Last updated: June 6, 2023 SMI Pay LLC, (“CT Child Support Internet Payment Website”, “we”, “us”, or “our” as applicable) respects and protects the privacy of visitors to our website and users of our internet payment services. This Privacy Policy describes our information handling practices when you access our website or use CT CHILD SUPPORT INTERNET PAYMENT WEBSITE to make a payment. Capitalized terms used herein and not defined are defined in our Terms and Conditions. Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Policy, please submit your request by calling 1-888-233-7233 during customer service hours. The hours are Monday-Friday, 8:00 a.m. to 5:00 p.m., Eastern Standard Time (EST), excluding state and federal holidays. By accessing and using our website or CT CHILD SUPPORT INTERNET PAYMENT WEBSITE to make a payment, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue using CT CHILD SUPPORT INTERNET PAYMENT WEBSITE and accessing our website. Please note that while we have taken reasonable steps to safeguard the integrity of the information that we collect and store, along with preventing unauthorized access to information maintained by us, given the inherent nature of technology and the internet, no security measures can ever be assumed to be 100% fail-safe. We may provide you with additional disclosures about the information processing practices of specific services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your information. To keep up with changing legislation, best practice and changes in how we process personal information, we reserve the right to amend this Privacy Policy at any time without notice by posting a revised version on our website. To stay up to date on any changes, check back periodically. 1. Information we may collect or receive Personal information is data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy. 1.1 Information you provide to us You may give us information about you when you sign up to use CT CHILD SUPPORT INTERNET PAYMENT WEBSITE. This also includes information you provide through your continued use of CT CHILD SUPPORT INTERNET PAYMENT WEBSITE, such as how you use our website, and information you provide when you report a problem related to a Payment Instruction or our services. We may collect the following types of information from you: Personal Identification Information: such as your full name, date of birth, geographic location information, phone number, home address, and/or email. Financial Information: such as Bank Account information (savings or checking number and routing number), Card account number and related details. Transaction/Child Support File Information: such as information about the transactions you make using our website, such as your name, the amount, and/or timestamp, as well as the relevant Child Support file, associated with your Payment Instruction. Correspondence: such as information provided to our Customer Service team. If you provide to us the personal information of any individual other than yourself during your use of our services, you certify that you have obtained consent from such individual to disclose such information to us, as well his/her consent to our collection, use and disclosure of such personal information, for the purposes set out in this Privacy Policy. 1.2 Other information we may collect To the extent permitted under the applicable law, we may collect certain types of information automatically, such as information about when you interact with our website or use CT CHILD SUPPORT INTERNET PAYMENT WEBSITE (e.g., the date and time and the web pages or services you accessed during your visit). We may also use identifiers to recognize you when you access our websites via an external link, such as a link appearing on a third-party website. This type of information helps us address customer support issues, improve the performance of our websites, and provide you with a streamlined and personalized experience. Information collected automatically includes: Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or your IP addresses. Usage Data: Authentication data, security questions, click-stream data, and other data collected via cookies and similar technologies. Please read about Cookies in Section 5 below for more information. Customer Service: Calls may be recorded. 1.3 Information we may receive from other sources From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include: Public Databases Payment Service Providers Advertising Networks & Analytics Providers Government Agencies with information such as a case number or social security number 2. Uses made of information we collect or receive Our primary purpose in collecting personal information is to provide you with our services in a secure, smooth manner. We may use this information in the following ways: 2.1 To provide CT CHILD SUPPORT INTERNET PAYMENT WEBSITE’s services to you We process your personal information to provide payment services to you. Third parties such as Payment Service Providers may also access and/or collect your personal information when providing fraud prevention or other services. We cannot provide you with services without such information. 2.2 To provide service-related communications We send administrative or payment and account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes. 2.3 To provide customer support We process your personal information when you contact us to resolve any questions or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your questions and ensure your uninterrupted use of our services. 2.4 To ensure network and information security and quality control We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. We also process your personal information for quality control and staff training. If we do not process personal information for quality control purposes, you may experience issues with the services and/or we may not be able to ensure the security of our services. 2.5 For research and development purposes and to enhance your experience We process your personal information to better understand the way you use and interact with CT CHILD SUPPORT INTERNET PAYMENT WEBSITE. Without such processing, we cannot ensure your smooth use of CT CHILD SUPPORT INTERNET PAYMENT WEBSITE functionality. 2.6 To engage in marketing activities Based on your communication preferences, we may send you marketing communications (e.g., emails) to inform you about our services. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law. 2.7 To maintain legal and regulatory compliance Some of our services or services provided by Payment Service Providers are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. When you seek debit your Bank Account or use a Card, we may require you to provide additional information which we may use in collaboration with Payment Service Providers to verify your identity or address, and/or to manage risk as required under applicable law. The consequences of not processing your personal information for such purposes is the termination of your ability to use CT CHILD SUPPORT INTERNET PAYMENT WEBSITE. 2.8 To enforce our terms in our user agreement and other agreements We monitor to prevent any prohibited or illegal activities on our website, enforce our agreements with third parties, and/or prevent and detect violations of our Terms and Conditions. We collect information about your usage and closely monitor your interactions with us. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your ability to use CT CHILD SUPPORT INTERNET PAYMENT WEBSITE. 2.9 For any purpose We may disclose your personal information for any purpose you consent to. The following chart summarizes how we use the categories of personal information we collect from you: Personal Information Category, as described above Sources of Such Personal Information Purpose of Collection of Such Personal Information Disclosure of Personal Information (A) Identifiers such as Personal Identification Information Information you provide us; Information collected from third parties Section 2.1, 2.2, 2.3, 2.4, 2.5, 2.6, 2.7, and 2.8 above - Payment Service Providers - Service providers - Professional advisors (B) Customer records such as signature Information you provide us; Information collected from third parties Section 2.2, 2.3, 2.5, 2.7 and 2.8 above - Payment Service Providers - Service providers C) Protected classifications under California and federal law, such as age Information you provide us; Information collected from third parties Section 2.7 and 2.8 above - Professional advisors (D) Commercial information such as records of services purchased, obtained, or considered Information you provide us; Information we collect from you automatically; Information collected from third parties Section 2.1, 2.2, 2.3, 2.4, 2.5, 2.6 and 2.8 above - Payment Service Providers - Service providers - Professional advisors (E) Biometric information Not Applicable Not Applicable Not Applicable (F) Usage Data Information we collect from you automatically Section 2.3, 2.4, 2.5, 2.6, 2.7 and 2.8 above - Payment Service Providers - Service providers - Professional advisors (G) Online Identifiers Information we collect from you automatically Section 2.1, 2.5, 2.7 and 2.8 above - Payment Service Providers - Service providers - Professional advisors (H) Sensory data, such as audio, electronic, visual information Information you provide us; Information we collect from you automatically Section 2.1, 2.2, 2.3, 2.4, 2.5 and 2.8 above - Professional advisors (I) Professional or employment-related information Not collected Not Applicable Not Applicable (J) Inferences about preferences, characteristics, predispositions, etc. Not collected Not Applicable Not Applicable We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. 3. Disclosure of your information It is our policy to treat all personal and transaction information as confidential. This means that we will not sell or rent your personal information to third parties without your consent. However, we may disclose information to third parties about you and/or the transactions you make, in the following situations: 3.1 Where it is necessary for completing transactions, such as to Payment Service Providers or other financial institutions with which we partner to process payments you have authorized. Your Card information, if you use such methods to make payments on our website, is securely transferred and hosted off-site by Payment Service Providers and is held in compliance with Payment Card Industry Data Security Standards (PCI DSS). When using CT CHILD SUPPORT INTERNET PAYMENT WEBSITE online you may be linked to other websites, such as those of other Payment Service Providers, and other third parties that are not operated by us. We strongly advise you to review the Privacy Policy of every such party. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or services; 3.2 Where required by law; 3.3 With professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our obligations; 3.4 With service providers under contract with us who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us and prohibit them from selling your information to anyone else. Examples include our cloud storage providers, customer support providers, network infrastructure and security providers; and 3.5 If you give us your written permission. The personal information that you submit, to us may become part of the child support file, however, all child support files are confidential. 4. Retention of personal information We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. We generally store information for up to 7 years. 5. Cookies CT CHILD SUPPORT INTERNET PAYMENT WEBSITE may use cookies on its website to distinguish you from other users. This helps us to provide you with a good experience and also allows us to improve our services. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The “Help” feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. Other ______________________________________________________________________________ This PRIVACY NOTICE IS FOR CALIFORNIA RESIDENTS ONLY and supplements the Privacy Policy above. Effective January 1, 2020, the California Consumer Act of 2018 (the “CCPA”) permits consumers who are California residents to ask businesses covered under the CCPA about personal information it has collected about the consumer, submit an access or deletion request, and opt-out of the sale of personal information, if applicable. • You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. We have not sold any of your personal information in the last 12 months. • You have the right to request access to or 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 or provide it to you, as applicable, unless an exception applies. If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at 1-888-233-7233 during customer service hours. The hours are Monday-Friday, 8:00 a.m. to 5:00 p.m., Eastern Standard Time (EST), excluding state and federal holidays. Or by mail at CT CCSPC, P.O. Box 990031, Hartford, CT 06199-0031. We will not discriminate against you for exercising any of your CCPA rights.