FCTI, Inc. (FCTI) is an Independent Operator of automated teller machines (ATMs) in the United States.
FCTI wants you to be familiar with how it collects, uses and shares your information. This Policy outlines the type of information that we collect and receive from you while you are using our Site or Service. Additionally, this Policy identifies the ways in which we retain, process, and sometimes share, such information and what control and choices you have with regard to the collection and use of your personal information. Please review this Policy carefully, especially before providing any personal information through our Site or Service. Our Site and Service are operated in and controlled from the United States of America. If you have any questions about this Policy or do not see your concerns addressed here, please use the contact information provided at the end of this Policy to contact us.
NOTICE OF ARBITRATION PROVISIONS:
- Information collected online on this Site.
- Information collected when you use our Service.
- Information collected when you participate in our SMS (Short Message Services) or MMS (Multimedia Messages Services) programs.
- Information collected by third parties, even if collected on or through our Site or Service. For example, we may embed an application from a third party on our Site or Service. These third-party applications may appear to be part of our Site or Service, but the content is provided by a third-party server. By accessing this third-party application, the third-party owner may send its own cookies and collect its own data regarding your interaction with the application and may solicit your personal information as part of your use of such application. We are not responsible for the actions and privacy policies of these third-party providers and you should review such privacy policies prior to providing any Personally Identifiable Information to them.
- Information not collected, stored, or used by us.
This Policy will be posted on this Site for your review and from time to time as part of registering or providing information in connection with this Site or Service, we may provide you with a short notice reminding you to refer to this Policy and other relevant information from us when using our Site or Service.
SECTION 1 – WHAT TYPES OF INFORMATION FCTI COLLECTS
We collect and use only that information that is necessary for our legitimate business purpose, in order to better understand your interests and to improve your experience of using our Site or ATM Service. In order to do so, we collect the following categories and types of information:
- Site Use & Service – Access to specific items, services, or areas of the website may require you to provide one or more of the following items:
- First name
- Last name
- Email Address
- Zip Code
- Company Name
- Work/Company Phone Number
- Mobile/Telephone Number
- Company Address
- Industry of Company
- Internet Protocol (IP) Address
- ATM Transactions – In the process of providing cash and financial account access at the ATM, the following Personally Identifiable Information is collected by FCTI:
- Terminal ID – The location at which the transaction is taking place.
- Partial PAN – A portion of the card number used for the transaction.
- Transaction Date and Time – The day and time of the transaction.
- Withdrawal Amount – The amount of money requested for dispense.
- Surcharge – The total amount charged by the ATM for the transaction to be processed.
- Response Code – The response from the queried financial institution.
- Transaction Code – The result of the transaction.
In some instances, when you use certain features of the Site or Service, FCTI may collect the email addresses or other Personally Identifiable Information of others that you may provide. Unless stated otherwise at the point of collection, we will treat any such Personally Identifiable Information that you submit about other people in accordance with this Policy.
SECTION 2 – HOW FCTI COLLECTS INFORMATION
An IP address is a number that is assigned to your computer automatically when you use the Internet. FCTI uses a third-party provider to note your IP address and uses your IP address to track your usage of the Site or Service. FCTI does not retain your IP address or log it within our systems.
Short online questionnaires may be used to collect Personally Identifiable Information prior to providing access to certain portions of the Site or Service.
FCTI ATMs communicate certain aspects of your Personally Identifiable Information through data processing partners as part of the transaction process. Portions of that data, listed above, are provided to FCTI post transaction.
Our Customer Service team may view Personally Identifiable Information on Caller ID and receive specific Personally Identifiable Information over the phone or in email format when addressing customer concerns.
SHORT CODE/SMS/MMS PROGRAM
Any Data or Personally Identifiable Information obtained through FCTI’s short code or SMS or MMS program will not be shared with any third-parties for their marketing reasons/purposes.
SECTION 3 – DEFINITIONS OF WHAT IS AND WHAT IS NOT PERSONALLY IDENTIFIABLE INFORMATION
PERSONALLY IDENTIFIABLE INFORMATION
Personally identifiable information is any information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked either directly or indirectly with a living individual, such as your first and last name, mailing address, phone number, mobile phone number, email address, credit/debit card number and expiration date (or other payment-method information), login ID, member name and password, and other information about a specific individual that identifies the individual (“Personally Identifiable Information”).
NON-PERSONALLY IDENTIFIABLE INFORMATION
SECTION 4 – HOW FCTI USES PERSONALLY IDENTIFIABLE INFORMATION
We will use your Personally Identifiable Information for the purposes for which it was provided. For example, FCTI may use your Personally Identifiable Information to notify you of changes to the Site or Service or to let you know about other products you may be interested in. FCTI also uses your Personally Identifiable Information to provide you with information that you request.
Personally Identifiable Information obtained by FCTI is used for internal business purposes and to provide information and services to you.
SALE OF PERSONALLY IDENTIFIABLE INFORMATION
FCTI does not sell the Personally Identifiable Information it collects.
SECTION 5 – HOW LONG FCTI RETAINS PERSONALLY IDENTIFIABLE INFORMATION
FCTI retains Personally Identifiable Information dependent on the reason such information was provided. To determine the appropriate retention period, we consider the amount, nature, sensitivity, purpose, and the applicable legal requirements.
SECTION 6 – DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION TO THIRD PARTIES
DISCLOSURE TO SERVICE PROVIDERS OR BUSINESS PARTNERS
Like many businesses, we sometimes hire other companies to perform certain business-related functions on our behalf such as hosting specific portions of the Site or Service, maintaining databases, providing fulfillment services, sending e-mails, managing sweepstakes, and processing payments. When we employ a third-party to perform these functions, that third-party will only be provided with the particular Personally Identifiable Information it needs to perform its function, and is required to protect the Personally Identifiable Information.
When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
FCTI may use your Personally Identifiable Information to inform you about relevant products, services, and offers (Marketing). We only use your Personally Identifiable Information to send you Marketing messages if we have either your consent or the legal ability to do so. You can request to stop receiving FCTI marketing messages at any time by contacting us or selecting the “unsubscribe” option in any electronic messages (if available in your jurisdiction). You can update your subscription choices at any time by contacting FCTI.
DISCLOSURE TO OTHERS
In addition, we may disclose Personally Identifiable Information under the following circumstances to: (1) protect our legal rights, privacy or safety, and those of our subsidiaries, affiliates, employees, agents, and contractors; (2) protect the safety and security of visitors to our web sites or other properties; (3) protect against fraud or other illegal activity, or for risk management purposes; (4) respond to inquiries or requests from government, regulatory, law enforcement, or public authorities; (5) permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain; (6) enforce our Terms of Service; or (7) comply with subpoenas, search warrants, the law, or other legal process.
SECTION 7 – SECURITY
To protect your Personally Identifiable Information, we maintain security measures to protect against the loss, misuse, and alteration of the Personally Identifiable Information under our control. Please be advised, however, that the Internet is not entirely secure, and your information may therefore be subject to interception or loss which is beyond our control. While we strive to protect your Personally Identifiable Information, we cannot ensure or warrant the security of any Personally Identifiable Information you transmit to us. Any transmission is done at your own risk. Accordingly, FCTI assumes no responsibility or liability for disclosure of your information (personally identifiable or otherwise) due to errors in transmission, unauthorized third-party access, or other causes beyond FCTI’s reasonable control.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with AES-256 encryption. We follow all PCI-DSS requirements and implement additional generally accepted industry standards.
SECTION 8 – GUIDELINES REGARDING CHILDREN: CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1998 (COPPA)
This website does not direct content to minors and is not designed or intended for use by children under 13. Children under 13 are expressly prohibited from submitting any Personally Identifiable Information to us, and if we discover that we have inadvertently gathered any such information from a child under 13, we will take appropriate steps to delete it.
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence.
If you allow your minor dependent (the “minor”) to access and use this website, you agree that you will be solely responsible for:
- The online conduct of such minor;
- Monitoring such minor’s access to and use of this website; and
- The consequences of any use by the minor.
SECTION 9 – APPLICABLE LAW
SECTION 10 – CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
WHAT IS CCPA?
The CCPA is a data privacy law which applies to businesses that collect Personally Identifiable Information from California residents. The law is effective as of January 1, 2020. The information and product updates provided here are based on the guidance provided by the California Attorney General as of October 2019 and are subject to change based on updated regulations from the California Attorney General. This section applies solely to all visitors, users, and others who reside in the State of California. We include this section to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this section.
LEGAL RIGHTS UNDER CCPA
The CCPA provides consumers who are California residents with specific rights regarding their Personally Identifiable Information.
ACCESS TO SPECIFIC PERSONALLY IDENTIFIABLE INFORMATION AND DATA PORTABILITY RIGHTS
The CCPA provides you with the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personally Identifiable Information we have collected about you.
- The categories of sources for the Personally Identifiable Information we have collected about you.
- Our business or commercial purpose for collecting that Personally Identifiable information.
- The categories of third parties with whom we share that Personally Identifiable information.
- The specific pieces of Personally Identifiable Information we have collected about you (also called a data portability request).
- If we disclosed your Personally Identifiable Information for a business purpose.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by the law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) or Title 12 or Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
FCTI, Inc. –
Attn: Internal Control Office
11766 Wilshire Blvd., Suite #300
Los Angeles California 90025
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us here.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and,
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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 relating 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 your identity or authority to make the request.
For instructions on exercising sale opt-out rights, see PERSONALLY IDENTIFIABLE INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing either by mail or electronically, at your option, within the initial forty-five (45) days.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personally Identifiable Information that is readily useable and should allow you to transmit the information from one entity to another without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
PERSONALLY IDENTIFIABLE INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS
We do not sell Personally Identifiable Information to any party.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personally Identifiable Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
When you use the Site or Service, you are accepting the terms and conditions of this Policy, and FCTI will have the right to use your Personally Identifiable Information or other information about you as described in this Policy. If you do not agree to have your Personally Identifiable Information used in any of the ways described in this Policy, you must not use the Site or Service and you must follow the opt-out provisions above. If you have questions or concerns about this Policy, please contact Internal Control Office or write to FCTI at the contact address listed below.
From time to time, we may revise this Policy to reflect industry initiatives, changes in the law or technology, or changes in our practices regarding information collection and use. You can determine when this Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to this Policy will become effective upon posting of the revised Policy on the Internet, accessible through the Site. By continuing to use the Site or Service following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, please do not continue using the Site or Service. To the extent that an arbitrator or court of applicable jurisdiction determines that applying any changes to this Policy would render this an illusory or unenforceable contract, such changes shall be applicable on a prospective basis only, with respect to events or circumstances occurring after the date of such changes, to the extent necessary to avoid this Policy being deemed illusory or unenforceable.
SECTION 13 – TERMS OF SERVICE
Your access to and use of the Site or Service is also subject to the Terms of Service.
SECTION 14 – CONTACT INFORMATION
Attn: Internal Control Office
11766 Wilshire Blvd., Suite #300
Los Angeles California 90025