Privacy Policy

Last modified: November 16, 2021

Routable, Inc. (“Routable”, “we” or “us”) is committed to protecting your privacy.. This Privacy Policy explains how Routable collects, uses, and shares the Personal Information we collect from visitors to our website (“Website”) as a data controller. For information about how we collect and use information (“Customer Data”) collected from our Customers during the provision of our service (the “Routable Services”), please see “Customer Data,” section below. By accessing or using the Routable Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy and our Terms of Service. This policy does not apply to personal information that has been aggregated and anonymized where such information is no longer capable of identifying a specific individual. 

1. About Us

We are Routable, a company headquartered in San Francisco, California.  Routable helps companies speed up their business payments using a secure invoice and bill payment platform. We provide a hosted platform and related tools, including the Routable web and mobile applications (the "Routable Services"), that help individuals and organizations across the globe to more effectively manage bill payments, payouts, and invoicing by reducing manual intervention and providing scalable flexibility.  If you are resident in the European Economic Areas ("EEA"), UK or Switzerland, the controller of Customer Data submitted through the service is the Customer and Routable is a processor. For information or data that is not Customer Data but which contains Personal Information that we process in accordance with this policy, Routable is a data controller. 

2. Routable as a Service Provider

Routable “Customers” are organizations or individuals who use the Routable Services to help them manage bill payments, payouts, and invoicing.  Routable processes Personal Information in these services only according to our Customer's instructions (as defined in our Terms of Service and the Data Protection Addendum). If you have questions about Personal Information you have entered into the Routable Services as Customer Data, or want to exercise any of your rights regarding such Personal Information, our Customer contract requires that we redirect your inquiry back to that Customer.  Except for the “Customer Data” section below, this Privacy Policy does not apply to the Personal Information we process as a service provider or processor on behalf of our Customers.  Routable does not sell any personal information it collects. Routable is not responsible for the privacy or security practices of our Customers, which may differ from those set out in this Privacy Policy. Please review the relevant Customer's privacy policy to understand more about their data processing activities.

3. How we Collect and Use Personal Information

We collect Personal Information from our website visitors in order to provide you with a personalized, useful and efficient experience. The categories of information,  we collect can include:Information that you provide to us. We collect business information when you register for an account or purchase our Routable Services. We may also collect any information, data or communications that you exchange with us.Information we receive from social networking sites. When you interact with our site through various social media, such as when you login through Facebook, or share Routable content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Routable Services.Information from other sources. We may obtain information from other sources, such as third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined Personal Information. We use this information to operate, maintain, and provide to you the features and functionality of the Routable Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Routable Services, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.Cookies and Tracking Technology. We, and our third party partners, automatically collect certain types of usage information when you visit our Sites, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our site, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the sits, whether you open emails or click the links contained in emails, whether you access the Sites from multiple devices, and other actions you take on the Sites. When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Routable Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Sites, as some features and services on our Sites may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered. We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below. For individuals located in the EU, UK, and Switzerland, we will ask for your consent prior to placing an LSO on your device. You can withdraw your consent at any time by contacting privacy@routable.com 

4. Processing Purpose, Use, and Legal Basis. 

Routable processes and may share the above referenced information with third parties for the following purposes on the on the legal basis of its legitimate interest: To analyze trends, update our records, promote events, engage in direct marketing, improve and personalize our marketing activities and websites, administer our websites and guarantee their security and continued proper functioning, track your movements around the website and to gather non-identifiable, demographic information about our user base as a whole, review compliance with applicable usage terms, provide necessary functionality, complete transactions, handle support requests, comply with legal obligations, improve the performance of our Routable Services, facilitate the provision of our Routable Services, and other business purposes including fraud prevention and product development. We may process your Personal Information for other purposes about which we notify you in advance, or for which we receive your consent. We may link automatically-collected data to Personal Information you have provided, we have received from third parties, or to other publicly available information hosted on the internet, so that we can better gauge our website visitors’ needs and provide specific information to best serve them.

5. How We Share Personal Information

Routable will not share Personal Information, or otherwise make your Personal Information available to any other parties except as provided in this Privacy Policy. We share the categories of information identified in Section 1 with the following categories of third parties: Event Co-Sponsors/Partners: If you sign up for an event or content that is co-hosted by Routable and one of its partners or co-sponsors, your  Personal Information may be shared with that partner or co-sponsor. Please see our partner or co-sponsors’ privacy policies for further information about how they use Personal Information.Legal or Regulatory Bodies and Agencies: Routable may share your information in order to respond to investigations, court orders, legal processes, or to investigate prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of Routable’s Terms of Service, or as otherwise required by law. If Routable is required by law or an order of a court of competent jurisdiction to disclose your information, Routable will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.Service Providers: In order to provide our websites and undertake our marketing and business activities, it may be necessary for us to disclose your information to contracted third parties and service provider partners who perform certain functions on our behalf.  Examples include payment providers (to authorize, record, settle and clear payment card transactions); cloud hosting providers (to provide data storage and processing services); communications providers (to process new queries and to manage our emails); and analytics companies to perform analysis. These third-party service providers or vendors may use data we provide to them only as instructed by Routable.Business Transfers: If Routable is involved in a merger, acquisition, or sale of all or apportion of its assets, Personal Information may be transferred to the acquiring person or entity, in which case you will be notified via email and/or a prominent notice on our website of any such change in ownership or uses of Personal Information, as well as any choices you may have regarding Personal Information.‍Advertising Partners: We may partner with third party advertising networks, exchanges and social media platforms to display advertising on our websites or to manage and service advertising on other sites and we may share Personal Information with them for this purpose. Please see the section above  "Cookies and Other Similar Technology"  for further information.Affiliates. We may share with other companies and brands owned or controlled by Routable, and other companies owned by or under common ownership as Routable, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your Personal Information in the same way as we can under this Policy.For further information on your choices regarding your information, see “Control Over Your Information.”

6. Customer Data

In providing our Routable Services, our Customers may upload data to our Routable Services, which may include the following categories of Personal Information or data(all of which we call “Customer Data”):

•  Information that you provide to us when you set up an account with us, use our Routable Services, or communicate with us. For example, we may request your “Personal Information” for account registration and onboarding purposes (E.g., name, postal address, email address, data of birth, telephone number, social security number, and account information);

• Business information (such as your name, job title, the person you report to, phone number, email address and country);

• Financial Information such as bank account and routing numbers, statements, and other financial information necessary to provide the Routable services. 

• Personal information that you provide to us or that is collected on behalf of our customer as it relates to payment (E.g., );

• Marketing information (such as your contact preferences);

• Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User/ team ID assigned to you in our systems);

• Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with Routable, and the product or service you are using related to your help inquiry); and

• Billing information (including your credit card numbers and associated identifiers, billing address and background information, but only where you pay for the Routable Services).

• Log and usage data, which is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use the Routable Services and which we record in log files. This log data may include the Internet Protocol (IP) address, device information, browser type and settings and information about your activity in the Routable Services (such as the date/ time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you use)), device event information (such as system activity, error reports and hardware settings).

• Location data, such as information about your device's location, which can be either precise or imprecise. How much of this information we collect depends on the type and settings of the device you use to access the Routable Services.  For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).  You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Routable Services.

Routable as Processor, Purpose and Legal Basis.Customer Data is owned and controlled by our Customers and processed by Routable, a data processor, in accordance with our DPA. Customer Data that we maintain or process we consider to be strictly confidential. We process Customer Data to the extent that it is necessary and for the purpose of performing a contract to provide our Routable Services to Customers, and otherwise in our legitimate interest in improving our products and Routable Services and providing customer support. We collect and process Customer Data solely on behalf of our Customers, and in accordance with our Customer’s written instructions. Specifically, we process Customer Data for the following purposes on the basis of our legitimate interest or to perform our Customer Contracts:

• Provide the Routable Services

• Maintain the security of the Routable Services;

• Provide necessary functionality;

• Support, improve performance of the Routable Services or to Secure the Routable Services;

• Assess and improve your experience of the Routable Services;

• Review compliance with applicable usage terms;

• Identify future opportunities for development of the Routable Services;

• Assess capacity requirements;

• Identify customer opportunities and for the security of Routable generally (in addition to the security of the Routable Services); 

• Enforce any of our rights under our agreements with you or any third party, including the Terms of Services; and

• Analyze overall trends, to help us provide and improve the Routable Services, and to improve their security and proper functioning.

Some of this information is collected using Cookies and other tracking technologies. For more information, see the “Cookies and Tracking Technologies” under Section 2. Disclosure to Third Parties. We do not disclose Customer Data to third parties except to service providers (that are “subprocessors” within the meaning of the GDPR) necessary to provide our Routable Services to our Customers. A list of subprocessors authorized to process Customer Data, and the function of each can be viewed here. Routable subprocessors are prohibited from selling Customer Data. International Transfers. Routable is headquartered in the United States. Therefore, please be aware that Personal Information submitted through our Routable Services or Website may be transferred to, stored, and processed by Routable in our facilities and by those third parties located in the United States and other international locations with whom we may share your Personal Information. These countries may have data protection laws that are different to the laws of your country.  Regardless of where your data is located, we will treat all Customer Data in accordance with applicable law and apply the same protections described in this Privacy Policy. We also comply with certain legal frameworks relating to the transfer of such data, including ensuring that Customer Data has been transferred pursuant to additional safeguards in the form of the Standard Contractual Clauses approved by the European Commission contained in our DPA. If you require further information about our international transfers of Personal Information, please contact us using the contract details in the “Contact Information” section further below

7. Your Privacy Rights

Rights for Individuals in Europe. Where Routable is acting as a controller, and depending on your location, your jurisdiction, and subject to applicable law, you may have the rights below with regard to the Personal Information we control about you. We will respond to your requests within the appropriate timeline under applicable law:

• The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us" heading below.

• The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the "Contact Us" heading below.

• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

• You can also ask us to correct or update your Personal Information; object to the processing of your Personal Information; ask us to restrict processing of your Personal Information or request the portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact Us " heading below

• While you cannot opt out of service-related emails if you are an account holder, as this is an essential part of the Routable Services, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or you can contact us using the contact information below.

• Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

• Routable does not engage in any automated decision making with Personal Information.

If your Personal Information has been submitted to us by or on behalf of a Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. For more information on how the Customer uses your Personal Information, please see your Customer’s privacy policy.California Privacy Rights. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at privacy@routable.com or writing to us at 600 California St Floor 11, San Francisco, CA 94108.

8. Control Over Your Information

Email Communications. From time to time, we may send you emails regarding updates to our website, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices). Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the website or service. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below. Please note that Routable does not own or control the Customer Data uploaded to our Routable Services by our Customers, and cannot modify or delete Customer Data except at the request of our Customer, or as permitted by our Terms of Service.

9. Third Party Tracking and Online Advertising

We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website over time so that they may play or display ads that may be relevant to your interests on our Site as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our Site or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at privacy@routable.com.Facebook Custom Audience Ads. We may work with Facebook to display interest-based ads to you or to your friends on Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on you or your friends’ experience on our Routable Services in order to provide ads tailored for each specific recipient. We do not share Personal Information about your activities on our Routable Services with Facebook, but we share a hashed email address or phone number which permits Facebook to identify our advertising audience based on the information that Facebook collects from its users. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings. If you do not want us to use your content to personalize advertising that we direct to your friends on Facebook, you may email us at privacy@routable.com.

10. Data Protection and Security

Data Retention: We will retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected, comply with any laws or regulations, resolve disputes, and enforce or perform our agreements. We may retain your data for a legitimate business interest where business benefit is not outweighed by your personal rights and freedoms. Customer Data processed on behalf of our Customers as a service provider or processor is retained in accordance with any applicable agreement between Routable and its Customer.Data storage and transfer: Your information may be stored and processed in the United States or any other country in which Routable or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.Keeping information safe: All of your Personal Information remains private and confidential. The security of your Personal Information is important to us. When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (SSL).Routable maintains a comprehensive written information security program that complies with applicable law and generally accepted industry standards. Our program includes appropriate administrative, technical and physical safeguards, procedures and practices to protect Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over theInternet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, the Routable web application owned and operated by Routable, or the Routable Services, please contact us using the contact information below.Routable and its representatives will never request your account credentials. You should never share your Routable account information, including your username and password, with anyone else. We recommend that you use a unique password for your Routable account that is not associated with other websites. You should check your Routable account regularly to ensure that your Personal Information has not been tampered with or altered. Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to your site administrator and Routable using the contact information below.In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations. Routable’s obligations with respect Customer Data are defined in our agreements with our customers and are not included in this Privacy Policy. Each customer will remain responsible for the privacy and security of the Customer Data that it collects and processes and for compliance with applicable data protection laws that may apply to the collection, processing and disclosure of Customer Data through the Routable Services. For additional details about the technical and organizational security measures employed by Routable for the protection of personal data, you can review our Security Measures. 

11. Children’s Privacy

Routable’s website and services are intended for use strictly by adults. We do not knowingly solicit or collect Personal Information from children under the age of 13. If we learn that any Personal Information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at privacy@routable.com.

12. Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the top of this page. Please check back often for any updates. Your continued use of our website or services after any change in this Privacy Policy will constitute your acceptance of such change.

13. European Representative and Data Protection Officer Details

For the convenient administration of regulatory compliance concerns related to individuals located in the European Union, United Kingdom, and Switzerland, Routable has appointed a Data Protection Officer.Routable’s Data Protection Officer (DPO) is:Mario Moreno, Routable Security and Compliance Manager privacy@routable.com

14. Contact us

For additional inquiries about this Privacy Policy, please send us an email at privacy@routable.com, or contact us at 600 California St Floor 11, San Francisco, CA 94108.