Vanguard Payment Systems

This Privacy Policy covers Vanguard’s treatment of nonpublic personal user information collected (i) from merchants who use Vanguard services, (ii) by Vanguard in the ordinary course of its business, and (iii) from Vanguard’s business partners. This Privacy Policy does not apply to the practices of companies that Vanguard does not own or control, or to people that Vanguard does not employ.

INFORMATION COLLECTION

In order to use Vanguard’s services, a user may be required to register with Vanguard. During registration a user may be required to give Vanguard user contact information, including name and email address and information about bank account and/or credit card numbers. It is optional for the user to provide demographic information (such as income level and gender), and unique identifiers (such as, username and password), but encouraged so Vanguard can provide a more personalized experience on Vanguard’s site.

Vanguard may also receive nonpublic personal user information from Vanguard’s business partners. Unless provided in this Privacy Policy, Vanguard is the sole owner of the information collected by its sales and marketing efforts.

Vanguard uses many means to protect the nonpublic personal user information it receives, including without limitation, encryption, physical access security, computer firewalls and other appropriate technologies. Like most standard website servers Vanguard uses log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.

Vanguard’s Privacy Policy limits access to nonpublic personal user information that is collected to those employees of Vanguard and its affiliates who need the information to fulfill their business responsibilities. Vanguard may disclose nonpublic personal user information to companies affiliated with Vanguard as business partners. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive personal information is safeguarded. Employees must adhere to Vanguard’s Privacy Policy. Employees violating Vanguard Privacy Policy are subject to disciplinary action, up to and including dismissal.

USE OF NONPUBLIC PERSONAL USER INFORMATION

Vanguard uses nonpublic personal user information to contact a user about services offered on Vanguard’s site for which a user has expressed interest. Vanguard also uses nonpublic personal user information to fulfill a user’s requests for certain products and services, to process payment transactions, to facilitate billing, and otherwise deliver Vanguard’s services. Vanguard may also send users service announcements, newsletters, and periodic notices about specials and new products.

Protecting nonpublic personal user information about users is an important part of Vanguard’s business. In addition to other disclosures provided herein, Vanguard shares and discloses nonpublic personal user information only as described below.

Vanguard will send nonpublic personal user information to other companies or people when: 1) Vanguard has a user’s consent to share the information; 2) Vanguard needs to share the information to provide the product or service the user has requested such as delivering payment processing services (these third parties are not allowed to use nonpublic personal user information except for the purpose of providing these services); 3) Vanguard needs to send the information to companies who work on behalf of Vanguard to provide a product or service to the user (unless Vanguard tells you differently these companies do not have any right to use the nonpublic personal user information Vanguard provides them beyond what is necessary to assist the user).

Vanguard also may release nonpublic personal user information when Vanguard believes release is appropriate to comply with any law, enforce or apply any agreement to which the user and Vanguard are parties, and protect the rights, property, or safety of Vanguard, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This also includes when Vanguard have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website.

BUSINESS TRANSITIONS

In the event Vanguard goes through a business transition, such as a merger or sale, a portion of its assets, including the nonpublic personal user information, will, in most instances, be part of the transaction. Prior to any disclosure of such nonpublic personal user information to a potential buyer, Vanguard will obtain appropriate non-disclosure and confidentiality agreements. Users will be notified via notice on our website of any change of ownership or control of nonpublic personal user information.

The Vanguard website contains links to other sites. Vanguard is not responsible for the privacy practices of such other sites. Vanguard encourages its users to read the privacy statements of each and every website that collects nonpublic personal user information. The Vanguard Privacy Policy applies solely to nonpublic personal user information collected by Vanguard’s website.

CORRECTING/UPDATING/DELETING/DEACTIVATING PERSONAL INFORMATION

If a user’s personal user information changes, or if a user no longer desires to use Vanguard’s services, Vanguard provides a way for the user to correct, update or delete/deactivate user’ personal user information. Contact Vanguard by email, telephone or postal mail at the contact information listed below.

NOTIFICATION OF CHANGES

If Vanguard changes its Privacy policy, Vanguard will post the changes on its homepage and other places Vanguard deems appropriate so the information is available for users to review.

Vanguard does not offer services or sell products to children. Vanguard does not request or knowingly collect personal user information from anyone under the age of 13.