Elavon Developer Portal Privacy Policy

Effective October 2020

At Elavon, Inc. (together with all successors and assigns, hereinafter "**Elavon**", "we", "us" or "our"), trust has always been the foundation of our relationship with our customers and partners. This Developer Portal Privacy Policy (the "Policy") applies to all commercial (i.e., non-consumer) customers and partners of Elavon and identifiable individuals directly connected with such customers and partners (collectively referred to herein "Users", "you" or "your") who access and use the Elavon Developer Portal (the "Developer Portal"). This Policy only describes and applies to Elavon's collection and use of information that is provided by Users, or collected about Users, at or through the Developer Portal. This Policy does not apply to any other product or service that may be offered to Users by Elavon or any of its affiliates.

1. Types of Information We Collect We may collect "User Information" from Users of the Developer Portal. "User Information" includes (i) identifying information provided by, or collected about, a User through the Developer Portal that is necessary for Elavon to identify the particular User; and (ii) any other information that may be provided by the User to Elavon when utilizing the Developer Portal. Examples of such information include (i) any information provided by a User during the registration process in order to gain access to the Developer Portal, such as User name, postal address, email address, telephone number; (ii) other credentialing information (e.g., account number, access code, etc.); (iii) any User contact information; or (iv) any data provided by a User to Elavon through the Developer Portal for purposes of developing, testing, or otherwise using in any way any application programming interface ("API") available through the Developer Portal.

For purposes of this Policy, User Information only includes information that is collected, provided, or otherwise obtained through the Developer Portal.

2. How We Collect Your Information We collect User Information when you provide this information directly to Elavon through the Developer Portal. In addition, some User Identifying Information may be collected about you by Elavon through the use of "cookies," as explained in Section 5, below.

3. How We Use Your Information User Information is used by Elavon only for the following limited purposes:

4. How We Share Your Information We do not share User Information with any party, affiliated or otherwise, for any purpose, except as otherwise provided in this Policy. We may share your User Information with third parties for the purpose of providing you with the services and functionality available through the Developer Portal. Elavon requires all such third party service providers to maintain the confidentiality of information provided to them by us, and to use such information only to provide the specific product or service intended. We may also share such information with third parties as follows:

Elavon may share or disclose information about Users that is aggregated, anonymous or that otherwise does not identify any individual User to unaffiliated third-parties.

5. Online Tracking and Advertising We and certain trusted service providers operating on our behalf collect information about User activity on the Developer Portal using tracking technologies, including:

Information collected through tracking technologies is used for many purposes including, for example, to:

We may associate this tracking data with your registration information, in which case we will treat it as User Information. Service providers that collect tracking data on our behalf may provide an opportunity for you to choose not to be tracked online.

Occasionally, you may encounter banner advertisements for our products and services on third-party websites and mobile applications. We use third-party advertising service providers to distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type and usage information in order to track the effectiveness of our advertising efforts. Such tracking technologies do not capture personal information about you, and our advertising service providers are prohibited from using any information collected except to track advertising effectiveness.

In addition, we use advertising service providers such as Google, Yahoo and Bing to place advertisements for our accounts and services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. We restrict access and collection of information by advertising service providers for purposes other than assisting us with our advertising efforts.

Do Not Track. There is no industry standard for how Do Not Track consumer browser settings should work on commercial websites. Due to the lack of such standards our websites do not respond to Do Not Track consumer browser settings.

6. Data Security Your privacy is very important to Elavon and we are committed to protecting your User Information from unauthorized access or use. We have implemented physical, technical and administrative security measures that comply with federal law and industry standards, including network firewalls, Secure Sockets Layer (SSL) encryption for online sessions, dedicated security teams and secured files and buildings. The Internet, however, is inherently unsecure, and Elavon does not guarantee the security and confidentiality of information you provide through the Developer Portal.

Users have the responsibility to help Elavon protect User Information by never revealing such information to unauthorized third parties.

7. Preventing User Information Theft In order to help us protect your User Information, it is important that you always keep your Developer Portal account information safe, including any name, access code, account number, or other credential information used to gain access to the Developer Portal.

Note that Elavon will never initiate a request via email or otherwise for your User Information. If you receive an email asking for such information, you should be suspicious of the request and promptly contact us at #SEDevPortalSupport@elavon.com to report the suspicious activity.

8. Changes to the Policy From time to time, we may make changes to this Policy in order to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We encourage you to review this Policy periodically to ensure that you understand how we collect, use and share information through the Developer Portal. If we do make changes to this Policy, we will also update the "Effective Date" posted at the top of the Policy.

Any changes to the Policy will become effective when the revised Policy is posted on the Developer Portal. By continuing to use the Developer Portal following such changes, you are agreeing to accept the terms of the revised Policy.

9. Governing Law The Developer Portal is intended for use in the United States of America. We attempt to protect the User Information of all users of the Developer Portal and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to the Portal, but the Portal is targeted to United States of America citizens and our policies are directed at compliance with those laws.  If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your User Information to Elavon.

10. Contact Us If you have any questions or comments about this Policy, or our privacy practices generally, we encourage you to contact our customer service department by emailing us at privacypolicyinfo@elavon.com .