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2024 - Copyright Cass Information Systems, All rights reserved  Privacy Statement
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Privacy Statement

Cass Information Systems Privacy Statement

  • Cass Information Systems provides this information to help you understand how we collect, use and share your information when you visit our site.

What we collect and how we use it

  • In order to service our customers, portions of our site may require you to submit information that may be deemed personal or confidential We will use the information you provide in the ways you’d reasonably expect – for example, delivery of a service or a payment to a service provider. Cass Information Systems does not sell, trade, or rent your personal information to unaffiliated third parties.

Security of Information

  • The security of the information we collect from and about you and your device(s) is very important to us. We protect this information by maintaining administrative, physical and technical safeguards that are consistent with industry practice and that we believe are reasonably appropriate to protect your information. We regularly review these safeguards to reduce the risks of unauthorized access, disclosure, and improper use of personal details collected from you. Although we take reasonable steps to protect and to prevent unauthorized access to such information, we cannot be responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied, or otherwise, that we can prevent unauthorized access to any of the information that we collect from or about you or your computer or other devices.

Cookies

  • When you use our site we may store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies may store information about you, your computer, or your preferences so that you may more easily use our site. The cookies make the site run more smoothly and help us to maintain a more secure site. You are always free to decline our cookies if your browser permits, but our site may not work properly.

Cass Europe B.V. and Cass TEM UK Privacy Statement

We at Cass Europe B.V. and Cass TEM UK Ltd. ("Cass" or "we/our/us") respect your privacy and are committed to safeguarding and protecting your privacy in connection with the recording, organization, structuring, storage, adaptation, alteration, retrieval, collection, consultation, use, disclosure, dissemination, restriction, erasure or destruction (“processing”) of your Personal Data. We may process your Personal Data for a variety of reasons and in a variety of ways.


This privacy statement (“Statement”) contains important information regarding our privacy practices and the choices we offer you with respect to your Personal Data. If you choose to provide us with your Personal Data, you are telling us that you have read, fully understand, and accept the privacy practices summarized in this Statement. We strongly encourage you to read this Statement in its entirety to understand our privacy practices before submitting any Personal Data to us.


If you have any questions about this Statement and/or the processing of your Personal Data, please do not hesitate to contact our EU or UK Privacy Managers at +31 76 5315 384 or +44 1256 679510 or our US Privacy Manager at privacy@cassinfo.com.


This Statement will inform you about:


• GDPR
• Scope of this Statement
• How We Collect Your Personal Data
• Who Has Access to Your Personal Data
• International Transfers of Your Personal Data
• Legal Ground(s) for Processing Your Personal Data
• Purposes for Which We Process Your Personal Data
• Your Rights with Respect to Your Personal Data
• Protection of Your Personal Data
• Retention of Your Personal Data
• Revisions to this Statement
• Our Privacy Concern Handling Process
• Our Contact Information

GDPR


Cass is operationalizing compliance changes in connection with the new EU General Data Protection Regulation (GDPR). The GDPR replaces the Data Protection Directive 95/46/EC, and similar domestic legislation in EU Member States with respect to most (but not all) areas of data privacy and protection. Significant changes include, but are not limited to:

• Increased fines (up to €20 million or 4% of global annual turnover);
• Enhanced rights for individual data subjects;
• Increased accountability;
• Changes in the ways that personal data should be obtained and held, including a requirement to document personal data processing activities; and
• Changes in the rules for responding to data breaches, requiring most data breaches to be reported to the relevant data protection authority within 72 hours of discovery.

Scope of this Statement


This Statement applies to our processing of the Personal Data of our business contacts, vendors, directors, agents, and customers (including their representatives and service providers), when the General Data Protection Regulation (EU 2016/679) applies to such Personal Data.


Personal Data is any information that relates to an identified or identifiable natural person and is sufficient to enable such person to be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, or an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. We act as a data processor for purposes of these processing activities. In this Statement, we use the word “you” to refer to anyone within the scope of this Statement.


How We Collect Your Personal Data


We use Personal Data on a day-to-day basis to run our business, provide our services, enter into contracts, and to protect our interests. We collect Personal Data from you when you provide it to us, or when we collect it from you, for instance, in the course of your dealings with us, because you use certain services (such as our online reporting tools), or because your Personal Data is included in our customer"s invoices, documentation, files, or systems.


Depending on the processing activity, the Personal Data we process in relation to you may include, without limitation:

(i) First and last name;
(ii) Phone number;
(iii) E-mail address;
(iv) Nationality;
(v) Address;
(vi) Data regarding your equipment, such as an IP address;
(vii) Data regarding your use of our IT systems; and
(viii) Information regarding your employer, your employment, or our client.

It is necessary to provide us with certain Personal Data in order for us to be able to provide you with our services, as applicable. In certain situations, if you do not provide us with your Personal Data, we may be unable to provide you with our services.


We may use various technologies to collect Personal Data about you when you visit and use our website, http://www.cassinfo.com (“Site”). These technologies may include:

• Cookies. Like many websites our Site may use “cookies.” A cookie is a small information file that some websites transfer to a user’s hard drive. We may use cookies to improve a user’s experience on our Site, for example, to personalize features of the Site for you, to analyze the traffic on the Site, to better understand visitor and customer usage of our Site, and to maintain and make improvements based on the information we collect. The use of cookies has become standard practice for websites, but whether you choose to accept or decline these cookies is entirely up to you. Most browsers are initially set up to accept cookies. You may set your browser to reject cookies and to let you know when a cookie is being placed on your computer. If you refuse cookies, you may not be able to use some of the functionality of our Site. Other third parties associated with the Site may also use cookies in connection with the services and websites to which the Site links. We do not control these third-party cookies.
• Web Beacons.Web beacons are small files that communicate with third parties and are embedded in web pages. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, to understand usage patterns of our customers and visitors. We also may use web beacons to learn if emails have been opened, acted on, or forwarded. We also may include web beacons in newsletters and other promotional email communications that we send to subscribers in order to count how many newsletters or other promotional communications have been opened or read. You can disable the ability of web beacons to store cookie information by declining cookies. Our web beacons do not collect, gather, monitor, or share any Personal Data about customers or visitors to our Sites. They are merely designed to compile usage data.
• Other Technologies.Examples of other technologies we may use to provide better service to you when visiting the Site include:
o Web Session Variables. Information that is passed from one web URL to another as you browse.
o Browser plug-ins/add-ons. Additional web components that may need to be installed to enable certain web features on the Site. You have the option not to install these components.

To find out more about how Cass uses cookies, please read our Cass Cookie Policy.


Who Has Access to Your Personal Data


Access to Personal Data relating to you is limited. It is our policy that persons within the organization should only have access to Personal Data on a need-to-know basis.


Under certain circumstances, we may share your Personal Data with third parties:


• Because Cass is a global company, we may share your Personal Data with other subsidiaries and affiliates belonging to the Cass Information Systems Group, including those in the United States. These subsidiaries and affiliates will maintain the privacy of your Personal Data in accordance with this Statement.

• We may also disclose your Personal Data to our agents, such as suppliers and service providers, acting on behalf of or for Cass under our instructions for the limited and specific purpose of assisting Cass with its normal business operations. In no event will that limited and specific purpose be inconsistent with this Statement. In all cases, these agents may only use this information in connection with providing support for or services to Cass.

• In the context of establishing and maintaining a customer relationship with you, we may disclose your Personal Data to your service providers.

• Sometimes a directive, law, regulation, court order, or other judicial, regulatory, or supervisory process requires us to provide Personal Data to a governmental body or party to a private lawsuit.

• Finally, we may disclose certain Personal Data if Cass is involved in a merger, acquisition, or sale of all or a portion of its assets, or we are required to bring or defend against litigation or any regulatory proceeding between, or relating to, you and us, or we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights, our property, our customers, or anyone else who could be harmed by such activities.

We will only transfer your Personal Data to the above mentioned third parties for the purposes stated in this Statement, and only to the extent that is permitted under the applicable data protection law.


Third parties to whom we transfer your Personal Data are themselves responsible for compliance with applicable data protection law. We are neither responsible nor liable for the processing of your Personal Data where we do not determine the purposes and means of the processing of that Personal Data.


International Transfers of Personal Data


We take steps to protect your Personal Data no matter what country to which it is transferred. We have procedures and controls in place, as appropriate, to help ensure this is the case. That said, in connection with our business, and for administrative, management, and legal purposes, when processing Personal Data in line with this Statement, we may transfer your Personal Data outside the European Economic Area (“EEA”), including to the United States. If we transfer your Personal Data outside the EEA, such as to our parent, Cass Information Systems, Inc., in the United States, we do so in accordance with applicable data protection laws, including on the basis of an EU Commission adequacy decision, where the transfer takes place pursuant to recognized appropriate safeguards, and/or where a specific derogation is permissible.


Furthermore, our parent company, Cass Information Systems Inc., and two affiliates, Cass Commercial Bank and Cass International, LLC are EU-US Privacy Shield certified and adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (“Privacy Shield Principles”).


If you would like to know more about how we protect your Personal Data when it is transferred outside the EEA, please contact our EU or UK Privacy Managers at +31 76 5315 384 or +44 1256 679510 or our US Privacy Manager at privacy@cassinfo.com.


Legal Ground(s) for Processing Personal Data


Under applicable data protection law, we are allowed to process Personal Data only if we can rely on one or more of the legal grounds for processing. The legal grounds we are most likely to rely on for processing Personal Data in relation to you are:


• Consent– In exceptional situations we may rely on your consent.

• Contract–The processing is necessary for performance of a contract with you/your company or to take steps at your request to enter a contract.

• Legal Obligation – The processing is necessary to ensure we comply with our legal and regulatory obligations. For example, to comply with our social insurance and tax-related obligations.

• Legitimate interests – The processing is necessary for our or a third party’s legitimate interests. We, as a service provider, or a third party on our behalf, may have legitimate interests in carrying on, managing, and administering our normal business operations and may need to process your Personal Data in connection with the same. Your Personal Data will not be processed on this basis if our or a third party’s legitimate interests are overridden by your own interests, rights, and freedoms.

• Vital interests – Where processing is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent. For example, in the case of a medical emergency.

Purposes for Which We Process Your Personal Data


Cass processes your Personal Data for certain purposes described below. As explained above, processing in this context might include transfers to third parties and/or transfers outside of the EEA. From time to time, we may publish specific notices setting out details regarding particular processes or programs being adopted by us.


• Customer Relationship – We may process your Personal Data for the purpose of establishing and maintaining a customer relationship with you and/or your service providers.

• Security– We may process your Personal Data for the purpose of ensuring physical, administrative, and technical security, including information gathered through the use of swipe and similar entry cards and sound and image data, such as CCTV or photographs.

• Order Processing – We may process your Personal Data for the purpose of handling the management and invoicing of shipments and orders.

• Corporate Transactions – We may process your Personal Data for the purpose of conducting corporate due dilligence (or permitting corporate due dilligence to be conducted) in the context of a potential merger or takeover.

• Legal Rights and Compliance Obligations – We may process your Personal Data for the purpose of meeting or complying with our legal, regulatory, or supervisory obligations or for the establishment, exercise, defense, or resolution of legal claims by or against you or a third party.

• Normal Business Operations – We may process your Personal Data for the purpose of meeting our day-to-day business operations.

Cass does not engage in decision-making based solely on automated processing.


Your Rights with Respect to Your Personal Data


Under applicable data protection law, you may have the following rights:


• To obtain access to the Personal Data that we hold about you;

• To object on grounds relating to your particular situation to our processing activities where you feel they have a disproportionate impact on your interests, rights, and freedoms;

• To request to review, revise, correct, or update any of the Personal Data we may have about you free of charge, if you believe that your Personal Data that we possess is, or has become, incorrect or is incomplete;

• To request that we restrict the processing activities related to your Personal Data (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);

• To request that we erase your Personal Data;

• To have Personal Data, which you have voluntarily provided to us, produced in a structured, commonly used, and machine-readable format, including for the purpose of transmitting it to another party; and

• To object to the processing of your Personal Data for direct marketing purposes.

Please note that the above individual rights are not absolute, and we may be entitled to refuse requests where certain exceptions apply. If you have given your consent and you wish to withdraw it, please contact our EU or UK Privacy Managers at +31 76 5315 384 or +44 1256 679510 or our US Privacy Manager at privacy@cassinfo.com.


Please note that where our processing of your Personal Data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services. If you have any questions about your rights regarding your Personal Data, please simply write to us at the postal address provided in our Contact Information below or contact our EU or UK Privacy Managers at +31 76 5315 384 or +44 1256 679510 or our US Privacy Manager at privacy@cassinfo.com, where you may initiate a request to access, reject, correct, restrict, or erase your Personal Data, or where you may initiate a request for transfer of your Personal Data or initiate a request that we refrain from sending you marketing information.


Protection of Your Personal Data


Cass takes reasonable and appropriate physical, administrative, and technical measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.


Retention of Your Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Statement. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (such as, if we are required to retain your information to comply with applicable tax/revenue laws, resolve disputes, and enforce our agreements).


Where we rely on legitimate interests as a reason for retaining your Personal Data, we have carefully considered whether or not those interests are overridden by your rights and freedoms and have concluded that they are not.


Please note that for corporate law and tax purposes, in the Netherlands, we are required to keep certain data, which might include Personal Data we hold about you (whether directly or indirectly), for a period of seven (7) years after the information has lost its relevance, and in the UK, we are required to keep certain data, which might include Personal Data we hold about you (whether directly or indirectly), for a period of six (6) years after the information has lost its relevance. In certain limited cases, local legal requirements in the Netherlands and UK may result in the preservation or retention of Personal Data for longer periods of time.


Revisions to this Statement


Cass reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of our policies and this Statement at any time, consistent with the requirements of applicable law. If we change the Statement in a material way, we will provide appropriate notice to you. The “Effective Date” at the top of this Statement reflects the date of the most recent revisions.


Our Privacy Concern Handling Process


Cass is committed to resolving concerns about your privacy and our processing of your Personal Data. Individuals with inquiries or concerns regarding this Statement should first contact our EU or UK Privacy Managers at +31 76 5315 384 or +44 1256 679510 or our US Privacy Manager at privacy@cassinfo.com. In the event that resolution cannot be reached, individuals may also contact their local data protection authority (“DPA”), which may investigate your concern further.


The Netherlands
Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
(+31) (0)70 888 85 00

UK
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
(+44) 0303 123 1113

Our Contact Information


If you have any questions or comments about this Statement and/or the processing of your Personal Data, please contact Cass at +31 76 5315 384 or +44 1256 679510 or at privacy@cassinfo.com. You may also write us at:


Cass Europe B.V.
EU Privacy Manager
Graaf Engelbertlaan 75
4837 DS
Breda
The Netherlands

Cass TEM UK Ltd.
UK Privacy Manager
Belvedere House
Basing View
Basingstoke
RG21 4HG
United Kingdom

Cass Information Systems, Inc.
US Privacy Manager
12444 Powerscourt Drive, Suite 550
St. Louis, Missouri 63131
United States

Cass EU-US Privacy Shield Framework

Cass Information Systems, Inc. complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Cass Information Systems, Inc. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

The following Cass Information Systems, Inc. subsidiary participates in the EU-US Privacy Shield Framework and adheres to the Privacy Shield Principals:

Cass International, LLC

Notice of Information We Collect, How We Use It and How You Control It

We collect personal and non-personal information via our various websites to provide you with additional content and reports on a continual basis or to provide you with a specific service through contractual agreements with your employer.

Cookies:When you use our site we may store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a website stores on your computer"s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies may store information about you, your computer, or your preferences so that you may more easily use our site. The cookies make the site run more smoothly and help us to maintain a more secure site. You have the choice to opt out of this functionality and are always free to decline our cookies if your browser permits, but our site may not work as effectively.

Registration: In order to service our customers, portions of our site may require you to submit information that is typically business related, but may be personal in certain circumstances. We will use the information you provide in the ways you’d reasonably expect – for example, providing additional content/information delivery, stipend payment, delivery of a contracted service, or a payment to a service provider. You have a right to access this data and correct or remove it. The specific registration site or additional communication information provided to you will supply directions on how to correct or remove your data at your request. In all cases you can always contact the Privacy Officer for assistance using the information below.

Onward Transfer and Liability

Cass Information Systems, Inc. does not sell, trade, share or rent your personal information to unaffiliated third parties. Affiliated third parties may receive your data in fulfillment of our service. We maintain specific contract agreements with these companies to ensure that they use the data only for intended purposes and protect the data as we would. If this practice were to change, we would specifically provide you with the opportunity to choose to “opt in” or “opt out” of the sharing of your data.

We may be required to release personal information to third parties in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Cass Information Systems, Inc. is potentially liable.

Recourse and Enforcement

In compliance with the EU-US Privacy Shield Principles, Cass Information Systems, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Cass Information Systems, Inc. at:

Cass Information Systems, Inc.

Attn: Privacy Policy

12444 Powerscourt Drive, Suite 550

St. Louis, Missouri 63131

Cass Information Systems, Inc. is subject to the investigative and enforcement authority of the United States Federal Trade Commission (FTC).

Cass Information Systems, Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If the complaint remains unresolved, the individual may invoke binding arbitration as outlined in the EU-US Privacy Shield Framework.

Cass Cookie Policy

Understanding How and Why We Use Cookies

We at Cass Information Systems use cookies on our website, www.cassinfo.com (“Site”), to create the most effective Site possible for our users. Among other things, the cookies we use allow us to improve your experience when using our Site and to ensure the Site performs as you (and we) expect it to.

This Cookie Policy explains what cookies are, how we use them on the Site, and what benefits they bring.

On local websites which are linked from this Site, cookies may be used to allow you to log on to our portals, choose log-in preferences, and apply for services online. Please bear in mind that our affiliate companies may have their own privacy and cookie policies that will govern their use of cookies on their local websites and any information you submit on a local website. Please read carefully any local website and/or product terms and conditions before using the local website or product.


Frequently Asked Questions


Can cookies pass on my personal information to others?

We will not share any personal information gathered through cookies on this Site with third parties.

We do use experience, insight, and marketing cookies on this Site to help provide a better user experience, and in doing so we do share certain limited information with our third party ‘analytics’ providers.


Do cookies compromise my security?

Many of the cookies used on our Site are used purely to provide important security features such as protecting your data and your accounts.


What are cookies?

Cookies are small text files that are sent to and stored on your computer, smartphone, or other device for accessing the internet, whenever you visit a website. Cookies are useful because they allow a website to recognize a user’s device.

Some of the functions that cookies perform can also be achieved using similar technologies. This policy refers to ‘cookies’ throughout, however the term includes these alternate similar mechanisms and technologies.

More information about cookies, including how to disable them, can be found on http://www.allaboutcookies.org/.


Types of Cookies

The length of time a cookie stays on your device depends on its type. We use two types of cookies on our Site:

  • Session cookies are temporary cookies which only exist during the time you use the Site (or more strictly, until you close the browser after using the Site). Session cookies help our Site remember what you chose on the previous page, avoiding the need to re-enter information and improve your experience whilst using the Site.
  • Persistent cookies stay on your device after you’ve visited our Site. For example, so that the Site remembers you the next time you use it. Persistent cookies help us identify you as a unique visitor.

    • Essential Cookies

    These cookies are essential for the running of our Site. We would recommend this type of cookie is not disabled for the following reasons:

  • they allow us to remember your cookie preferences; and
  • they allow us to see if something isn't working properly, so we can fix it quickly.

    • Experience, Insight, and Marketing Cookies

    These cookies help us to make sure you have the best possible experience on our Site and help us to manage the online advertising messages you see from us:

  • they help us to make the Site easier to use and help you find what you need more easily;
  • they help us to test and improve the content you see;
  • they help us understand how you found out about our services;
  • they allow us to show you more relevant messages and offers; and
  • they improve your online user experience.

    • How You Can Manage Your Cookies

    The browsers of most computers, smartphones, and other web-enabled devices are typically set up to accept cookies. If you wish to amend your cookie preferences for this Site, any local sites, or any other websites, you can do this through your browser settings. Your browser’s ‘help’ function will tell you how to do this.

    For browser-specific information on how you can manage the cookies that we use on our Site, please click on the relevant link below:

  • Internet Explorer
  • Firefox
  • Chrome
  • Safari
  • OSX/Mac OS
  • iOS

    • However, please remember that cookies are often used to enable and improve certain functions on our Site. If you choose to switch off or disable certain cookies, it is likely to affect how our Site works on your computer, smartphone, or device.


    Can cookies allow others access to my computer’s hard drive?

    The cookies we use cannot look into your computer, smartphone, or web-enabled device and obtain information about you or your family or read any material kept on your hard drive.


    If I use a public computer, will someone be able to get my details from the cookies?

    Our cookies cannot be used by anyone else who has access to the computer to find out anything about you, other than the fact that someone using the computer may have visited a certain website. The cookies from our Site do not compromise the security of our Site.

    What cookies are used by this website application?

    eup_acceptcookie - Track cookie usage acceptance
    aspnetcore.culture - Track Culture language preference
    casseup - Security token
    ai_user, ai_session - Track our application performance
    csrf - Protection against site attacks
    gman - Protection against site attacks
    cfduid - CDN delivery for speed and performance and does not contain user identitfication information
    muxData - Allow user to resume when interrupted watching the website application help videos

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