Privacy Statement - Last Updated 7/19/12
The VOLLY™ Secure Digital Delivery Service (“VOLLY”) is owned and operated by Volly LLC (“We”, “Us” or “Volly LLC”). This Privacy Statement applies to (i) any and all of the websites offered by Volly LLC in connection with VOLLY (the “VOLLY Website”), except to the extent such other websites contain their own privacy statements, and (ii) any applications hosted by the VOLLY Website.
We are committed to respecting the privacy of visitors to the VOLLY Website. We have created this Privacy Statement to describe how VOLLY operates, and how we collect, use, and share information gathered from our online visitors who visit the VOLLY Website and enroll in VOLLY.
The following topics are presented in this Privacy Statement:
- Your Choices
- Collecting Personal Information from VOLLY Website Users
- Collecting Other Information
- How We Use Personal Information
- Sharing Personal Information
- Transferring Personal Information to Other Countries
- Protecting Personal Information
- Visiting Other Websites
- Applicable Law
- Our Right to Change this Privacy Statement
- Dispute Resolution
You decide whether you want to receive electronic bills, account statements, records and other communications in your VOLLY digital mailbox. You decide whether to upload to VOLLY other personal documents you wish to store electronically. While we may recommend new billing partners to you as they become available to VOLLY end users, no mailer will be added to your VOLLY account without your prior consent.
Personal information we collect through the VOLLY Website, for example, your name, mailing address, and email address, may be used by us to contact you regarding products and services and upcoming events we believe you might find of interest. In the case of personal financial information from a bank or other financial institution, you may opt out of this arrangement by contacting firstname.lastname@example.org. We will not use bank transaction or billing data unless you ask us for assistance with such transactions or bills and payments, or unless you otherwise give us permission. We will not use or share protected health information about you for any marketing purposes without your explicit consent. We may provide non-personal information regarding your activity on VOLLY to certain third parties participating in the VOLLY system with whom you already have a relationship.
Under certain circumstances, the law provides you the right to request access to personal information we maintain on your behalf. If you are requesting access to your personal information, you may do so from your VOLLY account profile. As permitted by law, we may charge a reasonable fee for providing access to personal information, but we do not charge for submitting a request for access.
In order to provide you with access to the services of VOLLY, we require that you provide certain personal information. This information includes your name, mailing address, telephone number, email address, username if it is other than your email address, password that you choose to use for VOLLY, and answers to security questions. If you choose to receive bills, account statements, records and communications through VOLLY, including from third party websites, we may require your account numbers, your relevant usernames and passwords, or equivalent access information. If you choose to pay bills through the VOLLY service, we will also need the bank and billing account numbers you plan to use, as well as your credit card number and expiration date if you want to use your credit card for payment purposes and other requested services.
When you receive bills, account statements, records or communications through VOLLY, we will know your payment due dates, minimum payment amounts, and payoff amounts. If you agree, we will use this information to remind you when bills are due and the amounts that are due. We may also receive information that is contained in summaries for certain bills or account statements you receive through the VOLLY Website, for example, we may see the number of cell phone minutes or electricity wattage used in a billing period, or the state and federal taxes charged in connection with your cell-phone bill.
We monitor the way you click through the VOLLY Website so that we can improve your user experience. For example, we will know whether and when you accessed your account and viewed a particular bill, statement or advertisement. If you receive special offers or other materials through VOLLY, we may also know which pages and items you view or click on.
We do not knowingly collect information on children under the age of 18.
VOLLY uses several automatic data collection tools and techniques including cookies, clickstream, and web beacons.
We use a technology called "cookies" so that we can better serve you by understanding what products or services interest you. A cookie is a bit of text that is placed on your computer hard drive when you visit catalogs, catalog-related coupons or special offers. These cookies may be placed by us or by our service providers on our behalf to obtain data such as catalog pages, coupons, special offers or advertisements you view. We, or our service providers, may then use the cookie to customize certain information you ask to receive and to customize advertising placed on the VOLLY site.
You can set your browser to provide notice whenever a cookie is received, which gives you the opportunity to decide whether to accept it or not. Without cookies, however, you may not be able to take full advantage of all VOLLY features. For example, if you turn off cookies or refuse them, we will not be able to automatically recognize you when you return to VOLLY, provide customized information about new billers available to VOLLY end users, or customize information you ask to receive.
We, or our service providers on our behalf, may collect information about your "clickstream" during your visit to VOLLY. This clickstream data contains the pages you visited, the length of each visit, and the navigational paths you took.
We track the site from which you entered the VOLLY Website, and where you go after visiting the VOLLY Website. Additionally, we may track and match clickstream data with personal information you provide to us in order to deliver advertising content and other offerings that will be more relevant to you and your interests. We may also share clickstream data with third parties in an aggregate or otherwise anonymous format. In addition, we may share clickstream data on an individualized basis solely with certain third parties participating in the VOLLY system with whom you already have a relationship and with whom you have already shared your personal information.
Certain email communications you may receive from us may contain "web beacons." Web beacons consist of a line of code on our web site that delivers a small graphic image. The web beacon may not be visible as it is generally a 1x1 pixel that is often designed to blend into the background of a web page. Web beacons allow us to obtain information such as the IP address of the computer that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser used to view the page and the information in cookies. We, or our service providers on our behalf, may use web beacons for activities such as monitoring the effectiveness of the headlines in our emails or the ad banners.
Geolocation Data and Internet Protocol (IP) Addresses
When you use a mobile device to access your VOLLY account we may collect information about that device, such as the type of mobile device you use, your mobile telephone number or a device identifier, the date, time, and content of your Volly-related messages, as well as the location and the time zone in which your VOLLY account is accessed so we may better protect your Volly account from misuse, and to improve our products and services. You will be asked to provide your consent to our use of this data the first time we use it in connection with providing you services. We will not share this data with third parties, other than our service providers who have a duty to maintain its confidentiality, without your prior consent. We also collect information, such as, Internet Protocol (IP) addresses that could be used in connection with other information to personally identify users.
Personal information we collect through the VOLLY Website may be used by us (a) to authenticate your identity when you sign up for VOLLY and each time you sign in; (b) to obtain bills, account statements, records and other communications through VOLLY, including from third party websites; (c) to provide notice of bills that are due; (d) to pay bills you choose to pay, including pre-populating forms and retaining records of previous payments made through VOLLY; and (e) otherwise as required by law.
Personal information we collect through the VOLLY Website may be used by us to provide information regarding products and services and upcoming events we believe you might find of interest. We also may use the personal information you provide for internal purposes, such as administration and operation of the VOLLY Website, data analytics, and compliance with our legal obligations, policies and procedures.
Personal information we collect through the VOLLY Website, such as your name, address, email and date of birth, may be used by us to notify you of new companies participating in the VOLLY system with whom you may already have a relationship. We will not provide this personal information to these new participating companies unless you request us to do so.
5. Sharing Personal Information
We will not sell or rent your personal information, including your email address, to any third party under any circumstances.
We will not share or otherwise disclose personal information about you, except as described here, where required by law, or with your express prior consent. For example, we may ask for your permission to share your personal information with a third party who can help you save money on products or services that you currently use. We may share your personal information with the companies for whom you have chosen to pay bills through the VOLLY Website so that we may provide you services and support. We may also share your personal information with Affiliates (as defined below), and with third parties that perform services for us or on our behalf (for example, credit card companies, financial institutions, shipping companies, telecommunications carriers, consultants, data managers, address verification providers, advisors and market research firms). During account registration we will ask a major credit bureau to verify information you provide to us so that we can confirm your identity and improve the security of our system. Service providers and suppliers are required to keep confidential and secure the personal information received from us and may not use it for any purpose other than (i) in support VOLLY, or (ii) solely in an aggregate or otherwise anonymous format, for their internal use. When you update mailing address information in your VOLLY Account, we may disclose your change of address information solely to certain third parties participating in the VOLLY system with whom you already have a relationship and with whom you have already shared your personal information. We also may disclose personal information when, in our judgment, we believe it is necessary or appropriate to prevent fraud, injury, or harm to persons or property, to protect our rights or the rights of others, or as otherwise required by applicable law, regulation or legal process. For the purposes of this Privacy Statement, “Affiliate” means a legal entity that is controlled by, controlling, or under common control with Volly LLC. “Control” means more than 50% of the voting power or ownership interests.
We may share aggregate demographic and website usage information, and other anonymous information, about our VOLLY online visitors and account holders with our Affiliates and with certain third party service providers for their analytical purposes. For example, such aggregated, anonymous information may help us describe whether VOLLY has more users who are men than women, or vice versa, or whether a majority of VOLLY users reside in a particular part of the country.
Personal information may also be transferred in connection with a business transition such as a merger, acquisition, restructuring, spin-off or other divestiture, insolvency, or asset sale involving VOLLY. Should such a transfer occur, you will be given notice of your right to opt out of VOLLY and prevent your information from being shared with a new company.
By agreeing to open a VOLLY account, you agree to have your personal information used and/or shared for marketing purposes in the ways set forth in this Privacy Statement. In the case of personal financial information from a bank or other financial institution, you may opt out of this arrangement by contacting email@example.com. We will not use protected health information about you for any such purpose without your explicit consent.
You may elect to terminate your VOLLY account at any time by selecting “Need to Delete VOLLY Account” in the “Help” section or by contacting firstname.lastname@example.org. If you cancel your VOLLY account, we will delete your personal information from VOLLY servers where possible, although some data that cannot be removed in a commercially reasonable manner may remain in the VOLLY secure database, and will be protected by the terms of this Privacy Statement, as amended from time to time.
At any time, you may also elect to (i) withdraw your consent to us using your personal information for purposes other than the main functionality of the VOLLY Website by contacting email@example.com, or (ii) request that we delete your personal information by selecting “Cancel My Account” from your account settings screen. If you request that we delete all your personal information, we will cancel your VOLLY account and no longer be able to provide the VOLLY services to you. We will delete your personal information from VOLLY servers as set forth above.
We will only transfer your personal information to another country if there are issues that require us to utilize our third party service providers who perform administrative or trouble shooting services for us. If we decide to transfer your personal information to other countries for other purposes in the future, we will change this Privacy Statement accordingly and give you notice if it involves a material change.
We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of personal information you provide to VOLLY. We encrypt your bank statements, bills and all personally identifiable information. We control employee and contractor access to encrypted materials. We also employ secure transmission protocols in sending you emails and other electronic communications.
This privacy statement applies solely to information collected with your consent, as set forth herein, during your use of the VOLLY Website and it alone controls how that information is collected, used and disclosed, subject to applicable law and regulation.
VOLLY is a service offered by Volly LLC only in the United States and is intended to comply with all applicable federal and state laws.
This Privacy Statement may be updated periodically. We will not use your personal information in ways that differ from this Privacy Statement without prior notice to you and an opportunity for you to opt out, and in no event will we use your personal information in ways prohibited by law. If we make a material change to our Privacy Statement, we will let you know either by posting the new information or sending you an email describing any such material changes, and giving you an opportunity to decide whether to continue using the VOLLY service, and whether you agree to any new uses of information we have already collected. We will also indicate at the top of the Privacy Statement posted on the VOLLY Website when it was most recently updated.
If you have questions, comments or complaints regarding this Privacy Statement or our privacy practices, please contact us at Volly LLC, One Elmcroft Road, Stamford, CT 06926, Attn: VOLLY Customer Service, or by contacting firstname.lastname@example.org.