Service Privacy Notice

Paze◊ Service Privacy Notice

Updated:  June 25, 2024

This Privacy Notice applies to users of the Paze Service.

Thank you for using Paze. We take your privacy seriously and we want you to be fully informed about how we collect, use, disclose, and retain your Personal Information in order to provide the service.

This Privacy Notice applies to the Paze Service (referred to as “Paze” from here on out). It describes the Personal Information we collect, how it’s used and disclosed, and the choices you can make. We strive for transparency but if anything remains unclear, do not hesitate to contact us at the email address below with any questions or feedback you may have.

To make this Privacy Notice easy to find, we make it available through a link in the Paze checkout experience, in the Paze wallet management website accessed at https://mywallet.paze.com, and on the paze.com website.

Paze will collect, use, disclose, and retain your Personal Information as described in this Privacy Notice, including future updates. If you would like to opt out of using Paze, please click here to visit the Paze wallet management website.

Privacy Notice Contents 

  1. When this Privacy Notice applies
  2. What is Personal Information?
  3. Personal Information we’ve collected, used, and/or disclosed
  4. How we collect Personal Information
  5. How we use Personal Information
  6. Who we disclose Personal Information to
  7. How we use cookies and tracking technologies
  8. Minors’ privacy
  9. Your choices
  10. Our data retention practices
  11. How we protect Personal Information
  12. Where Personal Information is stored
  13. Changes to this Privacy Notice
  14. How to contact us

 

Paze◊ Service Privacy Notice 

1. When this Privacy Notice applies 

This Privacy Notice is provided by Early Warning Services, LLC (“Early Warning”) and applies to Paze.

Accordingly, this Privacy Notice only applies to the data processing activities Early Warning undertakes to provide Paze. This notice does not apply to any other data processing activity at participating merchants or participating financial institutions (your debit or credit card issuer). Please see their respective privacy notices for information on their privacy practices. Additionally, this Privacy Notice does not apply to other Early Warning products or services (e.g., Zelle®).

2. What is Personal Information? 

For the purposes of this Privacy Notice, “Personal Information” means information that identifies or can be used to identify you directly or indirectly. Examples of Personal Information include, but are not limited to, Social Security number (SSN), first and last name, email address, physical address, telephone number, IP address, device information, and bank account information.

Personal Information does not include information obtained from public sources or information that is made available by federal, state, or local governments. Personal Information also does not include deidentified, anonymized, or aggregate information.

3. Personal Information we’ve collected, used, and/or disclosed 

The following is a list of categories of Personal Information we may have collected, used, and/or disclosed in the past 12 months in order to provide Paze.

Categories of Personal Information we’ve collected in the last 12 months: Examples of Personal Information that we collect:Categories of sources from which Personal Information is collected: Business purpose(s) for collection, use, and disclosure: Disclosed for business purpose(s) to the following categories of third parties: Sold or shared (for targeted advertising) to the following categories of third parties: Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
Cardholder DataCardholder name, billing address, credit card account number (tokenized), card expiration date, email address, mobile telephone number, date of birthCategory 4.b (participating financial institutions) below.Categories 5.a, 5.b, 5.c, 5.d, 5.e, 5.f, and 5.g below.Categories 6.a (originating participating financial institution), 6.b, 6.c, 6.d and 6.e below. NoneUp to 7 years after inactivation (e.g., opt out of Paze or removal of all cards)*
Merchant DataEmail address (encrypted), shipping address, shopping session information, transaction dataCategory 4.c (participating merchants) below.Categories 5.a, 5.b, 5.e, 5.f, 5.g, and 5.h below.Category 6.b, 6.c, 6.d, and 6.e below. NoneUp to 7 years after inactivation (e.g., opt out of Paze or removal of all cards)
Fraud DataDevice data, session information, transaction data, IP address, browser type, unique device ID, cookie dataAll categories listed below in Section 4.Categories 5.a, 5.b, 5.e, and 5.g below.Categories 6.a, 6.c, and 6.d below.NoneUp to 7 years after inactivation (e.g., opt out of Paze or removal of all cards)
Consumer Profile DataCardholder Data, Social Security number (hashed), Paze opt-outs, default card selection, shipping address, wallet ID, wallet stateAll categories listed below in Section 4.Categories 5.a, 5.b, 5.c, 5.d, 5.e, 5.f, and 5.g below.All categories below in Section 6.None

Up to 7 years after inactivation (e.g., opt out of Paze or removal of all cards)

· Indefinite (e.g., hashed SSN, Wallet ID, Wallet state, Paze opt out status)*

Other information about you that is linked or linkable to the Personal Information above All categories listed below in Section 4.Categories 5.a, 5.b, 5.c, 5.d, 5.e, 5.f, and 5.g below.Categories 6.a, 6.b, 6.c, and 6.d below.NoneUp to 7 years after inactivation (e.g., opt out of Paze or removal of all cards)

* If you opt out of Paze before activating and using your Paze wallet, Cardholder Data will be deleted and will not be retained for seven years; however, some Consumer Profile Data will be retained indefinitely to honor your opt-out request.

4. How we collect personal information 

We collect Personal Information from various sources to provide Paze◊, including:

a. Directly from you: Information collected directly from you in the Paze experience (e.g., your shipping address(es)).

b. From participating financial institutions: Participating financial institutions provide credit and debit card account numbers and expiration dates and related information such as your name, Social Security number (hashed and not readable by Early Warning) or Taxpayer Identification Number, email address, mobile phone number, date of birth, and billing address (e.g., “Cardholder Data”).

c. From participating merchants: When you use Paze to make a purchase with a participating merchant, we collect information about your transaction. Participating merchants may share your email address and/or mobile telephone number with us during checkout on the merchant website to enable us to find your Paze wallet. Please note that the email address and/or mobile telephone number we receive is encrypted and is not readable by Early Warning. In addition participating merchants may provide additional shopping session and transaction information to make effective fraud decisions about your interaction.

d. From your device: We collect technical data about your device when you use Paze (e.g., your browser type, your device’s IP address, unique device ID); and

e. From our service providers: We work with service providers that may provide us with Personal Information to help us provide Paze (e.g., service providers that help us verify your identity when you use Paze and reduce fraud).

5. How we use Personal Information 

We collect, use, and disclose Personal Information for the following business purposes:

a. Wallet Provisioning, Maintenance, Transaction Facilitation & Operations

a. to facilitate the creation of your Paze wallet and resolve related issues to tokenize your payment credentials

b. to perform activities such as account servicing, and providing analytic services

c. to facilitate transactions

d. to help provide you with a safe and efficient experience

b. Identity Verification & Authentication (to validate your identity, authenticate you, and enable secure use of Paze)

a. to verify your identity

b. to enable your access to Paze

c. Choice & Consent (to effectuate your choices and consents)

a. to respond to your requests and comply with your stated communication preferences

b. to opt you out of Paze per your request

d. Communication & Notification (to contact you or notify you of relevant information)

a. to send you notifications pertaining to Paze

e. Fraud Detection & Prevention (to manage fraud and risk)

a. to prevent, detect, and protect against security incidents, fraud, and prohibited or illegal activities

b. to conduct fraud prevention, risk management, remediation and fraud program activities

f. Paze Analytics & Research

a. to identify and repair errors that impair existing or intended functionality

b. to research and resolve issues related to transactions

c. to conduct data analysis

g. Legal & Compliance (to comply with applicable laws and regulations and enforce our terms and conditions)

a. to enforce the Service Agreement

b. to respond to lawful requests by law enforcement, government agencies, and other authorized third parties

c. to comply with applicable law

h. Improve the Paze Service

a. to create, develop, and improve the service

6. Who we disclose Personal Information to 

We may disclose Personal Information to the following categories of third parties for the business purposes we described above in Section 5:

a. participating financial institutions;

b. participating merchants;

c. our service providers (e.g., companies that help us provide Paze);

d. law enforcement, government agencies, and other authorized third parties (we may be required by law to disclose information); and

e. other entities with your consent.

All disclosures to non-affiliated third parties are for the specific purpose(s) of providing the Paze service. We do not permit third parties to use the Personal Information they receive for any purpose other than those required to provide the service and to comply with law. 

If we sell or transfer all or substantially all of our business, or all or a material part of our assets, or are otherwise involved in a merger, acquisition, or transfer of all or a material part of our business (including transfers made as part of insolvency or bankruptcy proceedings), we may transfer information we have collected and stored, including your Personal Information, to the party or parties involved in the transaction as part of that transaction (e.g., new corporate owners).

7. How we use cookies and tracking technologies 

On paze.com

Like most websites, we use “cookies” and similar technologies (e.g., pixels and web beacons) to operate and improve our website, paze.com.

Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).

For more information on how paze.com utilizes cookies, please see the Paze.com Cookies and Tracking Policy.

In the Paze◊ Service

During the Paze service checkout experience, we only use strictly necessary, analytics, and performance-related cookies. These cookies are placed on your device when you initiate an interaction with Paze. These cookies are needed to provide basic functions on the website. We may use cookies and tracking technologies required to prevent fraudulent activity, improve security, and/or for system administration. These cookies are required to operate Paze. Without them, Paze cannot operate so they cannot be disabled. If you have certain privacy settings enabled on your device or if you clear your cache, you may experience additional authentication sequences when you return to Paze.

8. Minors’ privacy 

Paze◊ is only available to individuals the age of 18 and over.

Paze is not intended for children under the age of 18. We do not knowingly solicit or collect information from any individuals under the age of 18.

9. Your choices

Paze Wallet Management

You can view card details, add or remove cards from your Paze wallet, and view your profile details within the Paze wallet management website accessible at https://mywallet.paze.com . Accessing the wallet management site requires you to fully authenticate yourself, helping to ensure a secure environment to manage your wallet.

Paze Opt Out

You can choose to opt-out of Paze when the Paze experience displays on a participating merchant’s website or by clicking here to access the Paze wallet management website. For authentication purposes, you will be asked to request a passcode to be delivered via text message or email to opt-out. If you opt-out of Paze, your card details will be deleted from your Paze wallet, but some of your Personal Information will be retained to help prevent fraud, to honor your opt-out request, and to comply with law. After opting out, you will no longer have the ability to use Paze to make transactions with participating merchants. If you later want to use Paze, you may be able to add eligible credit and debit cards through your participating financial institution.

Communication Preferences

To cancel text messaging from Paze, send STOP to 24636. For help or information regarding text messaging, send HELP to 24636. You expressly consent to receipt of a text message to confirm your “STOP” request. However, text messages are a critical security element of the Paze service and failure to receive text messages will make the service unusable.

10. Our data retention practices

We generally retain information for as long as it is reasonably necessary and relevant for our business operations and to comply with applicable law. See Section 3 for more information.

 

11. How we protect Personal Information

To help us protect your Personal Information, we maintain technical, physical, and administrative security measures to protect against loss, misuse, unauthorized access, disclosure, or alteration. However, no website, mobile application, database, or system is completely secure. You are also responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or misuse.

 

12. Where Personal Information is stored

We are located in the United States. Our services are available for eligible United States users only. Our operations use a network of computers, cloud-based services, and other infrastructure and information technology that are based in the United States. Additionally, we may use third-party service providers that may be located in and process or store your Personal Information in the United States, the European Union, and other countries.

 

13. Changes to this Privacy Notice

From time to time, we may update this Privacy Notice. We may notify you about material changes in the way we process Personal Information by placing a notice on our website. You should check this Privacy Notice frequently for updates.

 

14. How to contact us

If your questions are not answered in this Privacy Notice, you may email us at  [email protected], or write to us at Early Warning Services, LLC., Attn: Privacy Office, 5801 N Pima Rd, Scottsdale, AZ 85250.

If you need assistance with Paze◊, please visit https://www.paze.com/.