Privacy Policy

This privacy policy explains how Ripple Treasury keeps personal information gathered through our products and services, private and secure.

Ripple Treasury knows that the information given to us by users is very important and that users care how that information is used and stored. Ripple Treasury takes privacy very seriously, and that is why we have this Privacy Policy in place. This Privacy Policy describes how Ripple Treasury goes about gathering user information and how it is used and stored, whether it be from information received online or offline.

This Privacy Statement starts with a general statement of our privacy practices and then provides specific information for residents of California and data subjects who are in the European Economic Area. If you are a resident of California or in the European Economic Area, please refer to that information in addition to the general statement.

By using the sites online or following the offline practices, users are agreeing to the practices that are outlined in the Privacy Policy mentioned herein. Ripple Treasury does not sell user information nor does Ripple Treasury obtain information about minors.

What Types of Information Does Ripple Treasury Collect About Its Users?

• Personal Information: “Personal Information” is identified as information that is used to tell who a user may be. Information that is used to do this can include: first and last name, title, company name, phone number, email address, and company address. By submitting any personal information to Ripple Treasury, users are giving us the consent to use this information as it pertains to this privacy policy.
• Other Information: “Other Information” is identified as information that does not directly tell who someone is, but instead is more of a generalization. Examples include: cookies, browser and device information, regions, lead sources, and search engine information or terms. This information is used to analyze where users are, and the channels used to reach us.
• IP Address: An “IP Address” is a set of numbers that is given to the user automatically by their internet service provider. IP addresses are automatically captured through our system when users access any Ripple Treasury owned or hosted sites. This is a standard practice throughout all industries. IP addresses are used to see where people are accessing Ripple Treasury’s website from, to track usage of the Ripple Treasury site, as well as to track user engagement and journeys to better assist in providing relevant information.

How does Ripple Treasury Collect Information?

Personal Information is gathered in many ways, for example:

• Through Users: Ripple Treasury will gather information such as: name, email address, full billing address, phone numbers, company name, and title by users voluntarily providing the information to us. Voluntary methods include: form submissions filled out on any website owned by Ripple Treasury, emails sent directly to any individual at the corporate domain (treasury.ripple.com) or by physically distributing your information to us via a business card, sign-up sheet, and the like. There are no legal obligations to give Ripple Treasury personal information, and any information given to us will be provided by your own free will.
• Offline: Personal information can be collected offline when users: attend trade shows or conferences Ripple Treasury is present at, User Meetings/Conferences hosted by Ripple Treasury, phone calls conducted by Ripple Treasury employees or contractors, or by contacting our Ripple Treasury Customer Support teams.
• Online: Personal information may be collected when users are online. Examples of this include: completing any forms on a website owned by Ripple Treasury including, but not limited to, request a demo form, contact us form, download a whitepaper form, download a product card form, download an infographic, download case study, download an eBook, or by signing up for any webinars hosted by Ripple Treasury or an announced partner of Ripple Treasury.
• Information from Other Sources: In order for us to provide users with the best quality service and relevant marketing, we may gather information about users from other third-party resources including: data cleansing tools, data enhancement tools, and social media platforms.

Other Information is gathered through a variety of ways such as:

• Through IP Address: Users’ IP address is automatically captured when visiting our site and is used to analyze where users are accessing us from. We also use the IP Address to see the usage of our site and to analyze any problems that may occur.
• Browser or Device: Information collected by users’ browser can include what browser they are using and what type of device they are using.
• Web Analytics: These analytics are captured through cookies and help provide Ripple Treasury with information like unique visitors, activity, traffic provided by certain devices, and what channels are providing Ripple Treasury the most web traffic.

How Does Ripple Treasury Use Personal Information?

• To make sure we have correct information in case we need to contact users regarding their service or respond to any questions.
• To send updates on what’s happening with Ripple Treasury.
• To send relevant marketing information that we believe to be of interest to users via email.
• To develop a user profile through a lead scoring process that customizes experiences that best pertain to users.
• For legitimate business purpose only, such as data analysis, running campaigns, developing new products, enhancing the user experience, and solving problems.

How Will Ripple Treasury Share Other Information & Personal Information It Receives?

Ripple Treasury will not share any information it is given by its users without consent. Any information shared will be general information such as number of users, preferred TMS preferences, etc. Ripple Treasury will not sell user information.

However Ripple Treasury maintains the right to share:

• Anonymized information. If Ripple Treasury anonymizes or deidentifies information (i.e., combines it with other information, redacts it, or otherwise makes it so that it no longer reasonably identifies you), Ripple Treasury may share that information with anyone for any purpose.
• Successors. If Ripple Treasury sells or otherwise transfers (or investigates the potential sale or other transfer of) all or a part of its business, Ripple Treasury may transfer to, or share with, the actual or potential buyer or other transferee, the personal information associated with the potentially or actually transferred business. Such transfer would be for the purpose of facilitating due diligence and/or allowing the buyer or other transferee to operate the business.
• To comply with legal requirements. Ripple Treasury may share your information if required by law enforcement, government agencies, courts, or others where Ripple Treasury believes that its cooperation with information requests is required by law.

How Does Ripple Treasury Secure Personal Information?

Ripple Treasury has technical and organizational practices in place to make sure user information is safe and secure. We monitor all network and security systems to ensure they are updated and running correctly.   Ripple Treasury requires that its service providers use, commercially reasonable physical, technical, and other safeguards designed to prevent unauthorized access to, use of, or alteration of, your information.

How May Ripple Treasury notify me in the case of a data breach?

For the purposes of any applicable law regarding notification of persons whose personal information was, or is reasonably believed to have been, acquired by an unauthorized person, Ripple Treasury’s information security policy provides that any required notification may, where permitted by law, be made by the use of e-mail, telephone, fax, mail (including, but not limited to, a notice printed in an available area of a bill or statement) or posting a notice on a Ripple Treasury website or other electronic resource. The specific means used is up to Ripple Treasury, and Ripple Treasury will use its commercially reasonable judgment based on the circumstances. Where any notice is to be sent to a specific address or number (such as e-mail address, physical address, telephone number, etc.), Ripple Treasury will use the latest available address in its records. EXCEPT TO THE EXTENT PROHIBITED BY LAW, YOU AGREE TO THIS MEANS OF NOTIFICATION.

How can you correct your personal information?

If your personal information changes, if you have reason to believe that your personal information as Ripple Treasury maintains it is incorrect, or if you no longer desire service, you may contact Ripple Treasury using the contact information below and Ripple Treasury will accommodate all reasonable requests for such changes.   Note that California residents might have additional or different rights. Please refer to that portion of this Privacy Statement to determine whether those rights apply to you.

How does Ripple Treasury handle choice and opt-out?

Users who no longer wish to receive newsletters, digital notifications, or promotional materials or have their information provided to third parties may opt to not receive such communications or have information shared by contacting Ripple Treasury using the information below. Please be prepared to tell us the specific Ripple Treasury good or service with respect to which you wish to opt out. Ripple Treasury will comply with such requests as soon as is commercially practicable. Such compliance may involve batch processing and other processes that take 30 days or longer. If you opt not to receive such communications or allow Ripple Treasury to share your information and then give your personal information to Ripple Treasury again using a site or under other circumstances that permit us to use your information, Ripple Treasury will regard your opt-out as rescinded.   Note that opting out will not have any effect on information that Ripple Treasury has shared with third parties as permitted by this Privacy Statement.   To change your preference with regard to the way your information is treated, contact us using the contact information below.   Note that California residents might have additional or different rights. Please refer to that portion of this Privacy Statement to determine whether those rights apply to you.

What if I opt out and then do things that opt me back in?

If, after opting out, you do certain things that invite us to use your personal information again, Ripple Treasury will regard you as having opted back in. Examples include, but aren’t limited to, asking one of Ripple Treasury’s personnel (verbally or otherwise) to send you information, signing up for an event, or similar communications or transactions. As always, Ripple Treasury will abide by the provisions of this Privacy Statement with respect to your personal information that you provide to Ripple Treasury.

How quickly does Ripple Treasury respond to requests?

Ripple Treasury will use commercially reasonable efforts to timely make any changes you request. Many such changes are accomplished using batch processing (i.e. collecting a number of similar change requests and making all such changes at once), so the changes might not be immediately effective. If you require an immediate change to your personally identifiable information and are unable to make such a change using the available site resources, please contact us.   Note that California residents and those in the European Economic Area might have additional or different rights. Please refer to that portion of this Privacy Statement to determine whether those rights apply to you.

How does Ripple Treasury handle changes to this Privacy Statement?

If Ripple Treasury decides to change this privacy policy, Ripple Treasury will post the changes on one or more websites and/or other places that Ripple Treasury reasonably believes will give you notice of the change if you’re paying reasonable attention to the privacy provisions of Ripple Treasury’s website(s) and/or resources.   Except as stated below, Ripple Treasury will use information in accordance with the privacy statement, or version of the privacy statement, under which the information was collected.   If Ripple Treasury decides to use information about you in a manner different from that stated in the privacy statement in effect at the time of collection, Ripple Treasury will notify you by e-mail if, and to the extent that, you have provided your e-mail address. If you reply to such an e-mail within a reasonable time and request that Ripple Treasury not use your personally identifiable information in the proposed new manner, Ripple Treasury will honor your request, but Ripple Treasury reserves the right to suspend your access to all or part of the services offered through one or more sites if you do so.   If you do not reply to such an e-mail, or Ripple Treasury receives a reply of “undeliverable” or similar message from your last known e-mail address, in either case after a reasonable time, Ripple Treasury will use the information in the proposed new manner.   Please be sure to update your e-mail and other contact information from time to time so that you don’t miss any communication by Ripple Treasury of the kind contemplated by this section.

Are there exceptions to the other provisions of this Privacy Statement?

Notwithstanding anything else in this privacy statement to the contrary, Ripple Treasury may collect personal information and use such information in ways other than those described above if Ripple Treasury is required to do so by law or if Ripple Treasury deems it advisable in the course of assisting law enforcement activities or protecting Ripple Treasury’s sites, resources, or property. Without limiting the foregoing, Ripple Treasury reserves the right to use and disclose any information that you provide to us if Ripple Treasury deems it advisable in the prosecution or defense of any litigation involving your use of Ripple Treasury’s goods, services, or software.

Special Information for California Residents

The California Consumer Privacy Act (the “CCPA”) provides specific rights to consumers who reside in California regarding their personal information. Note that Ripple Treasury does not sell the personal information of from California consumers. The following provisions apply to California consumers. To the extent that the following provisions are different from the general provisions above, the following provisions prevail.

Right to Know

You have the right to send us a request, not more than twice in a 12-month period, for any of the following information.

• The categories of personal information we collect about you;
• The categories of sources of the personal information that we collect about you;
• Our business or commercial purposes for collecting that personal information;
• The categories of third parties with whom we share that personal information, and categories of personal information that each recipient received; and
• The specific personal information that we collect about you.

Right to Deletion

You have the right to request that we delete any of your personal information that it has collected from you and retained, subject to certain exceptions.   For example, we may deny your deletion request if retaining the information is necessary for us to complete the transaction or service that you requested, detect security incidents, or enable internal uses that are reasonable aligned with your expectations.

How to Exercise your California Privacy Rights

To exercise the right to know and the right to delete, please submit a verifiable consumer request to us by sending us an email at: Compliance@gtreasury.com.

Please describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Process:

Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request. Any request that you submit to us is subject to an identification process to verify your identity or authority to make the request.

Time period:

We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you.

To exercise any of these privacy rights you can also designate another person to act on your behalf. In this case, we will need this person to provide us with a legally-enforceable written authorization (such as a power of attorney).

Fees:

We will typically not charge a fee to fully respond to your requests. However, if we determine that the request warrants a fee according to the CCPA, we will tell you why and give you a cost estimate before completing your request.

To obtain this information in an alternative format:

If you require this notice to be provided in a different format, please contact us at: Compliance@gtreasury.com

Special Information for Persons in the European Economic Area

The following provisions apply to persons in the European Economic Area (the “EEA”). To the extent that the following provisions are different from the general provisions above, the following provisions prevail.   If we transfer your personal information to a third party and that transfer, or an act or omission by the third party, results in a violation of this Privacy Statement or applicable EEA law, we are liable for the transfer and/or the act or omission, even if it was the third party that committed the act or omission.

Where we transfer personal information to a third party acting as an agent, (i) we transfer such data only for limited and specified purposes; (ii) we require (usually by contract) at least a level of privacy protection consistent with this Privacy Statement; (iii) we take reasonable and appropriate steps to ensure that the agent effectively processes the personal information transferred in a manner consistent with our obligations under this Privacy Statement; and (iv) we take reasonable and appropriate steps to stop and remediate unauthorized processing.

You have the right to choose (opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you. If you wish to exercise any of these choices, please contact us using the information below. This choice/opt-out doesn’t apply where the sharing of your personal information is with a third party who is acting as our agent (such as our service providers who perform services that help us to run our business). We won’t provide your personal information to a third party under these circumstances unless we have a contract in place with that third party that requires the third party to comply with obligations consistent with this Privacy Statement.

We do not intentionally or knowingly collect or maintain information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation. Please don’t provide such information to us. If you think that we have collected, or that you have provided, such information to us, please contact us immediately so that we can delete it.

Exception: Ripple Treasury’s goods, services, and software are focused on, among other things, accessibility of the web or other resources by persons with visual or other disabilities. If providing goods, services, or software to you requires that Ripple Treasury understand the nature of your circumstances or otherwise collect or use information that includes information that EEA or member-state law would consider health information or other sensitive personal data, Ripple Treasury will collect, store, use, and share that information, but only to the extent necessary to (a) provide goods, services, or software to you or provide information that is responsive to your needs or (b) engage in testing, support, or other activities to which you have agreed.

We process personal information that we need in order to carry out our business. We only process personal information in a way that is compatible with the purposes for which we collected it or subsequently authorized by the data subject.

We take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

We adhere to this Privacy Statement for as long as we retain the personal information.

Except as otherwise permitted by law, we destroy or anonymize personal information after it no longer serves a purpose of processing as contemplated above.

We give data subjects access to such personal information as we have that pertains to them and will help to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of this Privacy Statement or applicable law. If you wish to contact us to access your information, you can do so using the contact information below. We reserve the right to limit such access and related activity where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated.

We will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

How Can I Access, Correct, Amend, or Remove Information About Me?

To access, correct, amend, or remove information, please reach out to us directly at dpo@gtreasury.com.

How Long Does Ripple Treasury Keep My Information?

We will keep personal information for as long as is relevant for the purposes outlined in this policy or until users opt out or unsubscribe.

What Choices Do I Have?

Users have the right to opt-out of receiving marketing emails from Ripple Treasury by sending us an email at treasury-marketing@ripple.com, clicking unsubscribe or opt-out at the bottom of any email or managing their preferences in the preference center.

Changes to this Privacy Policy

Ripple Treasury reserves the right to make changes to this privacy policy as deemed necessary. The effective date of the policy will be displayed at the top of the page.

Questions, Concerns or Complaints

If users have questions or concerns in regards to how Ripple Treasury is gathering and housing user information, please reach out to us via email at dpo@gtreasury.com or by mail at 2100 E. Lake Cook Rd., Suite 1100, Buffalo Grove, IL 60089.   Privacy Policy – Ripple Treasury   Privacy Policy Index   Privacy Policy 2020

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