Treatio.io (“Treati”) respects your privacy and is committed to protecting it. Please read this Privacy Policy carefully to understand how Treati collects and uses your personal information and data. This Privacy Policy applies to all Personal Data that we receive from various sources, as outlined below. By using or accessing Treati’s website(s) in any way, or by engaging in transactions with Treati through any other means, you signify that you have read and understand this Privacy Policy and you consent to our collection, use and disclosure of your information in the manner described herein. If you do not agree with this Privacy Policy, please do not use this website or transact business with Treati.
For purposes of this Privacy Policy, “Personal Data” may include any information that can be used to identify or locate you, such as your name, address, IP address, mailing address, contact information, email address or phone number and other information you may produce to us. Both federal and state law in the United States define Personal Data or Personal Information, as do the laws of Canada, the European Union, and other countries and jurisdictions. This Privacy Policy is intended to include the most expansive definition. However, please recognize that your rights related to Personal Data, and how Personal Data is defined, differ somewhat from state to state and country to country. For example, a California resident likely has different rights than a Utah resident, and each of them likely has different rights than a resident of Canada.
Changes to Privacy Policy. We review this Privacy Policy regularly and may update it from time to time. We will post any changes on this page and may also provide notice of material changes to our Privacy Policy on our website home page or in the portal to our Hosted Service. If you object to any changes to this Privacy Policy, you may close your account and discontinue use of our website and services. Each time you use any service of Treati, you agree that the current version of this Privacy Policy applies.
Treati has developed software that enables its customers, such as banks and lenders (“Customers”) to have their form documents (“Customer Forms”) hosted online, for such Customers’ clients and potential clients (“End Users”) to fill out and sign the form documents online, as part of Treati’s online service on its website(s) (the “Hosted Service”). In connection with our business, we collect and process the following categories of Personal Data of individuals:
General. We collect Personal Data when you or your employer or organization register an account with us as a Customer or as a user of the Hosted Service, when you fill out a Customer Form as a End User of one of our Customers, when you visit our website, when you use our services or software, and when you otherwise transact business with or communicate with Treati.
Data received from credit checks and Know Your Customer (KYC) checks. Treati runs credit checks on End Users on behalf of Treati’s Customers, using the Customer’s credit account. Treati DOES NOT see any of the data obtained from these credit checks; that data is provided directly to Treati’s Customer. Treati also runs “Know Your Customer” (“KYC”) checks on End Users using Treati’s accounts with companies such as Plaid, Ekata, Iovation, Idology, and IDAnalytics, and provides such KYC check data to its Customer that requested the KYC check.
Data received from Hosted Service users and End Users of Customers. Our Customers who license our Hosted Service act as data controllers in the use of the Hosted Service and the collection and processing of Personal Data. In such cases, our role in processing the Personal Data provided by our customers is as a “Processor,” since we are processing data on behalf of the Customer. As a Processor, we are obligated to process Personal Data as part of our license agreement entered with the Customer. Processing of this Personal Data is performed on behalf of the Customer and for the purpose of providing the services requested by the Customer.
Data obtained for marketing purposes for potential Customers or others. We obtain marketing data from third parties that we use to reach out to inform potential customers and others of the services offered by our organization. The Personal Data collected generally includes email addresses for a potential customer’s personnel and may also include their name and phone number. We also use the contact information provided to us by our Customers to communicate information about our products and services to the Customer’s personnel, which may include marketing our products and services.
Cookies and Other Tracking Technologies: When you visit our website(s), information about your device hardware and software is automatically collected, including your IP address, browser type, domain name, access times, geographic location, referring website address and other technical information. Treati uses tracking technologies such as cookies to collect information from your web browser through our servers or filtering systems when you visit our website(s).
Cookies are small text files placed on a user’s computer with the user’s browser to collect standard internet log information and to enable our website to track a user’s activities on the website. We use cookies to: (1) keep you signed in on our website; (2) enable website features for you; (3) help us understand how you use our website and what products or services may be most relevant to you; (4) provide analytics to improve website performance and effectiveness; (5) store user preferences; and (6) facilitate relevant targeted advertising on advertising platforms or networks. Cookies may also be set within emails in order to track how often our emails are opened. We may share this information with our affiliates and service providers.
You can change your web browser settings at any time to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, our website may not function properly for you, and you may not be able to use some sections or functions of our websites.
To learn more about cookies and how to manage and delete them, visit http://www.allaboutcookies.org.
Treati may also use additional web user tracking technologies like clear GIFs, Flash cookies, pixel tags, and web beacons.
Information collected may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our site, the date and time of each visitor request, and information you search for on our sites. We can also track the path of page visits on a website and monitor aggregate usage and web traffic routing on our sites.
Information from Third Party Platforms.
If you access our website or communicate with us using your account or account credentials from a third-party owned or operated platform/service (e.g., Amazon, Apple, AWS, Facebook, Google, Shopify, Twitter, etc.), post content from our website to a social network, or use various social media features (e.g.,“Like” button), we may process certain information from the third parties, such as your username, “likes”, location, birthday, comments and reviews, preferences, network reach and influence, and any other information you provided to the third parties in connection with your account. Depending on your account and privacy settings, we may also be able to see information that you post when using these third parties whether or not you are an active customer. We may also collect Personal Data about you from our third party service providers who provide us with e-commerce and/or technical services related to the website. The information you post or provide to third parties, as well as the controls surrounding these disclosures are governed by the policies of these third parties.
Special categories of data not collected. We do not actively collect or otherwise process Personal Data from minors and include in our license and subscription agreement a condition that the customer will not provide any Personal Data of minors to us. The age of a minor varies by jurisdiction. For the purposes of Personal Data collected from the European Union, the age of a minor is under age sixteen (16). For purposes of the Children’s Online Privacy Protection Act (COPPA) in the U.S., the age of a minor protected by such law is under age thirteen (13).
We also do not actively collect or otherwise process special categories of Personal Data, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We do not actively collect or otherwise process Personal Data relating to criminal convictions and offences. However, it is possible that a Customer Form may request such information from an End User, which information would then be stored in Treati’s Hosted Service and disclosed to the Customer who provided that Customer Form.
We may use and process Personal Data for any purpose that is permitted under applicable data protection laws in accordance with this Privacy Policy. “Processing” of Personal Data includes collecting, recording, organizing, structuring, storing, altering or modifying, retrieving, transmitting, disclosing or otherwise making available to third parties, deleting, and otherwise using or dealing with your Personal Data. We may process your Personal Data with or without automatic means.
These purposes include:
If Treati, in good faith, determines that you have used the service to menace, threaten, harass, intimidate or otherwise deceptively pose as another person, or in any other way in violation of law. Simply, if you attempt to use the website or purchase or use a product for any unlawful means, you have no expectation of privacy and we may use and disclose any and all information for the protection of Treati and others.
If required or permitted to do so by law or if, in good faith, Treati believes that such action is necessary to: (1) comply with laws and regulations or with legal processes; (2) protect and defend Treati’s rights and property or prevent fraud; (3) protect Treati against abuse, misuse or unauthorized use of Treati’s products or services; (4) protect the personal safety or property of our personnel, users of our website or the public; and/or (5) comply with tax reporting requirements, then Treati may use and disclose any and all information as needed. The servers that serve our website automatically identify a computer by its IP address.
Legal basis.
We base our processing of Personal Data on the need to perform our contractual obligations under our license agreements and our legitimate activities as a provider of software and related services. We also process Personal Data to comply with applicable law and to exercise our legal rights. We may also use your Personal Data for internal purposes, including auditing, data analysis, system troubleshooting, and research. In these cases, we base our processing on legitimate interests in performing the activities of the organization.
No sale of Personal Data. We never sell or rent Personal Data to third parties.
Disclosures of Personal Data. We may disclose or share your Personal Data with other parties in the following circumstances:
We store Personal Data that we have collected (through the means described above) on our premises and in our information system at our facilities, in third party data centers, in the systems of third party service providers, and in cloud storage solutions. Treati is located in the United States. All Personal Data of End Users, whether contained in Customer Forms or in an End User’s account with Treati, will be stored only in the Hosted Service, in encrypted form. Currently hosting services for the Hosted Service are provided by Amazon Web Services (AWS), and the servers that host the Hosted Service and the Personal Data contained therein are located in the United States. If Treati transfers Personal Data from one country to another, we will ensure that the information is transferred in accordance with this Agreement and the Privacy Policy, and as permitted by applicable data protection laws.
Treati uses appropriate physical, organizational and technological measures to protect the Personal Data you provide to us against loss or theft, and unauthorized access, disclosure, copying, use, or modification. This includes limiting access on a “need-to-know” basis. Where third parties (such as AWS) are used to host our products, we use third parties who meet required privacy and security standards.
However, no electronic data transmission can be guaranteed to be secure from access by unintended recipients and Treati will not be responsible for any breach of security unless this breach is due to its negligence. Although we are committed to employing reasonable technology in order to protect the security of our website, even with the best technology, no website is 100% secure. In transacting business with us through our website, you assume the risk inherent in transacting business online.
To offer our website, products and services to you, Treati relies on plugins and services from third parties such as internet service providers, email service providers and plugins, calendar plugins, Customer Relationship Management (CRM) systems, credit card processors, and third party data storage. To the extent these providers have access to your Personal Data, we will require that they are legally or contractually committed to comply with applicable privacy laws, In the case of credit card processors, we require that they be PCI DSS-compliant. However, we cannot guarantee with certainty that the computer systems and storage systems whereon these services are offered will not be accessed by unauthorized parties. This is a risk inherent in providing any information or, or conducting any business, online. In transacting business with us through our website, you assume the risk inherent in transacting business online.
Treati uses technical and organizational measures to protect the Personal Data that we store, transmit, or otherwise process, against accidental or unlawful destruction or disclosure, loss, alteration, or unauthorized access. Our security controls and risk management program and processes are designed to implement appropriate technological and organizational measures to ensure a level of security appropriate to the risks. We regularly consider appropriate new security technology and methods. Security measures implemented include:
Treati processes Personal Data for a reasonable period of time to fulfill the processing purposes mentioned above. Personal Data is then archived for time periods as required or necessitated by law or legal considerations. Treati reserves the right to delete a customer’s data, including Personal Data provided by that customer, from its system after 30 days from the date of termination of its agreement with the applicable customer. Treati also deletes Personal Data in response to an individual’s request, as set forth in the “YOUR RIGHTS RELATING TO YOUR DATA” section below.
Treati reserves the right to retain usage data relating to our products and services, as well as data that has been anonymized and/or aggregated, to the extent permitted by applicable laws. With respect to any Personal Data collected by us for marketing or for our own internal purposes, we will retain that data for a reasonable time in order to fulfill those purposes.
We regularly review our retention policy to ensure compliance with our obligations under data protection laws and other regulatory requirements. We regularly audit our databases and archived information to ensure that Personal Data is only stored and archived in alignment with our retention policy.
If you wish to opt out from any of the uses of Personal Data that are specified in this Privacy Policy or request Treati to delete your Personal Data, except in the case of legal proceedings or where your data is required for tax and transactional purposes, please contact us as described in the “UNDER’S CONTACT INFORMATION” section below. Please note that your subsequent disclosure of Personal Information to us may override prior opt-out or deletion requests. Treati does not discriminate against those who opt out. However, opting out may prevent us from conveniently and efficiently providing further, product support services and information to you.
Unsubscribing to marketing communications: In particular, if we are sending you email communications of a marketing nature, an ‘unsubscribe’ option is provided in the footer of every email. You may also contact us directly to unsubscribe to marketing emails or other marketing communications, at the contact information set forth in the “UNDER’S CONTACT INFORMATION” section below. If you have agreed to receive marketing communications, you may always opt out at a later date.
Your California privacy rights. This section applies to California residents only.
Treati is not currently required to comply with the CCPA (Section 1798.100 et seq. of the California Civil Code). If that changes for any reason, Treati will comply with the CCPA’s requirements.
Treati may require you to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of Personal Data. The information provided shall only be used for this purpose.
Our website contains links to other websites. This Privacy Policy applies only to our website, so if you click on a link to another website, you should read their privacy policy. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within, or linked to, a page of our website.
If you have any questions about this privacy policy or your Personal Data that we hold, would like to cease receiving marketing materials from us, have any complaints, or would like to exercise any of your other rights related to your Personal Data, please contact us:
Treatio.io
222 W Merchandise Mart PlazaSuite 1212Chicago, IL 60654
support@under.io
