Privacy Policy

Our Mission

SilverBills® Inc (“SilverBills®”, “we”, “our” or “us”) is committed to assisting with correct and accurate bill paying. In addition, we are committed to safeguarding your information, and treating such information with security and respect. We understand the need to feel safe when sharing information with third parties, and we have developed this privacy policy (this “Privacy Policy”) to help you understand our practices and how to exercise choice regarding the collection and use of your information.

Scope and Other Agreements and Notices

Our Privacy Policy applies to Non-Personal Information and to Personal Information that we collect directly from you online and offline, as well as information we collect about you from other sources, such as from third party partners and affiliates, which we may append to other information we collect from or about you. This Privacy Policy applies to visitors and users of our website, SilverBills.com (our “Site”) (including the mobile version of our Site), users of Services that require payment of a fee (“Members”) (we may also refer to our Members at times as our “Customers”), and prospective Customers. See below for more about information we collect and how we use and share it.

In addition to this Privacy Policy, other contract terms such as our SilverBills^®’ Service Terms and Conditions (the “Service Terms”) and SilverBills^®’ Website Terms of Use (the “Website Terms”), will apply to you, based on the Services you select or use. If you use other Services, additional privacy terms may also be applicable. Our Service Terms and Conditions (the “Service Terms”) are available [here] and our website terms of use (“Website Terms”) are available [here].

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING THE SERVICES, YOU ACCEPT ALL OF THE TERMS AND CONDITIONS OF THE SILVERBILLS PRIVACY POLICY AND THE SILVERBILLS WEBSITE TERMS OF USE. IF YOU DO NOT AGREE TO OUR PRACTICES AS DESCRIBED IN THIS PRIVACY POLICY, THEN YOU MAY NOT ACCESS AND USE OUR SITE AND SERVICES.

Modifications

We may modify this Privacy Policy from time to time. We will post those modifications of our website here prior to the modifications becoming effective. We will notify you of material modifications to this Privacy Policy, including sending you a copy of the updated policy by email if we have your email address on file, prior to the change becoming effective. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. EACH TIME YOU USE THE SITE, THE LATEST VERSION OF THE POLICY WILL BE DISPLAYED AND WILL APPLY. YOUR CONTINUED USE OF THE SITE OR OUR SERVICES AFTER ANY SUCH MODIFICATION MEANS THAT YOU ACCEPT THE MODIFIED POLICY. IF YOU DO NOT AGREE TO ANY OF THESE TERMS OR ANY FUTURE PRIVACY POLICY, THEN YOU MAY NOT ACCESS AND USE (OR CONTINUE TO ACCESS AND USE) THE SERVICES.

Information We Collect

We may collect information about you from a variety of sources, including information we gather from you directly when you register or enroll (or are enrolled by an authorized third party), when you use our Services, view our Site or our online advertisements, or when we gather information from other sources as described below (collectively, “Information”).

Information We Collect Directly From You

Some Personal Information is collected when you register or enroll for the Services, otherwise agree to provide information directly to us, or are enrolled for the Services by an authorized third party by telephone, through SilverBills.com, by email, postal mail or other means. We collect and store all of the Personal Information you provide us through these channels. Moreover, if you provide information about someone other than yourself through any of these channels, you represent that you have authority to do so. Here are some of the kinds of Personal Information we may collect directly from you or an authorized third party:

• Name
• Contact information (including your email address, postal address, phone number)
• Social security number
• Date of Birth, Age, Gender
• Personal details to verify your identity, such as your mother’s maiden name
• Payment and Financial Information, such as a credit card or financial account number
• Government identity information, for example, driver’s license information, voluntarily identified by you in your portal
• Other information you may voluntarily provide for protection on the portal, such as your insurance information
• Communication Preferences
• Contact information for friends or family members that you wish to register as members or that you suggest we contact. Your family member may contact us at info@SilverBills.com to request that we remove this information from our Site
• Other information that you may voluntarily provide in response to member surveys or studies or as part of enrollment in a new product or service
• When you call or exchange emails with us, we will retain the content of the email messages (or hard copy correspondence) as required or permitted by law and our record and information management policies. We also may retain recordings of our phone messages or phone calls with you

Information We Collect When You Visit Our Site or View Our Online Advertisements

We and the third parties we engage to perform analytics or advertising services use Cookies or similar technologies to administer and improve our Site and the content on it, including to track user movements around the Site, to gather usage information and statistics about how our Site is used, to permit users to log in or make purchases, to store user preferences, to customize content, and for marketing and advertising purposes. Users can control the use of Cookies at the individual browser level. If you reject Cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine the information we have automatically collected from you with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality, to develop new products and services, and to customize content and advertising to you.

The following are some examples of information we may collect with Cookies, Log Files, Web Beacons, GIFs, pixel tags, server logs, customer relationship management (“CRM”) tools or other technologies that gather information automatically when you visit our Site or view online advertisements:

• Website pages you view
• IP address
• Emails from SilverBills^®’ that you open or forward
• SilverBills^®’ offers or links you connect to

In connection with the Site, for example during the enrollment process or upon log into your portal, information about your computer, such as the device id and other accompanying technical attributes and characteristics, may be accessed, retained and used by us or our service provider to confirm device identification, verify your identity, and to authenticate your account. If you access our Site through a mobile device, we also may collect information about your device, such as the device ID or other identifier as permitted by the manufacturer, length of time spent on the Mobile App, installations, clicks and gestures.

Information we collect from other sources

We may obtain information about you from third party sources (“Third Party Information”), such as the companies we work with to provide Services to you (i.e., our service partners), affiliates and other companies that we acquire or merge with, data aggregators or public databases. Here are examples of Third Party Information:

• Name
• Age
• Postal address
• Phone number
• Marital status and number of children
• Information used to populate our membership registration forms
• Information such as your social security number and date of birth, obtained affiliates or service partners

How We Use and Share Your Information

This summary tells you how we use your information, if we share it and why. It also explains how you can make decisions about these actions and how we will respond to those requests. We will share your personal information with third parties only in the ways that are described in this Privacy Policy, or otherwise where we have your consent. We do not sell your personal information to third parties. When we share your Personal Information with third parties as described below, we put in place contracts with them that include confidentiality restrictions on their use of your information and that require them to notify us if your Personal Information is lost, stolen or otherwise wrongly disclosed. In certain situations, SilverBills^®’ may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Security Standards

The security of your Personal Information is important to us and we have put into place multi-layered technical, physical and procedural measures to help keep it safe. For example, we keep Personal Information encrypted during transit and at rest using strong encryption technology and employ proactive monitoring and other tools to protect against unauthorized access. We work with third parties on an ongoing basis to keep our practices current. We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required, or for the establishment, exercise of legal claims, or for legitimate business purposes, or as provided by law.

Despite our mutual efforts, you understand and agree that perfect security does not exist and understand that there is a certain amount of risk inherent in providing and receiving services over the internet. You agree to use your Personal Information in a reasonable way and to avoid recklessly disclosing your Social Security number, financial account numbers or other Personal Information to those that could improperly use or disclose it. For example, take care not to visit sites that may transmit malware, or to respond to “phishing” scams, unsolicited emails, or pop-up messages requesting your Personal Information. You may have the opportunity to participate in contests, blogs, promotions or other functions by way of the Site. Use caution when deciding to disclose your information in such a submission as these functions may be provided by a Third Party Website and subject to terms which are different than those stated in this Privacy Policy.

If you have any questions about the security of your Personal Information or the security of the site, or to report a potential security issue, please email info@SilverBills.com. If you have a potential security issue, please describe the matter in as much detail as possible and include any other data that might be helpful.

Testimonials

We display personal testimonials of customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@SilverBills.com.

Children’s Privacy

We believe it is important to provide added protection for children on the internet and encourage parents and guardians to work with their children to understand how to be safe online. Our Site is not intended for the use by anyone under the age of eighteen (18). Other than as specifically described herein, we do not want or intend to collect or request Personal Information from anyone under the age of eighteen on this Site. If we become aware that we have unknowingly collected Personal Information from a child under the age of eighteen (18), we will make commercially reasonable efforts to delete such information from our database.

Marketing

If you provide us with your email address or mailing address, you may receive marketing messages and materials from us or our affiliates. You have choices on what communications you want to receive from us. Marketing materials for our Services may also be included in messages you receive from our partners (which may include your employer if they offer our services as part of their employee benefits) or service providers that offer our services as part of a special offer. If you choose not to receive marketing communications that we send, we will honor your request. However, we will continue to communicate with you as needed to provide the Services, respond to your inquiries or otherwise relay service-related messages. You may still receive information about our Services through other parties using their own mailing lists.

You can stop receiving promotional email or postal communications from us by following the instructions included in each communication, by changing your preferences in your member portal, or by contacting us at info@SilverBills.com or by regular mail at SilverBills®’ Inc, 300 West 57th Street, 40th Floor, New York NY 10019.

Special Notice to California Consumers

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. We may share your Personal Information with our affiliates for direct marketing, but we do not sell it to or share it with unaffiliated third parties. You may request a list of our affiliates by contacting us at SilverBills® Inc, 300 West 57th Street, 40th Floor, New York NY 10019. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please allow up to thirty (30) days for a response.

Your Access to Your Information

Upon request SilverBills®’ will provide you with information about any of your personal information we maintain. You may access, update, and correct the Personal Information you have provided to us on the Site by emailing us at info@SilverBills.com. If you are not a Member and want to know what Personal Information we have about you, you need to contact us in writing by postal mail with this request at the address set out in the “Contact Us” paragraph below. We will respond to your inquiry within ten (10) business days. If you cancel your Services, we may retain your information in accordance with this section. We will retain your information as follows:

• for as long as your membership is active
• as needed to provide you Services
• as required by company policy or legal obligation
• as needed to resolve disputes
• as needed to enforce our agreements

SilverBills© Commitment

We are committed to (1) working with our Customers to obtain a fair resolution of any complaint or concern about privacy concerns and our Services, and (2) supporting law enforcement and regulatory agencies committed to stopping crimes of identity theft and identity fraud. To contact us with a question or concern about our privacy practices or this Privacy Policy, please feel free to call us at 1-800-825-1924, email us at info@SilverBills.com or write to us at SilverBillsInc, 300 West 57th Street, 40th Floor, New York NY 10019. You hereby agree that we may use and disclose any suggestions, ideas, concepts, or information (other than your Personal Information) that you provide to us regarding the Privacy Policy, our business, or any other matter, without obligation to you or any third party.

Dispute Resolution

If you have an unresolved privacy or data use concern, please contact us at 1-800-825-1924.

Definitions Used in this Privacy Policy

Cookies. Cookies are small text files that are stored by a user’s web browser on the hard drive of a user’s computer. Cookies can “remember” what information (“Cookie Information”) a user accesses on a particular web page to simplify subsequent interactions with that website by the same user, or cookies can use that information to streamline the user’s transactions on related websites. The cookies we use on our Site may be “session” cookies that are erased when you leave the Site, or they may be “persistent” cookies that remain on your computer’s hard drive after you leave the Site. We also use a cookie installed by Google, Inc. to provide us with usage information regarding the Site. The cookies we use do not capture your Personal Information. We may also set cookies when you register at the Site, and may do so without notice to or permission from you or any third party.

Non-Personal Information refers to information about your use of the Site that is gathered automatically. Non-Personal Information does not directly or indirectly identify you individually, and cannot reasonably be used to identify you, but helps us better understand how the Site is used.

Log Files. As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

Our, We or Us refers to SilverBills® Inc.

Personal Information means information, or a combination of pieces of information, that reasonably (directly or indirectly) could allow us to identify you. Personal Information includes things like your name, address, date of birth, social security or driver’s license number.

Third Party Information refers to information that may be gathered on our behalf or which we lawfully obtain from third parties outside of this Site.

Tracking Technologies refers to technologies such as Cookies, JavaScript, Web Beacons (including clear GIFs), E-Tags, Local Storage (HTML5), and Flash Local Storage Object (LSO) Cookies.

Site refers to this website, www.SilverBills.com.

Services refers to the services offered by SilverBills® Incthrough SilverBills.com and offline including our bill paying services or other products or services for which you must register or enroll, as well as any on-line promotions that are associated with our Services, unless we tell you otherwise.

Web Beacons / Gifs. We employ (either directly or through one of our third party advertising partners) a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our Site by educating us on what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to Cookies, and are used to track the online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence.

We also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

You or Your refers to you as a Member.