Version 1.0.2

March 6, 2012

This Privacy Policy governs your Accumulus account and any information you provide while using Accumulus programs, web sites and services. Please view, download and save this policy.

1. Overview

In order to operate the Accumulus service and to reduce the risk of fraud, Accumulus Corporation ("Accumulus" or "we"), must ask you to provide us with information about yourself, your bank account and your credit or debit card. By consenting and agreeing to this Privacy Policy, you also expressly consent and agree to us processing your data in the manner set out in this Privacy Policy. This Privacy Policy describes the information we collect and how we use that information.

Accumulus takes the privacy of your personal information very seriously and uses your information only in accordance with the terms of this Privacy Policy. We do not sell or rent your personally identifiable information or a list of our customers to third parties. However, in order for us to offer our services to our users; to enhance the quality of our service from time to time; and to protect the interests of our users, we do in limited circumstances and as further described in more detail throughout this policy, share some of your information with third parties under strict restrictions.

It is important for you to review this Privacy Policy. This Privacy Policy applies to all programs, web sites and services hosted by Accumulus.

You accept the Privacy Policy and Terms of Use Agreement by using Accumulus' programs, web sites and services. Furthermore, you consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Accumulus Terms of Use Agreement. If you disagree with the terms of this Privacy Policy, please do not register for or use the Accumulus service. We may modify this Privacy Policy at any time by posting a revised version on our web site. The revised version will be effective at the time we post it. Please check the Accumulus website for the most current version of our Privacy Policy.

Some pages on the Accumulus website include links to third party websites. These sites are governed by their own privacy policies and Accumulus is not responsible for their operations, including their information practices. Users submitting information through these third party websites should review the privacy policies of these sites before providing them with personally identifiable information.

2. Information We Collect

Required Information

To open an Accumulus account, you must provide your company's name, address, phone number and default currency and your name and email address. To make payments to Accumulus, you must provide credit card, debit card or bank account information. To receive payments via Accumulus, you must provide a merchant account identifier and any other information required by your payment processor. We also ask you to specify a security question to answer. This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and current account fraud, and to contact you should the need arise in administering your account.

Transaction Information

When you use Accumulus to receive a payment from or send a refund to one of your customers, we ask you to provide information related to each transaction, consisting of payment mechanism information, the amount of the transaction and, optionally, customer and product data. We retain this information for each of your transactions indefinitely (unless specifically required otherwise by Payment Card Industry security requirements) and may add this information to your account profile to be used for future transactions. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your Accumulus account, in order to help detect possible unauthorized transactions. We do not market to your customers in any way at any time.

Information about You from Third Parties

In order to protect all our customers against fraud, we verify the information you provide with bank processors during each transaction. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Accumulus, we use card authorization and fraud screening services to verify that your card information and address match the information that you supplied to Accumulus, and that the card has not been reported as lost or stolen.

If you send or receive high overall payment volumes through Accumulus, we may conduct a background check by obtaining information about you and your business from a credit bureau or a business information service. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. Accumulus reserves the right to periodically retrieve and review a business credit report supplied by such a credit bureau and also reserves the right to close an account based on information obtained during this credit review process.

Website Traffic Information

When you arrive at an Accumulus web site, we receive the web address of the site from which you came. Likewise, when you leave an Accumulus website, we receive the web address of the site to which you go. We also collect IP addresses, the type of browser you use, the times you access our web site and which pages of our web site you visit. We use this information to try to understand customer preferences and to manage server to improve our service and your experience with Accumulus.

Session Information

"Cookies" are small data files that reside on your computer. We place a "session cookie" on your computer if and when you log into your Accumulus account. These cookies allow us to recognize you if you visit multiple pages on our site during the same session, so that you do not need to re-enter your password multiple times. Once you log out or close your browser, session cookies expire and no longer have any effect.

Also, we use a longer-lasting cookie to display your email address on our login form, so that you do not have to retype the email address each time you log in to your Accumulus account. We encode our cookies so that only we can interpret the information stored in them.

You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website.

We may also collect information about your computer or other access device to mitigate risk and prevent fraud.

Customer Service Correspondence

If you send us correspondence, including emails, faxes and chat sessions, we retain such information in the records of your account. We also retain customer service correspondence and other correspondence from Accumulus to you. We retain this data as a record of our relationship and use it to measure and improve our customer service, to investigate fraud and to investigate violations of our Terms of Use Agreement. We may, over time, delete this data if permitted by law.

Questionnaires, Surveys and Profile Data

From time to time, we offer optional questionnaires and surveys to our customers to collect demographic information or assess customers' interests and needs. The use of the information collected is explained in detail in the questionnaire or survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users are given notice of how the information is used prior to their participation in the questionnaire or survey.

3. Our Use and Disclosure of Information

Internal Use

We collect, store and process personal information. Our primary purpose in collecting personal information is to provide you with a safe, efficient and customized experience. You agree that we may use your personal information to:

provide the services and customer support you request

resolve disputes, collect fees, and troubleshoot problems

prevent potentially prohibited or illegal activities, and enforce our Terms of Use Agreement

customize, measure, and improve our services and our website

tell you about service updates and promotional offers

compare information for accuracy and verify it with third parties

Disclosure to Your Customers

When you execute a transaction with one of your customers via Accumulus, we issue a receipt to the customer that includes your company name, address, online address and a description of the goods or services purchased.

By accepting this Privacy Policy, you agree that each time you execute a transaction using Accumulus, Accumulus may then transfer the aforementioned relevant data to your customer, in order to process, execute or otherwise deal and provide information about the transaction.

Disclosure to Third Parties Other Than Your Customers

Accumulus does not sell or rent any of your personally identifiable information to third parties, and only discloses this information in the limited circumstances and for the purposes described below. Specifically, you consent to and direct Accumulus to do any and all of the following:

Disclose information including, without limitation, account information, transactions, personal details and the contents of communications to the police, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies (other than tax related authorities), departments or regulatory, self-regulatory authorities or organizations or other third parties that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms of Use Agreement. If false or inaccurate information is provided and fraud is identified, fraud prevention agencies and law enforcement agencies may access and use this information. We and other organizations may also access and use this information to prevent fraud and money laundering.

Disclose information in response to requirements of civil or criminal legal processes.

Disclose information to third parties in support of providing the Accumulus service to you. Third parties include payment processors (to process transactions), audit services (to investigate money laundering), customer service agencies (to provide customer service), credit reference and fraud agencies (to verify identity, make decisions concerning credit worthiness, and to carry out checks for the prevention and detection of crime including fraud and/or money laundering).

Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

Disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in a certain state, region or province. However, this aggregated information does not include personal information.

As with any other business, it is possible that Accumulus in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by Accumulus, including your account information, but would continue to be bound by this Privacy Policy unless and until it is amended.

Our Contacts with You

We communicate with users on a regular basis via email. We also communicate by phone to resolve customer issues, respond to requests for customer service, alert you if we believe your account or any of your transactions have been used for an illegitimate purpose, confirm information concerning your identity, business or account activity and conduct customer surveys. We use your email or physical address to confirm your opening of an Accumulus account, to send you notice of payments that you make or receive, to send information about important changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications, but they are primarily informational in nature rather than promotional.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

4. Information Security

Accumulus is committed to handling both you and your customers' information with high standards of information security. We use safeguards including physical access control, firewalls and data encryption, and we limit access to personal information only to those employees who require it to fulfill their job responsibilities.

The security of your Accumulus account also relies on your protection of your Accumulus password. You should never share your Accumulus password with anyone. If you do share your Accumulus password with a third party for any reason, the third party has access to your account and your personal information and you may be responsible for actions taken using your password. NOTE: Accumulus representatives never ask you for your password, so any email or other communication requesting your password should be treated as unauthorized and suspicious and forwarded to support@accumulus.com. If you believe someone else has obtained access to your password, please login to your account, change your password, and email support@accumulus.com immediately.

5. Accessing and Changing Your Information

You can review the information you provide us and make any desired changes to the information at any time by logging in to your account on the Accumulus website.

If you close your Accumulus account, we retain your information in our database, but mark your account as "Inactive". This is necessary to deter fraud, by ensuring that persons who try to commit fraud are not able to avoid detection simply by closing their account and opening a new one. Your personally identifiable information remains covered by the terms of this Privacy Policy.

6. Accountability

Accumulus is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you have questions, comments, concerns or other feedback regarding this Privacy Policy or any other privacy concern, please send an email to support@accumulus.com.