PRIVACY POLICY

Updated: June 6, 2023

Agentis Payments Ltd. (“Company”, “we” or “us”) is committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Policy is to inform you about our privacy practices, including how we collect, use and disclose your personal information. 

This Privacy Policy relates to all of our products, services and activities, including our websites and the Verto mobile app, unless we have provided you with a separate Privacy Policy for a particular product, service or activity. 

Please review this Privacy Policy carefully.  By submitting your personal information to us, by using any of the services we offer, by using our website or our mobile app, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your personal information as set out in this Privacy Policy, as revised from time to time.

WHAT’S IN THIS PRIVACY POLICY? 

• Meaning of Personal Information

• Your Consent to Collection, Use and Disclosure

• I’m How We Collect, Use and Share Your Personal Information

• More Ways we Collect, Use and Share Personal Data

• Opting Out of Communications

• Retention of Personal Information

• Information Security

• Accessing and Updating Your Personal Information

• International Transfer and Storage of Information

• End Customers

• Third Party Websites and Services

• Children’s Information

• Privacy Policy Updates

• Contact Us

Meaning of Personal Information

“Personal information” means information about an identifiable individual.  This information may include, but is not limited to, your name, home address, personal telephone number, personal email address, credit card and banking information.

Personal information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We will collect, use and disclose your personal information with your consent or as permitted or required by law.  How we obtain your consent (i.e. the form we use) will depend on the circumstances, as well as the sensitivity of the information collected.  Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question.  If you choose to use our products and services or to provide information to us, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy.

You may withdraw your consent to our collection, use or disclosure of your personal information at any time by contacting us using the contact information in the “Contact Us” section below.  However, before we implement the withdrawal of consent, we may require proof of your identity. Withdrawal of your consent may mean that we will no longer be able to provide you with our products and services.

How We Collect, Use and Share Your Personal Information

We may use your personal information for the following purposes:

• to provide you with our products and services and to personalize and support your use of our products and services;

• to contact you relating to our products and services;

• to monitor and improve our products and services;

• to develop new products and services;

• to analyze the needs and activities of our customers to help us better serve them;

• to conduct research and analysis related to our business, products and services;

• to respond to inquiries and other requests; 

• to collect opinions and comments in regard to our products and services; 

• to determine your credit qualifications;

• to comply with Know Your Client and other regulatory requirements; and

• to avoid fraud, manage legal risk and investigate legal claims.

We may also use your personal information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable law.

Account Details.  We collect information that you submit through your use of our products or services, including information you provide in connection with the creation and management of your account for our products or services, such as your name, profile photo, mailing address, telephone number, e-mail address, username and password.

Transactions. For payment transactions with Link, End User Personal Data is shared with others to enable or “process” the transaction. For example, when you choose to use a payment method for the transaction with Us or with Checkout (e.g. credit card, debit card, buy now pay later, or direct debit), the third party provider of your payment method will receive Transaction Data that includes your Personal Data. 

When you use Checkout, the merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and, with your separate consent, your bank account information. Please review the privacy policies of your payment method and the merchants who you choose to learn more about their processing of your Personal Data.  

Transaction Data. “Transaction Data” as used in this Privacy Policy includes Personal Data, and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number and past purchases.

If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive Transaction Data. We may also receive your transaction history with the Business User. Moreover, we may obtain information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User.

We offer you the opportunity to store your payment methods with Us so that you can conveniently use it across merchants who are our Business Users. When you opt in to Checkout, you agree to let us store your Personal Data such as your payment method so that you can more readily make purchases through Checkout with Business Users of our payment processing Business Services (e.g. name, contact information, payment method details (e.g. card number, cvc, and expiration date)). When you choose to pay with Checkout, we will also collect Transaction Data related to your transactions.

• If you choose to share bank account information with us, We will periodically collect and process your account information (e.g. bank account owner information, account balances, account number and details, account transactions and, in some cases, credentials). 

• With your separate permission, we will share this Personal Data with Business Users that you choose.  

• With your separate permission, we will share contact information (e.g. shipping address, billing address and phone number) with Business Users that you do business with. 

Should you not have used Checkout and receive an SMS in error due to an inaccurate number being inserted at the authentication flow stage you can opt out here and your personal data will be deleted.

Identity/Verification Services. We provide an identity verification service that automates comparing an identity document with your image (e.g., selfie).  You may choose to opt-in to allow us to store that verification for future use across other merchants and/or separately consent to letting us use your biometric data to improve our verification technology.

Contacts. You may choose to share contact data with us to enable finding your friends when you send or request payments. Sharing your contacts is a feature that can allow us to identify which of your contacts in your device’s address book are also using the app. If you choose to share your contacts, you may choose to interact with these contacts, for instance, by sending them money, requesting money, or inviting them to use the app. You may only interact with individuals with whom you have a personal or family relationship and who would want to receive the message from you. We will use these shared contacts to improve our services and offerings, enrich your own app experience, and provide you with better recommendations on potential contacts to invite. We may also share basic contact information (based on your privacy settings) with other users, to confirm they are sending money to the right person, or notifying existing users in your contacts when you join the app.

Electronic Data.  We collect log data and usage information relating to your use of our products and services.

Website and App. For individuals who visit our websites (www.ver.to, www.vrto.co) (“our websites”) or use the Verto mobile app (“our app”), we may collect personal information from you or from your activities on our website or app.

Like most websites and other Internet services, we may collect certain technical and device information about your use of our website.  Such information may include your Internet protocol address, information about your device, browser and operating system, your location, and the date and time of your visit.

We may also use “cookies” or enlist third party services which use cookies to track your preferences and activities on our website.  Cookies are small data files transferred to your computer’s hard-drive by a website.  They keep a record of your preferences, making your subsequent visits to the site more efficient. Cookies may store a variety of information, including the number of times that you access a site, your registration information and the number of times that you view a particular page or other item on the site.  The use of cookies is a common practice adopted by most major sites to better serve their users.  Most browsers are designed to accept cookies, but they can be modified to block cookies.  See your browser’s help files for more information.  You should note, however, that without cookies some of our website’s functions may not be available.

Other Interactions.  For individuals who otherwise interact with us, whether by phone by email, or otherwise, we may collect information that you provide to us during these interactions. This information may include your name, e-mail address and other contact information, and on-line chat text provided to us for customer service and support.

Products and Services. We use your Personal Data to provide the End User Service to you, including security, sanctions screening, delivery, support, personalization (e.g. language preferences and settings choices) and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). For example, we will use Personal Data to assess whether your use of Checkout to make a payment with a merchant is authorized by you (and not a bad actor) and likely to be successfully authorized by the payment method you choose to use when you choose to make purchases with Checkout.

Our Business Users. When you choose to connect your financial account with Us you may also choose to share account information with Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.

Fraud Detection and Loss Prevention. We use your Personal Data collected across our Services to detect fraud and prevent financial losses for you, us, and our Business Users and financial partners, including to detect unauthorized purchases. 

We may provide Business Users and financial partners (including card issuers, payment methods and others involved in payment processing activities) that use our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud or loss risk with a transaction.

Identity/Verification Information. We provide a verification and fraud prevention Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age-restricted goods) or your authorization to use a payment method. As part of these Services, you will be asked to share Personal Data with us for this purpose (e.g., your government ID, your image (selfie), and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image)). To protect against fraud, we may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and other third-party service providers and sources so that we can assess whether the person is likely to be you or a person purporting to be you.

Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Us or our financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry Our brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partners, if applicable, associated with the financial service (whose brands may be shown on the card).

Payments and Accounting. We use your Transaction Data to provide our Payments related Business Services to Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to help them calculate their revenue, pay their bills and perform accounting tasks. We may also use Personal Data to provide and improve our Business Services.

• For payment transactions, your Personal Data is shared with a number of parties in connection with your transaction. Because we act as a service provider or processor, we share Personal Data to enable the transaction. For example, when you choose to use a payment method for the transaction (e.g. credit card, debit card, buy now pay later, or direct debit), your payment method will receive the Transaction Data that includes your Personal Data. Please review your payment method’s privacy policy to learn more about how they use and share this information.

• The merchant you choose to do business with will also receive Transaction Data that includes your Personal Data and the merchant may share that Personal Data with others. Please review your merchant’s privacy policy to learn more.

Advertising. We may use your Personal Data to assess your eligibility for, and offer you, other End User Services or promote existing End User Services. Where allowed by law (including with your opt-in consent where required), we use and share End User Personal Data with others so that we may market our End User Services to you, including through interest-based advertising. 

• As allowed by law, we use and share Visitor Personal Data with others so that we may advertise and market our Services to you.  Subject to applicable law (including any consent requirements), we may advertise our Services to you through interest-based advertising and emails, and seek to measure the effectiveness of our ads.

• We do not sell or share End User Personal Data with third parties for marketing or advertising their products without your separate consent.

Our Business Users (their Authorized Third Parties). We share Personal Data of End Customers with their respective Business Users and with parties directly authorized by those Business Users to receive Personal Data. This includes sharing Personal Data of End Customers with Business Users when a Business User authorizes a third party application provider to access its account with Us. For example, when the Business User uses Identity Services to verify an End Customer’s identity, We share with the Business User the information, documents or photos provided by the End Customer to verify their identity. The Business Users you choose to do business with may further share your Personal Data to third parties they authorize (e.g. other third party service providers). Please review their privacy policy to learn more.

Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form (e.g. your contact information and other information about your question related to our Services).  We may also associate a location with your visit.

Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience (e.g. language and relevant geography) and to tailor content about Us and our Services to you.  For example, because not all of our Services are available in all regions, so we may tailor our answers for your region

Service Providers. We rely on third party service providers to perform a variety of services on our behalf, including payment processing services, telephone and technical support services, web hosting services, data storage and processing services, user engagement and marketing services, database building services, and authentication services.

If we provide your information to service providers, then we require that the service providers maintain the confidentiality of your personal information and keep your personal information secure.  We also require that they only use your personal information for the limited purposes for which it is provided.  In some circumstances, we may permit our service providers to retain aggregated, anonymized or statistical information that does not identify you.  We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes.  If you would like more information about our service providers, please contact us using the contact information in the “Contact Us” section below.

Other Purposes. Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; (g) to engage third party debt collection service providers, and (h) to allow us to pursue available remedies or limit the damages that we may sustain.  In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

More Ways we Collect, Use and Share Personal Data

Improving and Developing our Services. We use analytics on our Sites to help us analyze your use of our Sites and Services and diagnose technical issues. To learn more about the cookies that may be served through our Sites and how you can control our use of cookies and third-party analytics. We also collect and process Personal Data through our different Services, whether you are an End User, End Customer, Representative or Visitor, to improve our Services, develop new Services and support our efforts to make our Services more relevant and more useful to you.

Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:

• Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),

• Usage data associated with those devices and browsers and how you’ve engaged with our Services, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, payment methods used, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators, like mouse activity indicators, to help us detect fraud.

Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Our emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Us, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Our events and other interactions with Our personnel.

We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.

Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. We will also use that Personal Data and Personal Data you make available on social media to market to you unless we are not permitted to do so.

Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Us and Our Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.

Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer (“KYC”) laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas and other legal obligations.  We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Us, our End Users and their End Customers.

Minors. The Services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law.

Our Affiliates. We share Personal Data with other affiliated entities. When we share with these entities, it is for purposes identified in this Policy.

Service Providers or Processors. In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. 

We authorize such service providers to use or disclose the Personal Data that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. 

Financial Partners. “Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase or provide credit secured by the Capital loans that we have made to the associated Business Users.

Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services (e.g. professional services firms that we partner with to deliver Atlas). In these cases, we will disclose the identity of the third party and the information that will be shared with them and seek your consent to share the information.

Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.

Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by a payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Us, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us or by replying with “STOP” when using SMS communication.  You may also opt-out by contacting us directly using the contact information in the “Contact Us” section below. 

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request.  Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law. 

If you’ve interacted with Us or a merchant who uses Us, it’s possible We have collected information from you in your capacity as user or as a consumer. As a provider of payment services, We are required to comply with many regulations, including anti-terrorism and anti-money laundering laws. These laws require Us to retain certain information associated with Our users for a prescribed period of time after account closure. 

We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your account with US or complete a transaction with a Business User, we may retain your Personal Data: 

• to comply with our legal and regulatory obligations. 

• to enable fraud monitoring, detection and loss prevention activities. 

• to comply with our tax, accounting, and financial reporting obligations

• where required by our contractual commitments to our financial partners (and where data retention is mandated by the payment methods you used). 

In certain circumstances, We may be required by law to retain and process your Personal Data even after a deletion request or objection to the processing. For instance, We are required to retain certain Personal Data it receives from its Business Users to satisfy legal obligations under Know Your Customer (KYC) and Anti-Money Laundering (AML) laws.  

We may also rely on compelling legitimate grounds to continue processing your Personal Data. We may act on such grounds, for instance, when it takes steps to prevent fraud and financial crimes.  When Personal Data is necessary to enable or maintain the integrity of Our fraud detection and financial models, We may not be able to honor requests to delete or stop processing that data.  If We honored such requests, fraudsters might take advantage of its willingness to do so to seek deletion of data related to their past fraudulent activities.  Without such data, We would be less able to recognize similar activities in the future.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your personal information and other information from loss, theft, and unauthorized access, disclosure, copying, use or modification.  We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

To help us protect Personal Data, where you have an account with Us, we encourage you to use a strong password, protect that password from unauthorized use and not use the same log-in credentials (e.g. password) for your accounts with US as you do with other services or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account with Us has been compromised), please contact us immediately.

Accessing and Updating Your Personal Information

We will take steps to ensure that your personal information is kept as accurate, complete and up-to-date as reasonably necessary.  We will not routinely update your personal information, unless such a process is necessary.  We expect you, from time to time, to supply us with updates to your personal information, when required.

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by law.  You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information.  Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers, including Canada and the United States. As a result, your personal information may be transferred to countries outside your country of residence, which may have different data protection rules than in your country.  While such information is outside of your country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

End Customers

We offer Business Services to our Business Users (e.g. payment processing through in-person or online checkout, or processing pay-outs for those Business Users). When we are acting as a Business User’s service provider (also known as a data processor), we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions (e.g. when we process a payment for a Business User because you bought a product from them) or they instruct us to send funds to you. 

Business Users are responsible for making sure that their End Customers’ privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their products and services. If you are an End Customer, please refer to the privacy policy or notice of the Business User you choose to do business with for information regarding their privacy practices, choices and controls. 

Third Party Websites and Services

This Privacy Policy applies only to our products and services.  This Privacy Policy does not extend to any websites or products or services provided by third parties.  We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children’s Information

Our products and services are not intended for children under the age specified under applicable law, and we do not knowingly collect personal information from children under such age.  Children should not use our products and services and should not provide us with their personal information.

Privacy Policy Updates

This Privacy Policy is current as of the “updated” date which appears at the top of this page.  We may modify this Privacy Policy from time to time.  When changes are made to this Privacy Policy they will become immediately effective when published in a revised Privacy Policy posted on our website unless otherwise noted.  We may also communicate the changes through our services or by other means.  By submitting your personal information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us after we publish or communicate a notice about the changes to this Privacy Policy, you consent to our collecting, using and disclosing your personal information as set out in the revised Privacy Policy.

Contact Us

All comments, questions, concerns or complaints regarding your personal information or our privacy practices should be sent to our Privacy Officer as follows: