ONLINE PRIVACY NOTICE

1.    Introduction

(a)    Web Site Owner. Curo365, LLC, a Texas limited liability company ("Curo365") is the owner of this web site ("Web Site"). Curo365 can be contacted by mail at 310 South Saint Mary’s Street, Suite 2100, San Antonio, Texas 78205, by phone at (385) 419-4418, or by e-mail at C365info@curo365.com. This online privacy notice discloses Curo365 information practices for this Web Site, including what type of personal identifiable information is requested in order to make a purchase, how the information is used, and with whom the in-formation is shared. Note that other Web Sites may be governed by privacy notices containing different information practices applicable to those sites.

(b)    Web Site Visits. In general, you can visit on the Web Site without disclosing OR revealing any personal information. Curo365 analyzes the data gathered from Web Site visits for trends and statistics, and then the gathered data is discarded at intervals determined by Curo365.

(c)    Web Site Transactions. At times, Curo365 will need personal information regarding a customer or a prospect. For example to process an order or provide a subscription, Curo365 may need to know a customer’s name, mailing address, e-mail address and credit card details. It is Curo365’s intent to inform you know before Curo365 collects personal information, such as user’s name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, Curo365 will respect your wishes.

2.    Personal Information That May Be Collected

(a)    Identifying Information. In order to make a purchase OR to access designated subscriber services and /or restricted areas within the Web Site, Curo365 will request a user to provide certain personal identifying information, which may include: name, postal address, e-mail address, screen name, password, telephone number, method of payment, and, if applicable, credit card number. Curo365 may request additional information necessary to establish and maintain customer’s account.

(b)    Service Quality Monitoring. Some Web Site transactions may require a customer to telephone Curo365, or Curo365 to call the customer. Curo365 will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is Curo365’s practice to monitor, and in some cases record such calls for staff training or quality assurance purposes.

(c)    Information from Children. Curo365 does not sell products or services for purchase by children, and will not collect or post information from a child under the age of 18 without the involvement of a parent or guardian. Curo365 will notify the child’s parent or guardian at the e-mail address provided by the prospective customer, alerting the parent or guardian to the child’s use of the Web Site and providing instructions as to how the parent or guardian can delete the child’s registration from the Web Site.

(d)    Lost or Stolen Information. If a customer’s credit card and/or password is lost or stolen, the customer should promptly notify Curo365 in order to enable Curo365 to cancel the lost or stolen information and to update its records with a changed credit card and/or password.

(e)    Links to Other Web Sites. A Web Site may contain links to other web sites. Curo365 is not responsible for the privacy practices or the content of those other Web Sites.

3.    Uses Made of the Information

(a)    Limited Uses Identified. Without customer’s prior consent, Curo365 will not use personal identifiable information for any purpose other than that for which it is submitted. Curo365 uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in-program record-keeping. Curo365 also processes billing and business requests related to Web Site participation.

(b)    Stored Information Uses. Curo365 stores and retains the information entered on the Web Site. Stored information is used by Curo365 and/or its agents}: to support customer interaction with the Web Site; to deliver customer purchases; and/or to contact customer again about other services and products.

(c)    Online Advertising. Some companies that help Curo365 deliver interactive on-line advertising, such as banner ads, may collect and use information about Curo365’s customers to help Curo365 better understand the types of advertising or promotions that are most appealing to Curo365’s customers. After it is collected the information is aggregated so it is not identifiable to a specific individual.

4.    Disclosure of the Information

(a)    Within Corporate Organization. Curo365 may share your personal information within the Curo365 corporate organization, and may transfer the information to countries in the world where Curo365 conducts business. Some countries may provide less legal protection for customer personal information.

(b)    Mergers and Acquisitions. Circumstances may arise where for business reasons, Curo365 decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is Curo365’s practice to seek appropriate protection for information in these types of transactions.

(c)    Agents. Curo365 employs or engages other companies and individuals to perform business functions on behalf of Curo365. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments and providing customer services.

(d)    Affiliated Businesses. Curo365 works closely with affiliated businesses providing services or selling products on each other’s web sites. These businesses identify themselves to customers. Customer information related to a transaction with an affiliated business is shared with that affiliated business.

(e)    Marketing Analysis by Third Parties. Curo365 reserves the right to disclose to third parties personal information about customers for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer.

(f)    Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure pursuant to a judicial or other government subpoenas, warrants or orders.

5.    Use of Computer Tracking Technologies

(a)    No Tracking of Personal Information. The Web Site is not set up to track, collect or distribute personal information not entered by visitors. Through Web Site access logs Curo365 does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.

(b)    Use of Cookies. Curo365, or its third-party vendors, collects non-identifiable and personal information through the use of various technologies, including "cookies". A cookie is an alphanumeric identifier that a web site can transfer to customer’s hard drive through customer’s browser. The cookie is then stored on customer’s computer as an anonymous tag that identifies the customer’s computer, but not the customer. Cookies may be sent by Curo365 or its third-party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, some web sites may not then work properly.

(c)    Use of Web Beacon Technologies. Curo365 may also use Web beacon or other technologies to better tailor its Web Site(s) to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Web Site, a non-identifiable notice of that visit is generated which may be processed by Curo365 or by its affiliates. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer’s visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

(d)    Collection of Non-Identifiable Information. Curo365 may collect non-identifiable information from user visits to the Web Site in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on Web Site(s); Web Site and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." Curo365 or its contractors may use this data to analyze trends and statistics.

(e)    Collection of Personal Information. Curo365 collects personal identifying information from customer during a transaction. Curo365 may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help Curo365 understand trends and patterns. This information is not reviewed at an individual level.

6.    Information Security

(a)    Commitment to Online Security. Curo365 employs physical, electronic and managerial procedures to safeguard the security and integrity of personal information. Billing and payment data is encrypted whenever transmitted or received online. Personal information is accessible only by staff designated to handle online requests or complaints.

(b)    No Liability for Acts of Third Parties. Curo365 will exercise all reasonable efforts to safeguard the confidentiality of customer personal information. However, transmissions protected by industry standard security technology and implemented by human beings cannot be made absolutely secure. Consequently, Curo365 shall not be liable for unauthorized disclosure of personal information due to no fault of Curo365 including, but not limited to, errors in transmission and unauthorized acts of staff and/or third parties.

7.    Privacy Policy Changes and Opt-Out Rights

(a)    Changes to Privacy Policy. This privacy notice was last updated on August 1, 2018. Curo365 reserves the right to change OR update its privacy policy statement at any time. A notice of such change OR notice of any material change will be prominently posted on the Web Site.

(b)    Opt-Out Right. A customer has the right at any time to cease permitting personal information to be collected, used or disclosed by Curo365 and/or by any third parties with whom Curo365 has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting Curo365 via e-mail to C365info@curo365.com, by phone at (385) 419-4418, or by postal mail to 8 East Broadway, Suite 600, Salt Lake City, UT 84111. After processing the cancellation, Curo365 will delete customer or prospective customer’s personal information from its data base.

8.    Access Rights to Data

(a)    Information Maintained by CURO365. Upon customer’s request, Curo365 will provide a reasonable description of customer’s personally identifiable information that Curo365 maintains in its data bank. Curo365 can be contacted by e-mail at via e-mail to C365info@curo365.com, by phone at (385) 419-4418, or by postal mail to 310 South Saint Mary’s Street, Suite 2100, San Antonio, Texas 78205.

(b)    Corrections and Changes to Personal Information. Help Curo365 to keep customer personal information accurate. If customer’s personal information changes, or if customer notes an error upon review of customer information that Curo365 has on file, please promptly e-mail Curo365 C365info@curo365.com and provide the new or correct information.

9.    Accountability

(a)    Questions, Problems and Complaints. If you have a question about this policy statement, or a complaint about Curo365 compliance with this privacy policy, you may contact Curo365 by e-mail. If Curo365 is unable to resolve your complaint to your reasonable satisfaction or if customer does not receive acknowledgment of an inquiry, customer may elect to proceed by contacting the American Arbitration Association by visiting its website (https://www.adr.org/ContactUs) or by calling 800-778-7879.

(b)    Terms of Use & Contract. If customer chooses to subscribe to products or services, customer’s action is hereby deemed acceptance of Curo365 practices described in this policy statement. Any dispute over privacy between customer and Curo365 is subject to the provisions of this notice and to the subscription contract between Curo365 and such customer, which is hereby incorporated herein. 
 

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