Privacy Policy

This Privacy Notice applies to all ACHPC, LLC (along with its affiliates, successors, and assigns, “ACHPC”) websites, applications, promotions, products and services (collectively, the “ACHPC Service” or the “Service”), including all those that link to this Privacy Notice, and describes how ACHPC collects, uses, shares, transfers, stores, retains, or otherwise processes your personal information. This Privacy Notice also applies to any surveys, rewards, promotions, sweepstakes, contests, referrals, or other marketing activities conducted by ACHPC or in connection with the ACHPC Service (collectively “ACHPC Marketing”). This Privacy Notice does not apply to any third party website or service that ACHPC does not own or control. Capitalized terms not defined in this Privacy Notice have the meanings given to them in ACHPC’s Terms of Service. Please review this Privacy Notice carefully.

ACHPC will share your information only as described in this Privacy Notice, or as permitted by law. ACHPC will not sell, lease, rent, or trade your personal information to any third party for that party’s marketing or promotional purposes, unless you give your consent.

If you are an individual, or are acting on behalf of an individual, and obtained a ACHPC account primarily for personal family or household purposes, please read our Consumer Privacy Notice to understand our privacy practices and the privacy choices available to you.

By continuing to use the Service or participating in ACHPC Marketing after being provided with this Privacy Notice, you consent to ACHPC’s policies and practices as described herein.

Information we collect and the sources from which we collect it

ACHPC collects information about you from:

  • you;
  • your use of the Service or your participation in ACHPC Marketing; and
  • third parties.


Information that We Collect from You

Account information. When you sign up for a ACHPC account or register as a ACHPC User, we collect contact and identifying information about you, including but not limited to: your name; billing address; phone number; email; Tax Identification Number or Social Security Number (collectively, “TIN”); date of birth (natural persons); government-issued identification (natural persons); and Organization information, including company name and address, formation documents, business license, tax documents, phone number and business email address. We require you to choose a strong password, and may require you to provide device information to receive multi-factor authentication. We collect information from you when you use the Service, contact us for support, or provide us with feedback on the Service. As we introduce new products, services or features, we may collect new and different types of information from you when you use the Service or contact ACHPC in connection with your account.

US PATRIOT Act. To help the U.S. government fight the funding of terrorism and money laundering activities, federal and state law requires financial institutions, including money services businesses like ACHPC, to obtain, verify, and record information that identifies every customer. 

What this means for you: When you use the Service, we will ask you for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents, such as business related documents. We will let you know if additional information is required.

Financial information. When you use the ACHPC Service to make or receive payments, we collect certain financial information from you, such as bank routing and account information, including bank statements and verification of bank account ownership, and/or a credit or debit card to bill Service Fees. We may also collect information to verify financial condition and creditworthiness. 

Information about your Customers and Vendors. We may collect information from you about your Customers and Vendors, including but not limited to name, address, email address, phone number, TIN, and financial information, based on your use of the Service and payment instructions. 

Payment transaction information. When you request, make, receive, record, or otherwise process a payment through the ACHPC Service, we collect information about the payment transaction and the transacting parties, such as the date, time and location(s) of the transaction, identifying information of the sender and recipient, the payment or transfer amount(s), bank account information for the sender and/or recipient, a description of the transaction, and the Service Fees charged by ACHPC. 

Feedback. We collect information that you choose to provide to us in connection with your feedback about ACHPC or the ACHPC Service, including through your use of the ACHPC Service or your participation in ACHPC Marketing.

 

Online forms. We collect the information that you provide to us through online forms, including but not limited to forms on our Website or social media forms, such as ACHPC webinar sign-up forms or LinkedIn forms.

ACHPC marketing participant information. We collect the information that you provide voluntarily in connection with your participation in ACHPC Marketing, including but not limited to engagement at event booths, sweepstakes, contests, promotions, surveys, and referrals.

Importing your contacts. If you choose to import contacts from your email account, including to invite those contacts to use the Service, we will collect the username and password for the linked email account, as well as the contact information for your contacts. We will only use this information for the purposes for which it is shared by you.

Other. When you use the ACHPC Service or otherwise engage with ACHPC, even if you do not establish or use a ACHPC account, we may collect information about you, such as name, email address, phone, and mailing address. We may also collect information from you when you visit our Website.


Information We Collect from Your Use of the ACHPC Service

Device information. We collect information about your device when you install, access, or use the ACHPC Service on that device. The device information that we collect may include IP address, hardware model, operating system information, ACHPC app version, browser information, and mobile network. Your device may also allow us to collect and use information received through device-based settings, such as access to your contacts, camera, or photos, based on your settings.


Geolocation information
. When you use the Service, we collect the location of the device that you are using to access ACHPC.


How you interact with the ACHPC Services
. We collect information about how you access and use the Service, including but not limited to: your IP address; the domain name of the Internet Service Provider you use; and the date(s) and time(s) you access the Service; the pages you access and view; any term(s) you search; and the individual address of the device that you use to interact with the ACHPC Service. 


Information from third parties you choose to interact with through ACHPC
. We collect information about you from third parties with whom you interact through the ACHPC Service, including but not limited to your Vendors or Customers. We may also collect information about you from third party services that are supported by, or sync or integrate with the Service, including but not limited to third-party data entry services or accounting software providers. 


Information We Collect about You from Third Parties

Identify verification. We collect information about you from third parties as required and permitted by law, including but not limited to for purposes of verifying your identity and/or complying with anti-money laundering and anti-terrorism financing laws, “know your customer” regulations, and OFAC sanctions requirements. 


Compliance and fraud
. We collect information about you from third parties for purposes of fraud detection and prevention, in connection with certain types of investigations, or as otherwise permitted by law to ensure the safety and security of the Service. 


Address and Organization information
. We collect information about you or your Organization from commercially available sources to ensure your account information, for example your address, is accurate and up-to-date.


Marketing
. We collect information about current and prospective users of the Service from third party services, including but not limited to lead generation services and providers of customer and lead data, as well as enriched data about visitors to our Website, all as permitted by law.


How we use the information we collect

We use the information that we collect for purposes of:

  • providing the ACHPC Service, 
  • improving the Service,
  • maintaining the security of the Service and our network,
  • marketing our products and services (unless you choose to opt out), and 
  • as required or permitted by law. 


To Provide the ACHPC Service

Registering your account. When you create a ACHPC account or enroll as a ACHPC account User, we use the information that we collect about you, including any identifying information or financial information, for purposes related to the review, establishment, provision, administration, maintenance and monitoring of your ACHPC account or your use of the Service. We also use this information to verify your identity and your eligibility to use the ACHPC Service, and to comply with applicable law.


Providing our Service to you
. We use the information that we collect about you, together with information that you provide about your Customers and Vendors and the content that you upload to the Service, to provide the Service to you in accordance with your instructions and ACHPC account settings and elections. We also use your information to process payments requested by you and to provide you with transaction history and account information. 


Providing customer service and technical support
. We use your information, including your name, phone number, email address, account number, payment history and device information, to process and respond to your requests or inquiries, and to provide you with customer service, technical support, or software updates.


Communicating with you
. We will use your information to contact you about the Service or your ACHPC account, and to provide you with security, technical, support and administrative messages, including for purposes of multi-factor authentication. 


When contacting you by phone, we may use, and you consent to receive, as permitted by applicable law, informational autodialed calls and text messages, as described in our Terms of Service. If you wish to opt out of receiving autodialed calls or text messages from ACHPC, you can contact ACHPC Customer Support through our customer support portal. You understand that if you opt out of receiving informational autodialed calls or text messages, such as for multi-factor authentication, you may lose access to certain features and functionalities of the Service, including but not limited to the ability to request or send payments through the Service. ACHPC may, without further notice or warning and in its sole discretion, where permitted by law, monitor or record telephone conversations between ACHPC or its agents and you or anyone acting on your behalf, for quality control and training purposes or for ACHPC’s protection. While your communications with ACHPC may be overheard, monitored, or recorded, not all telephone lines or calls may be recorded by ACHPC, and ACHPC does not guarantee that recordings of any particular telephone calls will be retained or retrievable.


To Improve the ACHPC Service

Improving and developing the Service. We aggregate your information, including your payment transaction information and your feedback to ACHPC, with information from other ACHPC users and use that data to improve the Service, to develop new ACHPC products or features, and to enhance the quality of the Service. We use this information to provide you with a better experience, to administer the Service, to improve the quality and value of the Service, and to gather broad demographic information about how the Service is used.


Links to other websites or applications
. If you link to a third-party service, website or application through the Service, we may track whether the link has been followed to improve the quality of the Service and ACHPC’s partnership activities. This Privacy Notice does not apply to and we are not responsible for any third-party services, websites or applications that are not owned or controlled by ACHPC, including those that link to the ACHPC Service. To understand how third parties process and protect your information, we recommend that you review their privacy policies, terms of use, and websites.


To Maintain a Secure Environment

Protecting your account. We use the information we collect from you to prevent, detect, investigate, and report fraud or security incidents related to your use of the Service or your ACHPC account. We use your information to investigate any error, unauthorized transaction, or other fraud or security incident that we discover or that you report to us. 


Ensuring the reliability, safety and security of the Service
. We use the information that we collect to comply with and enforce our Terms of Service and all laws and regulations applicable to the Service. We use the information that we collect to secure and protect the integrity of our network, prevent unauthorized access to the Service, help diagnose and troubleshoot potential hardware malfunctions, and otherwise secure the Service.


Marketing and Promotional Purposes

Marketing and advertising. We use the information that we collect about you to market the Service to you, and to communicate with you about ACHPC products or features, or ACHPC Marketing, that may be of interest to you. If we send you a marketing email, we will provide you with information on opting out of future marketing emails or communications from us. If you opt out, we can continue to send you informational communications relating to the use of the ACHPC Service, such as transaction receipts or administrative messages about your ACHPC account. We may also use information about you for our marketing purposes, including to identify other similar prospective customers who may be interested in the Service.


Referrals
. If you refer another person to the ACHPC Service, we will collect a name and email address for the referral. We will use this information to send an email invitation to use ACHPC to the person you are referring. ACHPC may retain the referral information, but solely for the purpose of tracking the success of our referral program.

Sweepstakes, contests, and other promotions. We may use the information that you voluntarily provide in connection with a sweepstakes, contest or other promotion (“Promotion”) sponsored by ACHPC in accordance with the official rules for the Promotion.


As Required or Permitted by Law

We may use the information that we collect about you as required or permitted by law. Such uses include but are not limited to compliance with anti-money laundering and anti-terrorism financing laws, “know your customer” regulations, and OFAC sanctions requirements.


How we share the information that we collect

We share your information:

  • within the ACHPC corporate family,
  • with third parties that you authorize, 
  • with our partners and service providers, 
  • as required or permitted by law, and
  • with your consent.


With Third Parties That You Authorize

With other Users on your ACHPC account. If you are the Administrator for a ACHPC account, we will share your information with your Users in accordance with your account settings and preferences. If you are a ACHPC User, the account Administrator can access your information and change certain of your settings, and ACHPC may send information about your use of the Service to the Administrator.


With your authorized service providers
. If you sign up or authorize your accountant or another third party service provider to use or access the Service on your behalf or to use your ACHPC account, including by linking your ACHPC account to a Console, we will share your information with that authorized third party.


With third parties you choose to interact with through ACHPC
. We share your information with third parties that you choose to interact with through the ACHPC Service, including but not limited to your Vendors or Customers. We may also share your information with third party services that are supported by and integrate or sync with the Service, based on your choices and account settings, such third-party data entry services, accounting software providers, or social media sites that link to the Service. This Privacy Notice does not apply to collection, storage, or other processing of your information by third parties. The privacy practices of third parties, such as accounting software providers or social media sites, are governed solely by their privacy policies and terms of use. To understand how third parties process and protect your information, we recommend that you review their privacy policies, terms of use, and websites.


Fraud prevention
. We may share information about changes to your ACHPC account, such as changes to a bank account or to your address, with your Vendors or Customers for purposes of fraud prevention and detection.


With others on the ACHPC network, based on your choices
. Based on your profile visibility choices, we may share certain information about you with members of the ACHPC payment network. See Controlling your profile visibility for more information. The processing of your information by any other member of the ACHPC network with whom you choose to share your information, based on your profile settings, is governed solely by the privacy policy of the third party. 


With Our Third Party Service Providers and Partners

With our third-party service providers and business partners. We may share your information with our third-party service providers and business partners as needed to provide, maintain, support, secure, and improve the Service. Services provided to ACHPC by these third-party providers include, but are not limited to, identity verification, payment processing, fraud prevention, database management, data storage, web analytics, and marketing services. Our third-party service providers have access to your information only for the purposes of performing specific tasks on our behalf in compliance with our Terms of Service, and are obligated not to use or disclose your information for any other purpose or in any manner that is inconsistent with this Privacy Notice.


For example, ACHPC may use Plaid Technologies (“Plaid”) to gather certain information about you from financial institutions. By using the Service, you grant us and Plaid the right, power, and authority to access and transmit the information obtained about you from financial institutions for purposes related to the ACHPC Service. This Privacy Notice does not apply to collection, storage or other processing of your information by Plaid, which is governed by solely by the Plaid Privacy Policy. Another example is that if you access or use the Google Maps Platform (“Google Maps”) through the Service, your use of Google Maps is subject to Google’s Terms of Service and the Google Privacy Policy.


Aggregated and non-identifying information
. We share aggregated and anonymized information with third parties for industry and clickstream analysis, demographic profiling, and other purposes. Aggregated and anonymized information shared for these purposes will not contain personal information that can be associated with you.


As Required or Permitted by Law

As required by law. We will share your information with third parties as required by law. ACHPC cooperates with government, law enforcement, and private third party requests for information as we, in our sole discretion, determine is reasonably necessary to comply with any applicable law, regulation, government request or legal process, including but not limited to subpoenas. 


As permitted by law
. We may share your personal information as permitted by law, including, but not limited to, as we, in our sole discretion, believe necessary or appropriate to ensure the security and confidentiality of the Service, to prevent, detect or respond to fraud or security incidents, to respond to claims and legal process, to protect the property or rights of ACHPC or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. 


In connection with business transactions or corporate changes
. The information that we collect in connection with the Service is a business asset. As a result, we may share or transfer your information if we enter bankruptcy or are party to a business transaction, such as a merger, acquisition, reorganization, or asset sale. 


With Your Consent

We may share your information at your direction or with your consent.


How long we retain information

ACHPC will retain your information in accordance with our internal records retention and management policies and procedures, including as necessary to provide you with the Service or administer your ACHPC com account, or as long as necessary to comply with our legal obligations, resolve disputes, reserve our legal rights, and enforce our agreements.


How to cancel or make changes to your ACHPC account

You can update, correct, or restrict processing of the information associated with your ACHPC account at any time. You can make such changes through the Service, or you can request changes to your account information by contacting ACHPC Customer Support through our customer support portal. You understand that if you restrict processing of the information associated with your ACHPC account, you may lose access to certain features and functionalities of the Service, including but not limited to the ability to request or send payments through the Service.


You may cancel your ACHPC account at any time through the Service, or by contacting ACHPC Customer Support through our customer support portal. See our Terms of Service for more information on canceling your ACHPC account. After cancellation of your account, this Privacy Notice will continue to apply to any information collected about you by ACHPC.


Cookies and third party technologies

ACHPC and our third-party service providers set and use cookies and similar technologies to store and manage user preferences, enable content, gather analytic and usage data, and deliver targeted advertising. A cookie is a small text file that is placed on a computer or other device, and is used to identify the device and to collect information. 


Cookies are typically assigned to one of the following categories, depending on their function and intended purpose:

  • Essential cookies enable you to navigate our Website and to use the Service. Without these cookies, our Website will not perform as smoothly for you as we would like, and we may not be able to provide certain core functions and features.
  • Analytics cookies collect information about the use of our Website and application, and enable us to improve the way our Service works. For example, analytics cookies show us the most frequently visited pages and analyze site traffic. We use them to analyze broad trends and patterns of usage on our Website, rather than to monitor the usage of any particular individual.

    We use third-party service providers, including Google Analytics, to analyze the use of our Website. You can opt-out of the use of web analysis at any time either by downloading and installing a Browser Plugin offered by Google or by configuring your browser to delete and reject cookies.
  • Social Media cookies collect information about your visits to our Website, but only when you are logged in to your social media account(s).
  • Customer interaction cookies allow us to communicate with you, including for purposes of real-time communication through our chat feature.
  • Marketing cookies track browsing habits and are used to deliver targeted (interest-based) advertising. Most browsers are set up to accept cookies automatically. You can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Some browsers have “Do Not Track” features that allow you to tell websites not to track you. These features are not all uniform. ACHPC does not currently respond to “Do Not Track” signals.


Your choices and privacy rights

Controlling your profile visibility. When you create a ACHPC account, you will create an account profile. The settings that you choose for your profile will control how your profile information is shared within the ACHPC payment network or with the public. See Network Profile Visibility Settings for details about your profile visibility options.


Updating your account information
. You can access, update, change, or correct your account information at any time by accessing your profile through the Service or by contacting ACHPC Customer Support through our customer support portal. You can also change your email preferences through your ACHPC account profile settings at any time.


Managing marketing communications from us
. We will honor any request from you to opt out of receiving marketing communications, including emails and text messages. 

  • To opt out of receiving marketing emails from ACHPC, click the “unsubscribe” link at the bottom of a ACHPC marketing email. 
  • For marketing text (SMS) messages, reply “STOP” or follow the instructions in the message.


Please note that, even if you choose not to receive marketing communications from ACHPC, we can continue to send you informational communications related to your use of the Service or your ACHPC account.


Device settings
. The device that you use to interact with the Service may have setting options that can be enabled or disabled to allow the ACHPC Service to access and use certain information and features on your device, such as mobile app push notifications, your contacts, camera, or photos. You can adjust your device setting if you do not want ACHPC or the Service to have access to this information or these features. You can also adjust your device or browser settings to block or provide notice of Cookies on your browser or mobile device. Please note, however, that disabling or limiting certain cookie settings on your device or browser may prevent you from interacting with some or all of the features of the Service, or may require you to do additional authentication. Learn more about cookies here


Opting out of targeted online ads. We use cookies to gather information about your activities in order to provide you with targeted advertising based on your online activity and interests. You can opt out of receiving targeted ads by visiting the Digital Advertising Alliance’s opt-out page. Learn more here. You can also opt out of targeted advertising on the following channels using the included links: TwitterFacebookLinkedInGoogleBing.


If you sync or connect your ACHPC account with third party services
. If you choose to sync or connect your ACHPC account with third-party services, such as accounting software services or social media sites, we will share your information with the third-party service provider. If you do not want us to share your information with these third parties, you can choose not to sync or connect your ACHPC account with the third party service.


Community forums
. ACHPC may offer blogs and publicly accessible community forums. You should be aware that any information you provide in these forums may be read, collected, and used by others who access them. To request removal of your information from a blog or community forum, contact ACHPC Customer Support through our customer support portal.


Supplemental privacy notice
. Residents of some states and countries have additional privacy rights. Information on these rights are provided in the following supplemental privacy notices:


How we protect the security of your information

ACHPC is committed to protecting the security and privacy of your information. ACHPC recognizes the importance and confidentiality of your information. We have implemented technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, use, and modification. ACHPC maintains industry standard attestations and has formal SSAE18 SOC1, SOC2 and SOC3 attestation reports. Please be aware however that no security measures are perfect or impenetrable.


Notices to consumers

ACHPC’s E-SIGN Disclosure and Consent

Consumer Privacy Notice


Information for children under the age of 18

Persons under the age of 18 year are not eligible to use, access or otherwise interact with ACHPC or the Service. If we become aware that a child under the age of 18 has created an account with us or is otherwise using the Service, we will take steps to remove access, disable the account, and delete any information related to the child as soon as reasonably possible.


Updates to this Privacy Notice

This Privacy Notice may be updated periodically and will be posted on the Website, indicating when it was last updated. If there are material changes to our Privacy Notice, we will post a notice on our website and/or provide other notice as required by law. If you object to any changes to this Privacy Notice, you can cancel your account at any time.


California Consumer Privacy Act

This Supplemental Privacy Notice applies to you only if you are a natural person and a California resident (as defined under California law). This Supplemental Privacy Notice is incorporated into and forms part of the ACHPC Privacy Notice.


The California Consumer Privacy Act of 2018 (CCPA), as amended, requires ACHPC to describe how we collect, process, and share your personal information. This Supplemental Privacy Notice is designed to help you understand the categories of personal information that we collect about you, where we get that personal information, who we share it with, and the rights you have to know and control your personal information.


This Supplemental Privacy Notice does not apply to any employees, owners, directors, officers, or contractors of ACHPC or its affiliates.


ACHPC DOES NOT SELL YOUR PERSONAL INFORMATION
.

General Information. To understand all of the rights granted to covered California consumers under the CCPA, please review the California State Attorney General’s CCPA Fact Sheet, available at https://oag.ca.gov/privacy/ccpa.


Exercising Your Rights
. Subject to the exceptions and limitations described below, you have the following rights under the CCPA with respect to the personal information that ACHPC collects about you:

  1. Right to Know. You have the right to request that we give you information about our collection, use, and sharing of your personal information over the prior 12 months. If you want to exercise this Right to Know, you can submit a Request to Know by email. We will confirm receipt of your Request to Know within 10 days. If you do not receive a confirmation of receipt within 10 days, we may not have received your Request to Know and you should re-submit it. We may take up to 90 days to respond to your Request to Know.

    Once we receive your Request to Know and verify your identity, we will disclose to you the following information for the 12 months prior to the date on which we received your Request:

    • The categories of personal information we collected about you.
    • The categories of sources from which we collected your personal information.
    • Our business and commercial purpose(s) for collecting your personal information.
    • The categories of service providers or third parties with whom we share your personal information.
    • The specific pieces of personal information we collected about you, to the extent permitted by law. We can never share, even with you, your Social Security number, government-issued identification number(s), health or medical information, financial account number(s), password, or security questions and answers.


We reserve the right to deny your Request to Know, in whole or in part, if we cannot verify your identity or if responding to your Request would create a substantial security risk. If we deny your Request to Know, we will inform you and will provide the basis of the denial.

  1. Right to Delete. Subject to the exceptions described below, you have the right to tell us to delete the personal information that we have collected from you. If you want to exercise this Right to Delete, you can submit a Request to Delete by email your request by initiating a chat with our Support Team. We will confirm receipt of your Request to Delete within 10 days. If you do not receive a confirmation of receipt within 10 days, we may not have received your Request to Delete and you should re-submit it. We may take up to 90 days to respond to your Request to Delete.

    Please note that, under the CCPA, we will not delete personal information that we have collected from you if we need to maintain that personal information in order to:

    • Complete a transaction that you requested, or provide our Service to you;
    • Reasonably maintain our ongoing relationship with you;
    • Perform a contract between ACHPC and you;
    • Detect security incidents;
    • Protect you, ACHPC or others against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity;
    • Debug to identify and repair errors that impair the functioning of our Service or internal systems;
    • Perform internal uses or operations that are reasonably aligned with your expectations based on our business relationship;
    • Comply with a legal obligation; or
    • Otherwise perform internal uses or operations in a lawful manner compatible with the context in which we collected your personal information, including as needed to protect our legal rights.



Once we receive your Request to Delete and verify your identity, we will delete your personal information from our records, unless one of the exceptions listed above applies. In that case, we will notify you that your Request to Delete is denied, in whole or in part, and we will identify the applicable exception(s).


We may delete your personal information by any of the following means:

    • Permanently and completely erasing the personal information from our systems;
    • De-identifying the personal information so that it cannot reasonably be linked or identified to you; and/or
    • Aggregating the personal information such that individual consumer identities have been removed.


We will specify the means used to delete your personal information in our response to you. Please note that if your personal information is stored on an archived or backup system, we are not required to delete your personal information from that system until the next time we use or access the system.


We reserve the right to deny, in whole or in part, your Request to Delete if we cannot verify your identity. If we deny your Request to Delete, we will inform you and will provide the basis of the denial.

  1. Right to Opt out of Sale of Your Personal Information. If a business sells consumer personal information, the CCPA grants consumers a right to tell a business not to sell (i.e., opt out of the sale of) their personal information. ACHPC does not sell your personal information. For clarity, ACHPC does not permit persons under the age of 18 years old to use our Service, and we do not collect personal information from any person under the age of 16 years.
  2. Right Against Discrimination. We will not discriminate against you for exercising your rights under the CCPA. We will not:

    • Deny you goods or services for exercising your rights;
    • Charge you a different price or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, because you exercised your rights;
    • Provide you a different level or quality of goods or services because you exercised your rights; or
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services as a result of exercising your rights.
    •  
  1. Verifying Your Identity. When you submit a Request to Know or a Request to Delete, we must verify your identity. If you are a ACHPC account holder, we will ask you to verify your identity by logging in to your account. To verify identity, we may ask you for additional information, including by asking you to confirm other personal information you have provided to us. We reserve the right to deny your Request to Know or a Request to Delete if we cannot reasonably verify your identity.
  2. Requests from Authorized Agents. If you have authorized another person to make a Request to Know or a Request to Delete on your behalf, that person must provide to us your written authorization allowing them to make such a request on your behalf.  We reserve the right to deny a Request to Know or a Request to Delete by an authorized agent if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor.