LEGAL

Last updated: November 15, 2015

1. Description of Services

• SecureExchange, LLC provides a network directory service (the “Network Directory”) to U.S. financial institutions who participate in the Network Directory (our “Network Banks”) to enable convenient transfers of money between their deposit account holders registered with their respective payment services (each, a “Network Bank Customer”) using email addresses or mobile phone numbers. SecureExchange provides a service for individuals who have no deposit account with our Network Banks to enable such SecureExchange.com Users (each “User”) to (a) receive money from a Network Bank Customer using the User’s email address or mobile phone number (the “Receive Services”); and (b) send money to a Network Bank Customer through an authorized debit transfer from the User’s deposit account after that User has either participated in the Receive Services or provided additional information required to send money (the “Send Services and, together with the Receive Services, the “Services”).
• SecureExchange provides no deposit account or other financial services. SecureExchange neither transfers, moves nor initiates the transfer or movement of money. You may not establish a financial account with SecureExchange of any kind and your agreement to be a User relates to your registration of an email address or mobile phone number as your profile identification in the Network Directory and your permission for SecureExchange to share your personal information (including your bank account number provided to SecureExchange) with our Network Banks for the purpose of completing money transfers between Network Bank Customers and you. Our Service to you as a User will be provided at all times subject to the terms and conditions of this Service Agreement.

2. Accepting this Service Agreement

You must have a U.S. checking or savings account to be a User and your financial institution must permit electronic funds transfers to and from that account. When you register to use the Network Directory and the Services or establish a profile on SecureExchange.com (the “Site(s)”) or access your profile on the Site or permit others to use or access the Services, you agree to the terms and conditions of this Service Agreement. You represent that you are at least 18 years of age, you have the authority to authorize debits and credits to the registered bank account, and you agree that you will not use the Services for any unlawful purpose. Subject to applicable law, we may amend or change this Service Agreement (including any applicable fees and service charges) from time to time, in our sole discretion, by posting the updated terms on the Site. Please access and review this Service Agreement regularly. If you find the Service Agreement unacceptable to you at any time, promptly cancel your profile and enrollment with SecureExchange and immediately discontinue your use of the Services. Your continued access of our Site or use of our Services after any amendment, modification or change to the terms and conditions of this Service Agreement shall constitute your agreement and acceptance to such amendment, modification or change.

You may register a profile with SecureExchange with multiple email addresses or mobile phone numbers; however, you may register one bank account only. You understand that you will be ineligible to register as a User with a bank account at a Network Bank.

3. Consent to Share Personal Information (Including Account Information)

By accepting this Service Agreement, you consent to our disclosure of your personal information (including bank account information) to our Network Banks or other third parties for the following purposes:

• As necessary for our Network Banks to complete money transfers between Network Bank Customers and you;
• As necessary to resolve a problem related to a transfer or payment between you and a Network Bank Customer;
• To verify the existence of your bank account for our Network Banks;
• To verify your identity for purposes of compliance with applicable laws, including without limitation the USA PATRIOT Act;
• To comply with inquiries in connection with fraud prevention or any investigation; For our general business purposes, including without limitation data analysis and audits; or
• As otherwise permitted by the terms of our Privacy and Information Security Notice.

Further, if you register an account at a financial institution and that financial institution later becomes a Network Bank, you authorize us to share relevant information about you and your account with that financial institution.

Except as otherwise provided above, SecureExchange will neither disclose nor share any of your personal information with our Network Banks, affiliates or any third party for purposes of marketing their or SecureExchange’s products or services to you.

4. Privacy and Information Security

SecureExchange will keep your information secure and confidential. You can access our Privacy and Information Security Notice on the “Privacy” tab at https://www.secureexchange.com/legal, which Privacy and Information Security Notice is incorporated into and made a part of this Service Agreement by this reference.

5. Registering Your Emails or Mobile Numbers; Consent to Email or Automated Text Messages

• To participate as a User, you must first register your email address or mobile phone number as a profile ID in the Network Directory. You must provide us with an email address that you regularly use and intend to use regularly (i.e., no disposable email addresses) and a permanent mobile phone number that you intend to use for an extended period of time (i.e., no “burner” numbers).
• You must register through the Site from your personal computer or a web-enabled tablet or mobile device.
• We require you to use an email address as your username for access and to establish a password that meets the security requirements described on our Site.
• At registration, we will collect information from you necessary to verify your identity, which we will do to protect ourselves from fraud and to comply with applicable laws. We reserve the right to deny your registration or request additional information from you if you do not provide us with this information, if we cannot verify your identity, or if we have concerns about fraud or security.
• We also may request additional information about you from time to time. We may cancel or suspend your registration or block a transaction if you do not provide us with this information, if we cannot verify your identity with the information you provide, or if we have concerns about fraud or security. Once registered, you may receive money from any Network Bank Customer at that customer’s initiation or authorize a debit of your account to send money to any Network Bank Customer at your initiation or in response to that Network Bank Customer’s request.
• By participating as a User, you represent to SecureExchange that you are the owner, or that you have the authority to act on behalf of the owner, of the email address or mobile phone number you register as a profile ID in the Network Directory. You consent to the receipt of emails or text messages from SecureExchange, a Network Bank or their agents regarding our Services or related transfers between our Network Banks and you. You agree that SecureExchange or its agents may use automatic telephone dialing systems in connection with text messages sent to any mobile phone number you register. You further acknowledge and agree:

• You are responsible for any fees or other charges that your wireless carrier may charge for any related data, text or other message services, including without limitation for short message service.
• You and SecureExchange are solely responsible for the content transmitted through the text messages sent to and from SecureExchange.
• In addition, in the case of any messages that you may send through SecureExchange or that SecureExchange may send on your behalf to an email address or mobile phone number, you represent to SecureExchange that you have obtained the consent of the recipient of such emails or automated text messages to send such emails or text messages to the recipient.
• To cancel text messaging from SecureExchange, send STOP to 31061. For help or information regarding text messaging, send HELP to 31061 or contact SecureExchange customer service at 866-839-3488 or +1 501-748-8506. You expressly consent to receipt of a text message to confirm your “STOP” request.

6. Consumer Reports

By using the Service, you authorize SecureExchange and the Network Bank that is processing a transfer between you and the Network Bank Customer, to obtain consumer reports about you from a consumer reporting agency. This information is used to process your registration, to verify your identity, to verify your bank account information and to protect against or prevent actual or potential fraud or unauthorized use. We reserve the right to decline your registration if we are unable to verify your identity or your bank account information.

7. Receiving Money; Money Transfers by Network Banks; Liability for Failed Transactions

All transfers of money to you shall be performed by a Network Bank per the direction of that Network Bank Customer and at all times subject to the terms and conditions of the relevant service agreement between that Network Bank and its customer, including without limitation any restrictions  or prohibitions on permissible transactions. Once a Network Bank Customer initiates a transfer of money to an email address or mobile phone number registered in the Network Directory, you have no ability to stop it. By using the Receive Service, you agree and authorize our Network Banks to initiate credit entries to the bank account you have registered with SecureExchange. Debits and credit entries to your account and the transmission and issuance of data related to such entries shall be processed pursuant to the terms of this Service Agreement and the rules of the National Automated Clearing House Association ("NACHA") and the applicable automated clearing house ("ACH Operator") (collectively, the "Rules") and you, we and the Network Banks agree to be bound by such Rules. Except as otherwise provided below in Section 11, SecureExchange shall have no liability to you for any such transfers of money by our Network Banks, including without limitation, (i) any failure by a Network Bank to complete a transaction to your bank account in the correct amount or (ii) any related losses or damages.

8. Sending Money; Debits by Network Banks; SecureExchange Liability

From time to time, you may send money to a Network Bank Customer in response to that customer’s request for money or at your initiation. By using the Send Service, you agree and authorize our Network Banks to initiate debit entries to the bank account you have registered with SecureExchange. You understand that use of such Send Service by you shall at all times be subject to (i) your express authorization at the time of the transaction for our Network Bank to initiate a debit entry to your bank account and (ii) the terms and conditions of your account agreement with your financial institution. You understand that in cases where a Network Bank Customer has the ability to manually accept or decline your payment, you have the ability to cancel a payment sent to the Network Bank Customer if cancelled prior to acceptance; however, once the payment has been accepted and in cases of automatic acceptance by a Network Bank, when you send the payment, you will have no ability to stop it. You acknowledge that neither SecureExchange nor our Network Banks has knowledge of any restrictions on transfers from your account and neither SecureExchange nor our Network Banks shall have any liability for your failure to comply with the terms and conditions of your account agreement with your financial institution.

9. Transaction Errors

If you have a question about a transfer that you received or expected to receive, then you should contact the sender first and attempt to resolve the issue. ALL QUESTIONS ABOUT TRANSFERS FACILITATED BY SECUREEXCHANGE SHOULD BE DIRECTED TO US AND NOT TO THE FINANCIAL INSTITUTION WHERE YOU HAVE YOUR ACCOUNT.

We will not send you a periodic statement listing transfers facilitated through SecureExchange. Those transfers will appear only on the statement issued by your financial institution. PLEASE RETAIN THE RECORDS FROM YOUR USE OF THE SERVICES AND CHECK THEM AGAINST THE STATEMENT YOU RECEIVE FROM YOUR FINANCIAL INSTITUTION.

In case of errors or questions about your transactions facilitated through SecureExchange, please contact us by telephone at 866-839-3488 or +1 501-748-8506 or by e-mail at TransactionError@SecureExchange.com as promptly as you can. You understand that SecureExchange hosts a centralized database of information to facilitate payments, but neither initiates nor processes electronic payments or transfers directly.

Please contact us immediately if:

• YOU BELIEVE THAT YOUR SECUREEXCHANGE PASSWORD HAS BEEN STOLEN OR COMPROMISED OR THAT SOMEONE USING THE SERVICES HAS TRANSFERRED OR MAY TRANSFER MONEY FROM YOUR BANK ACCOUNT WITHOUT YOUR PERMISSION.
• Your bank statement or transaction record reflects an error in a money transfer using the Services.
• You need more information about a money transfer using the Services.
• An unauthorized person has discovered your SecureExchange password and may divert money meant for you to their account.
• You believe that someone has transferred money to you using the Services but you did not receive it.

IF YOU BELIEVE THAT THE SERVICES HAVE BEEN USED TO MAKE AN UNAUTHORIZED WITHDRAWAL FROM YOUR ACCOUNT, THEN YOU SHOULD CONTACT YOUR FINANCIAL INSTITUTION IN ADDITION TO SECUREEXCHANGE. FAILURE TO NOTIFY YOUR FINANCIAL INSTITUTION DIRECTLY AND PROMPTLY MIGHT LIMIT YOUR RIGHTS UNDER YOUR ACCOUNT AGREEMENT AND APPLICABLE LAW.

10. Your Liability for Unauthorized Transfers

A. Consumer Accounts Only

Telephoning is the best way of keeping your possible losses down.

If you tell us verbally, we may require you to send us your complaint or question in writing at TransactionError@secureexchange.com within ten (10) business days. When you contact us, please provide the following information to the extent known:

• Your name and the email address or mobile phone number you registered with SecureExchange.
• The date and dollar amount of the transaction in question.
• If known, the name of the Network Bank Customer and the name of their bank.
• A description of the transaction about which you are unsure.

Please explain as clearly as you can why you believe there is an error or why you need more information.

We will work with the Network Bank that initiated the transfer to investigate your claim and we will determine whether an error occurred within ten (10) business days after we hear from you. Any error discovered as the result of the investigation will be promptly corrected. If more time is needed, up to forty-five (45) days may be taken to investigate your complaint or question. In this case, your consumer bank account will be credited within ten (10) business days for the amount you think is in error, so that you have the use of the money during the time it takes to complete the investigation. If you are asked to put your complaint or question in writing, and your letter is not received in ten (10) business days, your account may not be provisionally credited.

We will give you the results of our investigation within three (3) business days after completing the investigation. If the investigation concludes there was no error, you will receive a written explanation. In this case, any provisional credit made to your bank account may be reversed and you authorize our Network Banks to debit the bank account you have registered with SecureExchange. You may request copies of the documents that were used in the investigation.

B. Business Accounts Only

You agree to: 1) keep your password secure and strictly confidential, providing it only to authorized signers on your account(s); 2) instruct each person to whom you give your password that he or she is not to disclose it to any unauthorized person; and 3) immediately notify us and select a new password if you believe your password may have become known to an unauthorized person. We will have no liability to you for any unauthorized payment or transfer made using your password that occurs before you have notified us of possible unauthorized use and we have had a reasonable opportunity to act on that notice. We may suspend or cancel your password even without receiving such notice from you, if we suspect your password is being used in an unauthorized or fraudulent manner.

We will have no liability to you for any errors or losses you sustain in using the Service except where we fail to exercise ordinary care in processing any transaction. Our liability in any case will be limited to the amount of any funds improperly transferred from your account less any amount which, even with the exercise of ordinary care, would have been lost.

Without regard to care or lack of care of either you or us, a failure on your part to report to us any unauthorized transfer or error from your account within thirty (30) days of your receipt of a bank statement showing such unauthorized transfer or error shall relieve us of any liability for any losses sustained after the expiration of such thirty-day period and you shall thereafter be precluded from asserting any such claim or error.

11. Liability for Failure to Complete Transfers: Consumer Accounts Only

If a transfer to or from your deposit account in the correct amount or according to our agreement with you is not completed, we will be liable for those damages as the law imposes in such cases. However, there are some exceptions, and SecureExchange and its Network Banks have no liability for your losses or damages:

• If, through no fault of ours, the sender does not properly complete the transfer to your account.
• If, through no fault of ours, your account does not contain sufficient funds to make the transfer and the transfer would exceed any credit line or any overdraft protection for such account.
• If our Services or Network Bank’s services weren't working properly, and the sender knew about the malfunction when the sender initiated the transfer.
• If the financial institution holding your account mishandles or delays processing or posting a transfer facilitated by the Services.
• If circumstances beyond our control (such as fire or flood) prevented the transaction or transfer, despite reasonable precautions we've taken.

The list of examples set out in this paragraph is meant to illustrate circumstances under which we would not be liable for a transfer not being completed and is not intended to list all of the circumstances where we would not be liable.

12. Notification of Change

Your financial institution may send a Notification of Change (“NOC”) to a Network Bank to indicate that your account information contained in an ACH entry is erroneous and needs to be changed. With respect to you sending or receiving payments through the Services, our Network Banks will share any NOC messages from your financial institution with SecureExchange. You agree that SecureExchange may correct your account information in our User database promptly upon receipt of that NOC notification without further notice to you.

13. Fees

SecureExchange charges no fees for your use of our Services to complete transfers between our Network Banks and you. However, SecureExchange reserves the right to charge a fee in the future for any current Services, and SecureExchange may develop new uses or other services for Users and a fee may apply for such other uses or services. You will be notified in advance of any fees in accordance with Section 2 above. Fees, when applicable, will be displayed prior to each use of Services. Please note that SecureExchange has no responsibility for any fees that your financial institution or your mobile carrier may charge you in connection with your transactions through SecureExchange.

14. Limitations on Transfers: Send Limits

Our Network Banks may impose limitations on transfers between their customers and you. Such limitations remain subject to the terms and conditions of the respective service agreements of our Network Banks with their customers.

We will limit the amounts you can send to a Network Bank customer using the Services (i) to $1,000 per calendar day, (ii) to $2,500 per rolling 7-day period and (iii) to $10,000 per rolling 30-day period. Such limits remain subject to change in the discretion of SecureExchange. In the event that your transfer exceeds a limit, you will be informed of the allowable amount you can transfer at that time.

15. Use of Our Site

You agree to access our Site in compliance with our Terms of Use, which are available on the “Terms of Use” tab on the Site at: https://www.SecureExchange.com/legal and incorporated into and made part of this Service Agreement by this reference.

16. Cancellation

You may cancel your use of the Services at any time by notifying us of your intent to cancel by calling us at 866-839-3488 or +1 501-748-8506. Canceling your use of the Services means SecureExchange will inactivate your access to our Site, as well as your profile ID in the Network Directory. At the time you instruct SecureExchange to cancel your use of the Services, any transfers in process using the Services will be completed to or from your bank account that was associated with your profile ID, but no new transfers will be initiated to or from that bank account through SecureExchange. You must re-enroll with SecureExchange, or enroll with a P2P service at one of the Network Banks to receive any subsequent payments that a Network Bank customer sends to you after you cancel your use of the Service.

17. SecureExchange Right to Terminate Access

Subject to applicable law, SecureExchange may terminate or suspend this Service Agreement and your use of our Site and our Services, in whole or in part, at any time for any reason without cause and without prior notice. Any obligations or liabilities incurred by you prior to the date of termination shall survive the termination of this Service Agreement.

You understand that at any time during the term of this Service Agreement your financial institution may become a Network Bank and you may become ineligible to continue as a User. Subject to the  terms and conditions of an agreement between SecureExchange and your financial institution, we will provide you notice and further instructions relating to the termination of this Service Agreement, access to our Site and our Services and instructions on how to enroll with your financial institution for similar services.

18. Disclaimer of Warranties

EXCEPT AS OTHERWISE PROVIDED HEREIN, AND SUBJECT TO APPLICABLE LAW, SECUREEXCHANGE MAKES NO EXPRESS OR IMPLIED WARRANTIES, REPRESENTATIONS OR ENDORSEMENTS WHATSOEVER WITH RESPECT TO OUR PRODUCTS OR SERVICES ON THIS WEBSITE. WE EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT, WITH REGARD TO ANY PRODUCT OR SERVICE DESCRIBED OR PROVIDED. SECUREEXCHANGE DOES NOT WARRANT THAT OUR PRODUCTS OR SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE, OR THAT DEFECTS WILL BE CORRECTED. THE SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.

19. Limitation of Liability

EXCEPT AS OTHERWISE PROVIDED HEREIN AND SUBJECT TO APPLICABLE LAW, IN NO EVENT WILL SECUREEXCHANGE, ITS OWNERS, DIRECTORS, OFFICERS, AGENTS OR MEMBER BANKS BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING, BUT NOT LIMITED TO ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY OR OTHER INDIRECT DAMAGES ARISING OUT OF (I) ANY TRANSACTION CONDUCTED THROUGH OR FACILITATED BY OUR SERVICE; (II) ANY CLAIM ATTRIBUTABLE TO ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE PRODUCTS OR SERVICES DESCRIBED OR PROVIDED, (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, OR (IV) ANY OTHER MATTER RELATING TO THE PRODUCTS OR SERVICES DESCRIBED OR PROVIDED, EVEN IF SECUREEXCHANGE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOU ARE DISSATISFIED WITH OUR SERVICE OR WITH THE TERMS OF THIS SERVICE AGREEMENT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE SERVICES.

IN THOSE STATES WHERE THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES MAY NOT APPLY, ANY LIABILITY OF SECUREEXCHANGE, ITS OWNERS, DIRECTORS, OFFICERS AND AGENTS LIABILITY IN THOSE STATES IS LIMITED AND WARRANTIES ARE EXCLUDED TO THE GREATEST EXTENT PERMITTED BY LAW, BUT SHALL, IN NO EVENT, EXCEED $100.00.

20. Indemnification

You acknowledge and agree that you are personally responsible for your conduct while using our Site and our Services and agree to indemnify, defend and hold harmless SecureExchange, its owners, directors, officers, agents and Network Banks from and against all claims, losses, expenses, damages and costs (including, but not limited to, direct, incidental, consequential, exemplary and indirect damages), and reasonable attorneys’ fees, resulting from or arising out of your use, misuse, or inability to use the Services, or any violation by you of the terms of this Service Agreement.

21. Governing Law; Choice of Law; Severability

This Service Agreement will be governed by and construed under the laws of the State of Delaware, excluding only its conflict of law provisions, and shall inure to the benefit of our successors and assigns, whether by merger, consolidation or otherwise. By using the Site, you hereby submit to the exclusive jurisdiction of the courts within the State of Delaware, and waive any jurisdictional venue or inconvenient forum objections to such courts. You further agree to comply with any applicable federal, state and local laws in your use of the Services. If any provision of this Service Agreement is found to be unenforceable for any reason by a court of competent jurisdiction, that provision will be deemed to be restated to reflect as nearly as possible the original intentions of the parties in accordance with applicable law. The remaining provisions of this Service Agreement will not be affected thereby, and each of those provisions will be valid and enforceable to the full extent permitted by law.

22. Miscellaneous

The Services are available 24 hours, seven days a week with the exception of outages for maintenance. Live customer service generally will be available Monday through Friday, excluding US bank holidays. Please consult our Site for exact customer service hours.

Last updated: November 15, 2015

YOU MUST AGREE TO THIS E-SIGN CONSENT TO REGISTER FOR THE SECUREEXCHANGE SERVICES.

This E-sign Disclosure and Consent (“E-sign Consent”) applies to all Records and Communications for SecureExchange.com Services. “Records and Communications” means the SecureExchange.com User Service Agreement (the “Service Agreement”) between you and SecureExchange for the SecureExchange services described in the Service Agreement as well as any modification or amendments thereto; any policies, notices or disclosures; and all other information that we may be required to provide to you in writing by law.

Last updated: November 15, 2015

This Privacy and Information Security Notice (“Notice”) describes how SecureExchange, LLC collects, uses, shares, and protects information from or about visitors to our website at www.SecureExchange.com (“the Site”) and individuals who register on the Site to receive our services. Please read this Notice carefully and consider printing a copy for your records.

SecureExchange provides U.S. financial institutions who are SecureExchange customers (our “Network Banks”) a network directory service to enable convenient transfers of money between their respective account holders using email addresses or mobile phone numbers. SecureExchange also provides an out-of-network service for individuals who have no deposit account with our Network Banks to enable such SecureExchange.com Users (each “User”) to send and receive money to and from a Network Bank and its customers using the User’s email address or mobile phone number (the “Services”).

By using our Site, you agree to the terms and conditions of this Notice that can be found in the “Service Agreement” tab at: https://www.SecureExchange.com/legal.

Personal Information We Collect

“Personal Information” means personally identifiable information such as your name, date of birth, postal or email addresses, telephone, mobile numbers, and financial account numbers.

We collect Personal Information from you when you register as a User or when you update your information through our Site. We may also collect Personal Information from our Network Banks if they receive a notification that your bank account information in our database is inaccurate and needs to be changed. In addition, we may collect Personal Information from consumer reporting agencies in order to process your registration, verify your identity, verify your bank account information and protect against or prevent actual or potential fraud or unauthorized use.

How We Use Personal Information

If you register as a User, we may use your Personal Information:

• to enable our Network Banks to complete money transfers between their customers and you;
• to send you an email or text message to notify you of a pending money transfer or request for payment;
• to verify changes you have made to your Personal Information;
• to facilitate your registration on our Site and to resolve issues relating to your SecureExchange registration;
• to resolve a problem related to a transaction with our Network Banks;
• to verify the existence of your bank account;
• to verify your identity;
• in connection with fraud prevention or any investigation;
• to send you information;
• for our general business purposes, including but not limited to data analysis, audits, developing new products, enhancing our Site, identifying usage trends, and improving our services; and
• as relevant if you register an account at a financial institution and that financial institution later becomes a Network Bank, you authorize us to share relevant information about you and your account with that financial institution.

How We Share Personal Information

We may share Personal Information of Users with Network Banks, affiliates, and other third parties (such as vendors or service providers) for the purposes described above under “How We Use Personal Information.” We require any service provider with whom we share Personal Information to protect the confidentiality of such information and use it solely for the purposes for which it was shared. SecureExchange will neither disclose nor share any of your Personal Information with our Network Banks, affiliates or any third party for purposes of marketing their or SecureExchange’s products or services to you.

How We Collect and Use Other Information

“Other Information” is any information other than Personal Information that does not reveal your specific identity or does not directly relate to an individual, such as information transmitted by your browser or information collected through cookies, pixel tags and other online technologies (as described below).

We and our third-party service providers may automatically collect such information from visitors to our Site, including individuals who do not register as Users, in a variety of ways, including:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version.
• Using cookies: Cookies are pieces of information stored directly on the device you are using. Cookies we use do not contain or capture unencrypted Personal Information. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. You can refuse to accept these cookies and most devices and browsers offer their own privacy settings for cookies. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept these cookies, you may not be able to access or use all or parts of our Site.
• Using pixel tags, web beacons, clear GIFs, JavaScript or other technologies: These are online technologies that function similarly to cookies and help us track activities on our Site and to count users who open our HTML-formatted email messages.
• Using your IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many web sites.

How We Use Other Information

We may use Other Information for a number of purposes, including:

• to ensure that our Site functions properly, to continually improve the design and functionality of our Site, to understand how customers use the Site, and to assist us with resolving questions regarding the Site;
• to facilitate Site navigation, to display information more effectively, to personalize your experience while visiting the Site, and to recognize your device to allow your use of our online services;
• to measure the effectiveness of our communications and the success of our marketing campaigns, and;
• for security purposes.

SecureExchange may also create or compile aggregated and de-identified data, which is data that is derived from various sources, including accounts and transactions. This information, which does not identify individuals, is used by SecureExchange for its business purposes, which may include offering services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws.

Links to Other Sites

We may provide links to non-SecureExchange websites, such as those of Network Banks or other third parties. If you follow links to websites not controlled by SecureExchange, you should review their privacy policies and other terms, as they may be different from those of our Site. SecureExchange does not guarantee and is not responsible for the privacy or security of these websites, including the accuracy, completeness, reliability or suitability of their information.

How We Protect your Personal Information

We use reasonable security measures to protect your Personal Information from unauthorized access and use. These measures include computer safeguards and secured files and buildings. We restrict access to Personal Information to our employees and service providers who need to know such information to provide you with the Services.

Maintaining the Accuracy of your Information

Keeping your SecureExchange profile information, including your bank account, personal information, and email addresses/mobile numbers, accurate and up-to-date is very important. If your SecureExchange profile information is incomplete, inaccurate or not current, please update your information by logging in to your SecureExchange profile https://www.SecureExchange.com/login.

Contacting Us

If you have any questions regarding this Notice, refer to the latest customer service hours at https://www.SecureExchange.com/contact-us and contact us at:

1-866-839-3488 or +1 501-748-8506

UPDATES TO THIS NOTICE

This Notice is subject to change. Please review it periodically. If we make changes to this Notice, we will revise the “Last Updated” date at the top of this Notice. Any changes to this Notice will become effective when we post the revised Notice on the Site. Your use of the Site following these changes means that you accept the revised Notice.