AccuagePrivacy Policy

Last Updated: January 10, 2020

1. Introduction

Welcome to the Website (the “Website” or “Site”) of Assurance Compliance Network (“Assurance Compliance Network,” “we,” “us,” or “our”). Assurance Compliance Network provides Services that enable business customers (“Customers”) to securely verify the age of individuals. We do not provide legal services and recommend seeking professional legal counsel before taking any action based on the information contained on our Website.

All use of Assurance Compliance Network’s Website and Services is subject to the terms and conditions as set forth in our Assurance Compliance Network Terms of Service. Any use of this Website constitutes the user’s agreement to abide by those terms and conditions.

This Privacy Policy explains what User Data (“Personal Data”) we collect, how we use and share that data, and your choices and rights concerning our data practices. The Assurance Compliance Network.Net Privacy Policy helps assure that our Customers and Users receive quality services with high integrity.

This Privacy Policy, together with our Terms of Service separately agreed to you and incorporating this policy, establishes the legal terms and conditions of the agreement between us governing the submission of the Information and our use of it in performing the Service. All capitalized terms used in this policy and not otherwise defined here will have the meanings assigned to them in the Terms of Service. By submitting the Information, you agree to be bound by this policy, User ("you") allow the Information to be used in the manner specified in this policy.

Please read this Privacy Policy before using our Service or submitting and Personal Data to Assurance Compliance Network.

2. Information we collect

We collect information in two ways, directly from your input into the Platform, and automatically through the Service.

a. Information provided by you

The verification process requires you to submit Information in order to verify your age and identity (the "Verification Process"). We collect any information you provide to us by filling in forms on our Platform. The information listed below is used to complete the Verification Process. Usually we are able to complete the Verification Process by collecting the following information:

Your first and last name.

Your date of birth.

Your address, including city, state, zip/postal code, and country.

In the event that we are unable to verify you using this information, we will collect a picture of your federally recognized photo I.D., such as your driver’s license (an “ID”). To send us your ID, you can upload a file from your computer or take a picture within your browser if it is supported.

If you choose to use your mobile phone to complete the Verification Process, we will collect your phone number in order to send you a link to continue the Verification Process.

b. Information collected automatically

We collect non-personally identifiable information automatically for the primary purpose of customizing the Platform and Service, understanding how they are used, and preventing misuse.

For example, when you use access the Platform, we automatically record information from your device, its software, and your activity using the Platform. This may include, but is not limited to the date and time of your access to the Platform, your device’s internet protocol (“IP”) address, browser type, the web page visited before you came to our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning files included in the Information submitted to us, and other interactions with the Platform.

Some devices allow applications to access real-time location-based information (for example, GPS or sensor data from your device that may provide information on nearby Wi-Fi access points and cell towers). We do not collect such information from your mobile device at any time as of the date this policy went into effect, but may do so in the future with your consent to improve the Service. Some of the information we collect from a device, for example IP address, can sometimes be used to approximate a device’s location. Finally, some browsers share your location information (either the location registered with your account or gleaned from other geo-location methods) with sites you visit and we may obtain location information about you in this way. If you do not wish us to receive this information, please configure your browser not to share it.

3. Use of your Information

The information collected through the Verification Process is used for the Verification Process, to communicate with you, and to customize your experience. We may retain all information collected in order to facilitate future Verification Processes, with the exception of your ID, which is deleted as soon as the Verification Process is complete. If you do not wish us to retain your personally identifiable information, you can send an email to privacy@accuage.net to request that we delete that information from our records. We may, however, retain your information even if you instruct us to delete it, if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Agreement. Information stored in routine backups may also be retained for the period those backups are retained in the ordinary course of business.

4. Sharing or Disclosing your Information

Your Information may be disclosed to our employees, vendors, contractors, consultants and other service providers who need access to such information to carry out work on our behalf, at our direction and subject to the terms of this policy, including a third-party identity verification provider. The results of the Verification Process, as well as some or all of your Information may also be shared with our Customers as part of the Verification Process. We also may share your information with your consent and at your direction.

If you submit a photo ID to our Service, it will be deleted as soon as the Verification Process is complete and will not be shared with any person except for our authorized employees or contractors.

Automatically collected non-personally identifiable information may be aggregated and disclosed without restriction. We may share aggregated, non-personally identifiable information publicly. For example, we may share information publicly to show trends about the general use of the Service with the press, in our marketing materials, or with our business partners. We may collate or connect non-personally identifiable information with your personal information, in which case the resulting personally identifiable information will be treated as personal information.

We may disclose to outside parties Information you submit and other information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with applicable Law; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of us or our customers and users; (d) to protect our property rights; or (e) enforce the Terms of Use, including investigation of potential violations. If we provide your information to a law enforcement agency as set forth above, we will remove encryption before providing it.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via a prominent notice on our website or popup) of any change in control or use of your Information or if either become subject to a different privacy policy. We will also notify you of choices you may have regarding the information.

5. Security

We use reasonable methods, consistent with industry practices, to protect the confidentiality of your information, including administrative, physical and technical methods. Information you submit to or receive from our Service is sent using an encrypted TLS (SSL) connection.

No method of transmission over the internet is completely secure, therefore we cannot guarantee the security of your information.

6. GDPR

The European Union (“EU”) General Data Protection Regulation (“GDPR”) is a data protection law that came into effect on May 25, 2018. Assurance Compliance Network takes appropriate steps to satisfy GDPR requirements as they apply to Users of our Service or Website in the EU.

Assurance Compliance Network’s role within GDPR framework is a “Data Processor” for “Data Subjects” (users of our Service). “Data Controllers” are our Customers and Data Partners.

When you visit our Website or use our Service as an individual, you may be entitled to certain rights under the GDPR concerning the use of your personal data. We will respond without undue delay to your requests to exercise these rights. They are:

Right to be informed. You may ask us to confirm whether we are processing your Personal Data, and how we are using it. This Privacy Policy informs you of how we use your Personal Data.

Right of access. If we are processing your Personal Data and you request access to it, we will provide you with a copy of that Personal Data.

Right to rectification. If your Personal Data is inaccurate or incomplete, you may ask that we correct or complete it.

Right to erasure. You may ask us to delete or remove your Personal Data. This is also known as your “right to be forgotten.”

Right to restrict processing. You may ask us to restrict the processing of your Personal Data in certain circumstances. We will tell you before we lift any restriction where possible.

Right to data portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, clear, commonly-used format. You may reuse it elsewhere, or request that we move, copy, or transmit your Personal Data to another service provider.

Right to object. You may ask us at any time to stop processing your Personal Data, and we will do so, unless we demonstrate legitimate grounds to process your Personal Data. Legitimate grounds to process your personal data may include our need to establish, exercise, or defend legal claims. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent. Please note that this will likely impede your ability to use our Service.

Rights in relation to automated decision-making. You have the right to request human intervention if you are subject to a decision that is based on automated processing and produces a legal or similar effect on you.

If you want to exercise any of the rights described above, or are dissatisfied with the way we have used your Personal Data, please contact privacy@accuage.net or call 1-888-276-2303. We will process your request without undue delay, and in any event in accordance with the requirements of the GDPR. We may keep a record of your communications to help us resolve any issues which you raise.

If Assurance Compliance Network is unable to comply with your request, we will provide you with an explanation. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal data for security, fraud prevention, regulatory, or legal reasons.

You have the right to file a complaint with a GDPR supervisory authority. A list of supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

7. Third-Party Sites

Our website may include links to other websites whose privacy practices may differ from those of this policy. If you submit information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

8. Cookies

Part of Assurance Compliance Network’s Website may use cookies to collect information about user action on our site and improve your experience and our Service. A cookie contains information that is either stored in your computer’s memory, or in a file on your computer’s hard disk.

9. Contact Us

If you have any feedback, comments, requests for technical support, questions about this Privacy Policy, questions about GDPR, or other communications relating to the Website or our Service, please contact us by email at the following address: privacy@accuage.net

For Merchants

1. Introduction

This Privacy Policy describes how Assurance Compliance Network (referred to as “we”, “our”, “us” or “accuage.net”) collects, uses, and stores your information. This privacy policy, together with our Terms of Use (“Terms of Use”) separately agreed to you and incorporating this policy, establishes the legal terms and conditions of the agreement between us governing the submission of the Information and our use of it in performing the Service. All capitalized terms used in this policy and not otherwise defined here will have the meanings assigned to the in the Terms of Use. By submitting the Information, you agree to be bound by this policy, User ("you") allow the Information to be used in the manner specified in this policy.

2. Information we collect

We collect information in two ways, directly from your input into the Platform, and automatically through the Service.

a. Information provided by you

We may collect and store any personal information you enter on our website or provide to us in some other manner. This includes identifying information, such as name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). If you contact us for support, we will keep an internal record of what support was given. From time-to-time, we may provide you with the opportunity to participate in contests or surveys. If you choose to participate, we may request certain personal information from you. Participation in these contests or surveys is completely voluntary and you therefore have a choice whether or not to disclose the requested information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code).

b. Information collected automatically

We collect non-personally identifiable information automatically for the primary purpose of customizing the Platform and Service, understanding how they are used, and preventing misuse.

For example, when you use access the Platform, we automatically record information from your device, its software, and your activity using the Platform. This may include, but is not limited to the date and time of your access to the Platform, your device’s internet protocol (“IP”) address, browser type, the web page visited before you came to our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning files included in the Information submitted to us, and other interactions with the Platform.

Some devices allow applications to access real-time location-based information (for example, GPS or sensor data from your device that may provide information on nearby Wi-Fi access points and cell towers). We do not collect such information from your mobile device at any time as of the date this policy went into effect, but may do so in the future with your consent to improve the Service. Some of the information we collect from a device, for example IP address, can sometimes be used to approximate a device’s location. Finally, some browsers share your location information (either the location registered with your account or gleaned from other geo-location methods) with sites you visit and we may obtain location information about you in this way. If you do not wish us to receive this information, please configure your browser not to share it.

We also use “cookies” to collect information and improve the Service. A cookie is a small data file that we transfer to your device. We may use “persistent cookies” to recognize you for future access to the Platform. We may use “session ID cookies” to enable certain features of the Platform, to better understand how you interact with the Platform and to monitor aggregate usage and web traffic routing on the Platform. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Platform or the Services.

3. Use of your Information

a. In General

We may use information that we collect about you to (a) deliver the Services, and manage the Platform and our business, (b) manage your account and provide you with customer support, (c) perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others, (d) communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties, (e) develop and display content and advertising tailored to your interests on our site and other sites, including providing our advertisements to you when you visit other sites, (f) perform ad tracking and website or mobile application analytics, (g) enforce or exercise any rights in our terms and conditions, and (h) perform functions as otherwise described to you at the time of collection.

b. Financial Information

We may use financial information or payment method information to process payment for the Services you use, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.

c. Third-Party Service Providers

In all circumstances, we may perform the functions described above directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us and only in conformance with this privacy policy.

4. Sharing or Disclosing your Information

a. Personal Information

We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared.

i. Service Providers

We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, supporting our website functionality, and supporting surveys and other features offered through the Platform. We may also share your name, contact information and credit card information with our service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes and are required to use the information in conformance with this privacy policy.

ii. Business Partners

When you click-through on third-party offers featured on the Platform, we may share personal information with the businesses with which we partner to offer you the applicable products or services. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that third party. To opt-out of cookies that may be set by third party data partners, please go to http://www.aboutads.info/choices. We may share your information with a third party application or a third-party merchant services provider or other reseller with your consent, for example when you choose to access the Platform through such an application or are provided with access to the Platform through such a third-party merchant services firm. We are not responsible for what those parties do with your information, so you should make sure you trust those third parties and that they have privacy policies acceptable to you.

b. Other Information

Automatically collected non-personally identifiable information may be aggregated and disclosed without restriction. We may share aggregated, non-personally identifiable information publicly. For example, we may share information publicly to show trends about the general use of the Service with the press, in our marketing materials or with our business partners. We may collate or connect non-personally identifiable information with your personal information, in which case the resulting personally identifiable information will be treated as personal information.

c. Other Disclosures

We may disclose to outside parties Information you submit and other information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with applicable Law; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of us or our customers and users; (d) to protect our property rights; or (e) enforce the Terms of Use, including investigation of potential violations. If we provide your information to a law enforcement agency as set forth above, we will remove encryption before providing it.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control or use of your Information or if either become subject to a different privacy policy. We will also notify you of choices you may have regarding the information.

5. Accessing Your Information; Your Choices

If you have an account with us, you have the ability to review and update your personal information online by logging into your account and editing your account profile. More information about how to contact us is provided below. If you have an account with us, you also may close your account at any time through the Platform. After you close your account, you will not be able to sign in to the Platform or access any of your personal information. If you close your account, we may still retain (a) any non-personally identifiable information, and (b) certain personal information associated with your account, if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Terms of Use. Information stored in routine backups may also be retained for the period those backups are retained in the ordinary course of business.

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of the Platform and Services because that information may be required in order for you to register as a customer, purchase Services, obtain customer support, or initiate other transactions.

When you register on the Platform site, you consent to receive email messages from us. You may modify this consent later by visiting the "My Account" page associated with your account. At any time you can choose to no longer receive commercial or promotional emails from us by visiting the "My Account" page associated with your account. You also will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future. It may take up to 10 days for us to process an opt-out request. We may send you transactional and relationship emails, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications, will only affect future activities or communications from us . If we have already provided your information to a third party (such as a service provider) before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Platform and Services.

6. Security

We use reasonable methods, consistent with industry practices, to protect the confidentiality of your information, including administrative, physical and technical methods. Information you submit to or receive from our Service is sent using an encrypted TLS (SSL) connection.

No method of transmission over the internet is completely secure, therefore we cannot guarantee the security of your information.

7. Third-Party Sites

Our website may include links to other websites whose privacy practices may differ from those of this policy. If you submit information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

8. Our Policy Toward Children

The Service is not directed or available to persons under 18. We do not knowingly collect information from children under 18. If a parent or guardian becomes aware that his or her child has submitted Information in violation of our policies and has provided us with information without their consent, he or she should contact us at help@accuage.net. If we become aware that a child under 18 has provided us with Information, we will take steps to delete that Information from our records, subject to any retention reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Agreement.

9. Changes to our Privacy Policy

We may make changes to this Privacy Policy from time to time. If this Privacy Policy is modified, we will update this page and the revision date.

10. California

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.

11. Contacting Us

To ask questions about this Privacy Policy, our privacy practices, your Information, or anything relating to the Service, including requests that we unsubscribe you from communications, you may email us at our contact email: privacy@accuage.net.