you provide on this site.|
B. Information We Collect
C. Our Use and Disclosure of Information
D. Information Security
E. Accessing and Changing Your Information
F. Contacting Us
In order to offer some of Roleoh Pay ’s services and reduce fraud, Roleoh Pay (“Roleoh Pay ” or “we”) may ask you to provide us information
the information we collect and how we use that information. Roleoh Pay takes
the privacy of your personal information very seriously and will use your information
your personally identifiable information or a list of our customers to third parties.
However, as described in more detail in Part C below, there are limited circumstances
in which some of your information will be shared with third parties, under strict
Policy applies to all services that are hosted on the Roleoh Pay website,
whether Roleoh Pay (or its subsidiaries or its affiliates) offers the services.
our use and disclosure of your personal information in the manner described in
Your personal information will be stored and processed
on our computers in the United States. The laws on holding personal data in the
United States may be less stringent than the laws of your country, but Roleoh Pay will hold and transmit your personal information in a safe, confidential and secure environment.
If you object to your personal information being transferred or used as described
Notification of Changes
This policy may be revised over time as new
features are added to the Roleoh Pay service or as we incorporate suggestions from
our customers. If we are going to use or disclose your personally identifiable information
in a manner materially different from that stated at the time we collected the information,
you will have a choice as to whether or not we use or disclose your information in this new manner. Any
material changes will be effective only after we provide you by e-mail with at
Roleoh Pay account, you will not be contacted to notify you of the amended Policy and
your personal information will not be used or disclosed in this new manner).
review what information we gather, how we might use that information, and whether
we will disclose it to anyone. Please check the Roleoh Pay website at http://roleoh.com
Pages on the Roleoh Pay website may include links to third party websites. Roleoh Pay is
not responsible for their operations, including but not limited to their information
practices. Their privacy statements govern those sites. Users submitting information
to or through these third party websites should review the privacy statement of
these sites before providing them with personally identifiable information.
B. Information We Collect
To open a Roleoh Pay account, you must
provide your name, company name (if any), address, phone number, home page (if any),
and e-mail address. In order to make payments through Roleoh Pay , you must provide credit
card, debit card or bank account information. We may also ask you to choose different
security questions to answer. This required information may be necessary for us to
process transactions, issue a new password if you forget or lose your password, protect
you against credit card fraud and checking account fraud, and to contact you should
the need arise in administering your account.
In order to comply with the Bank Secrecy Act, we will also require your SSN or TIN
if you send or receive certain high-value transactions or high overall payment volumes
through Roleoh Pay . If you choose to register or apply for certain optional features
or products offered through the Roleoh Pay websites, you will be required to provide
additional information to establish that you qualify for such features or products.
When you use Roleoh Pay to send money
to someone else or request money from someone else, we ask you to provide information
related to each transaction, including the amount of the transaction and the
e-mail address of the third party. We retain this information for each of your
transactions through Roleoh Pay . We also collect the Internet address (IP address)
of the computer or device you use to access your Roleoh Pay account, in order to help
detect possible instances of unauthorized transactions.
Information About You From Third Parties
In order to protect all our customers
against potential fraud, we verify with third parties the information you provide.
In the course of such verification, we receive personally identifiable information
about you from such services. In particular, if you register a credit card or debit
card with Roleoh Pay , we may use card authorization and fraud screening services
to verify that your card information and address matches the information that you
supplied to Roleoh Pay , and that the card has not been reported as lost or stolen.
If you send or receive high overall payment volumes through Roleoh Pay , in some circumstances
we may conduct a background check on your business by obtaining information about
you and your business from a credit bureau or a business information service. If
you incur a debt to Roleoh Pay , we will generally conduct a credit check on you
by obtaining additional information about you from a credit bureau, to the extent
permitted by law. Roleoh Pay , at its sole discretion, also reserves the right periodically
to retrieve and review a business or consumer credit report for any account, and reserves
the right to close an account based on information obtained during this credit
If we cannot verify the information that
you provide, or if you request a withdrawal by check to an address other than your
verified credit card billing address, we may ask you to send us additional information
(such as your drivers’ license, credit card statement, and/or a recent
utility bill or other information linking you to the applicable address), or to
answer additional questions online to help verify your information.
Website Traffic Information
Because of the way that Internet communication
standards work, when you arrive at or leave the Roleoh Pay website, we automatically
receive the Internet address of the site that you came from or are going to. We
also collect information on which pages of our website you visit while you are
on the Roleoh Pay site, the type of browser you use and the times you access our website.
We may use this information only to try to understand our customers’ preferences
better and to manage the load on our servers, so as to improve our service and your
experience with Roleoh Pay . We do not track the websites that you visit before
or after you leave the Roleoh Pay site.
Our Use of “Cookies”
“Cookies” are small files
of data that reside on your computer and allow us to recognize you as a Roleoh Pay customer if you return to the Roleoh Pay site using the same computer and browser.
We send a “session cookie” to your computer if and when you log in
to your Roleoh Pay account by entering your e-mail address and password. These
cookies allow us to recognize you if you visit multiple pages in our site during
the same session, so that you don’t need to re-enter your password multiple
times. Once you log out or close your browser, these session cookies expire
and no longer have any effect.
We also use longer-lasting cookies to display your e-mail address on our sign-in form, so
that you don’t have to retype the e-mail address each time when you log
program, described in Section C below. We may share cookie information regarding
whether or not a certain user is already registered with Roleoh Pay with certain
merchants with whom we have an official co-marketing relationship.
Customer Service Correspondence
If you send us correspondence, we may
retain such information in the records of your account. We may also retain customer
service correspondence and other correspondence from Roleoh Pay to you. We may retain
these records in order to measure and improve our customer service, and to investigate
these records if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we may offer
optional questionnaires and surveys to our users for such purposes as collecting demographic
information or assessing users’ interests and needs. The use of the information
collected will be explained in detail in the survey itself. If we collect personally
identifiable information from our users in these questionnaires and surveys, the
users will be given notice of how the information will be used prior to their
participation in the survey or questionnaire.
Non-member Recipients and Requests
When a member either sends a payment to,
or requests a payment from, an individual who is not a registered member of Roleoh Pay ,
we will retain the information that the member submits to us, including, for example,
the other party’s email address and/or name, for the benefit of the member
who is attempting to contact the non-member, so that the member can see a complete
record of his or her transactions, including uncompleted transactions. Although this
information is stored indefinitely, we will not market to the non-member in any
way at any time. Additionally, these non-members have the same rights to access and correct
information about themselves (assuming that their email addresses were correct
enough to reach them) as anyone else who uses Roleoh Pay .
C. Our Use and Disclosure of Information
We collect, store and process your personal
information on servers located in the United States. We use the information
we collect about you in order to provide our services and process your transactions,
to provide customer service, to determine your eligibility to receive offers for
special features or products, and to improve our products and services. At your option
(as indicated in your Roleoh Pay user settings), we use the information you
provide to access specific third party services on your behalf and perform the
actions that you request us to perform.
We give access to individually identifiable information about our users only to those employees
who require it to fulfill customer service requests.
Disclosure to Other Roleoh Pay Customers
If you are a registered
Roleoh Pay user, your name, e-mail address, date of sign-up, and other information may be displayed
to other Roleoh Pay customers whom you have paid or who are attempting to pay you through
Roleoh Pay . Your credit card number, bank account and other financial information will never
be revealed to anyone whom you have paid or who has paid you through Roleoh Pay , except if we are
required to do so pursuant to a subpoena or other legal process.
If you are buying goods or services and paying through Roleoh Pay , the seller of the goods or
services may request that you provide a mailing address that Roleoh Pay has confirmed as matching
the billing address in the credit card system. You do not have to provide this information. If you
do not provide the information, however, the seller may choose not to accept your Roleoh Pay payment and not to complete the transaction.
Roleoh Pay may also disclose to other Roleoh Pay customers the number of payments you have
site), or other aggregate measures that provide an indication of your reputation with other
Roleoh Pay customers.
Disclosure to Third Parties Other Than Roleoh Pay Customers
Roleoh Pay will not sell or rent any of your personally identifiable information to third parties. Roleoh Pay will not share any of your personally identifiable information with third parties except in the limited
circumstances described below, or with your express permission (and to other Roleoh Pay customers as
described above). These third parties are limited by law or by contract from using the information for
secondary purposes beyond the purposes for which the information is shared. We share information with
companies that help us process the transactions you request and protect our customers’ transactions
from fraud, such as sharing your credit card number with a service that screens for lost and stolen card
numbers. See “Information About You From Third Parties” in Section B above. Additionally,
if you go into a negative balance and owe us money, we may share information with processing companies
including collection agencies.
We disclose the information we collect, as described in Section B above, to companies that perform
marketing services on our behalf or to other financial institutions with whom we have joint marketing
agreements. These companies may be subject to confidentiality agreements with us and other legal
restrictions that prohibit using the information except to market the specified Roleoh Pay -related
products or services, unless you have affirmatively agreed or given your prior permission for other
We disclose information that we in good faith believe is appropriate to cooperate in investigations
Specifically, this means that if we conduct a fraud investigation and conclude that one side has
engaged in deceptive practices, we can give that person or entity’s contact information
(but not bank account or credit card information) to victims who request it.
We disclose information in response to a subpoena, warrant, court order, levy, attachment,
order of a court-appointed receiver or other comparable legal process, including subpoenas
from private parties in a civil action.
If a user signs up for a co-branded version of Roleoh Pay through links on our co-branded
partner’s website, Roleoh Pay will share with the co-branded partner that user’s name,
e-mail address and physical address in order to provide enhanced integration between
Roleoh Pay ’s services and the services of our co-branded partner.
If a user does not want his or her information shared with Roleoh Pay ’s co-branded partner,
he or she should not use this aspect of the site.
We disclose information to your agent or legal representative (such as the holder of a power of attorney
that you grant, or a guardian appointed for you).
We share aggregated statistical data with our business partners or for public relations. For
example, we may disclose that a specific percentage of our users live in British Columbia.
However, this aggregated information is not tied to personally identifiable information.
As with any other business, it is possible that Roleoh Pay in the future could merge with
or be acquired by another company. If such an acquisition occurs, the successor company would have
access to the information maintained by Roleoh Pay , including customer account information,
Section A above.
We share your information with our parent, subsidiaries and joint ventures to help coordinate
the services we provide to you, enforce our terms and conditions, and promote trust and safety.
Our Contacts with Roleoh Pay Customers
We communicate with users on a regular
basis via e-mail to provide requested services, and we also communicate by phone to resolve customer
complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening
of a Roleoh Pay account, to send you notice of payments that you send or receive through
Roleoh Pay (including referral payments described below), to send information about important
changes to our products and services, and to send notices and other disclosures required by law.
Generally, users cannot opt out of these communications, but they will be primarily informational
in nature rather than promotional.
We also may use your e-mail address to send you other types of communications that you can control,
including tips, newsletters, customer surveys and notice of special third-party promotions. You can
choose whether to receive some, all or none of these communications when you complete the registration
process, or at any time thereafter, by logging in to your account on the Roleoh Pay website
and changing your user preferences. You can also change your choices at any time through the same
In connection with independent audits of our financial statements and operations, auditors may
seek to contact a sample of our customers to confirm that our records are accurate. However, these
auditors cannot use personally identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and
access times to analyze trends, administer the site, improve site performance and
gather broad demographic information for aggregate use.
Your Use of Information and Our Services
In order to facilitate the transactions
between Roleoh Pay members, our service allows you limited access other users’
contact information. As a seller you may have access to the User ID, email address
and other contact information of the purchaser, and as a purchaser you may have access
to the User ID, email address and other contact information of the seller.
identifiable information that you obtain through the site or through an Roleoh Pay -related
communication or Roleoh Pay -facilitated transaction, you will only use this information
for: (a) http://roleoh.com-related communications that are not unsolicited commercial messages,
(b) using services offered through Roleoh Pay , and (c) any other purpose that such user
expressly agrees to after adequate disclosure of the purpose(s).
In all cases, you must provide users with the opportunity to remove themselves from your database
and review any information you have collected about them. In addition, under no circumstances,
except as defined in this Section, can you disclose personally identifiable information
about another http://roleoh.com user to any third party without our consent and the consent
of such other user after adequate disclosure. Note that law enforcement personnel and
other rights holders are given different rights with respect to information they
http://roleoh.com does not tolerate unsolicited commercial e-mail or “spam.” Therefore,
without limiting the foregoing, you may not add a http://roleoh.com user to your mail
list (e-mail or physical mail) without their express consent after adequate disclosure,
even if said user has previously made a purchase from you. Our anti-spam policy
is strictly enforced. To report http://roleoh.com-related spam to http://roleoh.com, please contact us
D. Information Security
http://roleoh.com handles your customer information
with high standards of information security. We restrict access to your personally
identifiable information to employees who need to know that information in order
to provide products or services to you. We maintain physical, electronic and procedural
safeguards that comply with federal regulations to guard your nonpublic personal information.
The security of your http://roleoh.com account also relies on your protection of your http://roleoh.com
password. You should not share your http://roleoh.com password with anyone. http://roleoh.com representatives
will never ask you for your password, so any e-mail or other communication requesting
your password should be treated as unauthorized and suspicious. If you do share your http://roleoh.com
password with a third party for any reason, including because the third party has
promised to provide you additional services such as account aggregation, the third
party will have access to your account and your personal information, and you
may be responsible for actions taken using your password. If you believe someone
else has obtained access to your password, please change it immediately by logging
in to your account at http://roleoh.com and changing your user settings, and also
contact us right away as described in Section F below.
E. Accessing and Changing Your Information
You can review the personal information you provided us and make any desired changes to such
information, or to the settings for your http://roleoh.com account, at any time by logging
in to your account on the http://roleoh.com">http://roleoh.com website and changing your user preferences. You
can also close your account through the http://roleoh.com website. If you close your
http://roleoh.com account, we will mark your account in our database as “Closed,”
but will keep your account information in our database. This is necessary in
order to deter fraud, by ensuring that persons who try to commit fraud will not
be able to avoid detection simply by closing their account and opening a new account.
However, if you close your account, your personally identifiable information will
not be used by us for any further purposes, nor sold or shared with third parties,
except as necessary to prevent fraud and assist law enforcement, or as required
F. Contacting Us
If you have any questions about this privacy statement, http://roleoh.com’s information practices,
or your dealings with http://roleoh.com, you can contact us at roleoh.com Notification.