Privacy Policy

Effective Date: July 19, 2017

  Great American Payment Systems Inc. (“Great American Payment Systems Inc.”) values your privacy and we desire to ensure that your experience with Great American Payment Systems Inc., our websites and related subdomains (the “Sites”) and all of our products, electronic portals, mobile applications, software, blogs, and forums (collectively with the Sites, the “Services”) are satisfying.  In that regard, Great American Payment Systems Inc. has established the following Privacy Policy (“Policy”) to explain and describe what personal information we collect, how we use it, and your options regarding information we may collect about you.  By accepting this Policy you expressly consent to the information handling practices described in this Policy.  In addition, by accepting this Policy you expressly represent that you are over the age of 18 or are not considered a minor in the jurisdiction in which you reside.  Your use of the Services or any other content, products, or other services covered by this Policy constitutes your acceptance of and agreement to this Policy, as updated from time-to-time.  You may access the current version of this Policy on Great American Payment Systems Inc. website or by contacting us to request a copy.  

1. Contact Information. If you have questions about this Policy, please feel free to contact us at:

TransNational Bankcard, Inc. 9550 W. Higgins Road , 8th Floor Rosemont, IL 60018 Telephone: (847) 655-1300 Fax: (847) 655-2422 support@tnbci.com

1. Gathered Information. In describing our collection, use, and sharing of information in this Policy, we refer to our collection and use of Personal Information. “Personal Information” as used in this Policy, is personally identifiable information which directly identifies an individual, such as first and last name, mailing address, email address, credit card numbers, billing information, IP addresses, demographics, usernames, passwords, other online contact information, or telephone number.  We collect Personal Information, as well as non-personally identifiable information through the Services.

• Collection. We collect Personal Information in the following ways:

1. Voluntary. We collect information you provide to us in optional, voluntary submissions, such as in registration forms, applications, user profiles, promotional signups, sweepstakes/contest entries, requests for customer service, software and mobile applications downloads and your voluntary contributions.
2. Through Services. We collect information received in connection with your use of the Services, including transactions processed under any related merchant agreement and information submitted to TransNational Bankcard in connection with the Services.
3. Third Parties. We also obtain information, including without limitation Personal Information, from third party sources. Third party sources may include, but are not limited to, analytics, tracking, and other services we may solicit to collect Personal Information on our behalf, gateway services used to access the Services, and various service providers you may use in connection with the Services.  We may directly combine information received from third parties with Personal Information that we have collected.  We treat and handle all Personal Information in accordance with this Privacy Policy.  Please note that third parties may not be bound by this Privacy Policy.

• Optional Disclosure. You are under no obligation to provide, and can decline to provide, any requested information at any time. By entering information into, engaging in, or using the Services, you are agreeing to provide TransNational Bankcard with all information related to or obtained from such activity.  If you decline to provide information that is reasonably necessary, or otherwise required by TransNational Bankcard, to participate in any of the Services, you may not be able to participate in such Services.
• Cookies. Our Services may use a variety of methods, including “cookies” to collect information.

1. About Cookies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie.  Cookies are useful because they allow a website to recognize a user’s device.  You can find more information about cookies at: allaboutcookies.org.
2. Uses. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.
3. Consent. TransNational Bankcard does not require that you accept cookies and you may withdraw your consent to our use of cookies at any time by adjusting your browser’s privacy settings; however, some functionality on our Sites and Services may be disabled if you decline to accept cookies.

• Disclosure Limitations. Other than as allowed by this Privacy Policy and applicable laws, TransNational Bankcard does not give away information about its users. If you choose to provide Personal Information about yourself, we may use this information to communicate directly with you.  TransNational Bankcard will not sell, rent or otherwise disclose Personal Information to third parties unless that disclosure is allowed under this Privacy Policy, required by law, necessary to provide the Services, or if such disclosure is contained in or associated with specific Site(s) and Service(s).  TransNational Bankcard may freely disclose any information, including Personal Information, which has been aggregated in such a way that makes such information not personally identifiable.
• Location Data. We may collect, use, and share (with TransNational Bankcard partners, service providers and licensees) precise location data, including the real-time information obtained from your device or through your participation in the Services.
• Third Party Analytics. We may use analytics tools and other third party technologies to collect non-personal information in the form of various usage and user metrics when you use our Services.

1.  Tracking. Third party analytics tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and purchase history, MAC Address, mobile unique device ID, and other similar information.
2. Use of Information. The third party analytics companies who collect information on our Sites and Services may combine the information they collect with other information they have independently collected from or through other websites, products, and services. Many of these companies collect and use information under their own privacy policies.

• Tailored Information Use and Sharing. In addition to our use of technologies as described in this Policy, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of the Services and to otherwise collect and use data about your use of the Services.

1. General Information Use. Generally, we use Personal Information to establish and enhance our relationship with our users through four main categories: Communication; Optimization; Advertising; and Sharing Features.

• Communication. We may use your information, including Personal Information, to provide customer support, evaluate and process transactions, respond to participating cardholders requests, respond to merchants requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect users to the Services and to products and services of merchants, our partners, and licensees.
• Optimization. We may use your information, including Personal Information, behavioral metrics, and non-personally identifiable information to operate, provide, improve, and maintain our Services, to develop new products and services, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
• Advertising. We may use user information, including Personal Information, behavioral metrics, geo-location data, demographic data, purchase information, purchase frequency, spending patterns, merchant identification, and marketing preferences to allow TransNational Bankcard to personalize and display advertisements and other content for you.
• Sharing Features. We may use your information, including Personal Information and any other information you submit directly or through passive means to provide you with various ways to connect and share content (e.g., web content , user generated content, text, drawings, media, tools, services and other products) with third parties.

1. Sharing Functions. We may request and use your Personal Information to fulfill any function within the Services which you elect to use. For example, we may provide you with the opportunity to email a link to certain content to another person.  To use this feature, we may require you to provide certain Personal Information including your email address and the email address of each person to whom you send the link.
2. Third Party Sharing. We also may allow you to share links to content with users of various third party services (e.g., social networking, search and sharing services). When sharing links using one of these third party services, if you are not already logged in to the third party service, you will need to supply login credentials for it.  If you are not a registered user of the third party service, you will need to sign up for it.  You are supplying the registration information or login credentials for the third party service directly to that third party, and not to us.  By using any of these third party services to share links to content, you permit us to access, use and disclose any information relating to your account on each third party service (such as your user name and profile information) that is available to us through the third party service, including through its application programming interface (API).

1. Third Party Information Sharing. We do not share Personal Information with third parties except in accordance with this Policy. We may, and may be required to, share certain information, including Personal Information, with third parties as follows:

• Performance of Services. The nature of some of the Services requires us to share your Personal Information with certain third parties. In particular, Services which authorize, capture, and settle transactions, and which perform risk, data security, and analytic functions, require that we share Personal Information and other information with third party vendors facilitating such functions, including without limitation information about each transaction, the time, amount, associated card number, the cardholder name, CVV code, your name, your product makeup, your pricing, and other Personal Information which is related to you and the transaction.
• Affiliates. We may share your Personal Information and other information with affiliates in connection with the performance of, implementation of, or for consulting purposes related to our general information use policies set forth in Section 3 of this Policy.
• Service Providers. We may provide Personal Information to third parties for their use in performing internal business functions (e.g., payment processing, customer service, maintenance, security, data analysis, email transmission, beta testing, or data hosting) on our behalf. In addition, TransNational Bankcard may provide Personal Information to financial institutions in connection with the Services, including any of TransNational Bankcard’s sponsor banks, the payment networks (Visa, MasterCard, Discover, and American Express), and various other third party’s involved in the performance of the Services.
• Partners. When you visit or use a part of any Service, website, mobile application, or other consumer product that is co-branded or that is a part of a joint promotion involving TransNational Bankcard and one or more third parties (each a “Co-Branded Party”), you are providing, consenting to provide, and transmitting your Personal Information and other information provided to, collected, or obtained by TransNational Bankcard and any Co-Branded Parties involved, to TransNational Bankcard and each of the Co-Branded Parties without any other notice or further consent. Please note that we may not control any Co-Branded Parties’ use or treatment of information you provide to them and you should consult each of their privacy policies or any separate Co-Branded privacy policy posted on or linked from the Co-Branded site to determine your rights with respect to their use and treatment of your information.  You will need to communicate with us and each Co-Branded Party directly, as applicable, if you decide you no longer wish to receive communications or if you wish to change any information you have supplied.
• Legal Requirements. We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to prevent violation of our Terms of Use; take precautions against liability; protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our Sites and Services or infrastructure; protect ourselves and our Sites and Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.
• Change of Ownership. Information about our users, including Personal Information, may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction.
• Interactive Features. If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through any of our Sites and Services, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. To request removal of your personal information from our blog, sharing service or community forum, contact us as provided for in this Policy.  In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

1. Information Security.

• Storage. Your Personal Information is stored on web servers that are protected against unauthorized access by third parties. While we take efforts to ensure the integrity and security of our network and systems, we cannot absolutely guarantee that our security measures will prevent third-party “hackers” or other malfeasants from illegally obtaining this information.
• Security Measures. Commercially reasonable physical, electronic and managerial procedures have been employed to safeguard the security and integrity of Personal Information. Only certain employees are authorized to access full and aggregated Personal Information.  Certain information may also be made available to you pursuant to a username, password, or other credentials (collectively “Credentials”) provided by TransNational Bankcard.  It is your responsibility to secure the Credentials and to immediately notify TransNational Bankcard of any compromise of the Credentials.  Any person with the Credentials will be able to access your Personal Information within the Services.  The Credentials belong to TransNational Bankcard and may be revoked at any time.
• Third Party Security. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third party services that may be triggered by using third party services in connection with the Services. You should review the terms of service and privacy policies of each third party carefully before providing any Personal Information to such party, whether directly or through the Services.
• Third Party Access. By using any third party services to log in to your TransNational Bankcard account or access Services, you permit us to access, store and use all information related to your third party account that may be accessible to us through the third party service, including through its application programming interface (API), pursuant to this Policy.

1. Other Important Privacy Information.

• Browser Do Not Track Requests. We do not treat browsers sending “Do Not Track” signals any differently than those that do not. We use affiliates to support this website. Therefore, this website may not comply with “Do Not Track” settings on your browser.
• Modifications. We may update this Policy from time to time. If we do, we will update the “effective date” at the top of the Policy.  You are responsible for checking this Privacy Policy for updates.  Although TransNational Bankcard may elect to notify you of changes to this Privacy Policy, we have no obligation to do so.  We will post the updated Policy on the affected Sites and Services.  We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information.  Your continued use of our Sites and Services or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.
• Children. We take special care to protect the privacy needs of children under the age of 13 and encourage parents to be an active participant in their child's online activities. We abide by the requirements of the Children's Online Privacy Protection Act (COPPA) and other relevant laws.  Our Sites and Services do not target and are not intended for children under the age of 13, and we will not knowingly collect any personal information from them.  If we discover personal data from a child under 13 is gathered through our Sites or Services, then we will eliminate that data.  The Sites and Services are not intended for children under the age of 18.  If you are under 18 you must ask a parent for permission prior to submitting any information through the Sites or the Services.
• Accuracy and Updating of Information. We take reasonable steps to maintain the accuracy of your Personal Information for as long as it is being used for the Services and you play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your mailing address or telephone number, will help us provide you with the best possible service.
• Foreign Customers. Our Services are hosted in the United States. If you are using our Services from outside the United States, by providing your information to us, you are consenting to the transfer of your information to the United States for processing and maintenance in accordance with this Policy and our Terms of Use. You are also consenting to the application of United States law in all matters concerning our use of your information.
• No Guaranty. TransNational Bankcard cannot guarantee error-free performance under this Policy. We will use reasonable efforts to comply with this Policy and will take prompt corrective action when we learn of any failure to comply with our Policy.  TransNational Bankcard will not be liable for any incidental, consequential or punitive damages relating to this Privacy Policy.
• This Policy will be governed exclusively by the laws of the State of Illinois and the United States. You agree that any controversy or litigation associated with this Policy shall be brought exclusively in the state and federal course in Cook County, Illinois, and waive any objection to such venue.
• Class Action Waiver. You and TransNational Bankcard agree that no claims under or related to this Policy may be brought on a class action basis. No court may order, permit, or certify a class action, representative action, or private attorney general litigation in connection with this Policy.  Furthermore, no court may order or permit a joinder of parties in connection with this Policy unless both you and Transnational Bankcard consent to such joinder in writing.  YOU HEREBY WAIVE THE RIGHT TO INITIATE OR PARTICIPATE IN A CLASS ACTION, REPRESENTATIVE ACTION, OR PRIVATE ATTORNEY GENERAL LITIGATION RELATED TO THIS POLICY.