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DOXO PRIVACY AND SECURITY POLICY

Version 1.2
Effective date: July 24, 2020

doxo is designed for doxo users to pay their bills, organize Provider accounts;
manage personal account information, reminders, and documents; and establish
connections with Providers to receive documents paperlessly, all in one place.

doxo is committed to maintaining the confidentiality, integrity and security of
any and all personal information about doxo users. This Privacy and Security
Policy (the “Policy”) explains how doxo protects information provided through
our websites www.doxo.com, secure.doxo.com, pay.doxo.com, and user.doxo.com and
applications accessing those websites (the “Site”) and how doxo uses that
information in connection with the doxo service offered through the Site (the
“Service”). “Private Information” for purposes of this Policy means information
provided to us that identifies you, such as your name, address, phone number,
email address, any account information or other information you store about your
relationship with your Providers, and any documents and accompanying information
that are stored on your behalf by doxo. doxo privacy standards are designed to
guard against identity theft, to protect sensitive data, and provide security
for your Private Information. doxo regularly re-evaluates privacy and security
policies and adapts them as necessary to deal with new challenges. Capitalized
terms used by not defined in this Policy will have the meanings defined in the
doxo User Terms of Service


1. YOUR PRIVATE INFORMATION IS NOT FOR SALE

Simply put, doxo will not sell or rent your Private Information to anyone, for
any reason, at any time. doxo uses and discloses your Private Information only
as follows:

 * to deliver and post your payments to Providers;
 * to analyze Site usage and improve the Service;
 * to deliver to you any administrative notices, alerts and communications
   relevant to your use of the Service;
 * for market research, project planning, troubleshooting problems, detecting
   and protecting against error, fraud or other criminal activity;
 * to third-party contractors that provide services to doxo and are bound by
   privacy restrictions at least as protective as this Policy (e.g. auditors,
   technical consultants);
 * to enforce the doxo User Terms of Service; and as otherwise set forth in this
   Policy.


2. WHAT INFORMATION DOXO COLLECTS AND STORES FOR YOU

Certain areas and features of the Site are available to you without registration
or the need to provide doxo any information. However, other features of the Site
or the Service require registration, which may involve provision to doxo of an
email address, a password and your zip code (collectively the “Registration
Information”). In order to benefit from the full functionality of the Service,
you may be required to provide additional information:

 * if you choose to establish a “connection” with a Provider on doxo (“Connect”
   or “Connection”) and/or if you choose to make a payment on doxo, you also may
   be required to provide your account credentials for those Providers (“Account
   Credentials”). When you submit Account Credentials for a Provider within the
   Service, you elect to share certain information from your doxo user profile
   with that Provider or other information (“Account Information”), and any
   Account Information or documents you exchange with that Provider will be
   accessible to that Provider.

doxo may de-identify or aggregate Private Information and use and disclose such
data only in a non-personally identifiable manner to:

 * improve the design, functionality and content of the Service;
 * to enable Providers to improve their use of the Service and to benefit their
   customers through the Service;
 * to provide reports and analysis that may benefit doxo users or Providers; or
 * to develop products and services that might interest doxo users and
   Providers.

Such information does not identify you individually. To verify the identity of
users and/or detect patterns of activity that may indicate or help prevent
fraud, our Service may utilize fraud prevention services and methods designed to
protect payment account information or other Private Information from being used
in a fraudulent manner through the Service. These methods utilized include use
of Sift Science’s anti-fraud service. Sift Science can use your Private
Information in accordance with their privacy policy on their website at
siftscience.com. doxo personnel (including employees, agents or contractors) may
need to access your Private Information in accordance with this Privacy Policy,
including to provide support or for security, fraud, or other problems involving
your account. Any such access is only conducted to the extent necessary. Any
personnel that conduct such activity have been selected in accordance with doxo
security policies and practices and are bound by confidentiality obligations.
They are subject to discipline, including termination, if they fail to meet the
standards of these policies and practices.


3. CHANGES TO THE INFORMATION DOXO COLLECTS

If your Registration Information or any other information stored in doxo
changes, you may update it any time by logging into the Service and editing the
information online via your account.


4. TECHNOLOGIES DOXO USES TO OPTIMIZE YOUR EXPERIENCE

When you visit the Site, doxo may collect session activity (including replay
activity) and technical and navigational information, such as computer browser
type, Internet Protocol address, pages visited, and average time spent on the
doxo Site and store it in log files. This information does not include
information such as payment card number or financial information and may be
used, for example, to alert you to software compatibility issues, to ensure
successful payment delivery, optimize the user experience, and assist in
customer support requests, or it may be analyzed to improve the design and
functionality of the Site or Service.

We may combine this automatically collected log information with other
information we collect about you. We do this to provide customer support to you,
and to improve the quality and functionality of the Service we offer to you.
Technologies such as: cookies, beacons, tags and scripts are used by doxo and
our analytics or service providers (e.g. online customer support provider).
These technologies are used in analyzing trends, administering the Site,
tracking users’ movements around the Site and to gather demographic information
about our user base as a whole. We may receive reports based on the use of these
technologies by these companies on an individual as well as aggregated basis.

We use cookies for authentication and personalization of the Service. Users can
control the use of cookies at the individual browser level. If you reject
cookies, you may still use our Site, but your ability to use some features or
areas of our Site may be limited. doxo may use third party service providers to
help doxo analyze certain online activities. For example, these service
providers may help doxo measure the performance of doxo online campaigns or
analyze visitor activity on the Site. doxo may permit these service providers to
use cookies and other technologies to perform these services for doxo. doxo does
not share any Private Information about doxo customers with these third party
analytics service providers, and these service providers do not collect such
information on behalf of doxo. doxo third party service providers are required
to comply fully with this Policy.


5. HOW WE SHARE INFORMATION WITH 3RD PARTIES

doxo does not share your Private Information with third parties for their
promotional or marketing purposes. doxo may share your Private Information with
third party service providers who assist doxo in providing Service to you or who
provide fraud detection or similar services on doxo’s or any vendor’s behalf.
doxo has contracts with these service providers that only allow them to use your
Private Information in connection with the services they perform for doxo and
not for their own benefit.

In addition, there are a number of features of doxo that are dependent on you
making a Connection with your Providers. If you choose to use these features,
you will be asked to disclose information about your relationship with that
Provider to the Provider. You should evaluate the practices of Providers before
deciding to provide them information and Connect with them on doxo. doxo is not
responsible for their privacy practices. doxo may also share Private Information
with the applicable Provider as necessary to fix security, fraud, or other
problems. Any information you share with your Providers is up to you. It may be
information that is already known by that Provider as part of your existing
relationship with them. Any additional information beyond that which is used to
establish a Connection with the Provider will only be shared with and used by
doxo to optimize your relationship with that Provider. If you click on a link to
a third-party site, doxo encourages you to check the privacy policy of that
site. doxo may present links in a format that enables doxo to keep track of
whether these links have been followed and whether any action has been taken on
a third party Web site. doxo uses this information to improve the quality of the
doxo Service.


6. DISCLOSURE OF INFORMATION WHEN REQUIRED BY LAW

Notwithstanding anything to the contrary in this Policy, doxo reserves the right
(and you hereby authorize doxo) to share and disclose your Private Information
when doxo determines, in its sole discretion, that the disclosure of such
information is necessary or appropriate:

 * To enforce doxo’s rights against you or in connection with a breach by you of
   this Policy or the doxo User Terms of Service;
 * To prevent prohibited or illegal activities; or
 * When required by any applicable law, rule regulation, court order, warrant,
   subpoena or other legal process.

In such an event, if permitted by law, doxo will make reasonable efforts to
notify you and give you the opportunity to seek a protective order. If doxo is
involved in a merger, acquisition, or sale of all or a portion of its assets,
you will be notified via email and/or a prominent notice on our Web site
(www.doxo.com) of any change in ownership or uses of your Private Information,
as well as any choices you may have regarding your Private Information. Should
such a change occur, doxo will require that the new entity follow this Policy
with respect to your Private Information. If your Private Information could be
used contrary to this Policy, you will receive prior notice and the opportunity
to communicate preferences you may have, if applicable.


7. YOU HAVE COMPLETE CONTROL OVER YOUR DATA

Your data is yours. You can remove it anytime you want. We will retain your
information for as long as your account is active or as needed to provide the
Service to you. If you wish to cancel your account or request that we no longer
use your information to provide the Service to you, you may close your account
using the settings menus, and if you have questions you may contact us at
support.doxo.com. We, and our service providers, will retain and use your
information as necessary to comply with our legal obligations, resolve disputes,
and enforce our agreements. When you request doxo to delete your doxo account,
your data will be permanently expunged from doxo’s primary production servers
and further access to your account will not be possible. doxo will also promptly
disconnect any Connection between you and Providers on the Service. All
Providers that you were Connected to will be notified that you no longer choose
to be Connected via doxo and it is up to each Provider to begin communications
via alternative means (for example, begin sending documents to you via US Mail
instead of doxo). It is the responsibility of the Provider to take action and
facilitate communication with you through the appropriate channel. doxo may also
retain aggregated or de-identified data derived from your Account Information
indefinitely. Your information may also remain on a backup server or media. If
your Private Information changes, or if you no longer wish to use the Service,
you may correct, update or delete inaccuracies by making the change within your
account and you can request assistance by visiting us at support.doxo.com.


8. EMAIL COMMUNICATIONS FROM DOXO

doxo provides you with periodic summaries of your account and email alerts for
certain events having to do with your doxo account – for example, when a
Connection with a Provider has been accepted or declined, a Provider we believe
you might have a relationship with has joined the doxo network, a new document
from a Provider is received, information about payments, when a bill is coming
due, or if new product features have become available to you. You have the
ability to opt-out of receiving some emails via settings in doxo or by clicking
the unsubscribe mechanism in the email doxo sends you


9. YOUR DATA IS ACCESSIBLE ONLY BY YOU

doxo uses a combination of firewall barriers, encryption techniques and
authentication procedures, among others, designed to maintain the security of
your online session and to protect doxo accounts and systems from unauthorized
access. When you register for the Service, doxo requires a password from you for
your privacy and security. doxo servers are operated in highly secure
facilities. Access requires multiple levels of authentication, including
biometrics (hand print scan) procedures. Security personnel monitor the
facilities 7 days a week, 24 hours a day. doxo databases are protected from
general employee access both physically and logically. doxo encrypts your
Service password so that your password cannot be recovered, even by doxo. All
backup drives and tapes also are encrypted. All Private Information (including
any documents stored on your behalf) is always encrypted with 256 bit encryption
or better, and is only viewable by you after entering your login credentials. No
employee may put any sensitive content on any insecure machine (i.e., nothing
can be taken from the database and put on an insecure laptop). doxo tests the
Site daily for any failure points that would allow hacking. However, it is
important to understand that these precautions apply only to the Site and doxo
systems. doxo exercises no control over how your information is stored,
maintained or displayed by you, third parties or on third-party sites. No method
of transmission over the Internet, or method of electronic storage, is 100%
secure. Therefore, we cannot guarantee absolute security


10. DOXO USES HIGHLY SECURE COMMUNICATIONS

From the time you submit your login credentials, the communications between your
computer and doxo are encrypted using industry-standard 128 bit TLS 1.1 or
higher technology or better. TLS enables client and server applications to
communicate in a way that is designed to prevent eavesdropping, tampering and
message forgery. Any data transmitted between one of your Providers and doxo
(e.g. when establishing a Connection or sending and receiving documents from the
Provider) is secured using TLS and encrypted in transport between the Provider
and doxo.


11. YOU ARE RESPONSIBLE FOR PROTECTING YOUR ACCESS CREDENTIALS

doxo maintains strict rules to help prevent others from guessing your password.
doxo also recommends that you change your password periodically. You are
responsible for maintaining the security of your doxo user name and password.
You are specifically restricted from providing these credentials to any third
party. If you believe that they have been stolen or been made known to others,
you must contact doxo immediately at security@doxo.com and change your password
immediately via the Service. doxo is not responsible if someone else accesses
your account through Registration Information they have obtained from you or
through a violation by you of this Policy or the doxo User Terms of Service.

If you have a security related concern, please contact doxo at
security@doxo.com. doxo will work closely with you to ensure a rapid and
personal response to your concerns. Our Site may offer publicly accessible blogs
or community forums. You should be aware that any information you provide in
these areas may be read, collected and used by others who access them. To
request removal of your Private Information from our blog or community forums,
contact us at security@doxo.com. In some cases, we may not be able to remove
your Private Information, in which case we will let you know if we are unable to
do so and why.


12. DOXO POSTS UPDATES TO THIS POLICY FROM TIME TO TIME

doxo reserves the right to modify this Policy at any time, so please review it
frequently. If doxo makes material changes to this Policy, doxo will notify you
here, by email, by means of a notice to the doxo home page, or via a
notification in your doxo account prior to the change becoming effective. The
date last revised appears at the top of the Policy.


13. CONTACT DOXO IF YOU HAVE QUESTIONS OR CONCERNS

If you have questions, comments, concerns or feedback regarding this Policy or
any other privacy or security concern, send an e-mail to security@doxo.com. Doxo
Inc. 1420 5th Avenue, 22nd Floor #524, Seattle, WA 98101.


14. YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to
residents of California. This section of the Policy applies if you are a natural
person who is a resident of California (“California Consumer”) and uses our
Service. This notice supplements the information in the Policy with respect to
California Consumers. Certain terms used below have the meanings given to them
in the CCPA. We collect and disclose the following categories of personal
information as indicated below:

Collected Disclosed A. Identifiers such as a real name, alias, postal address,
telephone or mobile contact number, unique personal identifier, online
identifier, Internet Protocol address, email address and account name. Yes Yes
B. Personal information as defined in the California customer records law, such
as name, contact information, and financial information. Yes Yes C.
Characteristics of protected classifications under California or federal law,
such as gender and date of birth. Yes No D. Commercial information, such as
transaction information, purchase history, financial details and payment
information. Yes Yes E. Biometric information, such as fingerprints and
voiceprints. No No F. Internet or other electronic network activity information,
such as browsing history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems and
advertisements. Yes Yes G. Geolocation data, such as device location. No No H.
Audio, electronic, visual and similar information, such as images and audio,
video or call recordings created in connection with our business activities. Yes
No I. Professional or employment-related information, such as job title as well
as work history and experience. No No J. Education information subject to the
federal Family Educational Rights and Privacy Act, such as student records. No
No K. Inferences drawn from any of the personal information listed above to
create a profile or summary about, for example, an individual’s preferences and
characteristics. Yes No

We collect this personal information from you and from other categories of
sources such as: public and publicly available sources; our vendors, data
suppliers, and service providers; and partners with which we may offer
co-branded services or engage in joint event or marketing activities.

We share this personal information with: our service providers; the
administrators authorized by Providers with whom you Connect and/or pay, and
other parties where required by law or to protect our rights. For more details,
please see Section 5 (How we share information with 3rd parties) and Section 6
(Disclosure of information when required by law) of this Policy.

We may use this personal information to: operate, manage, and maintain our
business, to provide our products and services, to communicate with you, for our
vendor management purposes, and to accomplish our business purposes and
objectives, including, for example, using personal information to: develop,
improve, repair, and maintain our products and services; process or fulfill a
request or other transactions submitted to us; personalize our products and
services; provide customer support; conduct research, analytics, and data
analysis; undertake quality and safety assurance measures; conduct risk and
security control and monitoring; detect and prevent fraud; perform identity
verification; perform accounting, audit, and other internal functions; comply
with law, legal process, and internal policies; maintain records; exercise and
defend legal claims; and fulfill legal obligations.

Doxo does not sell personal information to third parties within the scope of the
application of the CCPA.

California Privacy Rights

California residents have the right to request:

 * The categories of personal information we collect, along with the categories
   of sources from which we collect such information, the categories of third
   parties to whom we disclose it, and the business purposes for such
   disclosure;
 * The specific pieces of information we have collected about you;
 * Deletion of certain personal information we have collected from you; and
 * To opt-out of the sale of your personal information, to the extent that such
   sales occur.

We will not deny, charge different prices for, or provide a different level of
quality of services if you choose to exercise these rights. Note that each of
these rights is subject to certain restrictions and exceptions under California
law; for example, we may need to retain certain information for record keeping
or legal purposes.

California residents may exercise their California privacy rights by submitting
a request via one of the methods in the “How to Contact Us” section. You also
have the right to designate an agent to exercise these rights on your behalf.

For security purposes, we will verify your identity – in part by verifying your
email account or requesting certain information from you – when you request to
exercise your California privacy rights. Once we have verified your identity
(and your agent, as applicable), we will respond to your request as appropriate.
Consistent with California law, we do not disclose government IDs or financial
account numbers.

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right
under certain circumstances to request information regarding the manner in which
we share certain categories of Personal Information (as defined in the Shine the
Light law) with third parties for their direct marketing purposes. We do not
share your Personal Information with third parties for their own direct
marketing purposes.

DOXOPLUS: 5 PROTECTIONS

 * Private Pay™ Protection
 * Identity Theft Protection
 * Overdraft Protection
 * Late Fee Protection
 * Credit Score Protection

DOXO NETWORK: ONLINE BILL PAY

 * Alarm & Security Bills
 * Healthcare Bills
 * Home Service Bills
 * Insurance Bills
 * Loan & Credit Card Bills
 * Mobile Phone Bills
 * Mortgage Bills
 * Phone, TV & Internet Bills
 * Toll Roads & Travel Bills
 * Utility Bills

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