Last Modified: February 3, 2021
Capital Retail Solutions, Inc. (“CRS”), its affiliates and partners are committed to your privacy. We have instituted, and will continue to update, these comprehensive privacy policies and procedures. This is to ensure that our retailer account owner customers, Portal users, consumers and website visitors, ("Customers" or "you") are informed of applicable rights and given clear instructions on how to exercise your rights.
The purpose of this Policy is to inform you of the types and categories of personal information that CRS, including its brands, affiliates, partners, and service providers collect, use, share, and retain. CRS also provides instructions on how you can manage your personal information. Depending on where you reside, you may request the disclosure, deletion, or restriction of any sale or monetization activities of your personal information.
We do not require you to provide your personal information to us to enjoy some of our services. However, if you do not provide certain personal information, you may not be able to use or access portions of our Portal or website, such as the account features, account information, or services.
We reserve the right to change this Policy by publishing new terms on our Portal or website at any time. When we do, we will revise the effective date above. Your continued use of our Portal, website and services after such changes means you accept the Policy as revised. We encourage you to periodically review this Policy to stay informed about how we collect and process your personal information.
Categories and Types of Personal Information We Collect:
CRS collects personal information, which is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or consumer. This collection is a critical element in CRS's day-to-day operations in order to offer services, complete transactions, and maintain the highest level of customer service for all of our Customers and website visitors.
The personal information CRS collects and processes depends on how, where, and why you interact with us. Some of the personal information CRS collects or may collect includes:
Product and Service Purchases - If you purchase a product or service from CRS, an affiliate or partner, we may ask you for the recipient mobile number, the purchaser’s mobile number, the purchase amount, a barcode, the name on the account, whether payment is in US or foreign currency, the recipient’s name and/or mailing address in order to credit or provide the product to the individual.
Commercial or Transaction Information – In order to complete transactions and for the convenience of Customers and consumers, CRS collects credit card information, including account numbers, card holder names, telephone numbers and addresses. CRS collects data regarding Customer’s Portal transactions, account, usage, billing and payment history. Also, CRS will have records of product purchases on the Portal, including telephone and top-up services purchases, gift card purchases and bill pay services purchases, as well as redemptions, activation and port-in history, and records of information of products or services placed into the Customer’s or a consumer’s online cart.
Customer Proprietary Network Information (CPNI) and other Electronic Activities – As a provider of wireless telephone services on the Portal, CRS, its affiliates or partners are required to collect certain personal information in connection with your wireless services. CPNI, for example, is a subset of the personal information that is generated in connection with the telecommunications services CRS, its affiliates or partners provides to its consumers. CPNI includes, for example, call detail records, call location information, and information about your rate plans and features. Additionally, CRS maintains several internet webpages and mobile apps to inform Customers about plans, services, and help complete transactions. As part of this, CRS will collect certain information including browsing history, search history, interaction with website and apps, and interaction with advertisements.
Identifiers – Identifiers are any personal information that can be associated with a specific individual, entity or device. Examples of these identifiers include Customer or consumer name, alias, postal address, telephone number, e-mail address, partial or full social security number, recipient telephone number, and other similar identifiers.
Categories of Personal Information – These are other types of personal information collected from the Customer to facilitate business transactions. These include, for example, telephone numbers, signature, credit or debit card information, credit or debit card expiration dates, receipt data, and other financial or medical or financial records.
Characteristics of Protected Classification – Other information that CRS may receive and store is information viewed as characteristics of protected classification under state or federal law. Information that may be included in this category includes age, gender, marital status, disability, medical information, and military or veteran status. For identification and verification purposes, CRS may ask the Customer or consumer to provide a copy of his/her driver’s license. By doing so, CRS may see, but does not actively collect, other information about the Customer or consumer including race, color, religion, or national origin.
Network, Device, and Geolocation Information – We may collect information about your use of your device and our network, how you use or access our service or website, Wi-Fi usage, geographic locations, and performance information. Some examples of this type of information include internet protocol (IP) addresses, the type of internet browser you are using, the type of operating system you have configured on your computer or phone, the domain name of the website and/or Internet Service Provider (ISP) from which you are linked to our website, the model of wireless device that you are using, device identifier ("UDID"), web browsing and wireless application use information, date and time stamp, and clickstream data to analyze trends in aggregate and administer our website.
Inferences – CRS always seeks to provide the best service, products, features, and selections to our Customers. As part of this, we may develop profiles on our Customers to determine which service, prices, and offers would best suit their needs. As such, CRS may have inferential information on our Customers including preferences, predispositions, and behavior to see what product plans or offerings would be competitive in the marketplace.
Service Initiation and Customer Service - CRS does not have access to the content of private e-mail communications and text messages that are transmitted using CRS services. CRS may collect Customer text message information regarding product purchase or service initiation, as well as Customer service call records.
Educational, Professional, and Employment Information – CRS does not actively seek educational or employment information about our Customers.
How Personal Information is Collected:
Personal Information Submitted to Us. We collect personal and non-personal information from Customers based upon our business relationship with you. You supply information to us when you use or access our products and services, when you visit our Portal or website, when you make a purchase from us, or when you establish or modify an online account. Additionally, you may also provide us with information when you interact with our Customer service representatives.
How Personal Information is Used:
Business Relationship Purposes. CRS uses your personal information for various purposes, including but not limited to, billing purposes, to provide or change service, to anticipate and resolve problems with your service, for fraud prevention purposes, to comply with legal requirements, to communicate with you, to manage and administer our Portal, websites and services, for auditing and accounting purposes, to collect and process transactions, or to inform you of products and services that better meet your needs. This means that CRS may use your information in conjunction with information available from other sources to market new services that may be of interest to you. We also use your information for market research and for optimizing our systems in order to deliver the best customer experience possible.
How Personal Information is Shared:
Third Party Service Providers. Your wireless number may be shared for text messaging services operated by third party service providers. These vendors may directly contact you on our behalf by text messages with promotions, discounts, advertisements, reminders related to your services, or other information that may be helpful or informative to you. An opt-out mechanism is provided in these messages in compliance with applicable laws.
Third-Party Service Providers Obligations. When CRS uses third parties to perform services on our behalf, such as marketing, fulfillment services, and shipping to Customers, CRS will require that such third parties protect and restrict use of your personal information consistent with the terms described in this Policy.
CRS may further share Customer personal information in the following situations:
With affiliated and unaffiliated service providers and partners who help us perform and deliver our website and services, subject to confidentiality agreements where reasonably feasible, including service and sales fulfillment; form processing; website management and hosting providers; information technology and security providers; customer service; email and newsletter delivery services; background check providers; credit agencies; advertisement partners and corporate sponsors; and auditing providers.
With third parties to investigate and help prevent fraud, other unlawful activity or activity that threatens a service network.
With legal, governmental, or judicial authorities as reasonably requested or required by those authorities and applicable laws, or in relation to legal activity, such as to comply with a subpoena, request by public authorities for meeting national security or law enforcement requirements, or other similar legal process.
With the appropriate government and law enforcement authorities, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
With persons or any third party of your choosing and at your discretion; and
With necessary third parties in connection with, or during negotiations for, a merger, acquisition, or sale of all or a portion of CRS’s assets.
Software Application for Our Portal/Websites. CRS also works with other companies who may supply software applications for use on our Portal and websites. The software may be used to collect survey or feedback information or support real-time chat sessions from Customers who visit our website and utilize these tools. Information from your Portal or web session, including your device serial number, phone number, and account email may be associated with your responses when utilizing these tools. This information is used by CRS exclusively for analysis of survey or feedback results and will not be shared with any third party for any other purposes.
How Long Your Personal Information is Retained:
We will retain your personal information only as long as needed for business, tax, retention, and legal purposes. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Your information will be deleted when all of the following conditions are met:
once it is no longer needed.
when there is no legal obligation to retain it.
at the end of CRS’s information retention period; and
upon receipt of a verified request and where it can be deleted without affecting CRS’s legal obligations or ongoing business needs.
Absent a specific request to delete your personal information, as permitted by law, CRS will delete your information per its normal business processes and procedures.
How Personal Information is Secured:
CRS uses administrative, organizational, technical, and physical safeguards to protect the personal information it collects and processes. Nonetheless, CRS cannot guarantee your personal information will be perfectly secure at all times. Our security controls are designed to maintain data confidentiality, maintain data integrity, and give us an appropriate level of access to your data. For example, when you enter sensitive personal information (such as a credit card number or wireless phone number) on our Portal or forms, we encrypt the transmission of that information using secure socket layer technology (SSL). CRS, based on its reasonable judgment, will continue to enhance its security procedures as new technology becomes readily available. If you have any questions about security on our website, you can contact us at firstname.lastname@example.org.
How Customers Can Restrict the Sharing of Personal Information Used in E-Mail Marketing:
Declining E-mail Offers. CRS will only send our Customers e-mails regarding promotional offers or other news if a Customer grants us permission to do so by providing an email address. If a Customer does provide us an email address, we may use it to communicate with the Customer including sending promotional offers or other information.
Opting Out of E-Mail Offers. A Customer always has the right to choose not to receive CRS e-mail direct marketing communications by opting-out or unsubscribing. A Customer can opt-out or unsubscribe from our e-mail list by clicking on the unsubscribe link found at the bottom of every message or promotion delivered electronically to our Customers. Upon such election and within a reasonable time thereafter, CRS (a) will not contact that Customer directly with CRS promotional messages, and (b) will not use personal information obtained from that Customer's registration to contact that Customer with CRS product messages.
Links to Other Websites:
Third Party Links. CRS's Portal and websites may contain links to other websites that are not owned, operated, or controlled by CRS. Any personal information collected by such third party websites or links is not governed by this Policy. We recommend that you examine the privacy policies of such third party websites or links prior to submitting any personal information.
Third-Party Websites. In some instances, our website content is also featured on other websites with differing or non-existent privacy policies. These websites may collect personal information from website visitors that may or may not be used in conjunction with our website information. Prior to supplying personal information to any third party company linking to our website, please read and understand their privacy policies.
How Customers And Visitors Can Access And Update Personal Information:
You may call us at 855-922-4325 or mail us at email@example.com. In certain circumstances we may be required by law to retain your personal information or may need to retain your personal information in order to continue providing a service.
How to Contact Us:
Address: Capital Retail Solutions, Inc.
5704 Lonetree Blvd.
Rocklin, CA 95765
If you have any questions or unresolved privacy or data use concerns not addressed above to your satisfaction, please contact us at firstname.lastname@example.org, by calling customer service at 855-922-4325 or by mail at the address above.
California Privacy Notice
Last Modified: February 3, 2021
What is Personal Information and what does CRS collect?
For this Notice, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with, directly or indirectly, with you. Personal information does not include information that is aggregated, de-identified or information that cannot be reasonably linked to you.
To provide our services, we must process some information about you, including personal information.
Transaction information. You may provide your mobile phone number, the recipient mobile number, the purchase amount, whether payment is in US or foreign currency, and related information.
Other information. We sometimes collect drivers license information for identification and regulatory purposes. Information that may be included in this category could include age, gender, marital status, disability, medical information, and military or veteran status.
Customer support. You may provide us with information related to your use of our services, including some of the above information, and how to contact you so we can provide you customer support.
How do we use Personal Information?
How is Personal Information Shared?
We do not sell your personal information, and never will. You share the information you provide as you purchase and use our services, and we share each category of your personal information for business purposes to help us operate, provide, improve, understand, customize, support and market our services.
Service providers. Our affiliates, partners and service providers help us operate, provide, improve, understand, customize, support and market our services. For example, we work with retail stores and other companies to market and distribute our portal, provide our infrastructure, delivery, and other systems, supply information, help us understand how people use our services, and market our services. When we share information with our service providers, we require them to use your information in accordance with our instructions and terms or with express permission from you.
Legal process requests. We may share your information with law-enforcement or other third parties in connection with legal requests.
How can you exercise your rights under the CCPA?
Under the CCPA, you have the right to access the personal information we've collected about you during the past 12 months and information about our data practices. You also have the right to request that we delete the personal information that we have collected from you.
To request manual access or deletion of your personal information, please contact us at email@example.com, or by calling customer service at 855-922-4325.
Please note, for all manual requests, you will need to verify your identity by providing us with the following information:
Your full name.
Your email address.
Your Mobile number.
Whether you are a California consumer pursuant to Cal. Civ. Code Sec. 1798.140(g).
If you would like to know the specific pieces of personal information that we have collected about you, or to delete your personal information, you will need to provide the following additional information to verify your identity:
A recent wireless invoice or similar proof of ownership of your mobile number.
CRS will not be able to respond to your request unless you provide us with all of the above information. You can also designate an authorized agent to make a manual request on your behalf. If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent’s power of attorney. We may also follow up with you to verify your identity or before processing your authorized agent request.
Finally, you have the right to be free from any discrimination for exercising your right to access or delete your personal information. We will not discriminate against you for exercising any of these rights.
If you have any additional questions about this Notice or how to exercise your rights under the CCPA, please contact us as shown under the Policy, “How to Contact Us”.