*eLayaway defines a substantial change as anything affecting the collection, usage, protection, storage, accessibility, or sharing of your personal information.
Member Collected information
When a member visits the eLayaway website, eLayaway will collect the member’s IP address and standard web log information.
If a member enrolls to participate in any Services offered by eLayaway, eLayaway will collect the following types of information from the member:
Contact information – member’s name, address, phone, email, and other similar information.
Financial information – the bank account numbers that the member links to their eLayaway account.
Before permitting a member to participate in the eLayaway Services, eLayaway may require the member to provide additional information that eLayaway can use to verify the member’s identity or address or manage risk. eLayaway may also obtain information about the member from third parties, if necessary, and identity verification services.
When members begin accessing eLayaway and utilizing eLayaway’s Services, eLayaway will collect information about member account transactions and may collect information about a member’s computer or other access device in an attempt to deter against illegal transactions, for fraud prevention purposes and for marketing purposes.
Finally, eLayaway may collect additional information from or about the member in other ways not specifically described here. For example, eLayaway may collect information related to interactions with eLayaway staff or a member’s responses to marketing correspondence.
eLayaway will never ask for your password information. Also, eLayaway will never collect banking information over the telephone, chat system, or email.
When a member accesses the eLayaway website, eLayaway, or companies hired by eLayaway, small data files are used to track how our website is used. These small data files, called “cookies,” may be placed on your computer.
eLayaway sends a “session cookie” to a member’s computer when logging in to their eLayaway account. This type of cookie helps us to recognize a member when visiting multiple pages on the eLayaway site during the same session, so that eLayaway does not need to ask the member for their password on each page. Once the member logs out or closes their browser, this cookie expires and no longer has any effect.
eLayaway follows standard website operation practices and encodes its cookies so that only eLayaway can interpret the information stored within them. Members are free to decline the eLayaway cookies if their browser permits, but doing so will interfere with the use of the eLayaway website.
The Protection and Storage of a Member’s Personal Information
Throughout this policy, the term “personal information” is used to describe information that can be associated with a specific member and can be used to identify that member. eLayaway does not consider personal information to include information that has been anonymized, so that it does not identify a specific member.
eLayaway stores and processes a members personal information on eLayaway’s computers, located in the United States. eLayaway protects personal information by maintaining physical, electronic and procedural safeguards in compliance with applicable United States federal and state regulations. eLayaway uses computer safeguards such as firewalls and data encryption, which enforces physical access controls to the eLayaway buildings and files. eLayaway authorizes access to personal information only for those employees who require it to fulfill their job responsibilities.
The Use of Collected Personal Information
eLayaway’s primary purpose in collecting personal information is to provide its members with a safe, smooth, efficient, and customized experience while participating in the eLayaway Services. eLayaway may utilize a member’s personal information to:
- Provide the services and customer service requested;
- Process transactions and send notices;
- Resolve disputes, collect fees, and troubleshoot problems;
- Prevent potentially prohibited or illegal activities, and enforce the eLayaway Terms & Conditions;
- Customize, measure, and improve eLayaway’s services and the content and layout of its website;
- Send the member targeted marketing, service update notices, and promotional offers based on the member’s communication preferences;
- Validate information for accuracy and verify it with third parties.
Personal Information Shared with other eLayaway Merchants or Partners
To process a member’s payments, eLayaway needs to share personal information such as member name, mailing address, shipping address, phone number, purchase information, payment schedule and shipping date with the merchant and financial information such as member name, bank account number and bank routing number with the banks involved with processing the actual payments.
Regardless, we will not disclose the member’s bank account number to third party, except with the member’s express permission or if eLayaway is required to do so to comply with a subpoena or other legal process.
Personal Information Shared with Other Parties
eLayaway may share member personal information with:
Merchants of eLayaway providing joint content and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, services and communications. Partners with the eLayaway family will use this information to send the member marketing communications only if their services have been requested.
Service providers and partners under contract who assist with parts of eLayaway’s business operations (i.e. fraud prevention, bill collection, marketing, technology services). eLayaway contracts dictate that these service providers only use member information in connection with the services they perform for eLayaway and not for their own benefit.
Financial institutions that eLayaway partners with to jointly create and offer products where we share information with HSBC to determine whether the member should receive pre-approved offers available. These financial institutions may only use this information to market eLayaway-related products, unless the member has given consent for other uses.
Law enforcement, government officials, or other third parties when eLayaway is compelled to do so by a subpoena, court order or similar legal procedure. eLayaway does this to comply with the law. eLayaway believes it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety if any person, violations of the eLayaway Terms & Conditions or as otherwise required by law.
Other third parties with the member’s consent or direction to do so.
eLayaway will not sell, rent, lend, give, loan, or trade any of a member’s personal information to third parties in the normal course of doing business and only shares a member’s personal information with third parties as described in this policy.
Member Accessing & Changing of Personal Information
Members may review and edit personal information at any time by logging in to their account and clicking the “Setting” tab.
Contacting eLayaway with Member Questions
If members have questions or concerns regarding this policy, please contact us by emailing Compliance at compliance@eLayaway.com or writing us at eLayaway, Inc., Attn: Compliance Department, 3111 Mahan Drive, Suite 20 #121, Tallahassee, FL 32308.
Revised December 27, 2010