Privacy Policy

Effective as of: November 8, 2024.

Welcome. This privacy policy (“Policy”) explains how Effectiv or any of its affiliates or subsidiaries (“We”, “Us”, “Our”, “Effectiv”) handles personal information when we provide identity verification, fraud prevention and risk decisioning products and services (the “Services”) to our customers, when we market and sell our Services to you, and when you visit and engage with us in person or online, across our websites and digital content (the “Sites”). As for personal information collected and used in the employment process, please see our Employee & Candidate Privacy Policy.

Subject to applicable law, we may update this Policy from time to time by publishing a new version on this website.

HOW EFFECTIV WORKS

Effectiv is a fraud and financial crime management platform that provides services to business customers, who provide us with your personal information for those purposes. Effectiv does not provide any goods or services directly to consumers. We process personal information at the request of our business customers who might need to assess risks associated with an online transaction, like opening an account, making payments or other financial transactions, or updating the contact information in your account.

Please note the following distinctions about our platform:

Effectiv resells various products that our customers may choose to use, and those partners have their own data practices. You should refer to those partners’ privacy policies for information on their practices. (If you’re not sure which products our customers use, ask them!)
Effectiv enables our customers to access and orchestrate across various partner services. We are like pipes that allow data to easily flow from our customers to our partners, and our partners’ services back to our customers. Our customers are in control of their choices on where data flows and who processes it.

In sum, as regards the Services, Effectiv is a data processor, or service provider, as defined by consumer privacy laws. We are not a data controller of, or business collecting, personal information in the provision of the Services. Only the Effectiv business customer decides: (a) whether and for what reason(s) your information is provided to Effectiv; (b) which elements of personal information to provide to Effective to analyze on their behalf; (c) which alternative verification methods are available; and (d) whether and under what circumstances to accept, review, or reject a particular transaction.

HOW WE COLLECT, USE AND SHARE YOUR PERSONAL INFORMATION

PERSONAL INFORMATION THAT YOU PROVIDE US

When You are a(n)	What Personal Information We Collect	How We and/or our customers use our Personal Information	How long we retain this data	With Whom We Share Your Personal Information & Why
User with login credentials to use the Services.	Your contact information, such as your full name, email address, sign-up information.	Creation of a User account, verification of your identity and helping you log into the Services. To communicate with you regarding your existing Services including notifications of any alerts or updates. To send you information about our other products or services, events, webinars or programs which may be of interest to you.	For as long as you are a customer of Effectiv, and thereafter for 5 years.	Third party partners who assist Us in onboarding you and providing Our Services to you.
Individual whose personal information is used for verification, fraud and risk purposes when a customer uses our Services.	Identifiers, such as legal name, alias or nickname, mailing or physical address, email address, telephone number, social security number, driver’s license or state identification card number, national identification number, passport or other government-issued identity document number, death records, or other similar identifiers. Financial Account Information, including routing and account numbers and transaction history. Identity Documents such as your passport or driver’s license, identifiers we extract from your document, and your photograph.	To provide the Services to our customers To develop and improve Our Services	No more than 7 years from its collection.	Our customer that is using the Services to verify you or protect you from fraud.
User who submits certain information to Us when filling out a survey about their user experience or other feedback.	Information you have provided, such as name and work email.	To improve Our Services	For as long as you are a customer of or actively engaged with Effectiv, and thereafter for 5 years.	Third parties who assist Us in providing these services.
Individual who requests a demo.	Your contact information, such as your first and last name, email, phone number.	To give you the demo and To inform, promote and market our Services to you.	For as long as you are a customer of or actively engaged with Effectiv, and thereafter for 5 years.

PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU

When You are a(n)	What Personal Data We Collect	How We Use & Retain Your Personal Data	How long we retain this data	Whom We share Your Personal Data with
Visitor to the Sites	Your usage of Our Sites or emails (such as Internet Protocol (IP) addresses browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks or other identifiers Your contact information, such as your full name, email address, phone number, designation and business name. We may combine this information with any Personal Data provided by You.	For market analysis, and market research To protect the Our data from threats, violations, and breaches if any. To inform, promote and sell Our Services to you.	No longer than 25 months from collection	Third party partners who assist Us for these purposes.
Individual whose personal information is used for verification, fraud and risk purposes when a customer uses our Services.	Your device type, and the operating system version, web browsers, IP address, settings and other device characteristics and behavior information, and data extracted from such information. Consumer Report information	To provide the Services to our customers. To evaluate, develop and improve our Services.	No more than 7 years from its collection.	Our customer that is using the Services to verify you or protect you from fraud.

California Residents: We collect the same information above for you. Under the California Consumer Privacy Act (CCPA), we’re required to let you know that information may also fall under these categories:

Personal Information Categories Listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
Internet or Other Electronic Network Activity Information
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information
Inferences
Sensitive Personal Information

How We Use Your Personal Information

We use your personal information in accordance with law and our customer contracts to:

perform identity verification, fraud prevention, and risk assessment services on behalf of our business customers;
help ensure the security and integrity of the Services;
identify and repair errors that impair existing or intended Services functionality or performance; and
conduct internal research to develop, improve, test, or repair Services or related services or technology.

Where permitted or required by law, Effectiv may also use your personal information to:

comply with federal, state, or local laws, rules, or regulations, such as by verifying and fulfilling data rights requests;
comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities;
cooperate with law enforcement agencies concerning conduct or activity that we or our customers reasonably and in good faith believe may violate federal, state, local, or international laws, rules, or regulations;
investigate, establish, exercise, prepare for, or defend legal claims; and/or
perform internal operations aligned with your reasonable expectations or otherwise compatible with processing your personal information in our provision of the Services.

Effectiv does not market or advertise directly to consumers in connection with our provision of the Services to our business customers. However, if you engage with certain content on the Sites, such as demo or trial systems, white papers, webinars, or our chatbot, you may receive marketing or advertising communications from Effectiv in accordance with this Privacy Policy. To the extent we use third-party service providers to assist us with targeted (i.e. cross-contextual behavioral) advertising, we may disclose to them your identifiers, professional or employment-related information, and/or personal information categories listed in the California Customer Records statute, alone or in combination with information from other sources (like our data vendors and offline customer data), and they may use various tracking technologies.

How We Protect Your Information

Effectiv uses commercially reasonable physical, electronic, and procedural safeguards to protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction, in accordance with applicable law, and we require our customers and third-party service providers to do the same. Biometric information receives the same rigorous privacy and security protections as other sensitive personal information. This includes encryption in transit and at rest, strict access controls, data minimization, and data governance procedures. That said, there is simply no way to guarantee that any safeguards or security measures will be sufficient to prevent a security incident.

Your Consumer Privacy Rights

Generally, you have the right to file or lodge a complaint with the relevant supervisory authority and to not be discriminated against for exercising your rights. In addition, based on where you reside, you may be subject to one or more of the following data rights:

Right to Know / Be Informed as to the personal information or categories of personal information we have about you.
Right to Access a copy of the personal information we have about you.
Right to Correction / Rectification inaccurate personal information that we have about you.
Right to Deletion / Erasure of personal information about you.
Right to Opt Out of / Object to Certain Processing, such as certain types of profiling.

Right to Restrict Processing, if you meet certain limited applicable circumstances.

Right to Withdraw Consent at any time, free of charge. Any such withdrawal only applies prospectively and will not impact prior processing conducted in accordance with your prior freely given consent.
Right to Appeal a refusal to take action on a request within a reasonable period of time after you receive the initial decision.

Any withdrawal of consent only applies to future processing and does not impact prior processing conducted in accordance with your prior freely given, explicit consent. The right to data portability does not apply to Effectiv, but we use reasonable efforts to provide you with information in response to an access request that is in a structured, commonly used, and machine-readable format.

To make a request to exercise your consumer privacy rights, please email [email protected].

Cookie Policy

Our Sites use cookies to enhance your browsing experience and provide personalized services. This policy explains what cookies are, how we use them, and your choices regarding their use. By continuing to use the Sites, you consent to the use of cookies in accordance with this policy.

What are Cookies? Cookies are small text files placed on your device by websites you visit. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site.

Types of Cookies We Use – Effectiv uses four types of cookies when you visit the Sites: (1) Necessary Cookies: These cookies are essential for the website to function properly. They enable basic features such as page navigation and access to secure areas of the website, and cannot be switched off in our systems. (2) Analytics Cookies: These cookies help us to understand how visitors engage with the website. We may use a set of cookies to collect information and report site usage statistics. In addition to reporting site usage statistics, data collected may also be used, together with some of the advertising cookies described, to help show more relevant ads across the web and to measure interactions with the ads we show. (3) Advertisement Cookies: These cookies are used to track visitors across websites in order to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. Some common applications of cookies are to select advertising based on what’s relevant to a user; to improve reporting on ad campaign performance; and to avoid showing ads the user has already seen. (4) Functionality Cookies: We use a set of cookies that are optional for the website to function. They are usually only set in response to information provided to the website to personalize and optimize your experience as well as remember your chat history.

Third-Party Cookies – The Sites use third-party cookies for marketing and analytics purposes. These third parties may collect information about your online activities over time and across different websites.

Managing Cookies – You can control and/or delete cookies as you wish. For details, please visit http://aboutcookies.org. You can delete all cookies that are already on your computer and set most browsers to prevent them from being placed. However, if you do this, you may have to manually adjust some preferences every time you visit a site, and some services and functionalities may not work.

For Non-U.S. Persons, These are Our Lawful Bases for Processing Personal Data

Residents of Canada: Your personal information is processed with your express consent.

Residents of the United Kingdom or European Economic Area: (a) your biometric information is processed with your explicit consent; (b) your racial or ethnic origin data is processed for reasons of substantial public interest; and (c) your remaining personal information is processed for the purpose of legitimate interests such as fraud prevention. Personal information processed to evaluate and fulfill data rights requests are processed for compliance with a legal obligation. Where Effectiv relies on legitimate interests, we take into consideration your reasonable expectations based on your relationship with our business customers and balance them against Effectiv’s needs to support our business customers’ requests to validate identities, assess risk, and prevent, detect, protect or defend against, or respond to security incidents, identity theft, fraud, harassment, malicious, deceptive, or illegal activities.

How to Contact Us

Please do not email us your identity documents, selfies, or other personal information. If you are having trouble submitting your documents or need help troubleshooting or understanding the outcome of a specific transaction, please contact the Effectiv business customer who sent you to us.

To contact the Effectiv Privacy team, including our Data Protection Officer (DPO), you may email [email protected] or call 1-888-690-3709. Our DPO is Socure’s General Counsel and VP of Legal, Aviad Levin-Gur.

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Effectiv’s parent company has appointed the European Data Protection Office (EDPO) as its GDPR Representative in the EU. You may contact EDPO regarding matters pertaining to the GDPR: (1) by using EDPO’s online request form; or (2) by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

Pursuant to Article 27 of the UK GDPR, Effectiv’s parent company has appointed the EDPO UK Ltd as its UK GDPR representative in the UK. You may contact EDPO UK regarding matters pertaining to the UK GDPR: (1) by using EDPO’s online request form; or (2) by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.