Privacy Policy

1. Introduction and Scope

Elite Merchant Solutions, doing business as Elite 2A Pay, a wholly owned subsidiary ("Elite 2A Pay, " "we,” "us," or "our"), respects your privacy. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have.

This Policy applies to: https://elite2apay.com and all related subdomains, landing pages, forms, and portals (the "Site"); inquiries, quote requests, applications, and onboarding conducted with us; and our phone, email, text, and in-person interactions with prospective and current merchants, partners, and website visitors.

This Policy does not apply to: (a) the independent privacy practices of the sponsoring acquiring banks, processors, gateways, equipment providers, point-of-sale platforms, and other third parties through which merchant accounts and payment processing are provided ("Processing Partners"), each of which maintains its own privacy notice; (b) the practices of any third-party website linked from the Site; or (c) cardholder data processed by your business in your own merchant environment.

Our services are directed to businesses in the United States and are intended for commercial use.

2. Information We Collect

2.1 Information You Provide Directly

Contact and business identifiers: name, business name, legal entity name, DBA, title or role, business and mailing address, email address, phone number, website URL, and social media handles.

Business profile information: business type and industry, years in operation, sales channels (retail counter, online, events, auctions, phone), product categories, average ticket, monthly and annual processing volume, seasonality, existing POS or gateway, current processor, and current rates.

Licensing and regulatory information: Federal Firearms License (FFL) number and type, Special Occupational Tax (SOT) status, state and local dealer licenses, ITAR/DDTC registration, and related documentation.

Application and underwriting information: legal entity formation documents, ownership and beneficial ownership details, employer identification number (EIN), Social Security number and date of birth of principals, personal and business addresses, government-issued identification (such as a driver's license), voided check or bank account and routing numbers, prior processing statements, and personal guaranty information.

Financial and transaction information: processing statements, chargeback and dispute history, deposit and funding details, and, where applicable, limited transaction data.

Communications: the content of emails, form submissions, chat messages, text messages, support tickets, and call recordings.

Other: any information you choose to provide in a testimonial, review, survey, event registration, or referral submission.

2.2 Information Collected Automatically

When you visit the Site, we and our service providers may automatically collect: IP address and approximate location derived from it; device and browser type, operating system, screen resolution, language, and device identifiers; pages viewed, referring and exit pages, links clicked, scroll depth, time on page, and session duration; date and time stamps and server log data; and data from cookies, pixels, tags, SDKs, session-replay tools, and similar technologies (see Section 6).

2.3 Information from Other Sources

We may receive information about you from: consumer reporting agencies and credit bureaus (business and, where authorized, personal credit reports); identity verification, fraud prevention, and sanctions screening providers (including OFAC and watchlist screening); card network and industry databases, including the Mastercard MATCH (Member Alert to Control High-Risk Merchants) system and the Visa Consortium Merchant Negative File; Processing Partners, acquiring banks, gateways, and POS providers regarding your application or account; referral partners, resellers, agents, associations, trade shows, and lead providers; public records, business registries, licensing databases, and publicly available web sources; and advertising and analytics platforms, including data about your interaction with our ads.

2.4 Sensitive Information

Some of what we collect is sensitive, including Social Security numbers, driver's license or other government identification numbers, financial account numbers, and precise account credentials.

We collect this only where necessary for underwriting, identity verification, fraud prevention, and legal compliance, and we handle it with heightened safeguards.

2.5 We Do Not Knowingly Collect Certain Categories

We do not seek and do not want to receive information about health, biometrics, genetic data, precise geolocation from your device, religious beliefs, sexual orientation, or union membership.

Please do not submit such information to us.

3. How We Use Information

We use the information described above to: respond to your inquiries, quotes, and requests, and to prepare rate comparisons and statement analyses; evaluate, submit, and process applications for merchant accounts, equipment, gateways, and related services; conduct underwriting, know-your-customer (KYC) and know-your-business (KYB) diligence, identity verification, beneficial ownership verification, credit assessment, and sanctions and watchlist screening; board, activate, configure, integrate, and support your account and equipment; provide customer service, technical support, dispute and chargeback assistance, and PCI DSS compliance support; detect, investigate, prevent, and address fraud, transaction laundering, security incidents, and other unlawful or prohibited activity; monitor account activity for risk, reserve, and compliance purposes; communicate with you about your account, applications, service changes, outages, pricing, network fee updates, and policy updates; market and advertise our products and services, including by email, phone, text, direct mail, and targeted digital advertising, and to measure the effectiveness of that marketing; operate, maintain, secure, analyze, and improve the Site and our services, including analytics, A/B testing, and product development; comply with legal, regulatory, card network, and contractual obligations, including recordkeeping, anti-money-laundering, sanctions, and reporting obligations; establish, exercise, and defend legal claims, and enforce our Terms of Service and other agreements; and carry out any other purpose disclosed to you at the time of collection or to which you consent.

We may de-identify or aggregate information so that it no longer reasonably identifies you, and use and disclose that information for any lawful purpose.

4. How We Share Information

We do not sell your Social Security number, financial account numbers, or application data to third parties for money. We share information as follows:

4.1 Processing Partners and Financial Institutions

We share application, business, ownership, and financial information with sponsoring acquiring banks, processors, gateways, sponsor banks' agents, ISOs, equipment lessors, and payment facilitators for the purpose of underwriting, boarding, servicing, funding, risk management, and terminating merchant accounts. These parties handle your information under their own privacy notices and under card network requirements.

4.2 Service Providers

We share information with vendors who perform services on our behalf under contractual confidentiality and use restrictions, including hosting and cloud infrastructure, CRM and marketing automation, email and SMS delivery, telephony and call recording, e-signature, document storage, analytics, advertising, identity verification, credit reporting, background screening, security, accounting, and professional advisors.4.3 Credit Bureaus and Screening Databases. With your authorization, we and our Processing Partners may obtain and furnish information to consumer reporting agencies, business credit bureaus, and card network databases including MATCH and the Consortium Merchant Negative File. Placement on such a database may affect your ability to obtain processing services from other providers.

4.4 Card Networks and Regulators

We share information with Visa, Mastercard, American Express, Discover, NACHA, and with regulators, examiners, and self-regulatory bodies where required or permitted.

4.5 Referral and Channel Partners

If you were referred to us by a partner, agent, association, or lead provider, we may share limited information with that party to confirm the referral, calculate compensation, and coordinate service.

4.6 Legal and Safety

We may disclose information when we believe in good faith it is necessary to: comply with applicable law, regulation, subpoena, court order, warrant, or other legal process; respond to lawful requests from law enforcement or government authorities; enforce our agreements; investigate suspected fraud, security incidents, or violations; or protect the rights, property, or safety of Elite 2A Pay, our merchants, or the public.

4.7 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale of all or part of our assets, information may be transferred as part of that transaction or diligence, subject to reasonable confidentiality protections.

4.8 Advertising and Analytics Partners

We share online identifiers, device data, and browsing activity with advertising and analytics platforms to deliver and measure advertising. Under some state privacy laws, this activity may be considered a "sale" or "sharing" of personal information for cross-context behavioral advertising. See Sections 6 and 9 for your choices.

4.9 With Your Direction or Consent

We share information at your direction or with your consent, including publishing testimonials you provide.

5. Gramm-Leach-Bliley Act (GLBA) Notice

To the extent Elite 2A Pay provides financial products or services to individuals for personal, family, or household purposes, or handles nonpublic personal information about individuals such as sole proprietors and personal guarantors, we are subject to the Gramm-Leach-Bliley Act and its implementing regulations, including the Federal Trade Commission's Privacy Rule and Safeguards Rule.

What we do: We collect nonpublic personal information from applications, transactions, consumer reporting agencies, and other sources described in this Policy. We disclose that information only as permitted by law, including to Processing Partners, service providers, credit bureaus, and regulators, and in connection with servicing, processing, fraud prevention, and legal compliance.

Our commitment: We restrict access to nonpublic personal information to employees and agents who need it to provide products and services to you, and we maintain physical, electronic, and procedural safeguards designed to comply with federal standards, including a written information security program under the Safeguards Rule.

Opt out: We do not share nonpublic personal information with nonaffiliated third parties for their own marketing purposes. If our practices change, we will provide you with the notice and opt-out rights required by law.

Interaction with state privacy laws: Personal information collected, processed, sold, or disclosed subject to the GLBA, and information subject to the Fair Credit Reporting Act, is generally exempt from state consumer privacy statutes. Where an exemption applies, the rights described in Section 9 may not extend to that information.

6. Cookies and Tracking Technologies

6.1 What We Use

Strictly necessary cookies that enable core functionality, security, load balancing, and fraud prevention.

Preference cookies that remember your settings.

Analytics cookies and tags (for example, Google Analytics) that help us understand how the Site is used.

Advertising and conversion pixels (for example, Google Ads, Meta, LinkedIn, Microsoft Advertising) that let us measure campaigns and show relevant ads on other platforms.

Call tracking and form attribution tools that connect a phone call or form submission to the marketing source.

Session recording or heatmap tools, where enabled, that record on-page interactions.

6.2 Your Choices

Browser controls: most browsers let you block or delete cookies. Blocking some cookies may degrade Site functionality.

Analytics opt out: Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

Ad industry opt outs: https://optout.aboutads.info and https://optout.networkadvertising.org.

Mobile: use your device's "Limit Ad Tracking" or "Opt out of Ads Personalization" setting.

6.3 Do Not Track and Global Privacy Control

The Site does not currently respond to browser "Do Not Track" signals because no common standard exists. Where required by applicable state law, we treat an opt-out preference signal such as Global Privacy Control (GPC) as a valid request to opt out of the sale or sharing of personal information for that browser or device.

7. Marketing Communications and Your Choices

Email: every marketing email includes an unsubscribe link. You may also email support@elitedatacorp.com. We will continue to send transactional and servicing messages related to your account.

Text messages: reply STOP to opt out of a text program and HELP for help. Message frequency varies and message and data rates may apply. By providing your phone number you consent to receive calls and texts, including autodialed and prerecorded calls, as described in our Terms of Service. Consent is not a condition of purchase.

Phone: you may ask any representative to add you to our internal do-not-call list or write to support@elitedatacorp.com. We maintain an internal do-not-call list and honor the National Do Not Call Registry as required by law.

Call recording: calls to and from Elite 2A Pay may be monitored or recorded for quality, training, compliance, and recordkeeping. If you do not consent, please notify the representative or communicate with us in writing.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, and thereafter as required to: comply with legal, regulatory, tax, accounting, card network, and anti-money-laundering recordkeeping obligations, which for financial and transaction records commonly require five (5) years or longer after the relationship ends; resolve disputes, chargebacks, investigations, and audits; enforce our agreements and establish or defend legal claims; and maintain business records, security logs, and backups.

When information is no longer needed, we delete, destroy, or de-identify it using reasonable measures. Declined or abandoned applications are retained for a limited period consistent with our fraud-prevention and legal obligations.

9. Your Privacy Rights by State

Several U.S. states grant residents privacy rights. Important limitations: most state privacy laws apply to individuals acting in a personal or household capacity, not to information about you in a purely commercial or employment context, and they contain broad exemptions for information governed by the GLBA and the FCRA. We honor rights requests to the extent applicable law requires.

9.1 Rights That May Be Available to You

Right to know / access: confirm whether we process your personal information and obtain a copy, along with the categories collected, sources, purposes, and recipients.

Right to delete: request deletion of personal information we collected from you, subject to exemptions.

Right to correct: request correction of inaccurate personal information.

Right to opt out of sale or sharing: opt out of the sale of personal information and of sharing for cross-context behavioral or targeted advertising.

Right to limit use of sensitive personal information: where applicable, limit our use and disclosure of sensitive personal information to purposes permitted by law.

Right to opt out of profiling: opt out of profiling in furtherance of decisions producing legal or similarly significant effects.

Right to non-discrimination: we will not deny services, charge different prices, or provide a different level of quality because you exercised a right.

Right to appeal: if we deny your request, you may appeal by writing to support@elitedatacorp.com with the subject line "Privacy Request Appeal." We will respond within the period required by your state's law and, if we deny the appeal, provide information on contacting your state attorney general.

9.2 California Residents (CCPA/CPRA)

In the preceding twelve (12) months, we have collected the following categories of personal information as defined by the California Consumer Privacy Act:

We do not use or disclose sensitive personal information for purposes other than those permitted under CCPA Section 1798.121(a), so no right to limit applies to that use.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

How to exercise: To opt out of sale or sharing, submit a request by email to support@elitedatacorp.com, or by calling (844) 692-2792. We will verify your identity before acting on access, deletion, or correction requests, typically by matching information you provide against our records. An authorized agent may submit a request on your behalf with written permission and proof of identity.

Shine the Light: California residents may request information about disclosures of personal information to third parties for their direct marketing purposes by writing to support@elitedatacorp.com. We do not make such disclosures.

9.3 Texas Residents (TDPSA)

Texas residents have the rights described in Section 9.1. Requests may be submitted to support@elitedatacorp.com or (844) 692-2792. If we sell personal data or process it for targeted advertising, we provide the following notices as required by the Texas Data Privacy and Security Act:

NOTICE: We will never sell your sensitive personal data.

NOTICE: We may sell your biometric personal data.

We process personal data for targeted advertising. You may opt out by sending a request to support@elitedatacorp.com.

9.4 Other States

Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Texas, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and other states with comprehensive privacy laws in effect may exercise the applicable rights in Section 9.1 by contacting us a support@elitedatacorp.com. Colorado, Connecticut, and certain other states require opt-in consent before processing sensitive data, which we obtain where applicable. Nevada: Nevada residents may submit a verified request that we not sell covered information to support@elitedatacorp.com. We do not currently sell covered information as defined by Nevada law.

9.5 Response Timing

We respond to verifiable requests within forty-five (45) days, extendable by an additional forty-five (45) days where permitted, with notice to you. There is no fee unless a request is manifestly unfounded, excessive, or repetitive.

10. Data Security

We maintain a written information security program with administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Measures include access controls and role-based permissions, encryption of sensitive data in transit and at rest where appropriate, multi-factor authentication, network monitoring and logging, vendor due diligence, employee training, and an incident response plan.

We support merchants in meeting the Payment Card Industry Data Security Standard (PCI DSS). We do not certify or guarantee your PCI DSS compliance, and responsibility for securing cardholder data in your own environment remains with you. No system is perfectly secure. We cannot guarantee absolute security, and you transmit information to us at your own risk. Please do not send full payment card numbers, Social Security numbers, or other sensitive information by unsecured email or through unsecured web forms. Use the secure channels we designate.

If a breach of unencrypted personal information occurs, we will notify affected individuals and regulators as required by applicable law.

11. Children's Privacy

The Site is intended for business use by adults and is not directed to children. We do not knowingly collect personal information from anyone under eighteen (18) years of age. If you believe a minor has provided us information, contact support@elitedatacorp.com and we will delete it.

12. Third-Party Websites and Services

The Site may link to or embed third-party websites, platforms, marketplaces, POS providers, associations, and social media. We are not responsible for the privacy practices, content, or security of those third parties. Review their privacy notices before providing information to them.

13. International Users

The Site is operated in the United States and intended for U.S. users. If you access the Site from outside the United States, you acknowledge that your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your jurisdiction, and you consent to that transfer and processing.

14. Changes to This Policy

We may update this Policy from time to time. We will post the revised Policy with a new "Last Updated" date and, where required by law, provide additional notice. Your continued use of the Site after the revised Policy is posted constitutes acceptance of the changes. We encourage you to review this Policy periodically.

15. Contact Us

To ask a question about this Policy, exercise a privacy right, or report a concern:

Elite 2A Pay

Elite 2A Pay is a provider of merchant services and payment acceptance solutions and is not a bank. Merchant accounts and payment processing are provided through sponsoring acquiring banks and processors, each of which maintains its own privacy notice.