KEEPS America is committed to maintaining the confidentiality of your personal financial information in accordance with our established policies and in compliance with applicable law. This document outlines the manner in which we collect, use and maintain the nonpublic personal information we receive regarding you.
2. Our Collection and Use of Information About You. We collect nonpublic personal information about you in order to administer our business, process your transactions, understand your needs, and provide you, directly or through affiliates or third parties, with products and services. We obtain nonpublic personal information about you from the following sources:
3. Our Disclosure of Information. We may disclose all of the information we collect, as described above, to companies (including affiliates) that perform services on our behalf, including those who assist us in preparing and distributing cardholder communications, and responding to customer inquiries. We will also disclose information about your card, membership, and transactions: (a) to service your account; (b) where it is necessary or helpful to effect, process, confirm or enforce a transaction you request or your membership rights and obligations; (c) to verify the existence and availability of funds associated with your card; (d) to comply with legal process, such as subpoenas and court orders; (e) to law enforcement authorities if we believe a crime has been committed; (f) to our agents, service providers and auditors, and (g) if you give us your consent. We may also disclose non-public personal information about you as permitted by law.
4. Other Disclosures. We may enter into arrangements with affiliated and/or non-affiliated parties, such as financial service providers, lenders, insurance providers and agencies, card issuers, retailers and direct marketers, in order to provide you, directly or through third party relationships such affiliated and/or non-affiliated parties may have, with special offers that we believe may be of value to you. We may disclose contact information to those parties who may want to offer their products and services to you, unless you opt-out as described below.
5. Use of Agents. We may use an outside shipping company to fulfill orders, and a card processing company to bill you for goods and services. These companies do not retain, share, store or use personally identifiable information for any other purposes.
6. Use of Service Providers. We use other third parties to provide statistical tracking and advertising effectiveness for our web site. When you sign up for KEEPS Card services, we may share information such as your name and address and other information as necessary for the third party to provide that service. These third parties are prohibited from using your personally identifiable information for any other purpose.
8. Special Notice for Vermont and California Residents. We will not disclose information about consumers with a Vermont or California mailing address to unaffiliated third parties without your written authorization, unless otherwise permitted by law. Disclosures that are permitted under Vermont and California law without written authorization include, among others, disclosures necessary to effect, administer or enforce a transaction you request; disclosures to our authorized agents and service providers; disclosures permitted or required by law or disclosures to prevent fraud or other illegal activities.Written authorizations from Vermont residents may be delivered to us by mail at the address above or by email atthe address above. Vermont authorizations must contain your name, address and signature and your authorization to disclose your information to nonaffiliated parties. You may revoke your consent at any time by sending us written notice by mail or email at the addresses above.California residents should contact us at the addresses provided above for instructions on how to deliver their authorizations.
9. Communications from our Web Site. We will occasionally send you information on new products, features or promotions. Out of respect for your privacy, we present the option not to receive these types of communications. Please see the "Choice and Opt-out" section above. In addition, we may also send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
10. Information Security. We restrict access to nonpublic personal information about you to our employees who have a need to know such information (e.g., to process your transactions). We train our employees on the importance of customer privacy and confidentiality. We also maintain physical, electronic, and procedural safeguards that comply with federal standards to guard the nonpublic personal information of our customers.The security of your personal information is important to us. When you enter sensitive information (such your Social Security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).
11. Links to Other Web Sites. Our web site may feature links to third party web sites that offer goods, services or information. Some of these sites may appear as windows-within-windows at our web site. When you click on one of these links, you will be leaving our site and will no longer be subject to this policy. We are not responsible for the information collection practices of the other web sites that you visit and urge you to review their privacy policies before you provide them with any personally identifiable information. Third party sites may collect and use information about you in a way that is different from this policy.
12. Other Privacy Rights. You may have other privacy protections under some state laws. We will comply with applicable state laws regarding information about you. For example, certain state laws may restrict the types of information we may disclose about you or require us to provide you with additional notices or opt-out rights.
13. Maintaining Accurate Information. We have a process in place that helps us to maintain the accuracy of the personally identifiable information that we collect. Please visit our web site at www.esqcard.com to review and correct information about yourself, such as a change in your name or contact information. If you believe that our information is inaccurate or incomplete, you also can contact us at the phone number or address listed at the end of this document and ask us to correct or update our information.
KEEPS Cardholder Services
P.O. Box 4400
New York, NY 10163-4400