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PRIVACY POLICY



Tipalti, Inc. and our affiliated companies (including Tipalti Solutions LTD,
Tipalti Payments, Inc., Tipalti Europe LTD, Tipalti Canada, Inc., and Tipalti
B.V. – collectively, “Tipalti”, “we”, “our” or “us”), respects your privacy, and
are committed to ensuring that the personal data we process is secure, used in
accordance with this policy, and in compliance with privacy laws.   Please note
that this is a master privacy policy (“Privacy Policy”) and some of its
provisions only apply to individuals in certain jurisdictions. Important note:
Nothing in this Privacy Policy is intended to limit in any way your statutory
rights, including your rights to a remedy or means of enforcement.

This Privacy Policy describes how we collect, store, use and disclose the
following types of personal data relating to individuals who interact with
Tipalti (collectively “Personal Data”):

 * Prospect Data concerning our prospective customers, partners or individuals
   who visit our websites such as https://tipalti.com, https://www.approve.com,
   and their respective subdomains (collectively, the “Sites”) and interact with
   our online forms, or engage with our online ads and content, social media
   interactions (e.g. Facebook, LinkedIn, Twitter), emails or other
   communications under our control, or participate in events that we organize
   or take part in (collectively, “Prospects”);
 * Customer User Data concerning individuals (“Customer’s Users”) who use
   Tipalti’s cloud platform and related services (the “Services”) on behalf of
   our business customers (“Customers”);
 * Payee Data concerning individuals to whom (personally, or for their employer;
   “Payee Users”), following sign up, payments are made via the Services; 
 * Supplier Data concerning individuals (“Supplier’s Staff”) employed by
   suppliers of a Customer, or other individuals, that interact with the
   Services, whether or not payments are made to such suppliers or individuals. 



Specifically, this Privacy Policy describes our practices regarding: 

 1.  Data Collection
 2.  Data Uses
 3.  Data Location
 4.  Data Retention
 5.  Data Sharing
 6.  Cookies and Tracking Technologies
 7.  Communications
 8.  Data Security
 9.  Data Subject Rights
 10. Data Controller/Processor
 11. Additional Information and Contact Details



If you are our Prospect, a Customer User, Payee User or Supplier Staff (“you”),
please read this Privacy Policy carefully and make sure that you fully
understand and agree to it.

1. DATA COLLECTION

How We Collect. We collect, receive, and process Personal Data about you
through:

 * Your interaction with us, our Sites, or our Services; 
 * From our Customers, who provide us with Customer Data and in some cases,
   Payee Data; 
 * Through third-party services and providers, such as business partners, credit
   bureaus, social media tools, analytics and other publicly available sources;
   and
 * Events we organize or take part in, and other business initiatives (including
   partner promotions, communications, and events).  

What We Collect. We collect, receive, and process the following Personal Data
about you:

Prospect Data: 

 * Website usage information: technical and aggregated usage data, such as user
   agent, IP addresses, device data (like type, OS, device id, browser version,
   geolocation  and language settings used), connectivity data, activity logs,
   session recordings, and the cookies and pixels installed or utilized on our
   Sites or your device; 
 * Prospect account information: contact and business details (full name, email
   address, company name and phone number)  of our prospective customers and
   partners, which may also contain the details of their relevant internal focal
   persons; our communications with such Prospects (correspondences, call and
   video recordings and transcriptions, and analyses thereof), as well as any
   needs, preferences, attributes and insights relevant to our potential
   engagement.

Customer User Data: 

 * Account login information: e-mail address and, when applicable, hashed
   password or other information used for authentication and access control;
 * Profile and contact information: full name, title, company name, e-mail and
   phone number, profile picture, social media accounts, role, and additional
   information and media submitted by Customer’s Users or their organization;
 * Platform usage information: technical usage data, such as user agent, IP
   addresses, device data (like type, OS, device id, browser version,
   geolocation and language settings used), connectivity data, activity logs,
   session recordings, and the cookies installed or utilized on the Customer’s
   User’s device; and
 * Direct interactions and communications with us: including recordings and
   transcripts of your calls and correspondence with us, e.g. for user
   enablement, support and training purposes. 
 * Identification Information: Supplemental documentation may be required by
   Tipalti to verify the identity of Customer’s directors, officers, or owners
   (who may be Customer’s Users), such as a copy of a government-issued
   identification card, personal bank statements or other documentation serving
   as proof of identity or valid address. This includes any additional data you
   choose to provide to us directly through our Know Your Customer (“KYC”)
   process to comply with legal, regulatory, and other compliance-related
   requirements. To the extent that any of the foregoing solely relates to a
   non-human entity, we will not regard it as personal data, and this Privacy
   Policy will not apply to it.

Supplier Data:

 * Account login information: e-mail address and, when applicable, hashed
   password or other information used for authentication and access control.
 * Profile and contact information: full name, title, company name, e-mail and
   phone number, profile picture, role, department, and additional information
   and media submitted by Supplier Staff or their organization. When the
   supplier is a legal entity, we collect some information on contact persons.
   When the supplier’s data includes individual’s Personal Data, we also
   collect: social media accounts, field of occupation, bank and payment
   details, other information a user decides to share;
 * Platform usage information: technical usage data, such as user agent, IP
   addresses, device data (like type, OS, device id, browser version,
   geolocation and language settings used), connectivity data, activity logs,
   session recordings, and the cookies installed or utilized on the Payee User’s
   device.

Payee Data: 

 * Account login information: e-mail address and, when applicable, hashed
   password or other information used for authentication and access control;
 * Profile and contact information: full name, title, company name, email and
   phone number, profile picture, and additional information and media submitted
   by Payee Users or their organization;
 * Payment information: Payee User name, email address, physical addresses,
   phone number, VAT ID, Social Security Numbers or EU Tax Identification
   Number, bank account number, IBAN, SWIFT code (or alternatively, account
   details at payment processing services such as PayPal, where applicable) and
   payment preferences. Supplemental documentation may be required by the
   Customers, such as a copy of Payee User’s government-issued identification
   card, personal bank statements or other documentation serving as proof of
   identity or valid address. This includes any additional data you choose to
   provide to us directly, provided to us by the relevant Customer, banks,
   payment processing services, your representative, or that we may require in
   order to properly process your payment and in order to comply with legal,
   regulatory, and other compliance-related requirements. To the extent that any
   of the foregoing solely relates to a non-human entity, we will not regard it
   as personal data, and this Privacy Policy will not apply to it;
 * Platform usage information: technical usage data, such as user agent, IP
   addresses, device data (like type, OS, device id, browser version,
   geolocation and language settings used), connectivity data, activity logs,
   session recordings, and the cookies installed or utilized on the Payee User’s
   device; and
 * Direct interactions and communications with us: including recordings and
   transcripts of your calls and correspondence with us, e.g., for user
   enablement, support and training purposes. 

*Tipalti processes Personal Data  (1) as a processor on our Customer’s behalf,
in accordance with their reasonable instructions in connection with the
Services; and (2)  as a controller for our own legitimate purposes, as further
explained in Section 2 and Section 10 below.

For California Residents: The personal information that we may collect, or may
have collected from consumers in the preceding twelve months, fall into the
following categories established by the California Consumer Privacy Act
(“CCPA”), depending on how you engage with Tipalti:

 * Identifiers, such as your name, alias, address, phone numbers, or IP address;
 * personal information as described in subdivision (e) of Section 1798.80 of
   the California Civil Code, such as a credit card number;
 * characteristics of protected classifications under California or US federal
   law, such as age or gender, for example if we conduct due diligence and other
   identification checks;
 * commercial information, such as purchase activity;
 * Internet or other electronic network activity information, including browsing
   history, search history, and information regarding your interaction with the
   Services;
 * biometric information, including physiological, behavioral, and biological
   characteristics, or activity patterns used to extract a template or other
   identifier or identifying information, such as, fingerprints, faceprints, and
   voiceprints, iris or retina scans, keystroke, gait, or other physical
   patterns;
 * geolocation data, such as the location of your device or computer;
 * audio, visual, electronic or other similar information, including when you
   communicate with us by phone or otherwise;
 * professional or employment-related information, for example data you may
   provide about your business;
 * inference data, such as information about your preferences; and
 * education information, such as information about enrollment status, fields of
   study, or degrees, honors, and awards received.

Legal Basis for Collection: GDPR

For Personal Data that is subject to the EU General Data Protection Regulation
(“GDPR”), the lawful basis for collecting and using your Personal Data is
consent, where you have provided your consent, or for fulfilling our contractual
obligations in providing our Services. For instances where your consent is not
obtained or there is no contractual obligation, we collect and use your Personal
Data in our legitimate interests (which are not overridden by your data
protection interests), such as operating our business, understanding and
improving our products, direct marketing related to our products and services,
hosting events, communicating with you about our products, services, events or
related resources, improving our Sites, and protecting our legal rights and
interests.  

You are not legally required to provide us with any personal data and may do so
(or avoid doing so) at your own free will. If you provided your consent for us
to collect and use your Personal Data, you may withdraw that consent at any
time. If you do not wish to provide us with your personal data, or to have it
processed by us or any of our service providers (per Section 5 below), please
contact the applicable Customer or Supplier (if you are a Customer User or
Supplier Staff) and contact us (if you are a Prospect or Payee) about your
personal data request (per Section 11 below). By accessing and/or using any of
the Services, you signify and affirm your informed consent to the collection and
processing of your Personal Data as defined and explained in this Privacy
Policy. 

2. DATA USES

Tipalti processes the Personal Data described in Section 1 as necessary for the
performance of our Services; to comply with our legal and contractual
obligations; and to support our legitimate interests in maintaining, improving
and advertising our Services. 

Specifically, we use Personal Data and technical usage data, for the following
purposes:

 1.  To facilitate, operate, and provide our Services, including determining
     your initial and continued eligibility to use our Services;
 2.  To authenticate the identity of our Customer Users and Payee Users,  
 3.  To facilitate and manage access to and use of our Services, including
     account creation, login and deletion;
 4.  To provide you with customer care, assistance and technical support
     services;
 5.  To further develop, customize and improve the Services, and to improve your
     user experience;
 6.  To facilitate and optimize our marketing and advertising campaigns, ad
     management and sales operations, and to manage and deliver advertisements
     for our products and Services more effectively; 
 7.  To contact you with general or personalized service-related messages, or
     with promotional messages, in accordance with Section 7 below, and to
     facilitate, sponsor and offer certain events and promotions;
 8.  To support and enhance our data security measures, including for the
     purposes of preventing and mitigating the risks of fraud, error or any
     illegal or prohibited activity;
 9.  To create aggregated statistical and research data, inferred non-personal
     data, or anonymized or pseudonymized data (rendered non-personal), which we
     or our business partners and customers may use to provide and improve our
     respective services, or for any other purpose; 
 10. To enforce and apply our agreements, including for billing and collection
     purposes; and
 11. To comply with our legal, regulatory, compliance and contractual
     obligations, including in particular as a business and a financial services
     provider.

For California Residents: The personal information that we may have used and/or
disclosed about consumers for a business purpose in the preceding twelve months
fall into the following categories established by the CCPA:

 * To facilitate, operate, and provide our Services
 * To verify the identity of our Users
 * To determine your eligibility to use our Services
 * To further develop, customize and improve our Services, and to provide you
   with any such enhanced Services
 * To provide customer assistance and technical support
 * To contact our Users, Consumers, customers, and website visitors with general
   and personalized service-related notices, surveys and promotional messages
   including marketing and advertising messages
 * To create aggregated statistical data and other aggregated and/or inferred
   Non-personal Information, which we, our Users or our business partners may
   use to operate and improve our respective services
 * To manage and assess risk, enhance our data security and fraud prevention
   capabilities, and help protect against error, fraud or any illegal or
   prohibited activity
 * To act as permitted by, and to comply with any legal or regulatory
   requirements
 * To conduct any additional activities that may require the use of your
   Personal Information, for which we will request your consent in advance
 * And any other usage delineated in Tipalti’s Privacy Policy

3. DATA LOCATION

We and our authorized service providers (as detailed in Section 5 below) manage,
store and process personal data in the United States, Israel, the United
Kingdom, Germany, and other locations as reasonably necessary for the proper
performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Tipalti, its affiliates and
service providers are each committed to protect Personal Data in accordance with
this Privacy Policy, customary industry standards, and applicable laws in the
jurisdictions to which Personal Data may be processed. In particular, Personal
Data processed on behalf of our customers may only be processed in such
locations as permitted in our DPA and other commercial agreements with them.

International Transfers of Information

Personal Data is transferred to the United States, Israel, the United Kingdom,
and Germany by Tipalti in the general course of business, and in accordance with
applicable laws. For Personal Data that is subject to the GDPR, Tipalti utilizes
approved contractual transfer mechanisms, such as the EU adequacy decision for
transfers to Israel, and the Standard Contractual Clauses approved by the
European Commission for transfers to the United States. 

4. DATA RETENTION

We retain Personal Data for as long as it is reasonably necessary to achieve our
stated purpose (e.g. to provide you with our Services, to comply with
contractual obligations, or as required for proper log-keeping, records and
bookkeeping, and in order to have proof and evidence concerning our
relationship, should any legal issues arise following your discontinuance of
use), all in accordance with applicable laws and regulations. Where applicable,
we also retain Personal Data with our Customer’s reasonable instructions and as
further stipulated in our DPA and other commercial agreements with such
Customer. You may delete your Personal Data or request us to delete your
Personal Data, at any time. Please contact the Customer or Supplier (if you are
a Customer User or Supplier Staff), or otherwise contact us as outlined in
Section 11 below. 

Please note that except as required by applicable law or our specific agreements
with you, we will not be obligated to retain your Personal Data for any
particular period, and we are free to securely delete it or restrict access to
it for any reason and at any time, with or without notice to you. If you have
any questions about our data retention policy, please contact us by e-mail at
privacy@tipalti.com. 

5. DATA SHARING

Tipalti shares Personal Data as provided below. 

Legal Compliance: In exceptional circumstances, we may disclose or allow
government and law enforcement officials access to your Personal Data in
response to a subpoena, search warrant or court order (or similar requirement),
or in compliance with applicable laws and regulations, with or without notice to
you. All such disclosure requests will be reviewed by Tipalti to determine to
what extent, if any, Tipalti is required to comply with such request. Tipalti
will consult with its legal advisors on the request to determine if we are
permitted to notify you about such requests. Such disclosure or access may occur
if we believe in good faith that: (1) we are legally compelled to do so; (2)
disclosure is appropriate in connection with efforts to investigate, prevent, or
take action regarding actual or suspected illegal activity, counter terrorist
financing verification requirements fraud, or other wrongdoing; or (3) such
disclosure is required to protect our legitimate business interests, including
the security or integrity of our products and Services. Unless Tipalti is
prohibited from doing so by applicable laws or the applicable legal request,
Tipalti may notify you before disclosing Personal Data, so you may take the
necessary steps to object or seek protection from disclosure. 

Service Providers: We engage selected partners, and third-party companies and
individuals to perform services complementary to our own, and to support the
operation of our business. Such Service Providers include hosting and server
co-location services, communications and content delivery networks (CDNs),
internet service providers, operating systems and platforms, data analytics
services, marketing and advertising services, data and cyber security services,
fraud detection and prevention services, capital providers, and correspondents,
banks, financial institutions, credit bureaus, collection agencies, customer
engagement services, billing and payment processing services, web analytics,
e-mail and SMS distribution and monitoring services, session or activity
recording services, remote access services, performance measurement, data
optimization services, social and advertising networks, content providers,
support and customer relation management systems, service providers that help us
verify your identity and help us comply with our legal and regulatory
obligations to screen and monitor transactions; recruiters and companies that
provide background checking services; and our business, legal, tax, financial
and compliance advisors (collectively, “Service Providers“). These Service
Providers may have access to your Personal Data, depending on each of their
specific roles and purposes in facilitating, supporting, and enhancing our
Services, and may only use it for such purposes. 

Third-Party Websites and Services: Our Services may include links to third-party
websites, and integrations with third-party services. Such websites and
third-party services, and any information you process, submit, transmit or
otherwise use with such websites and third-party services, are governed by such
third-party’s terms and privacy practices and policies, and not by this Privacy
Policy. We encourage you to carefully read the terms and privacy policies of
such websites and third-party services. To the extent that our Service Providers
contact you in order to offer or promote our Service, they may additionally
interest you in their own services. Should you decide to engage in such
activities with Tipalti’s Service Providers, please note that such engagement is
beyond the scope of Tipalti’s Terms of Use and Privacy Policy and will therefore
be covered by our Service Provider’s terms and privacy policy.

Sharing Data with Other Users: Payee Data is typically shared with and is
available to Customer Users within the relevant Customer account. Customer Data
is shared with the administrator or other users of their Customer account. In
such cases, sharing such data means that the administrator or other users of the
account may access it on behalf of the Customer, and will be able to monitor,
process and analyze the Personal Data contained therein. This includes instances
where you may contact us for help in resolving an issue specific to you or to a
team of which you are a member (and which is managed by the same Customer).
Please note that Tipalti is not responsible for and does not control any further
disclosure, use or monitoring by or on behalf of the Customer, where the
Customer acts as the Data Controller of such data (as further described in
Section 10 below). Supplier Data is typically shared with other users of the
Services, primarily through access to the Supplier’s site in relation to the
Services. 

Protecting Rights and Safety: We may share your Personal Data with others if we
believe in good faith that this will help protect the rights, property or
personal safety of Tipalti, any of our Customers, their users, Payees, our
Prospects, or any members of the general public.

Tipalti Subsidiaries and Affiliated Companies; Change of Control: We may share
your Personal Data internally within our affiliates for the purposes described
in this Privacy Policy. In addition, should Tipalti or any of its affiliates
undergo any change in control or ownership, including by means of merger,
acquisition or purchase of substantially all or part of its assets, or will be
considered or found eligible for a governmental grant, personal data may be
shared with the parties involved in such an event. If we believe that such an
event might materially affect your Personal Data then-stored with us, we will
notify you of this event and the choices you may have via e-mail or prominent
notice on our Services.

Additional Sharing: Tipalti may share your Personal Data in additional manners,
pursuant to your explicit consent, or if we are legally obligated to do so, or
if we have successfully rendered such data non-personal, non-identifiable and
anonymous. 

6. COOKIES AND TRACKING TECHNOLOGIES

Tipalti and our Service Providers use cookies and other technologies on our
Sites and within our Services, for performance, tracking, analytics,
personalization purposes and in order to provide you with a better experience.
We may share non-identifiable/aggregated extracts of such information with our
partners for our legitimate business purposes. 

Cookies are small text files that are stored through the browser on your
computer or mobile device (for example, Google Chrome or Safari) when you visit
a website. Some cookies are removed when you close your browser session – these
are the “Session Cookies”, others last for longer periods and are called
“Persistent Cookies”. We use both types of cookies to facilitate the use of the
Services’ features and tools (for example, we use Persistent Cookies to remember
your login details and make it easier for you to login the next time you access
the Platform). 

The following describes different categories of cookies and how we might use
them on our Sites and within our Services. 

Required Cookies: These cookies are necessary for the functionality of our
Sites, and include session cookies needed to transmit authentication and
security cookies. These cookies cannot be opted out of, as they are required for
website functionality. 

Functional Cookies: These cookies assist us with enhancing the function and
performance of our Sites, including capturing analytics of website traffic,
assisting with market research, and providing non-targeted advertising. 

Google Analytics: We use Google Analytics to collect information to maintain and
improve the use of our Sites and Services. Google Analytics collects information
such as how often users visit the Services, which pages they visit when they do
so, and which other sites they used prior to coming to our Services. Google’s
ability to use and share information collected by Google Analytics about your
visits to and use of the Services is restricted by the Google Analytics Terms of
Service and the Google Privacy Policy. You can learn more about how Google
collects and processes data specifically in connection with Google Analytics
here. Further information about your option to opt-out of these analytics
services is available here. 

Mixpanel: We collect personal data such as your email address and your user
activity through Mixpanel. Mixpanel’s ability to use and share information is
governed by the Mixpanel Terms of Use, and the Mixpanel Privacy Policy. You can
opt-out of Mixpanel’s services by email at: compliance@mixpanel.com.  

Advertising Cookies: These cookies track a user’s activity across websites in
order to understand a user’s interests, and to direct marketing to the user.
More information on how we use advertising cookies in relation to interest-based
advertising is outlined below. 

Interest-Based Advertising: Interest-based ads are sometimes referred to as
personalized or targeted ads. We and our marketing partners may show
interest-based ads to display features, products, and services that might be of
interest to you. In providing interest-based ads, we follow the Self-Regulatory
Principles for Online Behavioral Advertising developed by the Digital
Advertising Alliance (a coalition of marketing, online advertising, and consumer
advocacy organizations). Some of these companies deliver advertising and content
based on your activity across websites, devices, and over time. These companies
may process your information for their own purposes of operating their
advertising networks in accordance with their own privacy policies. 

Opting Out. You can manage your cookies preferences, including whether or not to
accept them and how to remove them, through your browser settings. Please bear
in mind that disabling cookies may complicate or even prevent you from using the
Services. Please note that opting-out of cookies may require that you first
accept cookies from a provider, because your opt-out preference may be stored in
the form of a cookie. Likewise, when you get a new computer, install a new
browser, erase or otherwise alter your browser’s cookie file (including
upgrading certain browsers), you may also clear the opt-out cookies installed
once you opt-out, so an additional opt-out will be necessary to prevent
additional tracking. For more information regarding cookies, you may find the
following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.

If you do not want to receive interest-based advertising, you may opt out by
visiting www.aboutads.info/choices (US), https://youradchoices.ca/ (CAN), or
https://www.youronlinechoices.com/ (Europe). If you opt out of interest-based
advertising, you may still see ads that are less tailored for you as you browse
the internet. In addition, our advertising partners may have methods to opt out
on their individual websites, links to which are listed below as of February 11,
2021:

 * Adobe
 * Alphabet
 * Verizon Media
 * Microsoft Corporation
 * LinkedIn Corporation
 * Twitter
 * Facebook (on and off their service)
 * Claritas
 * Criteo

7. COMMUNICATIONS

We engage in service and promotional communications, through e-mail, phone, and
notifications within the Services. 

Service Communications: We may contact you with important information regarding
our Services. For example, we may send you notifications (through any of the
means available to us) of changes or updates to our Services, billing issues,
payment issues, login attempts or password reset instructions. Our Customers and
their users on the same Customer account may also send you notifications,
messages and other updates regarding their or your use of the Services. 

Notifications and Promotional Communications: We and our authorized partners
(e.g., event or webinar co-sponsors) may also notify you about new features,
additional offerings, events, webinars, special opportunities or any other
information we think you will find valuable. We may provide such notices through
any of the contact means available to us (e.g. phone, mobile or email), through
the Services, or through our marketing campaigns on any other third party sites
or platforms. 

You can typically control your communications and notifications settings from
your Tipalti profile settings, or otherwise by following the instructions
typically included in the communications sent to you. If you do not wish to
receive promotional communications, you may also notify Tipalti at any time
here, or by sending an e-mail to: opt-out@tipalti.com. 

8. DATA SECURITY

We and our hosting services implement appropriate technical, organizational, and
administrative systems, applications and procedures to secure your personal
data, to minimize the risks of theft, damage, loss of information, or
unauthorized access or use of information. Among other things, we:

 * Offer HTTPS secure access to most areas on our Services; 
 * Use industry standard SSL/TLS encrypted connections to protect the
   transmission of information that we believe in good faith to be of a
   sensitive nature; 
 * Use encryption tools to protect such sensitive information stored with us; 
 * Regularly monitor our systems for possible vulnerabilities and attacks; and 
 * Seek new ways and tools for further enhancing the security of our Services
   and the integrity of the personal data that we hold.

We believe that these measures provide sound industry standard security,
confirmed also by Tipalti’s SOC 2 Type I compliance certification. That said,
regardless of our continuous efforts to protect your privacy, we cannot
guarantee that our Services will be immune from any wrongdoings, malfunctions,
bugs, unlawful interceptions or access, or other kinds of abuse and misuse which
may compromise your privacy. As the security of information depends in part on
the security of the computer, device, or network you use to communicate with us
and the security you use to protect your user IDs and passwords, please make
sure to take appropriate measures to protect this information.

9. DATA SUBJECT RIGHTS

Individuals have the following rights concerning their personal data under
global privacy laws, including but not limited to, California Consumer Privacy
Act (“CCPA”) and GDPR. 

 * The right to access personal data held about you. Your right of access may
   normally be exercised free of charge; however we reserve the right to charge
   an appropriate administrative fee where permitted by applicable law.
 * The right to request that we rectify any personal data we hold that is
   inaccurate or misleading.
 * The right to request the erasure/deletion of your personal data (e.g., from
   our records). Please note that there may be circumstances in which we are
   required to retain your personal data, for example for the establishment,
   exercise or defense of legal claims.
 * The right to object, to or to request restriction, of certain processing
   activities.
 * The right to data portability. This means that you may have the right to
   receive your personal data in a structured, commonly used and
   machine-readable format, and that you have the right to transmit that data to
   another controller.
 * The right to object to profiling.
 * The right to withdraw your consent at any time. Please note that there may be
   circumstances in which we are entitled to continue processing your data, in
   particular if the processing is required to meet our legal and regulatory
   obligations. Also, please note that the withdrawal of consent does not affect
   the lawfulness of processing based on consent before its withdrawal.
 * For individuals subject to GDPR, the right to request certain details of the
   basis on which your personal data is transferred outside the European
   Economic Area, but data transfer agreements and/or other details may need to
   be partially redacted for reasons of commercial confidentiality.
 * The right to lodge a complaint with your local data protection supervisory
   authority (i.e., your place of habitual residence, place or work or place of
   alleged infringement) at any time or before the relevant institutions in your
   place of residence. We ask that you please attempt to resolve any issues with
   us before you contact your local supervisory authority and/or relevant
   institution.

If you wish to exercise your privacy rights under any applicable law, including
CCPA and GDPR, in relation to Personal Data held with Tipalti, please login to
your account via the Services or the relevant website (where you originally
uploaded this personal data) and view, edit or deactivate the data saved in that
account. If you do not have such an account, or if you wish to exercise your
right to restrict or object to such processing, to port such personal data (if
applicable), or to exercise any similar rights afforded to data subjects under
the laws that apply to you – please contact us by e-mail at:
privacy@tipalti.com. If you provided personal information to a Tipalti Customer
and believe it is being processed by Tipalti on behalf of that Customer, please
make any requests or queries regarding personal data to that Customer directly. 

Please note that we may require additional information, including certain
personal data, in order to authenticate and process your request. Such
additional information may be then retained by us for legal purposes (e.g. as
proof of the identity of the person submitting the request), in accordance with
Section 4 above. We may redact any personal data related to others from the data
which we will make available to you.

Please also note that such rights are not absolute. There are instances where
applicable law or regulatory requirements allow or require us to refuse to
provide some or all of the personal data that we hold about you. In the event
that we cannot accommodate your request, we will inform you of the reasons why,
subject to any legal or regulatory restrictions. 

We will respond within thirty (30) days upon receipt of your personal data
request; or (b) if additional time is required to meet your request, we will
notify you by mail or electronically of the reason and extension period,
provided, however, such extension shall not exceed forty-five (45) days.

We do not charge a fee to process or respond to your personal data request,
provided that it is not excessive, repetitive, or manifestly unfounded.

For California consumers: For specific inquiries concerning the CCPA, you must
submit a Verifiable Consumer Request to Tipalti via email to Privacy@Tipalti.com
and include all of the following information:

 * Your relationship with Tipalti (payer, payee, or advertising recipient);
 * The email address through which Tipalti communicates with you;
 * The name you have registered with Tipalti or to whom Tipalti addresses you;
 * A contact phone number so Tipalti may call you in order to verify your
   identity; and
 * Which rights you are exercising:
   * Your Right to Access your Data, and/or
   * Your Right to Delete your Data.

We cannot respond to your request or provide you with Personal Information if we
cannot verify your identity or authority to make the request and confirm the
Personal Information relates to you. Making a Verifiable Consumer Request does
not require you to create an account with us. We will only use Personal
Information provided in a Verifiable Consumer Request to verify the requestor’s
identity or authority to make the request.

Please note that any disclosures we provide will only cover the 12-month period
preceding the Verifiable Consumer Request.

10. DATA CONTROLLER/PROCESSOR

Certain data protection laws and regulations, such as the GDPR, typically
distinguish between two main roles for parties processing Personal Data subject
to those laws and regulations: the “Data Controller”, who determines the
purposes and means of processing; and the “Data Processor”, who processes the
Personal Data on behalf of the Data Controller. Below we explain how these roles
apply to our Services, to the extent that such laws and regulations apply.

Tipalti is the Data Controller of its Prospect Data. With respect to such
Personal Data, we assume the responsibilities of Data Controller (solely to the
extent applicable under law), as set forth in this Privacy Policy. In such
instances, our Service Providers processing such Personal Data will assume the
role of Data Processors. For our advertising and analytics purposes, we may
engage third parties who are also Data Controllers with respect to Prospect
Data.

Tipalti is both a Data Controller and Data Processor of Payee Data. Payee Data
is processed by Tipalti as a (1) Data Processor on our Customer’s behalf, in
accordance with their reasonable instructions in connection with Customer’s
specific use of the Services, and as further stipulated in our agreements with
such Customer; and (2) Data Controller for Payee Data gathered by Tipalti for
our own legitimate purposes. 

Tipalti is both a Data Controller and Data Processor of Customer Data and
platform usage data. Such Personal Data is processed by Tipalti for its own
purposes (as described in Section 2 above), as an independent Data Controller;
whilst also processing certain portions of it on the Customer’s behalf, as its
Data Processor.

Both Tipalti and the Customer are responsible for meeting any legal requirements
applicable to Data Controllers (such as establishing a legal basis for
processing and responding to Data Subject Rights requests concerning the data
they control). Where Tipalti processes Customer Data and Payee Data solely on
behalf of our Customer, we would do so strictly in accordance with such
Customer’s reasonable instructions and as further stipulated in our  agreements
with the Customer. 

For the avoidance of doubt, each Customer is responsible for the security,
integrity and authorized use of Payee Users’ information in their control, and
for providing adequate notice to their users and Payees whose personal data may
be processed – including sufficient reference to the processing of their
personal data via the Services, and any other information necessary to comply
with all applicable privacy and data protection laws; and to obtain all
approvals and consents from such individuals as required under such laws. 

11. ADDITIONAL INFORMATION AND CONTACT DETAILS

Updates and Amendments: We may update and amend this Privacy Policy from time to
time by posting an amended version on our Sites. The amended version will be
effective as of the date it is published. We will provide prior notice if we
believe any substantial changes are involved via any of the communication means
available to us or via Services. After such notice period, all amendments will
be deemed accepted by you.

External Links: While our Services may contain links to other websites or
services, we are not responsible for their privacy practices. We encourage you
to pay attention when you leave our Services for the website or application of
such third-parties, and to read the privacy policies of each and every website
and service you visit. This Privacy Policy applies only to our Services. 

Our Services are not designed to attract children under the age of 16: We do not
knowingly collect personal data from children and do not wish to do so. If we
learn that a person under the age of 16 is using the Services, we will attempt
to prohibit and block such use and will make our best efforts to promptly delete
any personal data stored with us with regard to such child. If you believe that
we might have any such data, please contact us by e-mail at
privacy@tipalti.com. 

EU Representative: Tipalti has appointed VeraSafe as a representative in the
European Union for data protection matters pursuant to Article 27 of the GDPR.
VeraSafe may be contacted only on matters related to the processing of Personal
Data. To make such an inquiry, please contact VeraSafe here. Alternatively,
VeraSafe can be contacted at: VeraSafe Czech Republic s.r.o, Klimentská 46,
Prague 1, 11002, Czech Republic. If you are a GDPR-protected individual, you
also have the right to lodge a complaint with an EU supervisory authority.

California Consumers: The following disclosures are required by the California
Consumer Privacy Act and are effective as of February 9, 2021:

 * No sale of personal information. In the preceding twelve months, we have not
   sold any personal information of consumers, as those terms are defined under
   the California Consumer Privacy Act.
 * No Discrimination. We will not discriminate against any consumer for
   exercising their rights under the California Consumer Privacy Act..
 * Designating an Authorized Agent. Only you or a person or entity that is
   either (i) registered as an agent with the California Secretary of State that
   you authorize to act on your behalf; or (ii) that you have provided power of
   attorney to pursuant to Probate Code Sections 4000 to 4465 (“Authorized
   Agent”) may submit a Verifiable Consumer Request related to your Personal
   Information. If you choose to use an Authorized Agent, Tipalti may require
   that you provide the Authorized Agent with written permission to do so, and
   verify the identity of the Authorized Agent directly with you.

Questions, concerns or complaints: if you have any comments or questions
regarding our Privacy Policy, or if you have any concerns regarding your
personal data held with us, or if you wish to make a complaint about how your
personal data is being processed by Tipalti, you can contact our Data Protection
Officer at privacy@tipalti.com. Alternatively, you can contact us at:
Tipalti, 1810 Gateway Dr., Suite 300, San Mateo, CA 94404.

How to opt-out of receiving Promotional Messages from Tipalti:

 * Opt-out landing page, or
 * Send an email to opt-out@tipalti.com and request to no longer receive
   promotional emails and/or phone calls.

Effective Date: August 25, 2021


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