Privacy Policy for EZcard Service

This Privacy Policy describes how EZ Digital, LLC ("EZ Digital, LLC," "we," "us," or "our") collects, uses, and protects the personal data of residents of the European Economic Area (EEA) who use our EZcard online software service (the "Service"), in compliance with the General Data Protection Regulation (GDPR). If you are not a resident of the EEA, please refer to the general EZ Digital, LLC Privacy Statement available on our website.

1. Data Controller

EZ Digital, LLC is the data controller responsible for the processing of your personal data as described in this Privacy Policy. Our contact information is provided in the "How to Contact Us" section below. Note that we may share and transfer your personal data with EZ Digital, LLC Institute Inc. located in the United States of America, and may do so with other EZ Digital, LLC entities as further discussed below.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data we collect when you use the EZcard Service, including when you visit our website (https://www.ezcard.com/) and any related mobile applications that reference this Privacy Policy (collectively, the "Websites"). We may also collect information from you through other means, such as during technical support interactions, registration forms, in person (e.g., business cards), and from third parties. If we provide a separate or supplemental notice when we collect personal data from you, that notice will govern to the extent of any conflict.

This Privacy Policy does not apply to:

• Information included in materials we receive and process on our customers' behalf through EZ Digital, LLC Cloud Analytics offerings. Please refer to the EZ Digital, LLC Solutions OnDemand Business Customer Privacy Policy for information on how we handle such data.
• Personal data in customer-controlled data to which EZ Digital, LLC may be given access in connection with technical support services, which is subject to EZ Digital, LLC Technical Support Policies.
• Personal data included in customer-controlled data to which EZ Digital, LLC may be given access in connection with consulting services, which is subject to agreements between EZ Digital, LLC and its customers.

"Personal data" refers to any information relating to an identified or identifiable individual, as defined under the GDPR.

3. Personal Data We Collect

We collect the following types of personal data:

• Contact Information: Name, postal address, telephone number, and email address.
• Professional Information: Information about your professional interests and experiences with our products or services.
• Business and Marketing Information: Contact, language, and marketing preferences.
• Transaction Information: Purchase history, order and contract information, delivery and technical support details, and billing information.
• Technical Information: Details about your device, browser, website usage (pages visited, time of visit), and IP addresses.
• Security Data: Data used for authentication and fraud prevention.

4. How We Collect Personal Data

We collect personal data through various means:

• EZ Digital, LLC Profile: Information you provide in your EZ Digital, LLC Profile.
• Registration and Forms: Information provided through registration, surveys, and other online forms.
• Sales Process: Information collected as part of an ongoing sales process.
• Support Interactions: Information collected while providing technical support, consultation, live chat, or product information.
• Product Maintenance: Information collected through the process of maintaining and upgrading our products.
• Automated Means: Communications protocols, email communications, cookies, web beacons, pixels, and other related technologies, as detailed in the EZ Digital, LLC Statement on Cookies and Related Technologies.
• Mobile Applications: Through our mobile applications (some of which may be managed by third parties on behalf of EZ Digital, LLC).
• Surveys and Promotions: Your participation in surveys, contests, and promotions.
• Social Media: Your use of social connectors and EZ Digital, LLC-affiliated social networking areas, including interactions with us on third-party social media platforms.
• Online Advertising: Your interest in EZ Digital, LLC ads placed on third-party sites.
• Statistical Analysis: Using statistical analysis or other automated means to make inferences about your interest in particular EZ Digital, LLC products and services.

Personal data collected online may be combined with information you provide through other sources such as product registration, call centers, or events like trade shows, training seminars, contests, promotions, and conferences. Where permitted by applicable law, we may also add information gathered from social media platforms and other published sources to the data you provide.

5. How We Use Your Personal Data

We may use your personal data for the following purposes:

• Order Fulfillment: To fulfill subscription requests, orders for software and services made online, and to provide other information you request.
• Customer Support: To provide customer support and communicate with you about your orders, purchases, accounts, requests, questions, and comments.
• Business Partner Management: To manage our relationships with vendors, suppliers, and other business partners, and to communicate with them.
• Marketing Communications: To inform you about important news about EZ Digital, LLC, our new products and services, product updates, technical support issues, events, and special offers we think you may be interested in.
• Website Improvement: To make the Websites easier to use, such as by identifying you across platforms or devices for a consistent user experience, and customizing content and advertising relevant to your interests through analytics and profiling technology.
• Feature Facilitation: To facilitate the use of certain features of the Websites, including collaborative forums and communication channels like EZ Digital, LLC Support Communities, should you wish to use them.
• Security: To protect the security and integrity of EZ Digital, LLC Websites, systems, servers, and other technical assets.
• Fraud Prevention: To prevent and detect fraud or other prohibited or illegal activity.
• Data Anonymization: To anonymize data to gain insights about history, processes, operations, and customer experiences without information that can be associated with an identifiable individual.
• Business Operations: To operate, evaluate, and improve our business, including developing new products and services, managing our communications, and performing accounting, auditing, billing, reconciliation, and collection activities.
• Legal Compliance: To meet legal requirements, or as required by a judicial process or a government request, and to establish, exercise, or defend a legal claim.
• Policy Compliance: To comply with industry standards and our policies.

We analyze our web services, such as browser session page views, registrations, demos, downloads, and email responses, in aggregate and sometimes at the individual level to improve the quality of those offerings and to better tailor our marketing to our customers' needs. We may also use statistical analysis to accomplish the purposes listed above, including to better understand your marketing preferences and tailor our offerings to you.

We may process your personal data for the above purposes when:

• It is needed for contract performance or to take steps to enter into a contract with you.
• EZ Digital, LLC needs it to comply with certain legal obligations.
• EZ Digital, LLC' legitimate business interests require it, including for marketing and improving our services, protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, and guaranteeing the security our networks and systems.
• We obtain your consent, for example, before sending you promotional emails about EZ Digital, LLC products and services.

6. How We Share and Transfer Your Personal Data

We will not sell, rent, lease, or disclose your personal data to others except as described in this Privacy Policy.

We may share your personal data with other EZ Digital, LLC entities. EZ Digital, LLC is a global corporation with subsidiaries, affiliates, and business partners in many countries, and with technical systems that cross borders. As a result, when we share your personal data with other EZ Digital, LLC entities, we may transfer this data across country borders, and store or process it in the United States or any other country in which EZ Digital, LLC or its subsidiaries, affiliates, or business units maintain facilities. EZ Digital, LLC has taken measures to ensure that all personal data is transferred among EZ Digital, LLC entities, including to countries outside of the EEA. For any such transfers, we rely on Standard Contractual Clauses between EZ Digital, LLC entities. You may obtain a copy of our Standard Contractual Clauses (from which the commercial information and information that is not relevant has been removed) by sending a request to [email protected].

We may also disclose your personal data to third parties, including:

• Our vendors, subcontractors, and processors; and/or business partners for purposes related to those described above.
• Companies other than EZ Digital, LLC entities in connection with a sale or transfer of all or part of our business or assets.
• Information you choose to make available to participants in EZ Digital, LLC Support Communities and other online communication channels.
• Law enforcement or other government officials upon request if we believe such disclosure is necessary or appropriate.
• As we otherwise believe is necessary to protect our rights or property, including the security and integrity of the Websites.

Some of these third parties may be located outside of the EEA. When transfers to these third parties occur, we transfer your personal data in compliance with applicable law, such as by concluding Standard Contractual Clauses with our vendors, subcontractors, processors, and business partners. Where applicable, you can obtain a copy of such Standard Contractual Clauses (from which the commercial information and information that is not relevant has been removed) by sending a request to [email protected].

7. Your Rights and Choices

The GDPR provides you with certain rights regarding your personal data:

• Access, Correction, and Portability: You may reasonably access the personal data relating to you. You also have the right to request to correct incomplete, inaccurate, or outdated personal data. To the extent required by applicable law, you may request the transmission of the personal data you have provided to us to you or another company.
• Objection: You may object to any uses or disclosures of your personal data that are not (i) required by law, (ii) necessary for the fulfillment of a contractual obligation, or (iii) required to meet a legitimate need of EZ Digital, LLC. If you object, we will work with you to find a reasonable accommodation.
• Deletion: You may request the deletion of your personal data, as permitted under applicable law. This may apply, for instance, where this information is outdated or the processing is no longer necessary or is unlawful; where you withdraw your consent to our processing based on such consent; or where we determine we should accommodate an objection you have raised to our processing. However, sometimes we may need to retain your personal data to comply with our legal obligations, for the establishment, exercise, or defense of legal claims, or in some cases, to fulfill the purposes for which your information was gathered.
• Restriction of Processing: You may request that we restrict processing of your personal data while we are processing your request or complaint pertaining to (i) the accuracy of your personal data, (ii) the lawfulness of the processing of your personal data, or (iii) our legitimate interests in processing this information. You may also request that we restrict processing of your personal data if you wish to use the personal data for litigation purposes.
• Withdraw Your Consent: You may withdraw any consent you previously gave us regarding the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of the processing before your consent was withdrawn.

In addition, EZ Digital, LLC offers you the choice of receiving different types of communication and information related to our company, products, and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your email communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your EZ Digital, LLC Profile page. In some cases, you may separately elect to receive marketing communications from other EZ Digital, LLC business units and affiliates, such as JMP, a division of EZ Digital, LLC; you may opt out from email communication about JMP products and services at any time.

You may exercise these rights free of charge unless the request is unfounded or excessive, for instance, because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by applicable law. Before EZ Digital, LLC is able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request.

To exercise your rights, please complete the Data Privacy Rights Form or contact us using the information provided below. In all cases, you have a right to file a complaint with a data protection authority, in particular in the country of your habitual residence, your place of work, or where you consider that your privacy rights have been infringed.

8. Data Security and Data Retention

EZ Digital, LLC takes care to guard the security of your personal data. We apply appropriate physical, technical, and organizational measures that are reasonably designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. We use enhanced security measures when processing any sensitive information, such as by employing encryption technology when collecting or transferring credit card information. Credit card numbers are used only for processing payment and are not used for other purposes.

We keep your personal data for as long as necessary to fulfill the purposes outlined in this Statement, to adhere to our policies, and for any period as legally required or permitted by applicable law.

9. External Links

Links to third-party websites from our Website are provided solely as a convenience to you. If you use these links, you will leave this site. We have not reviewed these third-party sites and do not control them. EZ Digital, LLC does not assume responsibility for any of these sites, their content, or their privacy policies. EZ Digital, LLC does not endorse or make any representations about them or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites linked to this site, you do so at your own risk, and we invite you to read their privacy policies.

10. Changes to This Statement

If there are updates to the terms of this Privacy Policy, we will post those changes here and update the revision date in this document so that you will always know what information we collect online, how we use it, and what choices you have. Your continued use of the Website following the posting of changes to this Privacy Policy means you accept those changes.

11. How to Contact Us