Revised January 2007
 

Any time you visit a Web site, you may be providing information about yourself to the site’s owner or operator. We at Strategic Payment Systems, like you, value privacy, so we want you to learn what you need to know to protect your personal privacy. When you visit or supply information to any Web site, it's a good idea for you to first understand the site's privacy policies. If the site owner doesn't tell you, don't hesitate to ask. The bottom line at our Web site is that we use information that we get from your visit to enable you to participate in and take advantage of the various programs and features presented on the Strategic Payment Systems site, for our own internal analysis, and to make the Strategic Payment Systems site and our programs and features more useful and interesting to you. We do not use the information that we collect from the Strategic Payment Systems site for any other purpose, nor do we share it with any affiliate or third party, except as specifically noted and with agencies, vendors, partners, or affiliates under contract with Strategic Payment Systems.

Applicability of this privacy policy
This privacy policy applies only to the information that we collect on the Strategic Payment Systems site and not to any information that we collect through other methods or sources, including sites owned or operated by our affiliates, vendors, or partners.

When visiting Strategic Payment Systems Web sites for other countries or regions or other Web sites that are not owned or operated by Strategic Payment Systems, please review the privacy policy for those sites.

On this page
● Notice
● What information we collect and how we use it
● Browsing and the use of cookies, Web beacons, and logs
● Sweepstakes, contests, games, and surveys
● Email, mailing lists, and other services
● Affiliated businesses and links to other sites
● Our policy regarding selling or renting of personal information
● Agents
● Banners and other advertisements on Strategic Payment Systems
● Business transfers
● Disclosure of personal information for legal purposes and protection of Strategic Payment Systems and others
● Choice
● How you can decide what communication you'll receive from us
● Access and data retention
● How to update, correct, or delete your personal information
● Printable page
● Security
● How we protect the security of your personal information
● Customer service and recourse
● Changes to the Strategic Payment Systems privacy policy
● How to contact Strategic Payment Systems regarding your concerns and questions

Notice
What information we collect and how we use it
When you visit the Strategic Payment Systems site, we capture your Internet provider's domain name (e.g., 'aol.com') and your IP Address. Note: For users who access the Internet from an Internet Service Provider (ISP), the IP address will be different every time you log on. Strategic Payment Systems does not typically associate this information with any individual. We also capture the country from where the visit came, and the paths taken as you move from page to page (i.e., your "click
stream" activity).

Information we collect on the Strategic Payment Systems site may be used to enhance this Web site in ways like these:
● Arrange this Web site in the most user-friendly way
● Customize your browsing experience of this Web site
● Communicate special offers and featured items to you, if you choose to receive such notices
● Respond to your questions or suggestions
Strategic Payment Systems only collects personal information that you choose to provide voluntarily when using or registering with the
Strategic Payment Systems site. "Personal information" includes information that can identify you, such as:
● Name, address, phone number, email address, or company name
● Log-in information
● Social Security number or Federal Identification number
● Credit/debit card information

While you can browse our Web site without providing personal information, you will need to input certain personal information as indicated on specific pages of our Web site in order to take advantage of certain features, such as requesting updates on promotional offers or participating in special programs. Strategic Payment Systems may also on occasion ask you to voluntarily submit information about other people. For example, you might be asked for the name and/or email address of people you know so we can inform them about a sweepstakes, contest, or other promotion or program offered on the Strategic Payment Systems site, or otherwise in connection with any program that Strategic Payment Systems or its member financial institutions might offer.

Browsing and the use of cookies, Web beacons, and logs Strategic Payment Systems uses cookie technology as part of our Web site's statistical reporting. A cookie is a small piece of information sent by a Web site that is saved on your hard disk by your computer's browser. It holds information a site may need to personalize your experience (such as, rotating images on the home page of the Strategic Payment Systems site). Cookies are also used to gather Web site statistical data, such as which pages are visited, what is downloaded, the Internet provider's domain name and country of origin, and the addresses of sites visited immediately before, and after, coming to the Strategic Payment Systems site, as well as your “click stream” activity (meaning, the paths taken by visitors to our Web site as they move from page to page). None of this, however, is associated with you as an individual and is measured anonymously and only in aggregate, unless you have selected to opt-in to participate in an email program. An email program consists of you voluntarily registering your email address at the Strategic Payment Systems site to receive periodic emails from Strategic Payment Systems. Cookies do not capture your individual email address or any private information about you.

If you prefer, you can configure your browser to reject all cookies, or to notify you when a cookie is set. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie and privacy preferences.)

A Web beacon is an electronic image, also called a single-pixel or clear GIF, placed in the code of a Web page. The Strategic Payment Systems site uses Web beacons to track traffic patterns of users as they navigate from one page to another. This information lets us tune and improve our users’ browsing experience. As with cookies, the information that Web beacons collect is aggregated, anonymous “click stream” data, and is not associated with you as an individual, unless you have selected to opt-in to participate in an email program.

We may use third party advertising and media companies to serve ads on our behalf across the Internet and to help manage and optimize our Internet business and communications. Through the use of cookies and Action Tags (commonly referred to as Web beacons or GIF tags – e.g., Atlas cookies and Action Tags, Omniture tags, and Doubclick Web beacons), which are inserted in various places within our Web site, such third party companies may collect anonymous information about your visits to the Strategic Payment Systems site and your interaction with our ads and content. For instance, they may keep track of how many of our ads you had seen before visiting our Web site. These third party companies may share such anonymous information about your visits to this and other Web sites with us, and may use it in order to provide ads about goods and services of interest to you. From time to time, we may also hare anonymous information with such third party companies in an aggregate form, for purposes of analysis and improvement of our Web site. If you would like more information about the use of third-party cookies and tags, or the process of opting out of such cookies or tags, please go to http://www.atlassolutions.com/privacy.aspx, www.networkadvertising.org, and www.omniture.com/privacy/product#optout.

We also use standard Web server log files to help us count visitors and evaluate our Web site's technical capacity. This information tells us how many people visit the Strategic Payment Systems site, and helps us decide how to arrange pages in the most user-friendly way. It also helps us keep the site browser-friendly and more useful to our visitors. We record information on site traffic, but not on individual visitors to our Web site, so no personal information about you will be kept or used, unless you have selected to opt-in to participate in an email program.

Sweepstakes, contests, games, and surveys
From time to time, Strategic Payment Systems may conduct sweepstakes, contests, games or other promotions, and also conduct surveys through our Web site. If you choose to participate—unless otherwise noted in the applicable rules, terms and conditions, or disclaimers—we may use the information you provide in connection with the administration of the applicable promotion, including for selection and notification of sweepstakes or contest winners and for creation of new promotions, and/or to publish survey results in aggregate on the site. Except where necessary to administer a sweepstakes, contest, game or other promotion, or survey, unless you have otherwise agreed or unless required by law, we will not share or publish any response you give connected to your name or address. We will hold these responses only as anonymous statistics.

Email, mailing lists, and other services
When you send us an email, we use your email address to thank you for your comment and/or reply to your question. We store your communication and our reply in case we correspond further. Beyond our initial reply, we will not use your email address to send you any unsolicited message or information, nor will we share it with, or sell it to, anyone else for such use, other than as specified in this policy.
When you request information or services, we use your email address and any other information you give us to provide you with the information or services you’ve requested until you ask us to stop (by using the “unsubscribe” instructions provided on each email and/or the Web site where you signed up and/or as we otherwise provide), or until the information or service is no longer available. We will not use your email address or other information to provide you with any unsolicited message or information (unless the message or information is part of the service you are requesting).

Affiliated businesses and links to other sites
We work closely with our affiliated businesses, vendors and partners, many of which have links within the Strategic Payment Systems site. Please remember that when you use a link to go from the Strategic Payment Systems site to another Web site, this Privacy Policy no longer applies. Your browsing and interaction on any third party’s Web site, including any Web site that has a link on the Strategic Payment Systems site, is subject to the rules and policies of that Web site. We encourage you to read the rules and policies of the Web sites you visit to better understand their procedures for collecting, using, and disclosing personal information.

Our policy regarding selling or renting of personal information
Our policy is simple: we do not sell or rent your personal information to any third parties under any circumstances, except in the event of a bankruptcy or reorganization, or a sale of all or substantially all of our assets, as further provided below.

Agents
We may employ other companies and individuals to perform services on behalf of Strategic Payment Systems, such as (1) administering special reward or other programs affiliated with Strategic Payment Systems, or sweepstakes, contests and other promotions, (2) sending emails, (3) providing marketing assistance, and (4) analyzing data. Some of these companies and individuals will have access to the personal information necessary to perform their services, but will not be permitted to use it for any other purpose.

Banners and other advertisements on Strategic Payment Systems
The Strategic Payment Systems site displays banners and other advertisements that may be placed by third parties. Such advertisers may collect non-personal information (meaning, information that is not identifiable to any individual) when you click or scan one of their advertisements, by placing cookies on your computer or by using other technology. We encourage you to review the privacy policies of any such third parties. In addition, we may share aggregate information about our visitors to third-party ad servers or potential advertisers in order to provide advertisements on Strategic Payment Systems about products and services that may be of interest to you.

Business transfers
If a third party acquires all or substantially all of our assets, your personal information, aggregated information, and any other information that we have collected on the Strategic Payment Systems site may be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and may be sold or transferred to third parties. Disclosure of personal information for legal purposes and protection of Strategic Payment Systems and others We reserve the right to share your personal information with third parties if required to do so by law, or if we believe such action is necessary in order to: (1) conform to the requirements of the law or comply with legal process served upon us; (2) protect or defend our legal rights or property, the Strategic Payment Systems site, or our users; or (3) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of the terms and conditions for using the Strategic Payment Systems site.

Choice
How you can decide what communication you'll receive from us
If you choose to receive them, we may periodically send you email messages describing updates, new features, or promotional offers related to this Web site or otherwise related to Strategic Payment Systems or its member financial institutions. You can choose to stop receiving this email at any time. Simply follow the instructions included in your email, or send a reply stating your request.

If you do not explicitly choose to receive informational emails, the only email messages you will receive from Strategic Payment Systems will be a response to an email inquiry that you send us.

Access and data retention
How to update, correct, or delete your personal information
You can access and modify certain personal information stored on the Strategic Payment Systems site, such as your name, phone number, email address, and mailing address, by contacting us via email at info@spsinfo.com or via mail at the address set forth below in the "How to contact Strategic Payment Systems regarding your concerns and questions" section.

To modify or delete personal information related to an email program, simply follow the instructions included in your email, or send a reply stating your request, and we will make the requested changes. We retain information provided to us indefinitely unless otherwise stated. We will keep some personal information you have requested to remove for the following purposes:

● Troubleshoot problems
● Assist with investigations
● Enforce our Web site rules
● Comply with legal requirements

Therefore, you should not expect that all of your personal information will always be completely removed from our databases in response to your requests.

How we protect the security of your personal information
The security of your personal information is very important to us, and we are committed to protecting the information we collect. While we cannot guarantee absolute security of your personal information, Strategic Payment Systems uses firewalls and Secure Socket Layers for all personal data we collect from you. We also employ many different security techniques to protect personal data against loss, misuse, alteration, and unauthorized access.

Customer service and recourse
Changes to the Strategic Payment Systems privacy policy
This privacy policy was revised and posted on January, 2007. Strategic Payment Systems reserves the right to change, modify, or amend this policy at any time. Please also read over the Strategic Payment Systems site rules. Strategic Payment Systems takes privacy matters very seriously, and intends to stay at the forefront of privacy policy and protection matters. Strategic Payment Systems will occasionally update our privacy policy and we will post those updates on this page. You are responsible for revisiting this page to review our privacy policy updates.

How to contact Strategic Payment Systems regarding your concerns and questions
Please note that whenever you submit any information to us in connection with any services related to the Strategic Payment Systems site, you consent to let us process this information in the United States as necessary to provide the services in which you are participating.

If you have any questions, comments, criticisms, or complaints about Strategic Payment Systems's privacy policy and/or the way it affects you, please feel free to email us at info@spsinfo.com.

Strategic Payment Systems
Austin, Texas

Attention: Webmaster
Should you have a dispute regarding this privacy policy, we will resolve it and take any remedial action as we reasonably determine in our discretion and in accordance with applicable laws.