FormPiper Privacy Policy

FormPiper, LLC

Effective Date: January 1, 2020

Last Updated: June 1, 2023

This Privacy Policy applies to your use of FormPiper and any web sites, mobile applications, services, programs, or features (collectively, the “FormPiper Platform”) owned or operated by FormPiper, LLC. or any of its subsidiaries or affiliates (collectively, “FormPiper,” “we,” “our,” or “us”). FormPiper values your privacy, and taking proper care of your information is a top priority for us. Our goal is to help you understand what information we collect about you (also known as “User Data”) and describe how we use that information. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service, including any agreements incorporated by reference within the Terms of Service (the “FormPiper Terms”). Any terms not defined in this Privacy Policy will have the meaning given to them in our Terms of Service. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you should stop using or accessing the FormPiper Platform and terminate your Account. Certain parts of this Privacy Policy apply only to the FormPiper Platform offered in particular geographies; for more information, please refer to the “California Residents” section if you reside in California.

Our Privacy Policy covers the following topics:

• Information We Collect
• How We Use User Data We Collect
• Cookies and Similar Technologies
• When You Choose to Not Provide User Data
• Our Retention of Your User Data
• Sharing User Data
• International Transfer
• Your Privacy Choices
• Privacy Rights Specific to California Residents
• How We Protect User Data
• Children’s Privacy
• CAN-SPAM
• Privacy Policy Modifications

Please familiarize yourself with our privacy practices. As one of our customers, you understand and agree that we collect, use, and disclose your information in accordance with this Privacy Policy.

If you have any questions or comments about this Privacy Policy, please submit a request to contactus@formpiper.com.

Information We Collect

We collect information, including personal information, to provide better services to all our customers and Platform visitors. The term “User Data” means any information that can be used to identify you. For example, we may collect personal information from you when you:

• Register, subscribe, or create an account with FormPiper;
• Purchase products from FormPiper;
• Use FormPiper’s services or access the Platform, including setting up an account on the Platform through the customer portal;
• Use the FormPiper services or the Platform through a merchant when you apply for a loan;
• Contact customer service or otherwise make use of our customer support tools, including, but not limited to, voice, messaging, SMS, chat, or our help center pages;
• Connect, link, message, or "share" our Platform via social networking sites;
• Provide a product review;
• Sign up for notifications;
• Report a problem or have a question about our Platform or products, you may provide us with contact information, such as a phone number or email address;
• Use our Platform or emails - we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as User Data under applicable law; and

Other Sources: We may also collect information about you, including personal information, from third-party sources. For example, we collect certain personal information about you from marketing research firms in order to improve our future marketing efforts and make them more efficient. This information may include name, interests, and publicly-observed data like shopping behavior. We may combine this information with the User Data we collect from you. We will treat any combined information as User Data pursuant to this Privacy Policy.

How We Use User Data We Collect

We use your User Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

• To present, operate or improve the Platform, including analysis of Platform activity;
• To inform you about products or promotions available from FormPiper;
• To authorize access to our Platform;
• To validate your identity or verify communications from you;
• To customize or tailor your experience of the Platform;
• To manage, store and enhance your data and preferences;
• To communicate about, and administer your participation in, special programs, surveys, online campaigns, online programs, and to deliver pertinent emails;
• To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of the Platform;
• For marketing purposes, including but not limited to, facilitating interest-based advertising, creating customer profiles, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest to you;
• To improve our customer service, conduct customer satisfaction, market research, and quality reviews;
• To process applications submitted to third parties that you submit through the Platform;
• To administer general recordkeeping;
• To comply with all applicable legal requirements;
• To manage our contractual relationship with you;
• To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy;
• For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, or for any other lawful purpose.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit Platform or use the FormPiper services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.

Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream Data. Clickstream data is information collected by our computers when you request web pages from the Platform. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Platforms, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Platforms.

When You Choose to Not Provide User Data

Your provision of User Data is required in order to use certain elements of the Platform. In some instances, if you fail to provide such User Data, you may not be able to access and use our Platform or order our products.

Our Retention of Your User Data

We use and retain your User Data for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

Sharing User Data

FormPiper may disclose your User Data to commercial providers for a business purpose, which include verifying your identity when making a payment. When we disclose User Data for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that User Data confidential and not use it for any purpose except for the purposes set forth in the contract.

We may disclose your User Data for a business purpose to the following categories of third parties:

• Our affiliates;
• Strategic business partners who provide goods, services and offers that enhance your experience with our Platform and our products, or that we believe will be of interest to you;
• Service providers and other third parties we use to support our business, including without limitation those performing core services (such as billing, credit card processing, customer support services, customer relationship management, accounting, auditing, processing insurance claims, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business or the Platform, the processing commensurate with any of our services, and making certain functionalities available to our users;
• Commercial providers.

We may disclose your User Data for legal reasons. Specifically, we will share User Data with companies, organizations or individuals outside of FormPiper if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Fulfill any purpose for which you provide it;
• Meet any applicable law, regulation, legal process or enforceable governmental request;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security or technical issues;
• Protect against harm to the rights, property, assets or safety of FormPiper, our customers or the public, content found on the Platform, or to protect the Platform from unauthorized use or misuse, as required or permitted by law;
• Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of FormPiper's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which User Data held by FormPiper about its customers and users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy;
• For any other purpose disclosed when you provide the information;
• When we obtain your consent to do so.

We attempt to notify you about legal demands for your User Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

International Transfer

We have centralized some of our data processing activities in accordance with applicable laws, and as a result, we may, directly or indirectly through our organization and affiliates, and through third-party entities around the world, process, store, and transfer the information you provide, including your User Data, as described in this Privacy Policy. Specifically, the information and User Data that we collect may be transferred to, and stored at, a location outside of your jurisdiction. The jurisdiction where your User Data will be processed may or may not have laws that seek to preserve the privacy of User Data. Your User Data may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your User Data using the Platforms, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your User Data is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and User Data we collect on the Platforms.

Your Privacy Choices

You may have certain rights relating to your User Data, subject to local data protection law. Whenever you interact with or in any way utilize the Platform, we aim to provide you with choices about how we use your User Data. Subject to applicable law, you may obtain a copy of User Data we maintain about you. In addition, if you believe that User Data, we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

Privacy Rights Specific to California Residents

If you are a California resident, this section applies to you. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope. As a California resident, you are entitled to certain privacy rights further explained below. These rights are not absolute and are subject to exceptions. We may be required or permitted by law to decline your request. When requesting to exercise your right to access and deletion under the CCPA, only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make such a verifiable request.

• The right to request a copy of the categories of personal information and specific personal information collected about you in the last 12 months.
• The right to delete personal information collected from you, except as necessary to comply with legal obligations, detect, prevent, and mitigate security incidents, bugs or fraudulent, malicious, deceptive, or illegal activity, or as otherwise provided under applicable law.
• The right not to have your personal information sold to third parties, if applicable. California law broadly defines what constitutes “personal information” such that cookie and technical information shared with targeted advertising vendors may constitute a “sale” of “personal information.”
• The right not to be discriminated against for exercising your privacy rights described above. You may contact us at contactus@formpiper.com with any requests, or if you have questions or concerns about our privacy practices or your rights.

How We Protect User Data

FormPiper maintains administrative, technical and physical safeguards designed to protect the user's User Data and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect User Data.

Although we take reasonable steps designed to protect your User Data, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your User Data or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of User Data that may affect you so that you can take the appropriate actions.

For your own privacy protection, we urge you to keep all passwords confidential. We also recommend that you do not include sensitive information such as passwords, social security numbers or payment information, in any emails that you send to us. If you become aware of any breach of the terms of this Privacy Policy or of the security of the Services, please notify us by email at contactus@formpiper.com.

Children’s Privacy

FormPiper is intended for access and use by individuals who are of legal age for the services offered based on the applicable regulations of their state or other government entities (“Qualifying Age”). We do not knowingly collect personal information from or about anyone who is not of Qualifying Age. If you are not of Qualifying Age, you should not attempt to access or use FormPiper, or send any information to us. If we discover that we have collected personal information from an individual who is not of Qualifying Age, we will take steps to remove that information.

CAN-SPAM Compliance Policy

CAN-SPAM Compliance Policy

This policy applies to all commercial messages sent by, or on behalf of, the company, which includes any electronic mail message the primary purpose of which is the commercial advertisement or promotion of a commercial product or service.

The following are the key requirements that FormPiper adheres to in compliance with the CAN-SPAM Act:

• Identification: Emails sent will be clearly identified as advertising messages as appropriate.
• Header Information: Emails will feature valid header information, including the correct "From," "To," and "Reply-To" data that accurately identifies the sender, recipient, and email address origin.
• Subject Lines: The subject line of any email will not be deceptive and will accurately reflect the content of the message.
• Opt-Out Mechanism: Each email will include a clear and conspicuous explanation of how the recipient can opt out of receiving future emails from us. This mechanism must be easy to execute and must be processed within 10 days of the request, with no cost to the recipient.
• Physical Address: Our emails will include our valid physical postal address to provide recipients with a way to contact us or manage communications.
• Content Compliance: We will ensure that our email content is in compliance with all laws and regulations applicable to our industry.

We provide all email recipients with the opportunity to opt-out of receiving future emails from us through a link at the bottom of each email. Requests to opt-out are treated seriously and are processed promptly without any further communication or delay.

Privacy Policy Modifications

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.