Privacy Policy, Copyright Notices, and Terms of Use

Privacy Policy | Digital Millennium Copyright Act Notices | Terms of Use | Vantiv eCommerce Privacy Shield Policy


Privacy Policy

At Vantiv we respect your concerns about privacy.  The following explains how Vantiv, our affiliates, and subsidiaries (collectively “Vantiv,” “we,” ‘us,” and “our”) collect, use, and share information based on our interactions with you via our websites, mobile sites and applications (“Sites and Services”). 

Changes

We may make changes to this Privacy Policy from time to time.  If we do, we will post those changes on our websites and update the effective date of this policy.  We encourage you to check back periodically to stay up to date on our privacy practices.  Your continued use of the Sites and Services after changes have been posted will constitute your acceptance of this Privacy Policy and any changes made to it.

Information We Collect

Information You Provide

When you interact with our Sites and Services you may voluntarily provide us with certain personal information, such as your name, email address and phone number.  You may provide this information to us when you contact us, create an account with us, inquire about careers at Vantiv, or request information about our Sites and Services.  We may also collect additional personal information from you as part of signing up for our Sites and Services.  This additional information may include your social security number, taxpayer identification number, bank account information, mailing address, and other information required to establish a commercial account with us.

Community and posting sections of our websites give you an opportunity to provide us with information regarding your opinions and reviews of products or services.  Your profile may also contain other information that identifies you. 

We may offer services that allow you to share information with third party social media sites such as Facebook, LinkedIn, Twitter, or others.  When you link your account or engage with our sites through third-party social media sites, you understand that you may be allowing us to have ongoing access to certain information stored on those social media sites.  We may also collect demographic information, such as your age, gender, or zip code, as well as certain information from third parties that we combine with information you provide to us. 

Information Automatically Collected

As a payment processor, Vantiv receives personal information for individuals related to processing payment transactions initiated through our merchant clients, and when individuals maintain a card with one of our financial institution clients. This information may include names, card or account numbers, CVV codes, purchase amounts, purchase dates, and methods of payment.

We also automatically collect other technical information about your use and interaction with our Sites and Services, which may be collected through cookies, web beacons and other similar technology. This information may include log file information such as IP addresses, the date and time of your visit, your browser type, your device ID, and information about how you interact with the website. We may collect additional information from you if you access our websites through a mobile device such as your unique device identifier, device’s operating system, mobile carrier, location or GPS/geo-location. 

Cookies & Tracking Technologies

A cookie is a small, sometimes encrypted text file which is stored on your computer's hard drive (or other device for accessing the Internet) by websites that you visit. We may use cookies and other similar technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our site when you return to our site. We may also use the aggregate information from these technologies to research and understand how the Sites and Services are used.

We may offer certain features that are only available through the use of tracking technologies.  Temporary cookies are used to enable you to navigate our site and use its features.  These are deleted when you close your browser.  IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access our site. 

Analytical or performance cookies collect anonymous information about how visitors use our websites.  They allow us to analyze information such as the count of visitors to our websites, what search terms our visitors are using, what pages were viewed, and the last page visited.  This information is based on the visitor’s IP address, and we cannot view individual activity tied to a single person.

Do Not Track

Our Sites and Services do not respond to Do Not Track signals communicated by your browser. We do not knowingly track your online activity over time across third party websites when you use, nor do we allow third parties to do so on our site. For more information about Do Not Track, please visit www.allaboutdnt.com.

How We Use & Share Information

We use the information you provide us in a variety of ways to offer you our various products and services.  For example, we may use identifiable or non-identifiable information to:

  • Authorize and establish commercial merchant accounts
  • Process payments
  • Respond to your inquiries
  • Maintain internal recordkeeping and reporting
  • Conduct research and analytics and develop new products and services
  • Provide you with information about products or services that may be of interest to you
  • Customize your experience on our websites
  • Enhance our service offerings and improve the quality, integrity and security of our systems and services
  • Detect and prevent fraud, unauthorized transactions, money laundering and terrorist financing
  • Provide advertising and marketing databases or services
  • Provide analysis of anonymized data
  • Monitor compliance with the law and our Terms of Use
  • Enforce our legal rights and satisfy our legal obligations, including without limitation any reporting or disclosure obligations under applicable law or regulations or subpoena, court order or other judicial or administrative process, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.
  • Comply with the rules, regulations and guidelines of the payment networks in which transactions are processed
  • For any other purpose permitted under applicable law and regulation or agreed to in this Privacy Policy or disclosed at the time the information is collected.

We may also share information with members of our corporate family, affiliates and subsidiaries, as well as:

  • To obtain commercial and credit information for you as a customer to establish, maintain or renew your contract(s), as may be required to provide any of the services for which you have subscribed; to comply with rules and regulations of any credit, debit or other payment network; or otherwise in accordance with this policy.
  • With service providers and other third parties under contract who help with our business operations (including, but not limited to, fraud investigations, advertising, site analytics and operations).
  • With companies in the mobile app industry, should you access this site through a mobile device, we may share your information with carriers, operating systems, and platforms.
  • With third parties for their own direct marketing purposes
  • In response to a court order, subpoena, or request for cooperation from a regulatory, law enforcement or other government agency to meet national security or law enforcement requirements; to establish or exercise our legal rights; to defend legal claims; when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others; or as otherwise required or permitted by applicable laws and/or regulations. In such events we will only disclose information relevant and necessary to the investigation or inquiry.
  • To transfer information and/or assets in the event of a merger, acquisition, sale, bankruptcy filing, or other corporate restructuring.

Public Posting

Additionally, if you post information or content, such as commenting on content or participating in online forums or communities, or when you interact with our site through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet.  We are unable to prevent or control further use of this information and refer you to the third party sites’ privacy policies and terms of use to learn more about their privacy practices.

Data Aggregation & Sharing

We may aggregate and anonymize information you provide to us in such a way as to ensure that you are not identified or identifiable from it.  This data may be used for statistical, analytic, and administrative purposes, including for customizing our web sites, analyzing trends, tailoring products and services, or conducting risk and cost analysis.  We may share anonymized or aggregated data at our discretion, in accordance with applicable laws.

Third Party Links & Advertising

Our Sites and Services may link through to third-party websites, and those processes may involve the placement of third-party cookies on your machine or device.  Please be aware that we do not control these third party websites or any of the content contained on those websites , including the third-party cookies used for these purposes.  Once you have left our Sites and Services, we cannot be responsible for the privacy practices of such other websites. We encourage you to exercise caution and review the privacy practices of these third-party sites prior to accessing or navigating those sites.  The inclusion of links to third party websites in no way constitutes an endorsement by us of such websites’ content, actions, or policies.

We may, from time to time, partner with ad networks and other online advertising providers in order to serve ads on behalf of us or other non-affiliated parties on our websites and across the Internet.  These ads may be presented to you based on products and services the advertising providers think are relevant to your interests.  These preferences may be inferred based on information collected about your browsing behavior on our websites and other non-affiliated sites and apps across time.  We adhere to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles.  To learn more about, or opt-out of, this type of advertising from participants in the DAA, you can visit www.aboutads.info

Your Choices

You can control how and when you want to receive subscription emails from Vantiv on the website by visiting the subscription center located on www.vantiv.com, or by clicking on the “unsubscribe” link located at the bottom of the email communication.  You may not opt-out of administrative emails (for example, emails about your account, transactions, or policy changes) for your registered account. 

You may opt-out of receiving advertising based on browsing multiple websites over time by visiting www.aboutads.info.

Children’s Privacy

Our websites are for general use and are not intended for children under the age of 18.  We do not knowingly collect information via our Sites and Services from users under the age of 18.

Security

We work to maintain your confidence and trust. We store and process your information on our servers located within the United States, and we have implemented physical, technical, and administrative measures to protect your information. .  However, data exchanged over the Internet is never guaranteed to be secure. Therefore, we urge you to always use caution when transmitting information over the Internet and remind you that you are responsible for ensuring the security of your password (s) and account registration information.

US – EU Privacy Shield

Vantiv eCommerce, LLC adheres to the Privacy Shield Principles developed by the U.S. Department of Commerce and the European Union (EU).  By using our client’s ecommerce sites, you are permitting the transfer of your personal information to Vantiv eCommerce, LLC in the United States, which has different data protection laws than those in European Union member countries. You consent to the transfer of this information for the uses described in the Privacy Shield Policy and in this Privacy Policy to the extent permitted by EU law. Please click here to view our Privacy Shield Policy. 

Your California Privacy Rights

California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. To make such a request, please contact us at Privacy@Vantiv.com, or Vantiv, 8500 Governors Hill Drive, Mail Drop 1GHY1, Cincinnati, OH 45249-1384, Attention: Chief Privacy Counsel.

Contact Us

If you have any questions about this privacy policy you may contact us at Privacy@Vantiv.com, or Vantiv, 8500 Governors Hill Drive, Mail Drop 1GHY1, Cincinnati, OH 45249-1384, Attention: Chief Privacy Counsel.

Policy Updated: July 14, 2017


 

It is the policy of Vantiv LLC (“Vantiv”) to respect the intellectual property of others and thus to respond to effective notices of alleged infringement of copyrighted material where (i) the copyrighted material is available at, or from, a system or network controlled or operated by or for Vantiv or where (ii) Vantiv, by providing or using an information location tool, such as a directory, index, reference, pointer, or hypertext link, refers or links a third party to a site that contains the copyrighted material.

If you are alleging that copyrighted material may have been or is being infringed, then you may notify Vantiv, pursuant to the U.S. Online Copyright Infringement Liability Limitation Act of the U.S. Digital Millennium Copyright Act, 17 U.S.C. §512 (c), by sending a notice to the address listed below.  Such notice must include the following to be effective:

  1. A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
  2. Identification of the copyrighted work claimed to have been infringed or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;
  3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit Vantiv to locate the material;
  4. Information reasonably sufficient to permit Vantiv to contact you such as an address, telephone number, and if available, an electronic mail address at which you may be contacted;
  5. A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  6. A statement that the information in the notification is accurate and, under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Counter Notices
If material that you have posted to a system or network controlled or operated by or for Vantiv has been removed or disabled, you may file a counter notice pursuant to 17 U.S.C. §512 (g).  To be effective, the counter notice must be a written communication sent to the address listed below that includes the following:

  1. A physical or electronic signature of the subscriber;
  2. Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access to it was disabled;
  3. A Statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled; and
  4. Your name, address, and telephone number, and a statement that you consent to the jurisdiction of the Federal District Court for the Southern District of Ohio or, if your address is outside of the United States, also for the Federal District Court for the Southern District of Ohio, and that you will accept service of process from the person who provided notification under subsection 17 U.S.C. §512 (c) (1) (C) or an agent of such person.

DESIGNATED AGENT FOR ALL NOTICES, INCLUDING COUNTER NOTICES
All written notices should be sent to the following Designated Agent:
Designated Agent:  Jonathan Ellman, Head Counsel Intellectual Property
Address of Designated Agent:  900 Chelmsford Street, Lowell, MA  01851
Email address of Designated Agent:  DMCAnotice@vantiv.com
Telephone number of Designated Agent:  (978) 275-6600


 

Terms of Use

Vantiv LLC, its subsidiaries and affiliates (“Vantiv”) requires that all visitors to our Websites adhere to the following rules and regulations.  By accessing the Website(s) you indicate your acknowledgement and acceptance of these terms and of use. 

  1.  Laws and Regulations

Access and use of this site is subject to all applicable federal, state, and local laws and regulations. 

  1. Intellectual Property

The trademarks, logos, and service marks displayed on this Website are the property of Vantiv.  All content and otherwise protectable features of our Websites, including but not limited to any  names, logos, trademarks, service marks, brand identities, characters, trade names, graphics, designs, copyrights, trade dress, or other intellectual property appearing on our Websites, including the organization, compilation, look and feel, illustrations, artwork, videos, music, software, and other works on the Website (“Content”) are owned by Vantiv or used under a license from a third party owner, and are protected under copyright, and trademark laws.

  1. Limited License

The use or misuse of any Content, except as provided in the Terms of Use or in the Content, is strictly prohibited. Vantiv grants you a non-exclusive, limited, personal, non-transferable, revocable license to access and use the Content, without right to sublicense, under the following conditions: (a) you shall not, without Vantiv’s express written consent, distribute text or graphics to others; (b) you shall not, without Vantiv’s express written consent, copy and retransmit, disseminate, broadcast, circulate, or otherwise distribute the Content on any other server, or modify or re-use all or part of the Content on this system or any other system; (c) you shall not use any tradename, trademark, or brand name of Vantiv in metatags, keywords and/or hidden text; (d) you shall not, without Vantiv’s express written consent; (1) copy, distribute, modify, transmit, perform, reuse, re-post, or otherwise display the Content, in whole or in part, for public or commercial purposes; (2) modify, translate, alter or create any derivative works thereof; or (3) commercially exploit the Content, in whole or in part, in any way; (e) you shall not use the Websites, the Content, and/or any portion thereof, in any manner that may give a false or misleading impression, attribution or statement as to Vantiv, the Owners, or any third party referenced therein; and (f) you shall use the Content, and/or any services and products on the Websites, or accessible via the Websites for lawful purposes only. Any unauthorized use, including, the reproduction, modification, distribution, transmission, republication, or display of the Content is strictly prohibited. Vantiv reserves all other rights. You do not acquire ownership rights to any Content viewed or accessed, and Vantiv’s posting of the Content on the Websites does not constitute a waiver of any right in such Content. You shall not alter, remove, or obscure any copyright notice, digital watermarks, proprietary legends, or any other notice included in the Content. Except as expressly provided herein, nothing on the Websites shall be construed as conferring any license under Vantiv’s and/or an Owner’s intellectual property rights, whether by estoppel, implication, or otherwise. Notwithstanding anything herein to the contrary, Vantiv may revoke any of the foregoing rights and/or your access to the Websites, or any part thereof, including the blocking of your IP Address, at any time without prior notice.

  1. No Warranty

THE CONTENT AND ALL OTHER INFORMATION AND MATERIALS CONTAINED IN THE WEBSITES, INCLUDING TEXT, GRAPHICS, LINKS, OR OTHER ITEMS, ARE PROVIDED “AS IS” AND “AS AVAILABLE”. VANTIV DOES NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THIS INFORMATION AND MATERIALS AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS OR OMISSIONS IN THIS INFORMATION AND MATERIALS. THE DOCUMENTS AND RELATED GRAPHICS PUBLISHED ON THE WEBSITES COULD CONTAIN TECHNICAL INACCURACIES OR TYPOGRAPHICAL ERRORS. NO WARRANTY OF ANY KIND, IMPLIED, EXPRESSED OR STATUTORY, INCLUDING BUT NOT LIMITED TO, THE WARRANTIES OF NON-INFRINGEMENT OF THIRD-PARTY RIGHTS, TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND FREEDOM FROM COMPUTER VIRUS, IS GIVEN IN CONJUNCTION WITH THE INFORMATION AND MATERIALS. VANTIV SHALL HAVE NO LIABILITY OR RESPONSIBILITY FOR ANY ERRORS OR OMISSIONS IN THE CONTENT ON THE WEBSITES. VANTIV DOES NOT WARRANT THAT THE WEBSITES ARE COMPATIBLE WITH YOUR EQUIPMENT OR THAT THE CONTENT IS FREE FROM ERRORS, VIRUSES, WORMS, TROJAN HORSES, OR ANY OTHER HARMFUL, INVASIVE, OR CORRUPTED FILES, OR THAT THE WEBSITES WILL BE UNINTERRUPTED, SECURE, OR ERROR-FREE. VANTIV IS NOT LIABLE FOR ANY DAMAGES YOU MAY SUFFER AS A RESULT OF SUCH DESTRUCTIVE FEATURES. SHOULD APPLICABLE LAW NOT PERMIT THE FOREGOING EXCLUSION OF EXPRESS OR IMPLIED WARRANTIES, THEN VANTIV HEREBY GRANTS THE MINIMUM EXPRESS OR IMPLIED WARRANTY REQUIRED BY SUCH APPLICABLE LAW. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM VANTIV, ITS EMPLOYEES, AGENTS, SUPPLIERS, OR ANY OTHER PERSONS SHALL CREATE ANY WARRANTY, REPRESENTATION, OR GUARANTEE NOT EXPRESSLY STATED IN THIS SECTION.

  1.  Limitation of Liability

YOUR USE OF THE WEBSITES IS AT YOUR OWN RISK. NEITHER VANTIV, ITS AFFILIATES, NOR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR OTHER REPRESENTATIVES WILL BE LIABLE FOR ANY DAMAGES, WHETHER DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE, INCLUDING, WITHOUT LIMITATION, LOSS OF DATA, INCOME, PROFIT OR GOODWILL, LOSS OF OR DAMAGE TO PROPERTY, AND CLAIMS OF THIRD PARTIES ARISING OUT OF YOUR ACCESS TO OR USE OF THE WEBSITES OR ARISING OUT OF ANY ACTION TAKEN IN RESPONSE TO OR AS A RESULT OF ANY CONTENT OR OTHER INFORMATION AVAILABLE ON THE WEBSITES, HOWEVER CAUSED, WHETHER BASED ON BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE), PROPRIETARY RIGHTS INFRINGEMENT, PRODUCT LIABILITY, OR OTHERWISE. THE FOREGOING SHALL APPLY EVEN IF VANTIV WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOU BECOME DISSATISFIED IN ANY WAY WITH THE WEBSITES OR THEIR TERMS OF USE OR PRIVACY POLICY, YOUR SOLE AND EXCLUSIVE REMEDY IS TO STOP YOUR USE OF THE WEBSITES AND THEIR SERVICES. YOU HEREBY WAIVE ANY AND ALL CLAIMS AGAINST VANTIV AND ITS AFFILIATES, AGENTS, REPRESENTATIVES, AND LICENSORS ARISING OUT OF YOUR USE OF THE WEBSITES.

  1. Postings

Apart from your personal information (which is addressed in the Privacy Policy), any communication or material you send to a Vantiv Website, electronically or otherwise, including but not limited to data, questions, comments, survey responses, suggestions or submissions is an will be treated as non-confidential and non-proprietary.  Anything you send to or through a Vantiv Website may be used by Vantiv for any purpose including, but not limited to modification, reproduction, transmission, disclosure, publication, broadcast, and posting.  By submitting material to a Vantiv Website, you irrevocably transfer and assign to Vantiv, and forever waive and agree never to assert, any copyrights, “moral” rights, rights of publicity or to privacy, or other intellectual-property or proprietary rights that you may have in such material.  Vantiv is free to use, without obligation of any kind, any ideas, concepts, techniques, or know-how contained in any communication you send to a Vantiv Website for any purpose whatsoever, including, but not limited to developing, manufacturing, and marketing products and services.   

  1.  Panels, Message Boards, and Survey Responses

Participation in and response to any invitation to participate in a panel, message board, or survey on our Website is completely voluntary, and there is no obligation to participate.  By creating a profile to participate in panel or survey activities, you agree to provide us with accurate, complete, and updated registration information. 
Vantiv may monitor postings on our Website and may decline to accept and may remove any postings that contain; (a) Any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, profane, hateful, racially, ethnically or otherwise objectionable material of any kind, including, but not limited to, any material which encourages or contributes to a criminal offense, gives rise to civil liability or otherwise violates any applicable local, state, or federal law; (b) Advertisements or solicitations of any kind (c) Messages posted by users impersonating others.; (d) Personal information such as social security numbers, account numbers, addresses or employer references; (e) Messages that offer unauthorized downloads of any copyrighted or private information; (f)  Chain letters of any kind.

  1.  Access to Password Protected/Secure Areas

Access to certain areas of the Website may require a username and password.  You may never use another’s username and password without permission.  Access to and use of password protected and/or secure areas of the Website is restricted to authorized users only.  Unauthorized individuals attempting to access these areas of the site may be subject to prosecution.   

  1.  Privacy Policy

We respect your privacy, and will maintain the confidentiality of your personal information in accordance with applicable law and our Privacy Policy. 

  1.  Links

The Websites may contain links to other Websites (Linked Sites”) controlled or offered by third parties. Linking to such Linked Sites will let you leave the Websites. Unless otherwise indicated, Vantiv is not affiliated with any of the Linked Sites. The Linked Sites are not under the control of Vantiv and Vantiv is not responsible for the contents of any Linked Site, including without limitation, any link contained in a Linked Site, or any changes or updates to a Linked Site. Vantiv disclaims liability for any information, materials, products or services posted or offered at any Linked Site. By creating a link to a Linked Site, Vantiv does not endorse or recommend any products or services offered, or information contained in that Linked Site, nor is Vantiv liable for any failure of products or services offered or advertised at the Linked Site. Such third party may have a privacy policy different from that of Vantiv and the Linked Site may provide less security than the Websites. Vantiv is providing the Linked Sites only as a mere convenience. If you decide to access any Linked Site you do so entirely at your own risk.
Vantiv prohibits caching, unauthorized hypertext links to the Website and the framing of any Content available through the Website.  Vantiv reserves the right to disable any unauthorized links or frames and specifically disclaims any responsibility 

  1. DIGITAL MILLENNIUM COPYRIGHT ACT - NOTIFICATION TO VANTIV REGARDING ALLEGED COPYRIGHT INFRINGEMENT

Vantiv has registered an agent with the United States Copyright Office in accordance with the terms of the Digital Millennium Copyright Act and avails itself of the protections under the Act.   For details, please see Digital Millennium Copyright Act Notices.

  1. Governing Law

These Terms of Use shall be governed by and construed in accordance with all applicable federal laws and the laws of the state of Ohio, without regard to conflicts of law provisions. 

  1.  Changes

All information posted to this Website, including these Terms, is subject to change without notice.  Your continued use of the Website after such changes is deemed to be your acceptance of such changes to these Terms of Use.  Please check the Terms of Use regularly.


 

Vantiv eCommerce Privacy Shield Policy

Vantiv eCommerce, LLC (“Vantiv eCommerce”) complies with the Privacy Shield Framework, as set forth by the U.S. Department of Commerce in consultation with the European Commission, regarding the collection, use and retention of personal data received from the European Union. As Vantiv eCommerce is a U.S. company, it has voluntarily decided to comply with the EU – U.S. Privacy Shield Framework and is subject to the investigatory and enforcement powers of the Federal Trade Commission. By using our client’s ecommerce sites, you are permitting the transfer of your personal data to Vantiv eCommerce, LLC in the United States, which has different data protection laws than those in European Union member countries. You consent to the transfer of this information for the uses described in the Privacy Shield Policy and in our general Privacy Policy to the extent permitted by EU law.

Vantiv eCommerce adheres to the Privacy Shield Principles. As such, Vantiv eCommerce commits to subject all personal data received from the EU to the Principles, and therefore this policy shall govern Vantiv eCommerce’s use of your personal data if there is any conflict between this policy and those contained in our general Privacy Policy.

Vantiv eCommerce annually certifies its adherence to the Privacy Shield Principles. To learn more about the EU – U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov/EU-US-Framework. To view Vantiv eCommerce’s certification, please visit https://www.privacyshield.gov/list.

Personal Data Collected and Processed by Vantiv eCommerce

Personal data means information that identifies or can identify an individual whether directly or indirectly and whether processed electronically by automatic means or manually. Vantiv eCommerce receives personal data for individuals related to processing payment transactions initiated through our merchant clients. This data is collected for the purposes of completing a payment for goods and services purchased on our client’s website(s). The personal data collected can consist of payment information such as names, addresses, email addresses, card or account numbers, and CVV codes.

We may also collect your personal data from other sources, such as credit bureaus, affiliates, or other companies.

Disclosures to Third Parties

When Vantiv eCommerce receives personal data from a client for processing, we are acting as an agent for the client, and we do not control or share such data without direction from the client. In relation to such processing, Vantiv eCommerce enters into appropriate agreements with the clients providing that the client is the data controller and is in compliance with the applicable EU data protection laws.

Vantiv eCommerce does not transfer personal data to unrelated third parties unless lawfully directed by our client or in certain limited circumstances in accordance with the Privacy Shield Framework. In the event that Vantiv eCommerce is directed by our client to transfer data to additional data processors, Vantiv eCommerce will enter into appropriate agreements providing that the processor is in compliance with the Privacy Shield. Vantiv eCommerce may be liable if it fails to meet those obligations and Vantiv eCommerce is responsible for the event giving rise to the damage.

Vantiv eCommerce may also share your personal data with other third parties as required or permitted by a duly authorized court order, subpoena, or request for cooperation from a regulatory, law enforcement or other government agency to meet national security or law enforcement requirements; to establish or exercise our legal rights; to defend legal claims; when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others; or as otherwise required or permitted by applicable laws and/or regulations.  In such events we will only disclose data relevant and necessary to the investigation or inquiry.

Vantiv eCommerce may also share information with a third party that acquires all or part of Vantiv or succeeds Vantiv in carrying on all or part of Vantiv’s business by sale, merger, acquisition, or other corporate restructuring.

Choice

You can request that Vantiv eCommerce no longer use or share your personal data with third parties or use your data for a purpose different from the purpose for which it was initially collected or subsequently authorized by you. If you wish to submit such a request, please submit your request via email to EUprivacy@vantiv.com. To begin processing your request we require your name, address, and email address. We will follow up with you to verify the request, and obtain any additional information required. Please note that not all requests can be honored and that we may only honor reasonable requests. For example, in some cases such a request may not be immediately or fully executed because it is possible that we have a legal obligation to keep using your personal data. Also, you must consider that for certain purposes, the revocation of consent to use your data means that we cannot continue providing the services you requested.

Access and Updates to Personal Data

An individual in the European Union may contact Vantiv eCommerce to learn whether or not personal data relating to him or her is found in Vantiv eCommerce’s databases, learn how any personal data about the individual has been used or disclosed, verify the accuracy of any personal data about the individual, and request correction, amendment and deletion of personal data about the individual. Should you wish to make such an inquiry, please submit your request via email to EUprivacy@vantiv.com. To begin processing your request we require your name, address, and email address. We will follow up with you to verify the request, and obtain any additional information required.

Please note that this right only applies to personal data about the individual making the request and is subject to other limitations as defined by law and the Privacy Shield Framework, including where the burden or expense of providing access would be disproportionate to the risks related to the privacy of the individual, where the rights of other individuals would be violated, where responding to or complying with an individual’s request would interfere with execution of the law or private causes of action, or where responding to or complying with and individual’s request would interfere with countervailing public interests like national security, defense, or public security. This right is also subject to reasonable limits on the number of times within a given period that access requests from a particular individual will be met.

Security

Vantiv eCommerce has adopted technical, physical, and administrative security measures adopted under U.S. law and regulations to help protect the security of your personal data. For additional information regarding our security measures, please see the section entitled “Security,” in our Privacy Policy above.

Data Integrity

Vantiv eCommerce makes reasonable efforts to only process personal data for the purpose for which it was collected as instructed by our client. Vantiv eCommerce takes reasonable steps to help ensure that personal data is accurate, complete, current, reliable for its intended use, kept only for the period necessary and not excessive for the purposes for which the personal data is processed.

Accountability, Enforcement and Inquiries

Any EU person who is not satisfied with Vantiv eCommerce’s compliance with the EU – U.S. Privacy Shield may contact Vantiv eCommerce to resolve such complaints at EUprivacy@vantiv.com. We will respond within 45 days. If any EU person believes that such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or some other dispute resolution procedure. The rules governing these procedures and information regarding how to file a claim free of charge can be found here: http://info.adr.org/safeharbor/.

Any EU person who remains dissatisfied may contact his or her national Data Protection Authority in the country where the person resides. Vantiv eCommerce has agreed to cooperate and comply with appropriate EU Data Protection Authorities and the Department of Commerce in resolving such disputes. If an EU person remains dissatisfied and meets the pre-arbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke binding arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here: https://www.privacyshield.gov/EU-US-Framework.

Verification

Vantiv eCommerce uses a self-assessment approach to ensure compliance with this Privacy Shield Policy, and verifies at least annually that the policy is accurate, comprehensive for the data intended to be covered, prominently displayed, completely implemented, and accessible and in conformity with the Privacy Shield Principles.

Questions & Contact Information

Any further questions and comments regarding Vantiv eCommerce, LLC’s Privacy Shield Policy or practices can be directed in writing to:

Vantiv eCommerce, LLC
Attn: Chief Privacy Counsel
900 Chelmsford Street
Lowell, MA 01851


Or via email at EUprivacy@vantiv.com

Policy Updated: July 14, 2017