Privacy Policy

We respect your privacy, and are committed to processing your personal data in accordance with this privacy policy (the “Privacy Policy”) and applicable privacy laws. This Privacy Policy applies to all websites (the “Sites”), mobile applications, and other online services on which we post this Privacy Policy (collectively, the “Services”), as well as other information we collect about you offline. As used in this Privacy Policy, “Tipalti”, “we”, “our” or “us” refers to Tipalti, Inc. and our affiliated companies (including Tipalti Solutions LTD, Tipalti Payments, Inc., Tipalti Europe LTD, Tipalti Canada, Inc., and Tipalti B.V.).

Nothing in this Privacy Policy is intended to limit your statutory rights, including your right to a remedy or means of enforcement.

This Privacy Policy describes how we collect, use, and disclose information about you. Without limitation, we may collect information about you if you are a prospective customer or partner, an individual who uses our Services on their own behalf or on behalf of our customer, an individual who accesses our Services in connection with receiving payments (on their own behalf, or on behalf of their employer), or a visitor to our website.

This Privacy Policy does not describe how Tipalti uses information that our customers provide to us (e.g., about their own payees, suppliers, or employees) to process on their behalf. For detailed privacy information related to a Tipalti customer who uses Tipalti products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy. We act as a data “processor” or “service provider” for our processing on behalf of customers under our agreements with them. In some cases, we may act as a data “controller” under certain data protection laws for the same data for specific purposes stated under this Privacy Policy.

By accessing and/or using any of the Services, you acknowledge that we may collect and process information about you as set forth in this Privacy Policy.

Specifically, this Privacy Policy describes our practices regarding:

1. Data Collection
2. Data Uses
3. Data Location and Consent to Transfer
4. Data Retention
5. Data Disclosure
6. Cookies and Tracking Technologies
7. Third-Party Websites and Services
8. Communications
9. Data Security
10. Choices and Data Subject Rights
11. Regional Privacy Disclosures
12. Additional Information and Contact Details

1. DATA COLLECTION

How We Collect. 

We collect, receive, and process information about you through:

• Your interaction with us or our Services;
• Our customers, such as when they provide us with information about employees who are authorized to use the Services under their account, or information about their suppliers and other vendors;
• Third-party services and providers, such as business partners, credit bureaus, social media tools, analytics and other publicly available sources; and
• Events we organize or take part in, and other business initiatives (including partner promotions, communications, and events).

Data You Provide to Us Directly.

You may provide information directly to us, such as when you:

• Register for an account;
• Complete your user profile;
• Register for an event or webinar, or download materials from our Sites;
• Fill out a survey or provide us with feedback;
• Request certain features (e.g., newsletters, updates, and other products);
• Use certain features that require your information to function (e.g., portions of our Services that require log-in to participate);
• Communicate with us; or
• Otherwise interact with us, such as at in-person events, by phone, or by video.

The information you provide to us directly may concern you and/or others and may include:

• The information you provide to us directly may concern you and/or others and may include:
• Contact information, such as full name, email address, and phone number;
• Business information, such as name of your employer, title/role at company and business address;
• Account log-in information such as email address and password, and other information used for authentication and access control;
• Financial information, such as data including VAT ID, Social Security Numbers, TIN or EU Tax
• Identification Number, bank account number, IBAN, bank routing number or SWIFT code (or alternatively, account details at payment processing services such as PayPal, where applicable) and payment preferences;
• Other information about you, such as social media accounts associated with you; and
• Other information you provide to us, such as when you communicate with us, including for support purposes.

We may also collect certain information for compliance purposes, such as through our Know Your Customer (“KYC”) process, to comply with legal, regulatory, and other compliance-related requirements. This may include date of birth, address, social security number, a copy of a government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address. To the extent that any of the foregoing solely relates to a non-human entity, we will not regard it as personal data, and this Privacy Policy will not apply.

Information We Collect Automatically.

We and our third-party vendors, which include ad networks and analytics companies, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Site. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of the Site you’re using; and (j) the type of device that you use. We may also track when and how frequently you access or use the Services, including how you engage with or navigate our site or mobile application. We may use this information (including the information collected by our third-party vendors) for analytics (including to determine which portions of the Services are used most frequently and what our users like/do not like), to evaluate the success of any advertising campaigns, and as otherwise described in this Privacy Policy.

We and our third-party vendors may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party vendors also may use certain of these technologies in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods. For more information, see https://www.allaboutcookies.org/.

When you use the Services, we may collect general location information (such as general location inferred from an IP address).

Information We Collect From Other Sources.

We may also collect information about you from unaffiliated parties. For example, your organization may provide us with additional information about you, such as contact information, company titles and roles. We use such information in accordance with this Privacy Policy, such as to provide our Services and set up payees for payments by customers.

We may also collect information about you from other users through referrals or otherwise. We may also collect information about you from third parties such as data enhancement providers. For example, we may collect information about preferences, attributes, and insights about prospects who may be interested in our Services.

2. DATA USES

We use information we collect about you for the following purposes:

• To facilitate, operate, and provide Services to our customers, including determining your initial and continued eligibility to use such Services;
• To authenticate the identity of our users, which may include verifying information we collect about you against third party data, such as data belonging to credit reference agencies or other public sources;
• To facilitate and manage access to and use of our Services, including account creation, login
• and deletion;
• To provide you with customer care, assistance and technical support services;
• To further develop, customize and improve the Services, and to improve your user experience;
• To facilitate and optimize our marketing and advertising campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and Services more effectively;
• To contact you with general or personalized service-related messages, or with promotional messages, in accordance with Section 5 “Data Disclosure” below, and to facilitate, sponsor and offer certain events and promotions;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
• To create aggregated statistical and research data, inferred non-personal data, or anonymized and/or aggregated data, which we or our business partners and customers may use to provide and improve our respective services, or for any other purpose;
• To enforce and apply our agreements, including for billing and collection purposes; and
• To comply with our legal, regulatory, compliance and contractual obligations.

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.

Tipalti also uses artificial intelligence and similar technologies for processing personal data within the Services.

We may aggregate and/or anonymize information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, and/or others.

3. DATA LOCATION AND CONSENT TO TRANSFER

We and vendors on our behalf manage, store and process information about you in the United States, Canada, Israel, the United Kingdom, the European Union, and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

For personal data that is subject to the GDPR, Tipalti utilizes approved transfer mechanisms, such as the EU adequacy decision, Standard Contractual Clauses approved by the European Commission, and the Data Privacy Frameworks. As used in this Privacy Policy, the Data Privacy Frameworks mean the EU-U.S. Data Privacy Framework (EU-U.S. DPF), and the UK Extension to the EU-U.S. DPF.

If there is any conflict between the policies in this Privacy Policy and data subject rights under the EU-U.S. DPF Principles (collectively, the “DPF Principles”), the applicable DPF Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification page, please visit https://www.dataprivacyframework.gov/.

Tipalti adheres to the DPF Principles regarding the collection, use, and retention of personal data that is transferred from the European Union (including European Economic Area member countries), and the United Kingdom to the United States. Tipalti has self-certified its commitment to comply with the EU-U.S. DPF Principles and relies on the European Commission’s adequacy decision for the EU-U.S. DPF to receive personal data transfers from the European Union/European Economic Area, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

Tipalti remains responsible and liable under the DPF Principles for the actions of any third-party agents engaged to process data on Tipalti’s behalf that processes the personal data in a manner inconsistent with the DPF Principles, unless Tipalti proves that it is not responsible for the event giving rise to the damage.

We encourage you to contact us as provided in the Additional Information and Contact Details section below should you have a Data Privacy Framework related (or general privacy-related) complaint. We will use our best efforts to address your concern within 45 days of receipt of your complaint. If you have a privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at: https://www.jamsadr.com/DPF-Dispute-Resolution. For any disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. Prior to initiating such arbitration, you must: (1) afford us the opportunity to resolve the issue; (2) seek assistance via Tipalti’s recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Data Privacy Framework, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Data Privacy Framework with respect to the individual.

Tipalti is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

4. DATA RETENTION

We retain information about you for as long as it is reasonably necessary to achieve the stated purposes of collection (e.g. without limitation, to provide you with our Services, to comply with contractual obligations, to meet with our legal and compliance obligations, or as required for proper log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use).

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain information about you for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@tipalti.com.

5. DATA DISCLOSURE

Tipalti may disclose information collected about you as provided below.

Legal Compliance; Safety: We may disclose or allow government and law enforcement officials access to information about you in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (1) we are legally compelled to do so; (2) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements fraud, or other wrongdoing; or (3) such disclosure is required to protect our employees or third parties, or our legitimate business interests, including the security or integrity of our products and Services.

Vendors: We engage vendors to support the operation of our business, and these vendors may process information about you. These vendors may include hosting and server co-location services, operating systems and platforms, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, capital providers and correspondents, banks, financial institutions, credit bureaus, collection agencies, customer engagement services, billing and payment processing services, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with our legal and regulatory obligations to screen and monitor transactions, and our business, legal, tax, financial and compliance advisors.

Events: Tipalti may receive from, and share with a third-party event host, personal data collected at events either managed by Tipalti or by a third party. For any event hosted by a third party, the collection and use of all personal data will be governed by the applicable third party’s privacy policy, and the terms provided to individuals at the applicable event.

Advertising and Analytics: We may disclose or make available some of your information with advertising and analytics partners to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies and tracking technologies to allow us to, among other things, track and analyze data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your online activity. For more information about how to manage having your web browsing information used for advertising purposes, please see the Cookies and Tracking Technologies section below.

Tipalti Subsidiaries and Affiliated Companies; Change of Control: We may disclose information about you internally within our affiliates for the purposes described in this Privacy Policy. In addition, should Tipalti or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with the parties involved in such an event, including in the diligence or negotiations in anticipation of such an event.

Disclosure with Consent/At Your Direction: Tipalti may also disclose information about you with your consent or at your direction.

Aggregated/De-Identified Data: We may disclose information that has been aggregated or de-identified, as such information is not subject to this Privacy Policy.

6. COOKIES AND TRACKING TECHNOLOGIES

Tipalti and its vendors use cookies and other technologies on our Sites and within our Services, for performance, tracking, analytics, personalization purposes and to provide you with a better Experience.

Cookies are small text files that are stored through the browser on your computer or mobile device (for example, Google Chrome or Safari) when you visit a website. Some cookies are removed when you close your browser session, these are the “Session Cookies”, while others last for longer periods and are called “Persistent Cookies”. We use both types of cookies to facilitate the use of the Services’ features and tools (for example, we use Persistent Cookies to remember your login details and make it easier for you to login the next time you access the Platform). The following describes different categories of cookies and how we might use them on our Sites and within our Services.

Strictly Necessary Cookies: These cookies are necessary for the functionality of our Sites, and include session cookies needed to transmit authentication and security cookies. These cookies cannot be opted out of, as they are required for functionality of our Sites.

Functional Cookies: These cookies allow us to enable additional functionality (e.g., third-party video or audio), remember your settings and preferences (e.g., language or region), and customize or personalize your experience (e.g., greeting you or recommending content based on prior visits). Analytics or Performance Cookies: These cookies assist us with analyzing use of our Sites and improving the performance of our Sites, including capturing analytics of website traffic, assisting with market research, and providing non-targeted advertising.

• Google Analytics: We use Google Analytics to collect information to maintain and improve the use of our Sites and Services. Google Analytics collects information such as how often users visit the Services, which pages they visit when they do so, and which other sites they used prior to coming to our Services. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available Here.
• Mixpanel: We collect personal data such as your email address and your user activity through Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, and the Mixpanel Privacy Policy. You can opt-out of Mixpanel’s services by email at: compliance@mixpanel.com.

Advertising Cookies: These cookies track a user’s activity across websites in order to understand a user’s interests, and to direct marketing to the user. This includes our ads on social media platforms. These cookies may also share information through social media “share” or “like” features on our Sites, or when you engage with our content on or through a social media platform such as LinkedIn, Facebook, and X/Twitter. If you disable these cookies, you may still see our ads on third-party websites or apps, but they will be less relevant to you.

Opting Out. You can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from accessing content in the Services. Please note that opting-out of cookies may require that you first accept cookies from a provider, because your opt-out preference may be stored in the form of a cookie. Likewise, when you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.com.

If you do not want to receive interest-based advertising, you may opt out by visiting www.aboutads.info/choices (US), https://youradchoices.ca/ (CAN), or https://www.youronlinechoices.com/ (Europe). If you opt out of interest-based advertising, you may still see ads that are less tailored for you as you browse the internet. Please note that we do not maintain or control the browser settings or third-party opt-out tools described here and are not responsible for their operation.

7. THIRD-PARTY WEBSITES AND SERVICES

Our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services. Should you decide to engage in such activities with such third-party, please note that such engagement is beyond the scope of Tipalti’s Privacy Policy and will therefore be covered by the third-party’s terms and privacy policy.

8. COMMUNICATIONS

We engage in service and promotional communications through e-mail, phone, and notifications within the Services.  

Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, payment issues, login attempts or password reset instructions. Our customers and their users may also send you notifications, messages and other updates regarding their or your use of the Services.  

Notifications and Promotional Communications: We and our authorized partners (e.g., event or webinar co-sponsors) may also notify you about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other third-party sites or platforms.

9. DATA SECURITY

We and our hosting services implement technical, organizational, and administrative systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

Regardless of our continuous efforts to protect your information, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, bugs, unlawful interceptions or access, or other kinds of abuse and misuse which may compromise your privacy. As the security of information depends in part on the security of the computer, device, or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

10. CHOICES AND DATA SUBJECT RIGHTS

We offer you certain choices regarding the collection, use, and disclosure of information about you.

Marketing communications. You can unsubscribe from marketing emails by following the directions in those emails. If you do not wish to receive promotional communications, you may also notify Tipalti at any time here, or by sending an e-mail to: opt-out@tipalti.com. Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding the Services, including, for example, notices of updates to our Website Terms of Use or this Privacy Policy.

Cookies and analytics. You can opt out of certain cookie-related and analytics processing by following the instructions in this Privacy Policy.

Rights to information about you. You may have other rights under applicable privacy laws. Depending on where you reside, you may have one or more of the following rights:

• The right to request information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting such information; and the categories of unaffiliated parties to whom we disclose such personal information. Such information is also set forth in this Privacy Policy.
• The right to access personal data held about you.
• The right to request that we rectify any personal data we hold that is inaccurate or misleading.
• The right to request the erasure/deletion of your personal data.
• The right to object, to or to request restriction, of certain processing activities, including for direct marketing.
• For California consumers, the right to opt out of, and limit the sale of and sharing of your personal data, and to limit the use and disclosure of “Sensitive Personal Information,” as that term is defined under the California Consumer Privacy Act.
• The right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller.
• The right to object to profiling.
• The right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law. You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

If you wish to exercise your privacy rights under any applicable law, please contact us by e-mail at: privacy@tipalti.com. If you provided personal information to a Tipalti customer and believe it is being processed by Tipalti on behalf of that customer, please make any requests or queries regarding personal data to that customer directly.

Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request). We may redact any personal data related to others from the data which we will make available to you.

Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of your request. If we cannot accommodate your request, then, as required by applicable law, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We may need certain information to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services. We will respond within 30 days upon receipt of your personal data request; if additional time is required to meet your request, we will notify you by mail or electronically of the reason and extension period, provided, however, such extension shall not exceed 45 days beyond the initial 30-day period.

We do not charge a fee to process or respond to your personal data request, unless it is excessive, repetitive, or manifestly unfounded.

Regional Privacy Disclosures and Rights. Additional disclosures for residents of the European Economic Area, United Kingdom, and California are set forth below in Regional Privacy Disclosures.

11. REGIONAL PRIVACY DISCLOSURES

Residents of the European Economic Area and United Kingdom

Tipalti is considered the “data controller” of the “personal data” (as defined under the General Data Protection Regulation) we handle under this Privacy Policy. In other words, Tipalti is responsible for deciding how to collect, use, and disclose personal data, subject to applicable law. The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing your personal data. To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments: We may use, share, or disclose personal data to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you.
• With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your consent.
• Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.
• Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

You may also have the right to lodge a complaint with an EU supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

Residents of California

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the California Consumer Privacy Act (“CCPA”), we must also provide you with the “categories” of personal information and sensitive personal information we collect and disclose for business or commercial purposes (as “categories” are defined by the CCPA).

The personal information that we may collect, or may have collected from consumers in the preceding twelve months, fall into the following categories established by the CCPA, as applicable, depending on how you engage with Tipalti:

• Identifiers, such as your name, alias, address, phone numbers, or IP address; 
• personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code, such as a driver’s license or state identification card number;
• characteristics of protected classifications under California or US federal law, such as age or gender, for example if we conduct due diligence and other identification checks;
• commercial information, such as purchase activity;
• Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with the Services;
• geolocation data, such as the location of your device or computer;
• audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
• professional or employment-related information, for example data you may provide about your business;
• inference data, such as information about your preferences; and
• education information, such as information about enrollment status, fields of study, or degrees, honors, and awards received.

The Sensitive Personal Information (as defined under the CCPA) that we may collect, or may have collected from consumers in the preceding twelve months is as follows: (1) copies of identification documentation, such as passports or driver’s licenses; and (2) Financial Account information, such as account number, transit and routing numbers and contact information related to banking details. We process the categories of personal information identified above for the purposes as described in more detail in the Data Uses section above.

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Services; and (3) other parties such as other users and through unaffiliated parties.

We describe our information disclosure practices in more detail in the Data Disclosure section above.

“Sale” and “sharing” of personal information

The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information. Where we refer to “sell” or “share” (or their variants) in quotes, we are referring to those terms as uniquely defined in the CCPA.

We may use third-party analytics services and online advertising services that may result in the “sharing” of online identifiers (e.g., cookie data, IP addresses, device identifiers, general location information, and usage information) with advertising partners to advertise the Services on other websites. If you or your authorized agent would like to opt out of our “sharing” of your information for such purposes, you may do so by clicking here.

We do not knowingly “sell” or “share” the personal information of children under 16. 

Do-Not-Track disclosure

We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

Retention of your personal information

Please see the Data Retention section above.

CCPA rights

California residents can make requests about their personal information as described as set forth in Choices and Data Subject Rights above. The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

For California consumers: For specific inquiries concerning California Privacy Laws, you must submit a Verifiable Consumer Request to Tipalti via email to Privacy@Tipalti.com and include all of the following information:

• Your relationship with Tipalti (payer, payee, or advertising recipient);
• The email address through which Tipalti communicates with you;
• The name you have registered with Tipalti or to whom Tipalti addresses communications with you;
• A contact phone number so Tipalti may call you in order to verify your identity; and
• Which rights you are exercising:
  • Your Right to Access your Data,
  • Your Right to limit use of your Sensitive Information, and/or
  • Your Right to Delete your Data.

12. ADDITIONAL INFORMATION AND CONTACT DETAILS

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Sites. The amended version will be effective as of the date it is published. Under certain circumstances (for example with certain material changes or where it is required by applicable privacy laws) we will provide additional notice of changes, such as through Email.

Our Services are not designed to attract children under the age of 18: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored by us about such child as required by applicable law. If you believe that we might have any such data, please contact us by e-mail at privacy@tipalti.com.

Questions, concerns or complaints: if you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Tipalti, you can contact our Data Protection Officer at privacy@tipalti.com. Alternatively, you can contact us at: Tipalti, 1051 E. Hillsdale Blvd, Foster City, CA 94404. If more convenient, you also can send us mail through our subsidiary Tipalti B.V., at Grote Bickersstraat 74-78, Amsterdam 1013KS Netherlands or our subsidiary Tipalti Europe Ltd, at 2nd Floor, St Martins Court, 10 Paternoster Row, London, EC4 7HP, United Kingdom.

Effective Date: March 10, 2025