CardFlex Inc. dba Cliq (“Cliq”) is committed to protecting your personal information. We have prepared this Privacy Statement (“Statement”) so you can learn more about what information is collected about you, how it is used, and what choices you have in accessing or correcting it.
Note: This Statement is deemed effective as of May 25, 2018, and
contains important changes that may affect your rights.
The following tables summarize, at a very high level, the contents of our complete and unabridged Privacy Statement, which can be found in its entirety below. They are included for convenience only.
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
|What?||The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Cliq chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Cliq share?||Can you limit this sharing?|
|For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus||Yes||No|
|For our marketing purposes— to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||No||We do not share|
|For our affiliates’ everyday business purposes— information about your transactions and experiences||No||We do not share|
|For our affiliates’ everyday business purposes— information about your creditworthiness||No||We do not share|
|For our affiliates to market to you||No||We do not share|
|For non-affiliates to market to you||No||We do not share|
|Who we are|
|Who is providing this notice?||CardFlex Inc. dba “Cliq” (www.cliq.com)|
|What we do|
|How does Cliq protect my financial information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.|
|How does Cliq collect my financial information?||We collect your personal information, for example, when you:
We also collect your personal information from other companies.
|Why can’t I limit all sharing?||Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
|Affiliates||Companies related by common ownership or control. They can be financial and nonfinancial companies.|
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Cliq does not share with non-affiliates so they can market to you.
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Cliq does not jointly market bank products with other financial Companies.
|Other important information|
|If you are a resident of California or Vermont, we will not share with non-affiliates except for our own marketing purposes, our everyday business purposes, or with your consent. Nevada residents: We are providing this notice pursuant to Nevada law.|
1. SCOPE/APPLICATION: This Privacy Statement describes how we may collect, store, process and use any personal information or data (defined below) that you provide to us.
1.1 Coverage: This Statement covers your use of our services, products, technologies, website and marketing content (collectively referred to as our “Services”), which are primarily targeted towards U.S. residents (and green-card holders) over the age of 18. It may, in certain limited circumstances, also apply to individuals residing outside the United States (e.g. the European Union) if and to the extent that such persons voluntarily choose to utilize one or more of our products/services.
1.2 Consent: By using any Service, including without limitation, applying or signing up for an account, making use of our website or smartphone app, or conducting transactions via any card or instrument issued to you, you accept all terms outlined in this Privacy Statement without reservation, exception or alteration. You also expressly consent to the collection, use, disclosure, sharing, processing and retention of your personal information/data as permitted by applicable law or regulation. If you do not agree with the terms of this or any future Privacy Statement, or to our data collection and use policies in general, you should refrain from using our Services.
1.3 Personal Information” (aka “Personal Data”) Defined: Throughout this Statement, concepts such as “personal information” and “personal data” will often be used interchangeably, and shall include any information or data that is associated with, or can be used to identify, a specific individual person (aka a “data subject”). Further, “Personal Information” shall also include “Cardholder Data” and “Sensitive Authentication Data,” as such concepts are specifically defined under the most-current version of the Payment Card Industry Data Security Standard (“PCI-DSS”). Conversely, we do not consider information/data that has been “de-identified” to such extent that it can no longer reasonably identify any specific person to be “personal information” or “personal data.”
1.4 Changes to this Statement: We may make changes to this Statement from time-to-time to reflect changes in applicable laws or regulations, and changes to our business or our services. When any changes are made, we will post a revised version of this Statement and update the “Last revision” date provided below. Any changes will become effective when posted unless indicated otherwise. We encourage you to check our website regularly to ensure that you are aware of the latest updates, and whenever you use any of our Services. Your continued use of Services following an update will be treated as your acceptance of any revision or update up to and including the date of said use.
1.5 Supplemental Policies: In addition, this Statement may be supplemented by additional statements, policies or notices that may apply to one or more of your Services and, by extension, to you. Such additional statements, policies or notices are intended to be read together with, and incorporated by reference into, this Privacy Statement. One such Supplemental Policy covers our Prepaid card offerings, and is available by clicking here: https://www.cliq.com/wp-content/uploads/2016/08/Prepaid-Privacy-Notice-12-30-2014-11.pdf
1.6 Third-Party Websites: This Statement only applies to Cliq and persons or entities that it owns, manages or otherwise controls. Cliq does not and cannot speak for companies or people that it does not own or control, may contain links to other destinations on the Internet whose privacy practices may be different from Cliq’s, and that have varying scopes of coverage. If you disclose information to any other party, different terms may apply to their use and disclosure of information, and Cliq has no control over any information (personal or otherwise) that you submit to external sites. As such, you are encouraged to carefully review the privacy policies of each site you visit.
2. WHAT INFORMATION IS COLLECTED AND PROCESSED: Cliq® collects and processes various forms of personally-identifiable information when you register with Cliq and use its products or services. Some examples are as follows:
- Identifying details about you, such as your name, address, date of birth, social security or tax ID number, government-issued identification (such as a driver’s license or passport), email address and telephone number (collectively known as “profile data”);
- Information collected through one or more technical processes, such as the name of your Internet Service Provider (“ISP”), your Internet Protocol (“IP”) address, geolocation information, details on the type of Internet browser you are using (Chrome, Firefox, IE, Safari, etc.), the specific web page(s) you accessed from our site, and the Media Access Control (“MAC”) address of your computer, smartphone or other device (collectively known as “technical data”);
- Information you submit to us as part of an inquiry about our products and services (collectively “inquiry data”);
- Information concerning what products and services of ours you use, your current funds balance(s), and past account history (collectively, “account data”);
- Information on one or more specific transactions made via your account (collectively, “transaction data”).
- Information obtained via cookies and similar technologies, as described in greater detail below (“cookie data”); and
- Information about any communications, notices and professional interactions we have with you, whether by e-mail, telephone or otherwise (“correspondence data”).
3. LEGAL BASIS FOR SUCH COLLECTION AND USE: The use, collection and processing of personal data is done by obtaining user consent, as denoted above. We also have a number of legitimate business justifications for performing these activities that directly benefit users, such as processing customer transactions, accounting and reporting tasks, maintaining security, improving our products and services, and providing customer support. In addition, we may collect, use and process such information in order to comply with certain legal obligations, such as where a court, law enforcement agency or regulator asks us to do so.
4. HOW INFORMATION IS USED: Cliq uses personal information/data in relation to the manner in which you interact with Cliq. For example, Cliq uses personal information to, inter alia: (i) customize the content you see on our website, legal disclosures or other communications; (ii) fulfill your product or service requests; (iii) improve our products and services (or add new ones); (iv) process transactions; (v) open and close accounts; (vi) keep records; and (vii) other uses related to our product and service offerings. We do not sell or provide your personal information/data to third parties for any marketing or sales-related purposes. If such data/information is shared with a third party, it is for a specific purpose directly related to the handling or one or more transactions associated with your account, and done pursuant to a contractual agreement we have in place with said third party that provides a similar level of protection to your information/data as discussed here.
5. YOUR CHOICES: In most cases, you may access, change, or correct any of your profile data by simply logging into your account. If you are unable to access your account due to technical difficulties or otherwise, you may send a written request to us using the contact details below. Please include a list of the specific data item(s) you would like to have corrected or changed and a brief summary of the reasons for doing so. Be advised that we will take steps to confirm your identity before accessing, changing or correcting any of your personal data. Also, from time to time, if we send you notifications concerning updates and helpful information concerning our Services, our policies/procedures, or industry developments that may have a material effect on the foregoing, these messages will include a link or other method for “opting-out” of future messages, which you are free to do at any time.
6. INFORMATION SHARED WITH THIRD PARTIES: Cliq limits access to your personal information wherever possible to only those individuals or entities that we reasonably believe have a legitimate need to know the information. Cliq neither sells, rents, licenses, loans nor otherwise distributes any personally-identifiable information about any of its users to third parties for marketing or similar purposes. As discussed above, we may share certain personal data with third parties in order to:
- Comply with a valid subpoena, court order, investigative demand, discovery request, or other form of legal inquiry;
- Establish or exercise our rights or those of our affiliates;
- Defend ourselves or our affiliates against legal claims;
- Investigate or take action concerning any potentially unlawful activities, including the violation of any agreement we or our affiliates have with you;
- To rectify any potential threats to our safety, your safety, or the safety of others;
- Satisfy the requirements of any law or regulation;
- Effectuate a merger, acquisition, financing, transfer, or other form of ownership change involving all or any portion of Cliq’s stock or assets;
7. COOKIES: Cliq may set and access first-party “cookies” and similar preference-preservation items on your computer. We use this information to customize your visit to our website, and to help us see how the site is used. If you do not want cookies placed on your device, this can often be prevented by changing certain settings in your Internet browser. Please consult the pertinent “help” files or user documentation for assistance in this regard. Be advised, however, that certain aspects of our website and other Services may not be available or provide the same level of interactivity and customization if these tools are disabled.
8. CHILDREN’S PRIVACY: Except for certain limited very specific circumstances (which will be explicitly identified) Cliq does not direct or target any of it Services, including, without limitation, this website, at children under 13 years of age, and Cliq will not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian and feel that we have received or used any personal information concerning your child without proper consent, please notify us in writing via any of the methods listed below so that we may investigate and, if needed, take corrective measures.
9. SECURITY: Cliq takes I.T. security very seriously. We use commercially reasonable physical, electronic, and procedural safeguards to protect and limit access to our systems and information. Safeguards are implemented in accordance with all applicable laws and regulations, such as the Gramm-Leach-Bliley Act (“GLBA”) and PCI-DSS, and may include, without limitation, network firewalls, encryption, anti-virus software and procedures for controlling physical access to our facilities. In addition, our staff receives regular training in sound security practices and the proper handling of customer information. Please note, however, that no data transmission or storage system can be guaranteed to be 100% secure, and it is therefore important for you to take affirmative steps on our your own to help protect your personal information. For example, you should always use “strong” passwords, and never share them with anyone. You should also let us know immediately in writing if your personal information has been compromised in any way.
10. PCI-DSS COMPLIANCE: Cliq complies with the PCI-DSS as a “Level 1” merchant/agent. Proof of said compliance is available at: https://www.visa.com/splisting/searchGrsp.do or upon written request.
11. CALIFORNIA AND VERMONT RESIDENTS: These states permit residents additional controls over the use of their personal information. In particular, unless you specify otherwise in writing, we may share your personal information with companies we own or control, or that own or control us (our “affiliates”). If you are a resident of either California or Vermont, and do not want this information shared for any reason, please let us know in writing via the contact methods listed below. However, please be advised that such sharing may be necessary in order to provide you with our full complement of Services, and a limitation on such sharing could impact our ability to provide Services in the manner you desire.
12. E.U. RESIDENTS: Cliq’s products and services are primarily targeted toward citizens and residents of the United States. However, if and to the extent that a European resident or national makes use of one or more of said product/service offerings, and Cliq is required by law or other rule, including inter alia the EU General Data Protection Regulation (“GDPR”), to give data subjects any rights or options concerning their personal data that differ or exceed those discussed herein under U.S. law, we will, upon written request, take all commercially reasonable steps to enable these rights or options in accordance with said law or regulation.
- International Transfer Considerations: Cliq’s main corporate offices are located in Southern California. It also maintains an offsite data center in the greater Phoenix, AZ area. As such, the company does not transfer the personal data of any European users it may have out of the European Union. Typically, the only “onward transfer” of personal data concerning an EU resident would be done by the resident him/herself, whether completing an application, performing a transaction, or visiting his/her account management page. However, if you are an EU resident or national and have a good faith belief that the company, or any third party acting on its behalf or under its direction or control, has effectuated an onward transfer of your personal data to a location outside the EU without proper consent, please let us know by written request via any of the methods listed below.
13. CONTACT: Please feel free to contact us at any time with questions or concerns regarding this Statement or any of the topics discussed herein.
Mailing address: 2900 Bristol St., Building F, Costa Mesa, CA 92626, U.S.A.
Fax: 1(714) 862-1224
Note: Please put “PRIVACY INQUIRY” as the subject of your message.
Last revision date: May 21, 2018