quality of services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or services, charging different prices or rates for goods or services, or providing a different level of quality of goods and services. However, we may offer a different price, rate, level, quality, or selection of goods or services, including offering goods or services for no fee, if you have exercised your right to opt out or the offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

You may make an authenticated consumer request under the VCDPA twice within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

C. Notice to Colorado Residents

To the extent any Colorado data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Colorado residents and how to exercise those rights and applies solely to Colorado residents. We provide the supplemental section below to comply with the Colorado Privacy Act ("CPA") and any terms defined in the CPA have the same meaning when used below.

1. Your Rights under CPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

    • Disclose whether we are processing your Information.
    • Provide you with access to your Information where we process it.

    Where exercising your right to access, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance ("data portability").

  • Right to Correct Inaccurate Information.To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your personal Information.

  • Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete your Information, subject to certain exceptions.

  • Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

    • Targeted advertising.
    • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Appeal. You have the right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit an appeals request via the information in the Contact Us section below. Within forty-five (45) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If you have concerns regarding the results of your appeal, you may contact the Colorado Office of the Attorney General by:

You may make an authenticated consumer request free of charge under the CPA once within a twelve (12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Sensitive Data

We do not process sensitive data including sensitive data inferences.

3. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant to Colo. Rev. Stat. § 15-14-705. We may deny a request from an authorized agent that does not submit proper verification proof.

D. Notice to Connecticut Residents

To the extent any Connecticut data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Connecticut residents and how to exercise those rights and applies solely to Connecticut residents. We provide the supplemental section below to comply with the Connecticut Act Concerning Personal Data Privacy and Online Monitoring ("CTDPA") and any terms defined in the CTDPA have the same meaning when used below.

Your Rights under CTDPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

    • Disclose whether we are processing your Information.
    • Provide you with access to your Information where we process it.

    Where the processing is carried out by automated means, and subject to certain exceptions, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance.

  • Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate personal Information, you have the right to request that we correct such inaccurate personal Information taking into account the nature of the personal Information and the purposes of the processing of the personal Information. Once we receive and verify your authenticated consumer request, we will use commercially reasonable efforts to correct your personal Information.

  • Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.

  • Targeted Advertising, Profiling, and the Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

    • Targeted advertising.
    • Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • Right to Non-Discrimination. You have a right to not be discriminated against on the Sites or in the quality of services you receive from us for exercising your rights. We will not discriminate against you for exercising any of your rights in this section including denying goods or services, charging different prices or rates for goods or services, or providing a different level of quality of goods and services. However, we may offer a different price, rate, level, quality, or selection of goods or services, including offering goods or services for no fee, if you have exercised your right to opt out or the offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

  • Right to an Appeal. You have the right to appeal our denial of any request you make under this Section. To exercise your right to appeal, please submit appeals request to us by either:

    Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Connecticut Office of the Attorney General by:

You may make an authenticated consumer request under the CTDPA once within a twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

2. Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, including through technology means, and identity verification from you; or (2) proof of power of attorney. We may deny a request from an authorized agent that does not submit proper verification proof.

3. Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

E. Notice to Utah Residents

To the extent any Utah data privacy law applies to the collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights guaranteed to Utah residents and how to exercise those rights and applies solely to Utah residents. We provide the supplemental section below to comply with the Utah Consumer Privacy Act ("UCPA") and any terms defined in the UCPA have the same meaning when used below.

1. Your Rights under UCPA

Subject to certain exceptions you may be entitled to the following rights:

  • Right to Access & Data Portability. You may have the right to request that we disclose certain information to you about our collection and use of your Information at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:

    • Disclose whether we are processing your Information.
    • Provide you with access to your Information where we process it.

    Where the processing is carried out by automated means, and subject to certain exceptions, you have the right to request and obtain a copy of your Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Information to another data controller without hindrance ("data portability").

  • Right to Delete. You have the right to request that we delete certain of your Information provided by or obtained about you. To the extent that we can delete your Information, once we receive and confirm your authenticated consumer request, we will delete (and direct our service providers to delete) your Information, subject to certain exceptions.

  • Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights in this section including denying goods or Site, charging different prices or rates for goods or Site, or providing a different level of quality of goods and Services.

  • Targeted Advertising, and Right to Opt Out. You have the right to opt out of the processing of your Information for the following purposes:

    • Targeted advertising.
    • Processing of sensitive Information.

You may make an authenticated consumer request free of charge under the UCPA once within a twelve (12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period. To exercise the rights described above, see the Exercising Your Rights section below.

11. Exercising Your Data Subject Rights

To exercise any of the rights described above, please submit a verifiable consumer request to us via the methods described below. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Information, or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request. Only you or your authorized agent may make a verifiable consumer request related to your Information. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above). You may also make a verifiable consumer request on behalf of your minor child.

12. Do Not Track Signals

We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of personal Information, or the use of sensitive personal Information.

13. Children’s Information

The Site is not intended for use by persons under the age of 18. We do not knowingly solicit, collect, maintain, or disclose any personal Information from children under the age of 18. If we become aware that a user is under eighteen (18) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

14. Difficulty Accessing Our Privacy Policy

Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

15. Contact Us

If there are any questions regarding this Privacy Policy you may contact us using the information below:

Email us: privacy@idstrong.com
Call us: (800) 470-7489

Write us:
IDStrong.com
InfoPay, Inc.
227 Lewis Wharf
Boston, MA 02110

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