Privacy and online safety are important to Carmel Solutions LLC (“Carmel”). We offer a software platform and services to facilitate consumer payments through the NACHA system, and perform backup servicing activities for our clients. We collect data about businesses and their customers (“Data”) when they use the platform, the services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.
In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User”), or a customer of a User (“Customer”). This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully. If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer after leaving our website, and (b) discontinue Your use of our Services. Our Sites may not respond to browser “Do Not Track” signals; however, since we do not sell or share data, cross context advertising restrictions do not apply.
The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when a Carmel account is created, test transactions are submitted through our website, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.
The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety, and reduce the risk of fraud, money laundering and other harmful activity.
a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a business registers for a Carmel account, a Customer makes payments or conducts transactions through a User’s website or application, or a person responds to Carmel emails. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes: Contact details, such as name, postal address, telephone number, email address.
Financial and transaction Data, such as credit or debit card number, and bank account information; and Other Personal Data, such as date of birth, SSN or EIN.
b. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include: Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using; Transaction data, such as purchases, purchase amount, date of purchase, and payment method; Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and Company data, such as a company’s legal structure, product and service offerings, jurisdiction, and company records.
a. Personal Data. We and our service providers use Personal Data to:
Examples of how we may use Personal Data include:
b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments.
Carmel does not sell or rent Personal Data to marketers or unaffiliated third parties. Carmel does not share personal information for cross-context behavioral advertising (As defined under the California Consumer Privacy Act / California Privacy Rights Act). We share Your Personal Data with trusted third parties, including:
a. Carmel Affiliates. We share Data with entities that we control, are controlled by us, or are under our common control, to provide our Services. Carmel is the party responsible for overall management and use of the Data by these affiliated parties;
b. Carmel Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing;
c. Authorized Third Parties. We share data with parties directly authorized by a User to receive Data. The use of Data by an authorized third party is subject to the third party’s privacy policy;
d. Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
e. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.
We collect Sensitive Personal Information (e.g., SSN, EIN, bank account data, DOB) solely to:
Carmel does not use Sensitive Personal Information for any purpose beyond those permitted under CPRA. Because of this, the CPRA right to limit does not apply to our use of Sensitive Personal Information.
We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.
We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy in keeping with required retention period based on fulfilment of business obligations and regulatory requirements. Please note that we have a variety of obligations to retain the Data that You provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back; to support audits, investigations, and business continuity; and to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if You close Your Carmel Account, we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.
We may collect, use and disclose certain Personal Data about Customers when acting as the User’s service provider. Our Users are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third-party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.
Carmel is U.S.-based. When transferring personal information from the EEA/UK, we use safeguards such as the EU Standard Contractual Clauses and the UK International Data Transfer Addendum.
We may change this Privacy Policy. Any changes are effective when we post the revised Privacy Policy on the Services.
We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You at the email address and/or the physical address listed in Your Carmel account. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.
You may have the right to:
You may have the right to:
To exercise rights, email support@carmelsolutions.com or write to our mailing address.
If Carmel processes your information as a service provider/processor, please submit your request to the business that collected your information.
Additionally, some data processed by Carmel may fall under GLBA or other financial laws, which may be exempt from certain state privacy requirements.
If You have any questions about this Privacy Policy, please contact us at support@carmelsolutions.com or at:
Carmel Solutions LLC
969 Keystone Way, Suite 120
Carmel, Indiana 46032
Sensitive Information. Because email communications are not always secure, please do not include credit card or other sensitive Data in Your emails to us.