Privacy Policy

Last Updated: 03/01/2022

Please note - This Privacy Policy includes important information about what you agree to by using DisburseCloud Technology and we encourage you to read it carefully - 

DisburseCloud (“DisburseCloud”, “we”, “our” or “us”) is on a mission to enable digital payments for claims and/or payments for a multitude of business verticals resulting in increased customer retention, revenue, and compliance for those that serve them. DisburseCloud’s developer-friendly API and complementary products (“Product”) lets businesses and financial institutions easily embed payments into their products. 

1. *Definitions

1.1 Clients - Direct customers of DisburseCloud

1.2 Customer Dashboard - web portal provided to Client’s to perform activities such as but not limited to measuring product usage, debugging,  API key management and defining access management.

1.3 End Users - Individuals accessing financial services with DisburseCloud API embedded for functionality (can be once or twice removed depending on business structure of DisburseCloud Clients)

1.4 Payer - Type of End User that is providing payment to independent workers, vendors, claimants or policyholders through services utilizing the DisburseCloud product

1.5 Payee - Type of End User that is getting paid (as an independent contractor or self-employed business, claimant, vendor or policy holder) thru services utilizing the DisburseCloud product

1.6 Product - Represents DisburseCloud’s complete Application Programming interface (API) and solutions

1.7 Subscribers - Customers of DisburseCloud’s direct customers in the event DisburseCloud is licensing to middleware providers

1.8 Website - DisburseCloud’s marketing and landing pages

*In the event of a conflict between the definitions set forth in these Terms and your MSA, the definition in the MSA shall apply.

2. Overview 

To support our Clients and their End Users, DisburseCloud collects and processes certain personal data from Clients and End Users, alike. This policy outlines the personal data we collect, use and share, and how we commit to protecting that data along the way. If you have any questions, you can always reach us at legal@withDisburseCloud.com.

3. Data Collection

We may collect and use personal data in the course of providing Product to Clients. While DisburseCloud does not typically collect personal data directly from the End User, DisburseCloud does collect Client-provided data and device data relating to a Client’s integration with DisburseCloud’s API. We also collect limited amounts of Client information.

3.1 End User Data 

3.1.i Data collected from Clients/Subscribers:

DisburseCloud collects personal data about end users to enable Product functionality including, but not limited to, payments, tax services and benefits services.

Data collected varies based on whether the end user is providing payment (“Payer”) or receiving payment (“Payee”). To make sure you understand not only what information may be collected, but what information is likely collected based on how you are interacting with Client offerings, we have broken out data collection tables for Payer and Payee.

3.1.ii Data collected directly from End Users:

In the event an End User were to reach out to DisburseCloud via the website, DisburseCloud would collect limited information directly from the End User including name, email and contact method in order to answer the inquiry. Otherwise no personal data is collected directly from the End User.

3.1.iii Device provided data

Each time an End User accesses a Client interface that is using DisburseCloud Product, we may receive limited personal data.

3.2 Client data

DisburseCloud collects personal data from its Clients or Client’s Customer’s (“Subscribers” for middleware Clients) to support Product functionality offered to Client or Client end users. Personal data that DisburseCloud may collect is listed below.

*Client personal data as collected by the website is subject to the discretion of the Client interacting with the DisburseCloud website. The outline of personal data collected is based on the assumption that Client interacts with the website in a predictable way - making a request, providing name, company and email only.

3.3 Inferences

DisburseCloud may make inferences based on the End User personal data provided in the API. 

3.4 Cookies

DisburseCloud uses cookies only to assist in authentication of select Products including the Customer Dashboard. We do not use cookies for marketing to the End User or for actively facilitating other partners to market to the End User.

This notwithstanding, our website uses cookies and other technologies that record information about you, including:

Usage data, such as time spent on the website, links clicked, pages visited, language preferences, and the pages that led or referred you to our website.

Online activities. We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online services.

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 language version of the Sites you are visiting.

We collect information when you engage with our marketing messages and when you click on links included in ads for our products. We use web-traffic analytics tools on our Sites to help us analyze your use of our Sites and diagnose technical issues.

4. Data Use

At DisburseCloud, our primary mission is to speed up payments to the End User. To that end, we use End User data primarily to provide and maintain our Product, as well as to develop new Products which benefit independent workers.

4.1 End User Data

4.1.i Data collected from Clients/Subscribers:

DisburseCloud may use Client-provided End User data to:

Operate, provide, maintain or modify DisburseCloud Product

Improve or expand DisburseCloud Product through creation of anonymized financial models

Develop new Service offerings

Manage Client relationships, including carrying out our obligations, and exercising our rights, as per Client agreements

Protect End Users, Clients, DisburseCloud and others from fraud, malicious activity, and other privacy and security-related concerns

Investigate any misuse of our Service, including violations of Client policies, criminal activity, or other unauthorized access to our services

Administer and protect the business

Comply with applicable laws, lawful requests and legal processes

DisburseCloud does not market to End Users based on the personal information collected.

4.1.ii Data collected directly from End Users:

In the event an End User provides personal data to DisburseCloud, DisburseCloud may use that data to reach out to assist the End User.

Note - DisburseCloud is contractually obligated to send all End User requests for data modification, updating, deletion or disclosure to Client with whom the End User has an agreement.

4.1.iii Device provided data

All End User personal data collected from devices is used to maintain functionality, performance and security (regardless of point of contact: Website, Customer Dashboard or API)

4.2 Client data

Client personal data collected from the website is used to contact the client POC when responding to a client-initiated request originating from the website. End User personal data collected from the Developed Dashboard is used for DisburseCloud/Client relationship management.

5. Data Sharing

5.1 End User Data

DisburseCloud shares End User data only in support of Product provided to/by Client.

Specifically, DisburseCloud may share information:

With Client application, to support End User functionality

With Client, to enforce Client contract with End User or as outlined in contract between DisburseCloud and Client

With Data processors and other service providers, partners, or contractors in connection with the operation of and vital to DisburseCloud Product

With law enforcement, if we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process

In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy)

Between and among DisburseCloud and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership

As we believe reasonably appropriate to protect the rights, privacy, safety, or property of End Users, Clients, our partners, DisburseCloud, and others

DisburseCloud may collect, use, and share End User Information in an aggregated, de-identified, or anonymized manner (that does not identify you personally) for any purpose permitted under applicable law. This includes creating or using aggregated, de-identified, or anonymized data based on the collected information to develop new products or services and to facilitate research.

DisburseCloud does not sell or rent End User data.

5.2 Client User Data

DisburseCloud shares Client-provided personal data as required by DisburseCloud/Client Contract, by law and/or for reasonable business purposes. Specifically, DisburseCloud may share Client information:

As outlined in DisburseCloud/Client contract

With law enforcement, if we believe in good faith that disclosure is appropriate to comply with applicable law, regulation, or legal process

In connection with a change in ownership or control of all or a part of our business (such as a merger, acquisition, reorganization, or bankruptcy)

Between and among DisburseCloud and our current and future parents, affiliates, subsidiaries and other companies under common control or ownership

As we believe reasonably appropriate to protect the rights, privacy, safety, or property of End Users, Clients, our partners, DisburseCloud, and others

6. Retention Practices

DisburseCloud maintains Client and End User data indefinitely unless otherwise outlined by Client contract. End Users may reach out to their Service Provider (DisburseCloud’s Client) to learn more about specific data retention policy/practices.

7. Data Protection

Your data is important to you, it’s important to DisburseCloud, too. To ensure Client and End User data is as safe as possible, DisburseCloud partners with best-in-class cloud service provider, AWS, encrypts all data whether in transit or at rest and employs reasonable preventative measures (organizational, technical and preventative). If you’d like to know more about security practices at DisburseCloud or have concerns about your security, please reach out to security@DisburseCloud.com - we’d be happy to help.

8. Location

DisburseCloud provides Product to US taxpayers only. To best serve our clients and their end users, all data is stored and processed within the United States of America.

 9. Changes To This Policy

At DisburseCloud, we are always changing and growing and that means the occasional change to our policies. Any updates to this policy will be posted immediately with the date of the last update.

10. Use by Minors

We request that children not provide personal data through DisburseCloud’s website. Further, Clients are not permitted to accept children’s Personal Data through the Services, as the Products are not directed to minors, including children under the age of 13.

11. Contact Us

For questions, comments or concerns with DisburseCloud’s Privacy policy, please contact us at legal@withDisburseCloud.com. For Clients requesting more information, please reach out to your designated contact at DisburseCloud. For all other general inquiries, please feel free to contact us through the DisburseCloud website https://www.DisburseCloud.com.