EBCS Consumer Privacy policy

EBCS Consumer Privacy policy

What does this policy cover

Welcome to EBCS, the online and mobile service of  Total Financial Services, Inc. and any and all of its affiliates (“EBCS,” “we,” or “us”). Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Service, and your choices about the collection and use of your information. If you do not agree with this Privacy Policy in general or any part of it, you should not use our online or mobile services.

This Website Privacy Policy Statement (“Privacy Policy”) applies to all websites owned, operated, controlled and otherwise made available by EBCS, its parent, their affiliates and subsidiaries (including, but not limited to, mirrored, co-branded and successor sites).  Our office address is:

Service means: Any contractual obligation you may have entered into with EBCS and/or any of its Partners that have extended you credit in an effort to purchase products and services and/or you have elected to enter into a membership type agreement that may or may not require periodic recurring billing.

Partners mean: Any Client of EBCS that has contracted with EBCS to manage their accounts receivable and/or recurring billing and/or any of Client’s consumers that were extended credit to purchase Client’s products or services.

Introduction

EBCS respects the privacy and security of your personal information. The following privacy policy describes the information we collect, how we use it and what rights you have to it.  By using this EBCS Website, you acknowledge and agree to the terms and conditions of this Privacy Policy.  If you do not agree to these terms and conditions, please do not use this EBCS Website.

We reserve the right to change or modify our privacy practices that are described herein from time to time simply by posting a revised Privacy Policy on this EBCS Website.  Any such change shall be effective immediately upon posting of the revised Privacy Policy on this EBCS Website.  We reserve the right to make the revised or changed Privacy Policy effective for information we already have about you, as well as any information we receive in the future.  We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current privacy practices.

1. Information we collect and its use

We collect the following types of information about you:

(a) Information you provide us directly

We may ask for certain information such as a username, your first and last names, address, birthdate, phone numbers (home, work, cell), social security number, gender, wage income, household income, bank and credit card information, your profession and e-mail address when you use our Service that creates an EBCS account through one of our Partners, or if you correspond with us directly. We also collect any messages you send us through the Service, and may collect information you provide in User Content you post to the Service  (such as text, documents and photos you upload to EBCS). We use this information to operate, maintain, and provide the features and functionality of the Service to you, to correspond with you, and to address any issues you raise about the Service.

(b) Information we receive from third parties

We may receive information about you from our Partners or third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Facebook by “following,” “liking,” adding the EBCS application, linking your account to the EBCS Service, etc., that third party may pass certain information about your use of its service to EBCS. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the EBCS Service. You may also unlink your third-party account from the Service by adjusting your settings on the third-party service. If you unlink your third-party account, we will no longer receive information collected about you in connection with that service.

We may receive information from credit reporting agencies and other similar third-party companies to identify you and/or any bank information you may supply to us from time to time.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

(c) Information we collect from you automatically

We may directly collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information (in respect of which, please see the paragraph on log file information below) that assists us in improving the Service. 

(d) Cookies information and information taken from similar technologies

When you visit the Service, we will send cookies — small text files containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets EBCS help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business Partners to track your usage of the Service over time.

You can control or reset your cookies and similar technologies through your web browser, which will allow you to customize your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. 

(e) Log file information

Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

(f) Clear gifs/web beacons information

When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. This information allows for more accurate reporting and improvement of the Service.

(g) Device identifiers

When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by EBCS. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled. Device Identifiers used by EBCS include the Android Advertising ID and iOS Advertising Identifier.

(h) Location data

You may enter your location in your profile when you sign up for a EBCS account. Location data will convey to us information about how you browse and use the Service and enable us to offer you localized content.

2. How we use your information

We use the information we collect about you for the purposes set out above which we have described in more detail below:

• Providing you with the Service: We use the information that you provide us to provide the Service to you. This includes allowing you to log in to EBCS, operating and maintaining the Service, giving you access to your account(s) and billing you for transactions that you make via the Service. We also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.
• For payment compliance: We use information about you to help us process and/or collect on your contractual obligation directly with EBCS and/or our Partners.
• For data analytics: We use information about you to help us improve the EBCS Service and our users’ experience, including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns.
• Customizing the Service for you: We use information you provide us and information about you to make sure that your use of the Service is customized to your needs. 
• To communicate with you about the Service: We use your contact information (address, home, work and mobile phone numbers, email and any other contact information you provide) to get in touch with you and to send communications via USPS, phone, email or text messaging about critical elements of the Service. For example, we may send you emails or text messages about missed payments or administrative matters.
• To promote and drive engagement with the EBCS Service: We use your contact information to get in touch with you about features and offers relating to the Service that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Service, and your preferences. You can opt-out of getting these communications as described below.
• Customer happiness: We use information about you, information that you provide to our customer happiness team, and information about your interactions with the Service to resolve technical issues you experience with the Service, and to ensure that we can repair and improve the Service for all EBCS users.
• For security measures: We use information about you to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations of this Privacy Policy or our Terms of Service.
• For matters that you have specifically consent to: From time-to-time EBCS may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.
• For matters that we are required to use your information by law: EBCS will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of EBCS, our Users or others.

3. Sharing your information

We will not rent or sell your information to third parties outside EBCS and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted in this section:

(a) Who we share your information with

We share your information with third-party service providers for the purpose of providing the Service to you and to facilitate EBCS’s legitimate interests in providing a service which is useful to you. Those service providers will only be provided with access to your information as is reasonably necessary for the purpose that EBCS has engaged the service provider, and we will require that such third parties comply with this Privacy Policy, appropriate data processing terms and any applicable laws.

Some of the third parties that EBCS may share your personal information with include providers who assist EBCS with functions such as:

• Qualifying your account(s) and billing for your contractual obligation.
• Customer support and customer management;
• Email services;
• Hosting and storage;
• Analytics; and
• Delivery of physical products or services

(b) Who you can choose to share your User Content with

Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If you remove information that you posted to the Service, copies remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. By default, all content you post on EBCS is private. 

(c) Sharing with other third parties

EBCS will also share your information with third parties in certain circumstances, such as where:

• it is necessary to qualify you for the Service
• we are required to do so as a result of a court order, subpoena or other legal requirement;
• we believe that it is necessary to protect you or EBCS, such as where we consider that there is a need to investigate potentially fraudulent or criminal activity;
• you have consented to our sharing it with a third party for a particular purpose;
• you or your account administrator elects to install third party apps that interact with our Service. For example, you may install a third-party document sharing app in order to store, share and edit content through our Service. These third-party apps are not controlled by us, and this privacy policy does not cover how third-party apps use your information. You should review the terms and conditions of any third-party apps before connecting them to the Service. If you object to information about you being shared with these third parties, do not install the app.

EBCS will also share your information with a third party in circumstances where we sell, divest or transfer EBCS (including any shares in EBCS), or any combination of its products, services, assets and/or businesses to a third party. Information such as customer names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We will also sell, assign or otherwise transfer such information in the event of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of EBCS. You will be notified via email and/or a prominent notice on the Service if such a transaction takes place and be given notice of any material changes to the way we handle your data under this policy.

We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

4. Ads on EBCS

We may share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business Partners to deliver personalized advertisements (“ads”) that may be of interest to you. Please see our Cookies Policy for more information. EBCS may allow third-party ad servers or ad networks to serve personalized advertisements either on the Service or on third party websites, including Facebook and Google. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, these personalized ads and ad links, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalize the advertising content. EBCS does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask EBCS to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, EBCS determines the target audience and EBCS serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

The EBCS Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

5. How we transfer, store and protect your data

Your information collected through the Service will be stored and processed in the United States in which EBCS or its subsidiaries, affiliates or service providers maintain facilities. 

6. Keeping your information safe

EBCS cares about the security of your information, and uses appropriate safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from EBCS, at all times. However, EBCS cannot ensure or warrant the security of any information you transmit to EBCS or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third-party sites and services that you add to the EBCS Service, such as social networks. EBCS is not responsible for the functionality or security measures of any third party.

7. Compromise of information

In the event that any information under our control is compromised as a result of a breach of security, EBCS will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

8. Your choices about your information

(a) You control your account information and settings

You may update your account information by logging into your account and changing your profile settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests.

You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations, demand for payment notices and reminders, changes/updates to features of the Service, technical and security notices) although you can object to us providing these emails by emailing customersupport@ebcs-solutions.com.

If you have any questions about reviewing or modifying your account information, you can contact us directly at customersupport@ebcs-solutions.com.

(b) Opting out of collection of your information

Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents EBCS or its business Partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by EBCS, including via third parties’ websites. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, please read our Cookies Policy or you can contact us directly at customersupport@ebcs-solutions.com.

If you want us to stop collecting information about you, there may be some settings you can adjust in your browser or device. 

(c) Rights in respect of your Information

Should you wish to make a request in respect of your personal information please contact us at customersupport@ebcs-solutions.com. You also have the right to object to our processing of personal data about you in order to send you marketing and we will stop processing data for that purpose.

In some circumstances EBCS will not be able to comply with a request that you make in respect of your personal data. For example, we may not be able to provide a copy of your information where it infringes on the rights of another User. We may also be required to retain certain information that you ask us to delete for various reasons, such as where there is a legal requirement to do so. In some cases, you may have shared your information with third parties. In that case EBCS will not be able to delete the information, and you will need to contact that third party directly.

If we are unable to resolve your request, or if you are concerned about a potential violation, you also have the option to report the issue or make a complaint to the data protection authority in your jurisdiction. Where you have provided your consent to certain processing and no longer want us to use your information for that purpose, you may withdraw your consent to this use, although this will not affect the lawfulness of processing based on consent before its withdrawal. Please see paragraph “You control your account information and settings” for more options on how to opt-out of marketing communications.

9. How long we keep your information

Following termination or deactivation of your User account, EBCS will retain your profile information and User Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, EBCS will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

10. Children’s privacy and EBCS for Education

EBCS does not knowingly collect or solicit personal information from children under the age of 13 and the Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at customersupport@ebcs-solutions.com.

11. Links to other websites and services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not exercise control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

12. California users’ Privacy Rights

Californian users of EBCS have additional rights afforded to them under the California Consumer Privacy Act (CCPA).

Categories of personal information collected by EBCS

For more details about the personal information EBCS has collected in the past year, please see section 1 “Information we collect and its use”. For details on how we use that information, and who we share it with, please see section 2 “How we use your information” and section 3 “Sharing your information”.

EBCS does not “sell” (as defined in the CCPA) the personal information of EBCS users. 

Making a request in relation to your personal information

The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):

• Request to access the personal information EBCS has about you; and
• Request that EBCS delete all of your personal information.

California users may make a request by contacting us at customersupport@ebcs-solutions.com. We will authenticate your request using the email address associated with your EBCS account and if necessary, proof of residency.

13. Changes to this Policy

We may update this policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this policy, we will revise the “Last Updated” date at the top of this policy. If we make any material changes to the way we collect, use, store and/or share your personal information, we will notify you by prominently posting notice of the changes on our website and/or sending an email to the email address associated with your EBCS account. We recommend that you check this page from time to time to inform yourself of any changes.

14. How to contact us

If you have any questions about this Privacy Policy or the Service, or wish to make a complaint please contact us at:

• Email: customersupport@ebcs-solutions.com
• Write:
  EBCS
  PO Box 245
  Timonium, MD 21094-0245