Privacy Policy for IP Commerce

Revised March 2012

At IP Commerce, Inc. (“IP Commerce”), maintaining and protecting the privacy of our customers is very important. We believe that protecting your privacy is an integral part of the service we provide and we know that you care about how your information is used and shared.  This policy describes how we collect, store, use and protect your personal information.

BY APPLYING FOR OUR SERVICES, YOU EXPRESSLY CONSENT TO OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Throughout this policy we use the term “personal information” to describe information that can be used to identify a specific applicant (person or business).  We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

How does IP Commerce Collect your Personal Information and What Personal Information Does IP Commerce Gather?

We have limited relationships with third parties (“Partners”) and the service we provide for them allows you to conveniently apply on-line for a variety of programs offered by our Partners.  When you request our Partners’ products or services, you are permitting us to collect your personal information on their behalf and to provide your personal information to the Partner to fulfill your request.  In order to process your application, for example, we will request your full name, address, phone number and email address.  Our Partners may require additional information, such as your date birth, credit/debit card number, bank account information, social security number or taxpayer identification number, in order to process your application. We may also obtain information about you from third parties, such as credit bureaus and identity verification services.

What Security Measures We Take

We store and process your personal information on our computers located in the US.  We protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees and contractors who require it to fulfill their job responsibilities. When we ask you to provide your personal information, we will do so through the Secure Sockets Layer (SSL) protocol, also known as HTTPS.  This protocol provides security for your information by encrypting it as it travels from your computer to our computer.  For security purposes, we encrypt all submitted data and limit access via other access controls.  Our employees and contractors who have access to personal information are trained in security measures and are required to safeguard your information.  Additionally, we regularly monitor the adequacy of our security procedures through internal and third-party audits.
  

How We Use and Share your Personal Information

If you indicate to us that you are interested in applying for a program offered by an IP Commerce Partner, the information we collect about you will be shared with that Partner.  Please note that our Partner has its own privacy policies and IP Commerce does not monitor the subsequent use of your personal information by its Partners.   If you prefer that we not communicate your personal information to the Partner – DO NOT APPLY.  In the course of performing our services, we may also be reporting to our Partner the personal information we collected about you from credit bureaus and/or consumer reporting agencies.  We may disclose your personal information to law enforcement, government officials or other entities when we are compelled to do so by a subpoena, court order or similar legal procedures, when we need to do so to comply with law or credit card rules or when we believe in good faith that the disclosure of personal information is necessary to prevent physical hard or financial loss or to report suspected illegal activity.  Finally, we may also share your personal information with companies that we merge with or are acquired by.  See below for further information regarding business combinations.

IP Commerce will not sell or rent any of your personal information to third parties for their marketing purposes and only shares your personal information with third parties as described in this policy.

The Collection of Anonymous Data

In order to enhance the usefulness of our products and services, we will collect data about our customers' use of our service in a manner that does not include any personal information.  While you utilize our service, we note which service pages you visit and the IP address of your computer, but we do not link that address information to your personal information.  The general information we gather enables us to serve our customers better by continually enhancing our service based on up-to-date use patterns.

How Long does IP Commerce Retain Your Personal Information

IP Commerce retains all of your information in an on-line fashion for 90 days. We do not retain hard copies.   After 90 days, applicant information is destroyed.  Partners will retain information per their own privacy policies.

Accuracy of your Personal Information

Commerce is neither responsible for the accuracy of the information you provide, nor the information that is returned from processing.  IP Commerce cannot edit applicant data or results.  If you believe that some of the information that was returned is inaccurate, you must contact the Partner to whom you are applying.  Information concerning which services your application was processed through, as well as reasons for acceptance or decline, is available from the Partner.
 

Notification of Changes to this Privacy Policy

This privacy policy may be revised over time as IP Commerce adds new features to its services or as we incorporate comments from our customers.  We may amend this privacy policy at any time by posting a revised version on our Website.  Generally, the revised version will be effective at the time we post it. If we propose to change this privacy policy is a substantial way, we will provide you with at least 30 days’ prior notice of the change by posting notice of the change on our Website, after which you will be considered to have expressly consented to all amendments to the privacy policy.  If you disagree with the terms of this privacy policy, you may close your account at any time, but we will keep your account information in our database.  This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new one. However, if you close your account, your personal information will not be used by us for any further purposes, except as required to prevent fraud and assist law enforcement, as required by law in accordance with this privacy policy.

Business Combination

In the event of an acquisition of all or part of IP Commerce by another company, or in the event that IP Commerce were to sell or dispose of all or a part of the business, or engaged in another form of business combination, the acquirer would have access to the information maintained by IP Commerce, which could, subject to applicable law, include your personal information.  The acquirer's privacy policy might be different than IP Commerce's privacy policy, or the acquirer might choose to amend IP Commerce's privacy policy. We will follow the procedures described above, “Notification of Changes to this Privacy Policy,” in the event of changes in this Policy resulting from a business combination. Please check the IP Commerce website at http://developer.ipcommerce.com/privacy_policy.aspx at any time for the most current version of our Privacy Policy.

The Use of Cookies

IP Commerce uses "cookies," which are pieces of information that a service transfers to your web browser for record keeping purposes, to facilitate your use of our Products and Services.  These cookies provide us with a means of identifying you and locating your record in the event you save or submit an application.  They do not contain personal information and do not grant any access to the application you have on file with us.

You may decline our cookies if your browser or browser add-on permits, but doing so may interfere with the use of our Website.

Our Partners who allow you to use our services may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure usage.  IP Commerce cannot comment on their usage. 

Links to Other Services

Some pages on the IP Commerce Service may contain links to other services provided by third parties.  We do not provide any personally identifiable customer information through these links. When you click on one of these links, you are moving to third party’s site. Any information you submit after that point is out of IP Commerce’s control.  We do not have access to or control over cookies or other features that they may use and encourage you to read the privacy statements of these linked services as their privacy policy may differ from ours.
 

Policy Regarding Children

Children are not eligible to use our services and we ask that minors (persons under the age of 18) do not submit any personal information to use or use our services.  We do not knowingly collect personal information about children.

You Can Contact Us

If you have privacy-related questions that are not addressed here, please contact Operations Support at IP Commerce, Inc., 1001 17th Street, Suite 400, Denver, CO  80202.