Service Privacy Notice

Privacy Notice Contents 

1. When this Privacy Notice applies
2. What is Personal Information?
3. Personal Information we collect, use, and/or disclose
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). 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.

Cardholder Data (e.g., cardholder name, billing address, credit card account number (tokenized), card expiration date)

• Categories of sources from which Personal Information is collected:
  • Category 4.b below.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Categories 6.a, 6.d and 6.e below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Merchant Data (e.g., email address (hashed), shipping address, shopping session information)

• Categories of sources from which Personal Information is collected:
  • Category 4.c below.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Category 6.d below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Fraud Data (e.g., device data, session information, IP address)

• Categories of sources from which Personal Information is collected:
  • All categories listed below in Section 4.
• Business purpose(s) for collection, use, and disclosure:
  • Category 5.e below.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Categories 6.a, 6.c, 6.d, and 6.e below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Device Data (e.g., browser type, IP address, unique device ID, cookie data)

• Categories of sources from which Personal Information is collected:
  • Categories 4.e and 4.f below.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Categories 6.a, 6.c, 6.d, and 6.e below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Transaction Data (e.g., cardholder name, billing address, shipping address, transaction value)

• Categories of sources from which Personal Information is collected:
  • Categories 4.d and 4.f below.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • All categories listed below in section 6.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Consumer Profile Data (e.g., cardholder name, Social Security number (hashed), email address, mobile telephone number, date of birth)

• Categories of sources from which Personal Information is collected:
  • All categories listed below in Section 4.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Categories 6.a, 6.c, 6.d and 6.e below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

Other information about you that is linked or linkable to the Personal Information above

• Categories of sources from which Personal Information is collected:
  • All categories listed below in Section 4.
• Business purpose(s) for collection, use, and disclosure:
  • All categories listed below in Section 5.
• Disclosed for business purpose(s) to the following categories of third parties:
  • Categories 6.a, 6.d, and 6.e below.
• Sold or shared (for targeted advertising) to the following categories of third parties:
  • None
• Length of time Personal Information is intended to be retained: (unless subject to a legal hold)
  • Up to 7 years after inactive (e.g., opt out)

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 or tax identification number, email address, mobile phone number, and billing address (“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 share your email address with us during checkout on the merchant website to enable us to find your Paze wallet. Please note that the email address we receive is hashed 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 the services 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 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
• 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, and remediation activities
• f. Analytics, Research, & Product Improvements (to manage and improve Paze)
  • a. to identify and repair errors that impair existing or intended functionality;
  • b. to research and resolve issues related to transactions
  • c. to create, develop, and improve the service
• 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

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. Early Warning Services, LLC (Early Warning is the operator of Paze);
• b. participating financial institutions;
• c. participating merchants;
• d. our service providers (e.g., companies that help us provide Paze);
• e. law enforcement, government agencies, and other authorized third parties (we may be required by law to disclose information); 
• f. existing owners (e.g., current owner banks of Early Warning) and their employees and agents;
• g. new owners (in the event we plan to merge with or be acquired by that business entity) (e.g., future owner banks of Early Warning); and
• h. 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.

In connection with the sale or transfer of some or all of our business assets, we may transfer or share Personal Information with third parties (e.g., with a successor business). We also may retain a copy of that Personal Information. 

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 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.

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 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 secure wallet management website. For authentication purposes, you will be asked to request a passcode to be delivered via text message 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 and to honor your opt-out request. 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 treat 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 contact Consumer Services.