PRIVACY POLICY

SCOPE OF THIS POLICY

This Privacy Policy covers Fluid Pay^® LLC's treatment of personally identifiable information collected from merchants (hereafter "merchant" or "you") and our affiliate partners (hereafter "affiliate partner") who use the Fluid Pay^® payment gateway services, as well as consumer information that we acquire in the course of our business. This Policy also covers the treatment of personally identifiable information that Fluid Pay^®'s business partners may share with it and this website: www.fluidpay.com, owned and operated by Fluid Pay^®, LLC. This Policy does not apply to the practices of companies that Fluid Pay^® does not own or control, or to people that Fluid Pay^® does not employ or manage.

INFORMATION COLLECTION AND USE

Fluid Pay^® collects personally identifiable information when you register for Fluid Pay^® account, and when you use certain Fluid Pay^® products and services. Fluid Pay^® may also receive personally identifiable information from its affiliate partners and other business partners. When you register with Fluid Pay^®, we ask for your contact information (such as your name, street address, email address and phone number), as well as certain information pertaining to your business, along with billing information such as a bank account and/or credit card number. In the course of processing a payment transaction, we typically receive information related to the transaction from the merchant or a financial institution. This normally includes information about the payment that a consumer has furnished to the merchant or financial institution in the course of placing the order. We do not acquire any information directly from consumers through the www.fluidpay.com Web site. We do not sell your personally identifiable information to third parties. The personally identifiable information we acquire in processing payment transactions varies according to the nature of the transaction and the way in which merchants or financial institutions are using our payment services. It may include, for example, the amount of the transaction, the consumer's name, credit card number and expiration date or checking account number, billing address, and shipping address and in some cases product information related to an order. Fluid Pay^® uses the information collected to fulfill your requests for products and/or services, to process payment transactions, to facilitate billing, and otherwise deliver the payment gateway services. Personally identifiable consumer information is only used to process payment transactions and is never used for any other purpose. Fluid Pay^® does not offer services or sell products to children. Fluid Pay^® does not request or knowingly collect personally identifiable contact information from anyone under the age of 13.

PASSIVE COLLECTION

As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

INFORMATION SHARING AND DISCLOSURE

Protecting personally identifiable information about merchants, affiliate partners and consumers is an important part of our business. We share and disclose such information only as described below. Fluid Pay^® will only send personally identifiable information about you to other companies or people when: 1) we have your consent to share the information; 2) we need to share your information to provide the product or service you have requested; 3) we need to send the information to companies who work on behalf of Fluid Pay^® to provide a product or service to you (unless we tell you differently these companies do not have any right to use the personally identifiable information we provide them beyond what is necessary to assist us). Personally identifiable consumer information is shared with third parties (such as banks and credit card processors) to the extent necessary for Fluid Pay^® to deliver payment processing services. We also may release personally identifiable information when we believe release is appropriate to comply with law, such as a subpoena, or similar legal process; enforce or apply our Merchant Agreement and other agreements; or protect the rights, property, or safety of Fluid Pay^®, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. In certain situations, Fluid Pay^® may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In the unlikely event that Fluid Pay^® is acquired, merchant account information may be one of the transferred assets. We will notify our merchants via email and/or via a prominent notice on our Web site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information.

INFORMATION SECURITY

Information security is critical to our business. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you input. We store information gathered on secure computers located in locked data centers. The number of employees involved in the management of the data center that have physical access to these computers is limited. We use firewalls and other security technology to prevent our computers from being accessed by unauthorized persons. We also require that all personally identifiable consumer information sent to us by you be encrypted using SSL encryption. It is important for you to protect against unauthorized access to your Login ID/password and to your computer. Be sure to sign off when finished using a shared computer and otherwise protect the password used to access Fluid Pay^® services. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at help@fluidpay.com

TRACKING TECHNOLOGIES

Fluid Pay^® and its partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests.

ACCOUNT INFORMATION AND PREFERENCES

Upon request Fluid Pay^® will provide you with information about whether we hold any of your personal information. To request this information please email us at help@fluidpay.com Fluid Pay^® gives you the ability to edit or delete your Fluid Pay^® Account Information and preferences at any time by using the Fluid Pay^® Control Panel, or by emailing us at help@fluidpay.com. We will respond to these requests within a reasonable timeframe. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us a help@fluidpay.com

LINKS TO 3RD PARTY SITES

Our Web site includes links to other Web sites whose privacy practices may differ from those of Fluid Pay^®. If you submit personally identifiable information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

SOCIAL MEDIA WIDGETS

Our Web site includes Social Media Features, such as the Facebook and Twitter button or interactive mini-programs that run on our Web site. These Features may collect your IP address, which page you are visiting on our Web site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Web site. Your interactions with these Features are governed by the privacy policy of the company providing it.

NOTICE FOR EUROPEAN USERS

Fluid Pay^® is located in the United States. Any information that you provide to Fluid Pay^® will be transferred out of the EU to the United States. By providing personally identifiable information to us, you are consenting to its storage and use as described herein.

CHANGES TO THIS POLICY

Fluid Pay^® reserves the right to modify or amend this Privacy Policy at any time and for any reason. If there are material changes to this policy or in how Fluid Pay^® will use personally identifiable information, Fluid Pay^® will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to implementing the change. If you have additional questions about this Policy, please contact us at help@fluidpay.com