365Pay Privacy Policy – User
Revised: February 25, 2016

365Pay collects certain information through its 365Pay application and related consumer websites. Your privacy is important to 365Pay and this Privacy Policy lays out 365Pay’s policies and procedures surrounding the collection and handling of such information. If you do not agree to all the terms and conditions of this Privacy Policy, do not use 365Pay or its affiliated services. This Privacy Policy applies only to 365Pay. It does not apply to any other third party services linked to 365Pay sites or offline activities related to 365Pay.

By using the 365Pay services you consent to the transfer of this information and to 365Pay’s use of such data as outlined in this Privacy Policy.

Information 365Pay Collects
365Pay may collect the following information from individual persons who use our services (each individual person a “User” and collectively, “Users”): first name, last name, street address, city, state, zip code, phone number, e-mail address, site-specific display name, GPS location (mobile), electronic signature and credit card information (365Pay stores only last four digits) (collectively, “Personally Identifiable Information” or “PII”). Use of 365Pay or its affiliated services requires that you register and/or create an account (“Account”). In addition to the PII set forth above, 365Pay may collect information regarding Account holders’ 365Pay purchases, account funding, favorite products, customer service inquiries, product reviews, and certain social networking preferences relating to 365Pay services (e.g., pages or entities you like, recommend, or follow).

365Pay also collects aggregated information, demographic information and other information that does not reveal your specific identity (“Non-PII”). Non-PII may include information about the device you use to access 365Pay services, information from referring websites and your engagement with 365Pay services. 365Pay also aggregates certain information collected by third party providers. 365Pay may publish this information without including PII.

365Pay uses HTTPS cookies to collect information about you and your activity on 365Pay services. This information is retained perpetually. 365Pay uses this information to remember Users on 365Pay services and to enhance users’ experience with 365Pay services. For example, when Users with 365Pay accounts return to 365Pay services, cookies identify those Users and provide certain User-specific information such as 365Pay account information, past purchases, favorite products and User product reviews. To learn more about cookies, visit www.allaboutcookies.org. 365Pay also works with third parties for the purpose of advertising delivery on 365Pay Market services. The Non-PII collected about your use of 365Pay Market services may be used by third parties in order to provide advertisements about goods and services of interest to you. These third parties may also set cookies to assist with advertisement delivery services. To learn more about opting-out of cookie-targeted advertising on the Sites (sometimes referred to as online behavioral advertising or OBA), visit www.AboutAds.info.

365Pay may use automatic data collection technology to record other information that identifies your device and tracks your behavior using the 365Pay services. 365Pay may automatically receive and record information on our server logs from your browser, including your IP address, cookies, and the pages you request, as well as pages you have visited of our partner and affiliate websites and the products you were interested in on that site. At the current time, we do not comply with Do Not Track settings on your browser and 365Pay will not treat you differently if we receive Do Not Track signals from your browser.

365Pay’s Use of Collected Information
365Pay uses PII to create a User’s 365Pay Account, to communicate with Users about 365Pay services, offer Users additional services, assist with User service inquiries, share promotions and special offers, and charge for purchases made through 365Pay. 365Pay uses certain stored PII to customize future order processing for you. 365Pay may also use PII to enforce 365Pay Terms & Conditions.

365Pay does not sell the information it collects through 365Pay services to third parties. 365Pay shares collected PII with third-party vendors and service providers (“365Pay Partners”) only to the extent required to fulfill 365Pay orders. 365Pay may share collected PII with 365Pay Partners with whom 365Pay works to provide application programming interfaces (“APIs”) and other functions for 365Pay services in connection with the delivery of 365Pay services only to the extent necessary to provide those APIs and services. Full credit card numbers are directly and securely transmitted to 365Pay’s credit card processor but are not stored by 365Pay. 365Pay may also disclose PII to third parties such as attorneys, collection agencies, tribunals or law enforcement authorities pursuant to valid requests in connection with alleged violations of 365Pay Terms & Conditions or of this Privacy Policy, or other alleged contract violations, infringement or similar harm to persons or property. Users of 365Pay services must consent to the 365Pay Terms & Conditions (365RetailMarkets.com/365PayTC).

User generated content posted through 365Pay services such as product reviews and certain social networking preferences (e.g., pages you “Like” or “Follow”) may be viewed by the general public. Accordingly, 365Pay cannot ensure the privacy of any PII included in such user generated content.

365Pay’s Protection of PII
365Pay uses reasonable security measures equal to or exceeding industry standards to protect PII from unauthorized access, destruction, use, modification and disclosure. Unfortunately, even with these measures, 365Pay cannot guarantee the security of PII. By using 365Pay services, you acknowledge and agree that 365Pay makes no such guarantee, and that you use 365Pay services at your own risk.

Accessing and Correcting Your PII

Registered 365Pay account holders can access and change their own PII on the 365Pay Application. Account e-mail addresses cannot be deleted, however, an account may be closed and 365Pay will cause the corresponding e-mail address and password to be scrambled. A user may later open a new account with a different e-mail address. If you have questions regarding this Privacy Policy or 365Pay’s use or collection of your PII, please contact 365Pay’s privacy officer at info@365smartshop.com.

Children’s Privacy Protection
The 365Pay services are not intended for persons under the age of 18. If you are under 18 you must ask a parent for permission prior to submitting any information to 365Pay. 365Pay takes special care to protect the privacy needs of children under the age of 13 and 365Pay encourages parents to be an active participant in their child’s online activities. 365Pay abides by the requirements of the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The 365Pay services do not target and is not intended for children under the age of 13, and 365Pay will not knowingly collect Personal Information from them. If 365Pay discovers personal data from a child gathered through the 365Pay services, 365Pay will eliminate that data.

Privacy Policy Amendments
365Pay may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the posting date, which will be listed at the top of the page. If you have an active email address for use with 365Pay services, we will notify you of any change, addition or deletion by email. By continuing to access and/or use 365Pay following the posting of a new Privacy Policy version, you agree to be bound by the then-current version. If you do not agree to the terms of the new version of the Privacy Policy, you will stop using 365Pay services.