I. Purpose of this Privacy Policy

Origins Ecommerce (“Origins Ecommerce,” “us”, “we”, “our”) is committed to protecting the privacy and integrity of information entrusted to us. Origins Ecommerce provides card processing and related services and products to businesses (collectively “Payment Services”). Origins Ecommerce business clients sell goods and/or services to their consumer and business customers using Origins Ecommerce Payment Services. Origins Ecommerce Payment Services are provided only to its business clients. The Payment Services are not for use by individual consumers; however, our business clients may share consumer personal information with us. This Privacy Policy applies to personal information that may be collected on www.originsecommerce.com (the “Site”), which is owned and operated by Origins Ecommerce, and personal information that may be collected by Origins Ecommerce as a result of the transactions that are completed using the Payment Services. All information obtained by Origins Ecommerce via the Site is for commercial purposes only and not for consumer (family, personal or household use) purposes. Personal information shared with Origins Ecommerce by its business clients may arise out of consumer transactions or/and commercial transactions. Protecting the privacy of users of our Site and the privacy of personal information obtained as a result of the use of our Payment Services is a priority for us. We have implemented security measures to ensure your information is protected, including secure networks and servers that are accessible to a limited number of employees and industry standard encryption technologies for our receipt and transfer of sensitive information. This Privacy Policy provides information about what kinds of personal information we may collect, hold or use, how Origins Ecommerce collects and uses personal information, the choices you have regarding our use of your personal information, and how you can access and update your information. As further described below, we may amend this Privacy Policy from time-to-time, so we encourage you to revisit this Site and review it on a regular basis to ensure you are aware of our current practices.  

II. Personal Information Collected

Personal information is generally recognized as information relating to a living individual who can be identified from that information or from that information and other information which is in our possession or is likely to come into our possession and includes any expression of opinion about the individual and any indication of our intentions or the intentions of any other person in respect of the individual. The personal information we collect permits us to conduct our business, including the marketing, sale and provision of our Payment Services. Personal information we collect, store and use will vary depending on the nature of our interaction with you and/or the Payment Services you use. Personal information includes, without limitation:

• Full name;
• Gender;
• Date of birth or age;
• Contact phone numbers (mobile, landline, fax);
• Physical address;
• Email address;
• Financial account details such as your credit or debit card number and/or bank account details;
• Occupation;
• Employment and income details;
• Identification details such as social security number (or tax identification number), passport and/or national ID card information;
• Credit check results;
• Background check results including criminal background checks; and
• Ownership interests in companies and businesses.

We may collect, store and use personal information of, without limitation, the following:

• our business clients’ beneficial owners, directors, shareholders, key employees, other representatives, vendors and/or suppliers;
• our business clients’ customer who purchases goods and/or services using the Payment Services; and
• our vendors, suppliers and/or contractors and their respective beneficial owners, directors, shareholders, employees, other representatives.

Social security numbers will be collected only when necessary to conduct our business and in compliance with applicable law. We limit access to social security numbers to only those who need it to perform their job duties. Social security numbers will not be shared with third parties unless there is a legitimate business “need to know,” in accordance with applicable laws and regulations, and provided the third parties have a contractual or legal duty to appropriately protect the social security numbers. Social security numbers may be collected and disclosed for the purposes of:

• performing identity verification, sanctions list screening, and any other screening and checks required by law and applicable to the business in which Origins Ecommerce engages;
• obtaining credit reports to determine eligibility to receive Origins Ecommerce Payment Services;
• meeting any government agency reporting requirements; and
• as otherwise permitted, authorized or required by state or federal law.

A refusal to provide your social security number where requested by Origins Ecommerce may result in Origins Ecommerce being unable to offer or continue to provide Payment Services to you or the entity you represent.  

III. When Personal Information May Be Collected

We may collect your personal information:

• when you visit our Site and request information about our Payment Services;
• when you respond to questions on a form (including without limitation an application for Payment Services) posted on our Site or otherwise provide us with responses to a form related to our Payment Services;
• when we conduct “know your customer” and “due diligence” checks on you;
• from third parties working with us to perform certain functions including, without limitation, facilitating our “know your customer” and “due diligence” procedures, facilitating the provision of services to you, providing fraud prevention services;
• in the course of providing Payment Services to you;
• in the course of administering our relationship with you;
• when you seek assistance from us, provide us with feedback or contact us by phone, email, fax or in any other manner;
• when you offer to provide us with goods and services; and
• where we are otherwise authorized or required by law to do so.

If we collect sensitive personal information (social security number or financial, health, children’s or precise geolocation information), we will seek your consent unless the law allows us to collect it without your consent. In most cases, if you choose not to provide us with your personal information for the purposes stated in this Privacy Policy, we may not be able to provide you with our Payment Services. Where you provide us with personal information relating to others (such as beneficial owners), you warrant that you have their consent, are entitled to provide the information for the purposes stated in this Privacy Policy, and you will inform the third party that you have provided the information to us. When you visit the Site, we may collect, store and use information about your computer and your visits such as geographical location, IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, clickstream data, and length of visit. Additionally, you indirectly provide information on pages you visit and what you do on the Site. This information may be collected through Web server logs and cookies that assist us in tracking the aggregated statistics and data from Site users. More specifically, the Site uses 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 and functions on our Site or with respect to our Payment Services.  

IV. How We Use the Personal Information Collected

We (or our affiliates or vendors who are under contractual confidentiality requirements) use and may disclose the personal information we collect for business purposes such as:

• to respond to requests for more information on the Payment Services we offer;
• for underwriting, risk assessment, approval and set up purposes with respect to the Payment Services you request from us;
• to identify and communicate with you;
• to facilitate and complete our business clients’ authorized payment transactions for you;
• to investigate, verify and combat fraud and/or suspected money laundering or other illegal activity;
• to manage and administer any account you may have with us;
• to respond to any questions or complaints you have;
• to comply with applicable international, federal, state and local laws including, without limitation, card association rules and credit reporting laws, and requests from any court, governmental body or authority in any jurisdiction;
• in connection with legal or anticipated legal proceedings;
• to defend our legal rights including, without limitation, providing information to third parties for the purposes of reducing credit risk and fraud prevention;
• to notify you about changes to our Payment Services or changes to our contract terms and conditions;
• to conduct statistical analytics and for business reporting in relation to our services, provided the information is aggregated and anonymized such that no individual can be identified from the information, even when combined with other information;
• to administer our Site and for internal operations including, without limitation, data analytics, testing, research, troubleshooting;
• for business purposes including audit, backup, maintenance and keeping the Site secure;
• to improve the functionality and quality of the Site;
• for our promotion and marketing purposes including, without limitation, sending you information we believe you would find interesting or helpful by mail, email or similar technology; and
• to make recommendations or suggestions to you and other Site users about services or products that may be of interest.

In some instances, our systems use automated processing, including profiling and automated decision-making that is not optional. If you have provided personal information to us in conjunction with a request for information about our Payment Services, you consent to Origins Ecommerce using your personal information to send you marketing and other promotional materials about us and our Payment Services and about third parties’ related services and products, now and in the future. Further, you consent to us sending such information by direct mail, email, and text messages (both SMS and MMS messages). In the event the assets of Origins Ecommerce are sold or otherwise transferred (such as in bankruptcy), your personal information may be transferred to the successor in interest to Origins Ecommerce. Prior to such occurrence, you will be notified of such transfer and any opt-out rights you may have.  

V. When We May Disclose Your Personal Information

We may disclose your personal information to:

• third parties including, without limitation, our contractors, agents and representatives that provide services and products to us or through us, assist us in providing services to you, or assist us in maintaining and administering our business;
• our employees, agents, affiliates and others with whom we have a business relationship who have a need to know the information to fulfill their business responsibilities;
• your nominated representative;
• our professional service providers including accountants, financial advisors and attorneys;
• regulatory authorities (government and otherwise) and other organizations as authorized or required by law such as the police and/or credit card associations;
• analytics and search engine providers that facilitate the improvement and optimization of our Site; and
• a potential and/or actual purchaser of our business or any of our assets or in the event of our insolvency to third parties involved in the insolvency proceeding.

In some circumstances, your personal information may be transferred, disclosed, stored, processed or used across borders or overseas by us, our affiliates or by third party service providers. By providing your personal information to us, you consent to your information being transferred, disclosed, stored, processed or used across borders or overseas. Any information that you post to a community-based website, personal entry site, chat room, public bulletin, blog or forum is available to all users of that site. Origins Ecommerce cannot control, nor is it responsible for the use, disclosure, or dissemination of such information by any third parties. To request removal of your personal information from our blog or community forum, contact us using one of the methods set forth at the end of this Privacy Policy. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.  

VI. Securing Your Personal Data

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and when held on our computer systems, which may include, among other security mechanisms and technologies, encryption, physical access security, limited access servers, and other procedural security measures. We take reasonable precautions to protect the information that has been collected and to safeguard the servers where such information is stored. No method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information. Any transmission of personal information to us is at your own risk. Once we receive your personal information, we employ strict security features to try to prevent unauthorized access to your personal information. We store your personal information only as long as it is reasonably necessary after taking into account:

• the length and scope of our contractual relationship with you;
• the volume and type of your payment transaction activity;
• our anticipated need to respond to questions or demands from you, your representatives, our contractors, agents, representatives or affiliates, law enforcement, governmental authorities, or other entitled parties;
• our need to resolve problems; and
• our need to assess and improve our services and products.

Accordingly, we may retain your personal information for a reasonable time after you stop using our services and products, to the extent permitted by applicable law. If you have any questions about security on our Site, you can contact us using one of the methods set forth at the end of this Privacy Policy.  

VII. Third Party Websites

Our Site contains links to other websites. We are not responsible for the privacy policies of third party websites and your connection to and use of these websites is at your own risk. Origins Ecommerce is not responsible for, and makes no representations or warranties as to, their practices for dealing with your personal information. We recommend you review the privacy policy of any website at the beginning of your visit.

VIII. Social Media Widgets

Our Site may include Social Media Features, such as the Facebook Like button and Widgets like the Share this button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our 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 Site. Your interactions with these features are governed by the privacy policy of the company providing it.  

IX. Accessing and Updating Your Personal Information

In general, you are entitled to access your personal information that we are holding. You may request access by contacting us in writing using the email or physical address methods set forth at the end of this Privacy Policy. In the event you request access to your personal information, we will provide you with a description of your personal information we hold, advise you on why we are holding it, let you know who it could be disclosed to, and give you a copy of the information in intelligible form. In accordance with applicable law, there may be a charge from us for providing the above described access. Such charge will not be excessive. There may be legal or administrative reasons to deny you access to your personal information that we hold. If we refuse to provide you with the above-described access, we will advise you of the reason(s) where required by applicable law. To assist us in keeping your personal information accurate and up-to-date, we ask that you at all times provide us with complete, true, accurate and current personal information as requested and that you timely and properly update the information you have provided so as to keep it complete, true, accurate and current. If you believe your personal information we hold is incomplete, untrue, inaccurate or out-of-date, please contact us in writing using the email or physical address methods set forth at the end of this Privacy Policy and we will use reasonable efforts to correct the information. In your contact to us, please include as much detail as possible. This will allow us to promptly and properly respond.  

X. Policy Modifications

We may change this Privacy Policy at any time and without prior notice to you in order to reflect our practices and provide greater protection for your information. Any changes to this Privacy Policy will be posted promptly here, on the Origins Ecommerce Home Page, or in a prominent location or place that we deem appropriate so that you are aware of any changes to this Privacy Policy. Please check back periodically.  

XI. Acceptance of Terms

By accessing the Site and/or using the Origins Ecommerce Payment Services, you are consenting to the practices relating to information collection, storage and use practices that are described in this Privacy Policy.

XII. This Site is Not Intended for Persons Under the Age of 18

This Site is not intended for or directed at persons under the age of 18 (or the legal age of majority in your jurisdiction) and such minors’ use of the Site on their own is not permitted. Origins Ecommerce does not knowingly collect or maintain any personal information from children under the age of 13 and children under the age of 13 are not permitted to use the Payment Services. If you believe a child under the age of 13 has provided us with personal information, please contact us using one of the methods set forth at the end of this Privacy Policy. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it.  

XIII. Contact for Questions, Concerns and Complaints

If you have any questions, concerns or complaints about this Privacy Policy or our treatment of your personal information, you would like to opt out of the disclosure of your personal information for direct marketing purposes, you wish to access, correct or update your personal information, please contact us:

• by email at privacy@originsecommerce.com; or

We will investigate any concerns and complaints and will advise you of the outcome of our investigation.   Contact Us Origins Ecommerce. privacy@originsecommerce