The Clareon
division of Fleet National Bank ("Clareon")
is committed to safeguarding information about our
customers ("Clients") that it collects. Please read
the following practices to understand how information
we collect from our Clients will be collected, used
and disclosed. These practices apply to www.fleet.paymode.com
and all other Web sites owned and
operated by Clareon. They apply to products and services
provided by Clareon in the United States, used primarily
for business purposes (not for personal, family or
household purposes). We reserve the right to change
these practices from time to time. Changes will be
posted to our Web site. Clients may review updates
to these Privacy Practices at any time via links
on our Web site.
These
Practices cover the following topics:
What
information does Clareon collect?
During the Client enrollment process, Clareon
asks its prospective Clients and their authorized
representatives ("Representatives")
for certain identifiable information, including
name, work address, e-mail address, employer
identification number, bank account information, the names of principal Representatives
who will work with Clareon, and any other information we need in order to
provide the PayMode service to you. Clients and their Representatives who
communicate with Clareon are assigned PayMode account identifier(s) and digital
signature certificates that are used to identify the Client and the Representative
when he or she is using the PayMode service.
Clareon
does not collect names, postal or e-mail addresses,
and phone numbers of non-Client visitors to Clareon's
Web site for future calls and mailings, except
to complete pending enrollment applications or
to respond to inquiries. In order to increase
the utility of the PayMode service to all Network
members, we may use information provided by a
Network member about its trading partners for
the sole purpose of soliciting the enrollment
of such trading partners to become, and enrolling
them as, members of the PayMode system.
Clareon
also collects information necessary to process
payment transactions for its Clients, including
the amount of the Client's digital payment authorization
("DPA"), the recipient, the bank accounts
to be debited and credited and remittance information
necessary to allow correct crediting of the DPA.
Clareon may retain copies of any
communications we send
to or receive from Clients and other visitors
to our site for our records.
How
does Clareon use the information it collects?
Clareon authenticates and verifies the identity
of prospective Clients and the Representatives of those Clients
who are communicating with Clareon. Clareon may also conduct
credit checks on companies and other organizations that apply
for the PayMode service. Clareon will use the information
it collects during the enrollment process, and other information
it collects through the authentication process, to evaluate
the Client's enrollment application and to conduct continuing
security assurance and monitoring, and risk assessment. Clareon
may use personally identifiable information about a Client's
Representatives collected in the authentication and investigation
process as necessary to complete the authentication process
(for example, we may call the Human Resources Department
of a Client to verify that an individual Representative communicating
with us is, in fact, employed by or otherwise authorized
to represent the Client).
Clareon
uses information it collects from Clients in connection
with specific payment
transactions to complete the specific transactions.
Clareon may also use such information to analyze
the business Clients conduct with Clareon, to determine
how Clients are using the PayMode service, and to
make improvements to our service and our Web site
to better meet our Clients' needs. We also use such
information to bill Clients for their use of our
services and to monitor their compliance with the
Terms of Use Agreement and the rules, policies,
and practices of the PayMode service.
Clareon also
does research on its Clients' demographics, interests
and behavior
based on the information provided to us during
the enrollment process, in connection with specific
transactions,
from our server log files or from surveys. We do
this to better understand and serve our Clients.
This research is compiled and analyzed on an aggregated
basis. Clareon may share this aggregated data with
its business partners. However, aggregated information
is not identified with any particular Client or
any particular Client's Representative. Information
about
a specific Client or a Client's Representative
will not be disclosed to a third party without the
Client's
express authorization, except in the circumstances
described below. Clareon may access enrollment
and transaction information for administrative and
other
purposes that we deem necessary to maintain, service
and improve our products and services.
Clareon may use information about a Client or its
Representatives within Clareon and Fleet National
Bank in order to identify ways to better serve Clients
and their Representatives and to offer additional
products and services to Clients and their Representatives.
How
can Clients access, update or delete information
collected by Clareon?
Upon request by postal mail or e-mail, Clareon
will provide to Clients a summary of any Client information
retained by Clareon regarding the Client. Clients may correct,
change or update their company records and information about
their Representatives through online access and account maintenance
by the Client's PayMode Membership Administrator. Clients
can update e-mail addresses by contacting customersupport@fleet.paymode.com and
should update or correct inaccurate or incomplete enrollment
or account information by accessing the PayMode secure site.
With
whom does Clareon share the information it
collects?
Clareon and its authorized representatives
have access to information about Clareon's Clients and their
Representatives. Clareon company policy requires each authorized
representative to agree to keep all such information confidential.
As a general rule, Clareon will
not disclose, sell, rent, license, exchange or release
any information about its Clients or their Representatives
(such as names, e-mail addresses or other enrollment
or transaction information) to a third party except
when we have permission or under special circumstances,
such as when we believe in good faith that the
law
requires it or under the circumstances described
below. We will disclose information such as bank
account numbers to participants in the banking
system who process DPAs. Each Client's DPAs will
contain
certain remittance information that we disclose
to the payee(s) per the Client's instructions.
Clareon
may disclose information about Clients or their
Representatives in special
cases when we have reason to believe that disclosing
this information is necessary to identify, contact
or bring legal action against someone who may be
violating a Clareon Terms
of Use Agreement or may be causing injury
to or interference (either intentionally or unintentionally)
with Clareon rights or property, other Clareon
Clients, or anyone else who could be harmed by such
activities.
Clareon may disclose information when we believe
in good faith that the law requires it.
We may share
aggregated information about our Clients and/or
their Representatives with
market analysts, advertisers, business partners,
sponsors, our affiliates and any other third parties
(in which case the information will not be identified
with any particular Client or Representative).
From time to time, Clareon may retain the services
of
third-party technical service providers and consultants.
We may allow these third parties to access information
about Clients and their Representatives, but only
to the extent required to perform the tasks we
retain them to perform. Clareon's practice is to
require
such third parties to agree to maintain the confidentiality
of such information in compliance with the terms
of these Privacy Practices.
Does
Clareon use cookies?
Clareon may use Internet address information
to help diagnose problems with our server, to track Client
traffic patterns and to administer the PayMode system. This
may be done through the use of a standard feature of browser
software called a "cookie" to assign each visitor
a unique, random number. A cookie is a file that identifies
a Client's computer as a unique user. Most browsers are initially
set up to accept cookies. Clients may be able to reset their
browsers to refuse all cookies or to indicate when a cookie
is being sent. If Clients disable cookies, however, they
may find Clareon's Web site, and many other Web sites, harder
to use. Our site may use cookies to recognize each Client
as a PayMode Member, and to help keep track of what each
Client does on the site. A cookie cannot read data off the
hard drive of a Client's computer. Clareon's practice is
not to accept cookies from third parties unless Clareon is
jointly offering a product or service with that third party.
Clareon will not put sensitive customer information in the
cookies that it may use.
What
choices regarding collection, use and distribution
of information are available?
By accepting the terms of the Terms
of Use Agreement and becoming a Client, each Client
agrees that Clareon may collect certain information (as detailed
in these Privacy Practices) from and about the Client to
authenticate the Client and its Representatives and enroll
the Client as a member of the PayMode service. If a prospective
Client does not agree to these Privacy Practices, it may
not become a Client.
Clareon
may, from time to time, send Clients e-mail regarding
our products and services.
In addition, if we offer a Client during enrollment—and
the Client accepts—the opportunity to receive
offers and information from Clareon and its partners,
we may occasionally send the Client information
about products and services that we believe may
be of interest
to the Client. Only Clareon (or agents working
on behalf of Clareon) will send such information.
However,
if Clareon offers Clients such an opportunity we
will offer an opt-out option so that Clients will
not receive such information if they do not want
to do so.
When
might authorized representatives of Clareon
contact Clients?
Clareon reserves the right to contact Clients
regarding account status and changes to the Terms
of Use Agreement, Operating Rules, these Privacy Practices,
or any other policies, practices, or agreements relevant
to Clients. Clareon may also contact Clients whenever they
or their Representatives use the PayMode service as either
a Disburser or a Collector.
What
about children's privacy?
Clareon provides only business services and
does not intend to collect any information from children.
It is possible that a child impersonating a business applicant
may send Clareon the child's name, e-mail address and address.
When such personally identifying information is received,
it is used only to reject the child's request to join the
PayMode service and is never shared with third parties. Clareon
cannot always determine if a visitor to its Web site or the
sender of an e-mail is a child.
What
security precautions are in place to protect
the loss, misuse or alteration of information?
A Client's communications with us through our
Web site will be through a secure Web site. We also maintain
extensive information security within our own network. Thus,
while no encryption and system security are impregnable,
there are substantial security protections involved in using
the PayMode service.
These Privacy Practices cover
exchanges of information within the Clareon site.
The Clareon site may contain links to other sites
but Clareon is not responsible for the privacy practices
or the content of such sites. Please be sure to check
the privacy practices of each site you access through
Clareon, as they may differ.
What
if a Client does not agree to these Privacy
Practices?
If
a prospective Client does not agree to these Privacy Practices,
it may not become a Client. By accepting the terms of the
Terms of Use Agreement and becoming
a Client, each Client shall be deemed to have consented to
the collection, use and disclosure of information as described
in these Privacy Practices.
How
can Clareon make changes to these Privacy Practices?
Clareon may change its policies and practices
(including these Privacy Practices) at any time. If we decide
to change these Privacy Practices, we will post the changes
to this page and in a prominent place on our Web site so
that Clients may be aware of such changes. Any change to
these Privacy Practices will become effective ten (10) days
after it is initially posted on our Web site. A Client's
continued use of Clareon services following such ten (10)
day period will mean that the Client accepts such changes,
which shall also bind its Representatives. If a Client does
not agree to any such change, it must terminate its Terms
of Use Agreement.
How
can Clients and others contact Clareon?
If you have any questions about these Privacy
Practices or our information collection, use and disclosure
practices you can contact:
Customer
Support
Clareon Corporation
15 Casco Street
Portland, Maine 04101
877-443-6944
customersupport@fleet.paymode.com
Version 1.3 (09-24-03)
