Privacy Policy

Introduction

This Privacy Policy describes how we collect, use, and share your information, which may include Personal Data (as defined below) in connection with our websites, and platforms (the “Site”) and any other online content, tools, or services (together, the “Services”) that we control and that link to this Privacy Policy. For the purposes of this Privacy Policy, “Personal Data” means any identifiable information about you, like your name, email, address, telephone number, payment information, support queries and so on. Under certain circumstances, Personal Data may also include other information that can reasonably link to a particular person, such as internet protocol (IP) addresses, unique device identification numbers, employment information, medical information and internet activity.

Who are “We”

When we refer to ‘we’ (or “GCPay” ‘our’ or ‘us’), we mean Hart Business Solutions, LLC, its affiliates and wholly owned subsidiaries

Why this privacy policy matters

In order to provide best in class Services to you, we require certain information, including Personal Data. Please be sure to read this entire Privacy Policy before using or submitting information through the Services. By using or submitting information through the Services, you are indicating that you agree to the collection, transfer, modification, manipulation, processing, storage, disclosure and other uses of your personal data as described in this Privacy Policy, and to be bound by the terms of this Privacy Policy.

Information you provide to us directly

We collect Personal Data from you when you voluntarily provide such information, including but not limited to when you access, complete and/or use one of our online tools or content items, contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services.

Generally, we collect the following categories of Personal Data:

Demographic Data	Contact data such as your name, email, and phone number
Commercial Information	Business name, business address, ownership and employee full name and email, payment information, formation documents, and commercial other information
Account Registration	If we offer a log-on experience, this would include the information we collect when you create an account such as name, email and/or other information to provide account related functionalities to our users
Feedback & Support	If you provide us feedback or contact us for support, we may collect your name and email address, as well as any other content that you send to us. We collect and use this data based upon our business need to receive and act upon your feedback or provide you with support.
Internet or Online Information	When you visit or use some parts of our websites we might collect online information such as browsing history, IP address, device type and information regarding interaction with our websites, applications, or advertisements.
Inferences	Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics related to our Services.
Social Information	Information provided when you request a demo, fill out a survey, join us on social media, or take part in training and events.
Other Information	Information we may collect which is not specifically listed here is described in this Privacy Policy or is otherwise disclosed at time of collection

By voluntarily providing us with Personal Data, you are consenting to our use of your Personal Data in accordance with this Privacy Policy. You represent that the Personal Data you provide is true, accurate, current and complete, and that you have the authorization to provide it to us. If you provide Personal Data to us through the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of GCPay and the authorized third parties referred to herein, including our affiliates and wholly owned subsidiaries. If we don’t collect Personal Data about you, we may not be able to provide the Services.

Information we collect automatically

We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible.

Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website. GCPay does not sell cookies, and will only share your cookies as described in this Privacy Policy. You can set your browser not to accept cookies and the websites listed below tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result. For further information visit www.aboutcookies.org (http: /www.aboutcookies.org/) or www.allaboutcookies.org (http: /www.allaboutcookies.org/).

Information we get from third parties

The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.

We may collect Personal Data from third parties, generally under the following circumstances:

To perform a contract with you.
Where we have legitimate interests to process the personal data and they’re not overridden by your rights, or in accordance with a legal obligation
Where we have your consent.

How we use your data

GCPay uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. Generally, we may use information we collect in the following ways:

To provide and improve the Services
To communicate with you as part of the Services, and to provide technical support and assistance
To identify you and, at times, personalize your experience on our Sites
For fraud detection and information security
For marketing communications and to display targeted advertising to you
To analyze, anonymize and produce analytics and reports
To manage our relationships and relationships you bring onto our Sites
To provide you with access to additional services through third party providers
To respond to inquiries related to support or other requests

In addition, if you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. Also, if you provide Personal Data in order to learn about certain products that may be available to you through third-party providers, we will use your Personal Data to provide you with information on such products and providers, to provide other personalized services, and/or to monitor your use of the Services.

GCPay and our subsidiaries and affiliates (the “GCPay Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users, to offer new services, products, and features through the GCPay Related Companies and through third parties, and to generally improve the Services.

How we disclose your data

GCPay is not in the business of selling your information to third parties and will not, under any circumstances, sell your data. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Certain Business Partners	When we contract with third party service providers and partners provide content or services to you. In addition, we may share relevant Personal Data in connection with such content or services.
Products, Services, and Features	We may share your Personal Data in connection with offering products, services, and features to you as part of the Services or in order to maintain, operate and enhance our existing products, services and features.
Business Analytics	When we partner with certain businesses in order to learn and improve user interface, content, site performance, and our Services and to provide reporting and personal insights as part of the Services.
Fraud Detection and Prevention	We may share your Personal Data to prevent and detect fraud, to verify your identification, or for other fraud detection and prevention purposes.
Business Transactions	In connection with an actual or potential buyer (and its agents and advisers) related to an actual or proposed purchase, merger or acquisition of any part of our business.
GCPay Related Companies	We may also share your Personal Data with the GCPay Related Companies for purposes consistent with this Privacy Policy
Legal and Regulatory	We may share your Personal Data with regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights.
Consent	Where we have your express consent.

Other important information

In general, you can visit the Sites without providing Personal Data. If you choose not to provide any Personal Data, however, you may not be able to use certain features, products or the Services.

International Data Transfers

When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws different to what you’re used to. Where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected. For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like Australia).

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to employees and contractors who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information.

Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk.

Retention

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need or a regulatory need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements). We’ll retain your personal data for as long as we have a relationship with you, and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices or as otherwise required by applicable law or regulation for the period required by any such applicable law or regulation. Following that period, we’ll make sure it’s deleted or anonymized.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website, when you follow links to other websites you should read their own privacy policies.

Non-personal information

This Privacy Statement does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.

Your rights

It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you will only receive these emails if you have opted in. You may opt out at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to unsubscribe@gcpay.com..

You also have rights to:

know the information we have about you and make sure it’s correct and up to date
request a copy of your Personal Data
ask us to restrict certain processing of your Personal Data
object to our processing of your Personal Data
ask us to delete your Personal Data

You can exercise these rights at any time by sending an email to privacy@gcpay.com. If you’re unhappy with how we’re processing your Personal Data, please let us know by sending an email to privacy@gcpay.com. We will review and investigate any request or issue and get back to you within a reasonable time period. You can also complain to your local or national data protection authority.

Children’s privacy online

GCPay does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to GCPay through the Services, please contact us, and we will endeavor to delete that information from our databases.

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to GCPay through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and GCPay shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Changes to our Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for GCPay to make changes to this Privacy Policy. GCPay reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

How to contact us

If you have a question or feedback for us on this notice, or how we hold your personal data, please get in touch. As a technology company, we prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames.

Our email is privacy@gcpay.com

Our address is:

Hart Business Solutions, LLC
405 E Laburnum Ave, Ste 3 PMB 53
Richmond, VA 23222-2120

(877) 447-2584, Option 1