Check21 Privacy Policy

I. Who we are and Some Other Definitions

A. Personal Information. “Personal Information” is any information that identifies, relates to, or reasonably could be linked to or associated with a particular person or organization.

B. Services. “Services” means financial products, technology, payment services, OCR and imaging services, verification services, and all other services provided by Check21.

II. What Personal Information We Collect About You and Where It Comes From

A. Information Check21 Collects from You

We collect and process Personal Information through our Services when you interact with Check21. The data we collect from you varies depending on what specific Services you and your company use. In some cases you actively provide us with the information and in others, Check21 may collect the information automatically. Check21 collects personal information from you when you directly interact with Check21 in the following ways:

• Filling out an agreement and creating a Check21 Account
• Making or receiving payments (such as sending or receiving funds via ACH, wire, or check)
• Processing images of checks or remittance items
• Signing in to access your Check21 Account
• Browsing the platform or our website
• Using our iOS or Android mobile apps
• Using integrations to connect your Check21 Account to third party services
• Calling, chatting, contacting, or interacting with Check21 (such as with our Customer Experience or Sales, or texting us a copy of a receipt, or clicking through our advertising)
• Reading emails from Check21
• Attending a Check21 event (offline or online) or webinar

Check21 may collect the following categories of Personal Information from you when you interact with or use our Services.

• Contact Data, such as your name, business email, phone number, and address.
• Professional Data, including your title or role on your team.
• Account Credentials, including your password (hashed) and information for authentication and account access.
• Identity Data, such as your Tax Identification Number (TIN) or your Social Security Number (SSN) and copies of your passport, driver’s license, or other national ID and any information captured on such ID (such as facial images/ photographs) or through our ID verification process (including the ID verification results).
• Financial Data, including your bank account information, routing and account numbers for debits, reimbursements, transaction history, and related information.
• Transaction Data, including information associated with payments submitted through and by the Check21.com Platform.
• Company Data, any Personal Information submitted to us related to a company when that company applied for or maintained a Check21 Account. This could include information about the insectioniduals involved in that company's leadership and ownership.
• Communications and Online Content, including content within any messages you send to us (such as when contacting support or asking a question). We also collect content within any messages you exchange with other users.
• Marketing Data, such as your contact preferences and webinar /event registration, attendance and participation information.
• Referral Data, including information you provide about any potential referrals as part of our affiliate referral program, such as their name, email address, and phone number.
• Service Use Data, Device Data and Location Data via Tracking Technologies. When you access or interact with our Platform or use any of our mobile apps, Check21 uses several types of activity tracking tools to collect data about how and when you interact with our web pages and mobile application; the type of device, browser, and operating software you use; your IP address and other device event information; and imprecise location data that can be derived from this information (such as location that can be identified from your IP address). Unless these technologies have been disabled by a user, Check21 automatically collects this data through the following types of tracking technologies:
  • Log Files record events that occur in connection with your use of the Services.
  • Cookies are small data files stored on your device that allow us to uniquely identify your browser. We use two types of cookies: session cookies and persistent cookies.
    • Session cookies support website navigation and expire when you close your browser
    • Persistent cookies allow us to identify your unique device across different sessions. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
  • Pixels are code embedded in a website, email, or advertisement that sends information about your usage to a server. Pixels are used in combination with cookies to allow Check21 to track a particular browser’s online activity, like what communications or pages you viewed.
  • Device Fingerprinting is the process of combining and analyzing data elements from your device's browser to uniquely identify your browser and device.

B. Information Check21 Collects from Other Sources

1. Personal Information Collected from Third Parties

Check21 may also collect information about you from other sources. The paragraphs below describe the categories of third parties Check21 collects Personal Information from and what categories of data we collect from them. The information categories referenced in the paragraphs below have the same description as provided in Section II.A of this Policy.

• Category of Third Party: Check21 Account Holders
  • Personal Information Category Collected: Contact, Identity, Professional, Company
  • When Data is Collected:
    • When a business applies for or adds you as an authorized user, administrator, manager, controlling officer, or beneficial owner of a Check21 Account
    • When a referral partner provides us with information about you as a representative of a potential customer
• Category of Third Party: Financial Institutions, Card Network Providers, Payment Processors, Card Issuers
  • Personal Information Category Collected: Contact, Financial, Transaction
  • When Data is Collected: These entities are Check21’s partners in processing payments submitted by you or your organization.
• Category of Third Party: Identity Verification Services; Financial Information Providers; Fraud and Financial Crime Monitoring, Prevention, and Detection Service Providers
  • Personal Information Category Collected: Contact, Identity, Professional, Financial, Transaction, Service Use Data, Device Data, Location Data, Company
  • When Data is Collected: When Check21 is confirming bank account validity, bank account ownership, or managing fraud, financial crime, or other legal risks.
• Category of Third Party: Social Networks and Online Advertising
  • Personal Information Category Collected: Contact, Professional, Marketing
  • When Data is Collected: When Check21 uses these providers to serve or assist in serving our advertisements
• Category of Third Party: Joint Marketing, Business Partnership, and Referrals
  • Personal Information Category Collected: Contact, Professional, Marketing, Referrals, Rewards, and data regarding your relationship with these partners
  • When Data is Collected: When Check21 engages in joint marketing activities and our referral partners, as well as when we acquire information about your and your relationship to these partners
• Category of Third Party: Publicly-available sources (including the media and public domain)
  • Personal Information Category Collected: Contact, Professional, Company, Online Content
  • When Data is Collected: When Check21 is identifying potential customers and partners or conducting due diligence or other risk management activities for existing and potential customers

2. Personal information related to administrators, employees, company owners, and authorized persons or representatives

In some circumstances, Check21 requires our business customers and their representatives to provide us with Personal Information relating to another person (such as providing us with Personal Information about the owners of your business during the application process or providing us with Personal Information about employees). You must inform all persons whose information you share with us how we collect and process Personal Information and all other terms of this Policy.

III. How Check21 Processes and Stores Personal Information

A. How Check21 Processes Personal Information

Check21 processes Personal Information to provide its customers with a reliable and secure payment solution. That requires us to process Personal Information for a number of purposes, as described below:

• Providing Check21 Services. We use all of the categories of Personal Information we collect to provide Check21’s Services. Personal information may be used as part of the processes that enable our Services.
• Improving and developing the Services. We use all of the categories of Personal Information Check21 collects other than identity data to understand how you use our Services, and to improve them. We also use the information to analyze trends and performance to identify future opportunities for the development, promotion, and improvement of our Services. We use analytics services, such as Google Analytics, to help us understand how users access and use our Services.
• Securing the Services and Fraud Detection. We process and analyze Personal Information Check21 collects for the purposes of maintaining the safety and security of our systems, websites, Services, including identifying and troubleshooting any problem with the Check21 Products or Services, investigating suspicious activity, detecting potentially fraudulent or unauthorized transactions, enforcing our terms and policies, and in protecting the rights of Check21 and our customers.
• Providing Customer Support. We process Personal Information Check21 collects to troubleshoot and diagnose problems with our Services, and provide other customer care and support services, including to help us support, improve, and secure the quality of our Services, to investigate security incidents, and provide appropriate training to Check21 staff. We may use automated chat capabilities where you may be interacting with a bot rather than a person for appropriate questions.
• Sending administrative communications. We may use your Contact, Professional, and Transaction information to send you information related to our Product and Services such as confirmations, invoices, technical notices, service updates and security feeds, security alerts, and support, onboarding, and administrative messages.
• Sending marketing communications and placing advertising, including marketing analytics. We use your Contact, Professional, Transaction, and Marketing information we collect to advertise and promote Check21 Services by phone, text, email, or chat, and additional products, according to your marketing preferences. We also use Service Use Data, Device Data and Location Data to place and deliver advertisements to you.

In addition, we may work with agencies, advertisers, ad networks and other technology services to place advertisements on our behalf on other websites and services. For example, we may place ads through advertising and social media firms that you may view on their platforms as well as on other websites and services. As part of this process, we (or these third parties) may incorporate tracking technologies into our own Website and emails or other communications as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you ("Interest-based Advertising").

While you may disable some tracking technologies in your browser settings by blocking cookies in your browser, using global privacy controls, or using other privacy settings on your device or browser, you may still receive non-targeted advertisements we send as part of a general marketing campaign.

• Complying with legal obligations, defending legal claims, and preventing and detecting crime and misuse of Check21 Services. We may process all categories of Personal Information Check21 collects to fulfill Check21’s legal and regulatory rights and obligations, including in the following situations:
  • when cooperating with public and government authorities, courts or regulators in accordance with applicable laws;
  • to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
  • to protect Check21’s legal rights, pursue remedies available to us, and limit our damages;
  • to protect against misuse or abuse of our Services;
  • to protect personal or public property or safety;
  • to comply with judicial proceedings, court orders or legal processes; or
  • to respond to lawful requests.

When complying with court orders and other similar legal processes, Check21 strives for transparency. We will make reasonable efforts to notify our customers and users of any disclosure of their Personal Information, unless we are prohibited by law or court order, or exigent circumstances prevent us from doing so.

• For our business purposes. We may use information for other legitimate business purposes, such as developing new Services; enhancing, improving or modifying our Services; mitigating financial loss, claims, liability, and other harms to our users, Check21, our partners, or third parties.
• With Notice to You and Your Consent. We may otherwise process Personal Information after providing notice to you and obtaining your consent. You may opt out of or refuse your consent for this processing.

B. Anonymized and aggregated data. To improve and market our Services, better target advertisements, and for other promotional purposes, Check21 may transform Personal Information into de-identified information removing or masking information that could be used to identify you and by aggregating or combining de-identified data with other information.

C. For EEA and UK residents: Legal basis for processing

The General Data Protection Regulation (GDPR) in Europe requires a "lawful basis" for processing personal data. Our lawful basis includes where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our Service Providers, partners, or business customers; (b) processing is necessary for the performance of a contract with our customers; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.

The legal basis for Check21’s different Personal Information processes is as follows:

• Process: Providing Check21 Services
  • Legal Basis:
    • Check21’s legitimate business interest in providing our business customers with Services; and
    • Check21’s customer’s legitimate interests in processing payments.
• Process: Improving and developing the Services
  • Legal Basis:
    • Check21’s legitimate business interests in developing, promoting and improving our Services and identifying future business opportunities; and
    • In some cases, your consent to providing Check21 with feedback and data.
• Process: Securing the Services and Fraud Detection
  • Legal Basis:
    • Check21’s legitimate interest in ensuring the safety and security of our Services and our interest in protecting Check21’s rights and the rights of our customers, including avoiding being the victims of or involved in crime.
• Process: Providing Customer Support
  • Legal Basis:
    • Check21’s legitimate interest in providing our users and business customers’ authorized representatives with customer care and assistance, identifying and investigating security and technical incidents, and providing, improving, and securing our Services, as well as our staff’s knowledge and training.
• Process: Sending administrative communications
  • Legal Basis:
    • Check21’s legitimate interests in administering and securing our Services; and
    • In some cases, compliance with Check21’s regulatory obligations.
• Process: Sending marketing communications and placing advertising, including marketing analytics
  • Legal Basis:
    • Check21’s legitimate interest in marketing its Services to appropriate groups; and
    • In some cases, in reliance on your consent to receive marketing materials or have your information used in analyses.
• Process: Complying with legal obligations, defending legal claims, and preventing and detecting crime and misuse of Check21 Services
  • Legal Basis:
    • Compliance with Check21’s legal and regulatory obligations; and
    • In furtherance of Check21’s legitimate interests in protecting against the misuse or abuse of our Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or to respond to lawful requests.
• Process: For Check21’s business purposes
  • Legal Basis:
    • In reliance on Check21’s legitimate interests for pursuing legitimate business purposes.
• Process: With Notice to You and Your Consent
  • Legal Basis:
    • In reliance on your consent.

IV. How Check21 Discloses Personal Information to Other Parties

A. Check21’s Disclosures of Personal Information to Third Parties

Check21 discloses Personal Information for several business purposes. Check21 discloses the following data categories for the following purposes:

• Business Purpose: Making a payment
  • Data Categories Disclosed: Contact, Financial
  • Category of Recipient: Person or organization being paid or debited
• Business Purpose: Providing contracted Services to Business Customer
  • Data Categories Disclosed: Contact, Financial, Transaction, and Communications
  • Category of Recipient: The Check21 account holder that has made you an authorized user, administrator, or otherwise provided your personal information in connection to a Check21 Account
• Business Purpose: Providing Check21 Services and determining eligibility or interest in additional Services
  • Data Categories Disclosed: All categories collected
  • Category of Recipient: Other Check21 affiliates
• Business Purpose: Providing and securing Check21 Services, complying with our regulatory obligations, data analytics, data hosting, and technical support
  • Data Categories Disclosed: All categories collected
  • Category of Recipient: Service Providers operating and providing services and staff augmentation on Check21’s behalf
• Business Purpose: Advertising and Marketing Analytics
  • Data Categories Disclosed: Contact, Marketing, Service Use, Device, Location
  • Category of Recipient: Advertising agencies, advertisers, ad networks, technology Service Providers
• Business Purpose: Providing credit card networks
  • Data Categories Disclosed: Contact, Financial, Transaction, Identity
  • Category of Recipient: Credit card networks such as MasterCard or Visa
    • For more information on how MasterCard and Visa handle your personal information, please visit Mastercard’s Global Privacy Notice or Visa’s Global Privacy Notice, respectively.
• Business Purpose: Processing transactions
  • Data Categories Disclosed: Contact, Financial, Transaction, Identity
  • Category of Recipient: Financial institutions, financial services providers
• Business Purpose: Risk mitigation
  • Data Categories Disclosed: Contact, Financial, Transaction, Identity
  • Category of Recipient: Bank account validity providers

B. Restrictions on Service Provider’s Use of Your Personal Information

Check21 may transfer your Personal Information to our Service Providers. Check21 contractually prohibits our Service Providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us and fulfilling their own regulatory and legal obligations, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for other purposes except as prohibited by applicable law or contractual obligation.

C. Data transfers in corporate transactions

In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information and data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Check21 may continue to process Personal Information consistent with this Policy.

D. Compliance and compelled disclosures

We may disclose or transfer Personal Information in the following circumstances:

• To comply with applicable law, regulation or payment network rules;
• To enforce our contractual rights or comply with contractual obligations;
• To protect the rights, privacy, safety and property of Check21, you, our customers, our business partners, or others; or
• To respond to requests from auditors, courts, law enforcement agencies, regulators, and other public and government authorities, which may include authorities outside your country of residence. When complying with court orders and other similar legal processes, Check21 strives for transparency. We will make reasonable efforts to notify our customers and users of any disclosure of their Personal Information, unless we are prohibited by law, court order, or exigent circumstances prevent us from doing so.

E. For California residents: No sale or sharing of Personal Information

Check21 does not sell or allow our Service Providers to process your Personal Information for their own use without your consent, unless the processing of that information is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, protect our property or operations, or enforce the rights and protect the property or operations of our business partners and customers. As part of our arrangements with Service Providers, Check21 may receive your Personal Information from and transfer your Personal Information to our Service Providers as part of providing our Services and Products, but these transfers are conducted under a premise that protects your data from additional uses and are not considered a sale pursuant to California law.

V. How Check21 stores and protects Personal Information

A. How long Check21 retains Personal Information and when we delete it

Check21 collects and retains Personal Information to provide our Services. We retain that information for as long as we have a business or operational reason to retain that information, or where we have a legal or regulatory obligation to continue to retain that Personal Information after it has served its business or operational purpose. Check21 deletes or de-identifies Personal Information when we no longer are required to or have a reasonable business purpose to retain it.

Check21’s legal retention obligations may require us to retain your Personal Information after you are no longer an authorized user or after your Check21 account has closed. These retention obligations also prohibit us in some cases from deleting certain Personal Information after you have asked us to delete your data under the data privacy and data rights laws in different jurisdictions. Check21 retains data where it is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements or where deleting it prevents us from billing for our Services, calculating taxes, conducting required audits, or carrying out other legitimate business functions.

B. Where Check21 stores Personal Information and international data transfers

As we strive to serve our customers everywhere in the world they operate, Check21 may process and store Personal Information for the purposes described in this Policy in the United States or any other country in which Check21, its subsidiaries, affiliates, or Service Providers operate. These countries may have data privacy or protection laws that are different. Check21 takes measures to comply with applicable data privacy laws when we transfer Personal Information internationally.

C. Check21’s data security

Check21 uses organizational, technical, and administrative measures to protect Personal Information that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing Personal Information. The specific measures we use include encrypting Personal Information in transit and at rest, device and identity verification processes, and idle lockouts.

Where you have created a username and unique password to enable you to access your Check21 Account, or use our Services, it is your responsibility to keep this password secure and confidential.

Please contact us immediately if you believe that your Personal Information or any other confidential information that you have provided to us is no longer secure or has been lost or stolen.

VI. Additional Important Information About Your Personal Information

A. Check21 Account users and administrators’ access and authorities

Check21 Services are intended for use only by companies, and you may only use a Check21 Account if you are an employee or other authorized representative of a company that has opened a Check21 Account. The information in your Check21 Account is governed by our agreements with the applicable business customer. You may access, update, or delete certain information within your Check21 Account through the Platform, provided that the business customer’s administrator is responsible for determining how that data is managed. The business customer's administrator is responsible for your Check21 Account. The administrator can also access information about you via their own access to Check21’s Services, access and retain information we have stored on its behalf, and limit your ability to edit, modify, delete, or use information associated with your use of the Services.

However, losing authorized access to a company’s Check21 Account does not deprive you of rights you may have under the data privacy or other data rights laws in your jurisdiction.

B. Closure of a Check21 Account

Closure or deletion of your company’s Check21 Account will mean that the business customer will permanently lose access to the Personal Information and data associated with the Check21 Account. Personal information or de-identified information associated with your company’s Check21 Account may nonetheless remain on systems owned or maintained by Check21 where required to comply with the law, our contractual obligations, or carrying out legitimate business functions.

C. For EEA and UK residents: Check21’s role as a data controller and processor

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors"). Check21 acts as a controller with respect to personal data collected as you interact with and use our Services. For the Products, Check21 acts as a processor when we act on the instructions of or on behalf of a business customer, and as a controller when Check21 is deciding how to process data directly.

VII. Your Rights and Choices

A. Your Choices with Check21

1. Electronic Communications

• Emails. You may choose not to receive promotional emails from us by following the unsubscribe/opt-out instructions in those emails at any time. Please note that you cannot opt-out of non-promotional messages, such as those about your Check21 account, transaction information about our Services (such such as updates to our platform agreement, privacy notices, security alerts, and other notices relating to your access to or use of our Services) or our ongoing business relationship.
• Text, SMS, or WhatsApp Messages. If you have opted in to receiving text, SMS, or WhatsApp messages related to your use of the Products or Services, you can opt-out at any time by texting "STOP" to the short code. After you send the SMS or WhatsApp message "STOP" to us, we will send you an SMS or WhatsApp message to confirm that you have been unsubscribed. After this, you will no longer receive SMS or WhatsApp messages from us. Please note that you cannot opt-out of non-promotional messages, such as those about your Check21 Account.

2. California Resident Rights and Choices

If you are a California resident, you have certain rights over the information that we have about you. You can:

• Delete any Personal Information we have collected from you when we do not have legal or contractual obligations to keep the information or a need for the information to carry out a legitimate business function.
• Opt out of the sale of your Personal Information and opt out of having your personal data shared for the purpose of cross-context behavioral advertising. As discussed above, Check21 does not sell your Personal Information nor share it for these purposes.
• To request that Check21 corrects any inaccurate Personal Information Check21 holds about you.
• To request that Check21 limit the use and disclosure of your sensitive Personal Information to uses that are necessary to provide our Services and to the uses defined in California law or regulation (defined in the California Civil Code, Section 1798.121).
• Request that Check21 provide you with any or all of the following regarding Check21’s data processing for the 12 months preceding the request:
  • The categories of information Check21 has collected about you;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purpose for collecting Personal Information;
  • The categories of third parties to whom Check21 discloses Personal Information; and/or
  • A copy of the specific pieces of information Check21 has collected about you.
• Appoint an authorized agent to act on your rights on your behalf. Check21 will require appropriate proof of the agent’s authority to make these requests and will need to verify your identity directly.

Check21 will not discriminate against you for any use of your privacy rights.

To exercise any of these rights, you may make a request by emailing us at privacy@Check21.com. Check21 will confirm receipt of your request and provide you with information about our processes for acting on your request, including when you can expect a response, within 10 business days. We will need to verify your identity to ensure the security of your Personal Information before providing you with any Personal Information.

If you are currently a Check21 user, you may correct any Personal Information we have about you either in your settings, by contacting your administrator, or by using the contact details above.

3. European and United Kingdom Rights

You have the following rights regarding the Personal Information we collect and use about you:

• You may access, correct, update or request deletion of your Personal Information.
• You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, and request we transfer your Personal Information to a third party.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us at privacy@Check21.com.
• If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a supervisory authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

To exercise any of these rights, please contact us at privacy@Check21.com. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.

If Personal Information about you has been processed by us as a processor on behalf of a business customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of the customer on whose behalf we processed your personal data. We will refer your request to that Customer, and will support them to the extent required by applicable law in responding to your request.

Please note that we retain information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use your Personal Information, even after a data subject request, for purposes of our legitimate interests and to comply with our legal obligations, including where needed to resolve disputes, prevent fraud and financial crime, and enforce our agreements as well as to comply with statutory retention obligations.

4. Residents of other locations

If you reside in a US state or territory other than California or anywhere else in the world other than the European Economic Area or United Kingdom and would like more information about how Check21 processes your Personal Information or have questions about your rights under this Policy, please submit your request to privacy@Check21.com.

B. Your Choices with Google Analytics and Interest-Based Advertising Providers

1. Google Analytics

Check21 uses Google Analytics to better understand how users interact with our websites and advertising. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb.

2. Interest-Based Advertising

The companies we work with to provide you with targeted ads in connection with the Services are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative ("NAI"). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; and (ii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants' other customers or from other technology services).

Please note that if you opt out using any of the methods described for Google Analytics, DAA,or NAI, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities' statements regarding their opt out options or programs.

VIII. Updates to This Policy

We may update this Policy from time to time in response to changing legal, regulatory, technical or business developments. We will obtain your consent to any material changes to this Policy if, and where, required by applicable data protection laws.

IX. How to Contact Us

If you have concerns, questions, or would like to better understand our privacy practices at Check21, please contact us using the following details:

By email: privacy@Check21.com

Check21 Inc.

1440 Coral Ridge Drive

Suite 366

Coral Springs, FL 33071

By phone to our Customer Experience team: +1 866-989-CHECK