Last Update Posted: September 16, 2020

Introduction 

At Marquis Software Solutions Inc., we respect your privacy, and work hard to protect your personal information.  This Policy explains our practices regarding the personal information we collect about customers of financial institutions as part of our role as a service provider in the financial industry.  This Policy applies to information we collect through our software and websites (including https://legacy.gomarquis.com/), from your financial institution, or through your written or verbal communications with us (collectively, our “Services”).  This Policy applies whenever you or your financial institution use our Services.   

What does Marquis do? 

Founded in 1986, Marquis is a Plano, Texas-based service provider that provides compliance and marketing software solutions to financial institutions throughout the United States.  Our offerings include data analytics, consulting, customer relationship management, and direct-marketing services.

Our contractual agreements with our client financial institutions generally require us to follow the same practices as they do with respect to the privacy and protection of personal information.  In many cases, though, we merely provide software.  It is up to the financial institution to configure the software properly, including selecting appropriate privacy and security options.

In addition to reviewing this Privacy Policy, we encourage you to read the privacy notice provided to you by your financial institution in order to better understand the types of collection and processing that apply to your personal information.   

Information for Business-to-Business Contacts

We collect the following types of information from employees of our financial institution customers who interact with us in the business-to-business context:

  • Identifiers (for example, name, alias, title, username, IP address, signature);
  • Contact Information (for example, email address, postal address, phone number, communication preferences);
  • Marketing Engagement Activity (including clicks or other interactions with emails we generate);
  • Responses to Surveys, Competitions, Promotions, and Sweepstakes; and
  • Information from Cookies, Pixels, Web Beacons, HTTP Referrers, user authentication technologies, and Website Analytics.  More information about our use of these technologies can be found above.

If you wish to unsubscribe from our marketing emails, please click on the unsubscribe link found at the bottom of each marketing email we send, or contact us at [email protected].  If you opt-out of receiving our marketing emails, you may still receive email communications from us related to your account or products and services purchased from us.  Unsubscribing from our marketing communications will not affect our service to you.

If you have any questions about our collection or processing of your personal information, please contact us by phone, using the Contact tab on our website, or email us at [email protected].

Personal Information We Collect as a Service Provider

“Personal information” is any information that identifies, relates to, describes, or is capable of being associated with, a particular individual.  Personal information does not include information that is publicly available, aggregated, or deidentified.

Our software solutions collect the following categories of personal information and we have access to provide services for some financial institution clients:

  • Identifiers (for example, name, alias, title, username);
  • Contact Information (for example, email address, postal address, phone number, communication preferences);
  • Bank Account, Mortgage, Credit Card, Loan, and Insurance Information for Accounts You Hold at Financial Institutions that Use Our Services (including account numbers, expiration dates, loan balances, credit limits, and related information);
  • Demographics / Account Application Information (i.e., birthdate and age, gender, employment, education, earnings, and other information you may have provided your financial institution when you applied for an account, loan, or insurance product);
  • Protected Classification Characteristics Age, Race or color, National origin, marital status, sex or Ethnicity.
  • Commercial Information (for example, which products and services offered by your financial institution you’ve enrolled in, considered, or declined; information relating to real estate, vehicles, and other property you may own; information about your purchasing or consuming history or tendencies);
  • Communications Sent Through our Services by Phone, Email, Mail, and Text.;
  • Marketing Engagement Activity (including your clicks or other interactions with emails we generate);
  • Responses to Surveys, Competitions, Promotions, and Sweepstakes.
  • Information From Cookies, Pixels, Web Beacons, HTTP Referrers, and Website Analytics (IP address, cookie ID; browser user ID; domain; browser ID; browser GUID; browser information; language preference; device ID; other unique device identifiers; device type; device model; platform; operating system type information; advertising interactions; website browsing behavior (such as pages viewed on our website and the websites you visit before and after ours, search and browsing history, click tracking, and access date, time, and duration); web log information; and geolocation data). For our full Cookies Policy, please click here;
  • Inferences About You Based on Any of the Above.

How We Collect Your Personal Information

We collect your personal information through various means, including: primarily from your financial institution, when you directly provide information to them, and automatically when you interact with their website, email, text and other communications.  In some instances, you may be able to choose what information to provide.

Information From Your Financial Institution.  As a provider of services to the financial industry, our primary source of personal information about you is from your financial institution.  While many financial institutions choose to license our software and manage their services to you in a way that does not involve us accessing your personal information and others provide us only with aggregated or deidentified data, or some of our clients provide us with access to their customer databases in order for us to assist them with marketing their products and services.  We encourage you to review the privacy notice provided by your financial institution in order to understand the types of information that may be shared with us in your particular case.  

Information You Provide to Us.  We may collect personal information you provide directly to us, including when you:

  • Communicate with us by phone, email, mail, text, or through our website;
  • Participate in a survey, marketing promotion, sweepstakes or contest run by us;
  • Apply for employment with us;
  • Connect with us via social media;
  • Correspond with us as a client or prospective client;
  • Register as an end-user of our services; or
  • Register for one of our conferences or webinars.

Information We Collect Automatically Through Cookies and Similar Technologies.  Our website and email communications automatically collect some personal information through the use of technologies such as cookies, pixels, web beacons, HTTP referrers, and other tracking technologies.

These technologies involve the use of small pieces of data sent from a website and stored on the user’s computer that provide a reliable mechanism for websites to remember information about you.  Marquis uses these technologies to understand site usage, to improve web content, and to offer products, programs or services.  We also provide software to financial institutions allowing them to collect information about users’ browsing activities on their websites.  More information on how we use cookies can be found in our cookie policy. 

Most browsers allow you the option to block or accept cookies and other similar tracking technologies.  Please visit www.aboutcookies.org or www.allaboutcookies.org for further information.

Web Analytics Services.  Marquis uses proprietary and Google website analytics for marketing and demographic data analysis, and to improve the functionality of our website.  This software may record information such as your IP address, location, age, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter and other actions you take while visiting us, and the pages you view immediately before and after accessing our website.  Marquis also provides web analytics services to our financial institution clients, allowing them to track these same types of information when you visit their websites.

User Authentication.  We use Google reCAPTCHA to ensure that those who access our website are real people and not bots.  Before accessing certain portions of our website, users may be directed to first use the Google reCAPTCHA tool so that an integrity check can be performed.  Through this tool, Google collects hardware and software information, such as device and application data.  For more information about reCAPTCHA, please click here.

Website Links. Our outbound emails may contain links to our website.  Users who click on these links to reach our website can be identified and cross-referenced to their email address by means of a proprietary software called WebTrax.  We also license WebTrax to some of our clients.

How We Use Your Personal Information 

Subject to further limitations that may be part of our agreement(s) with your financial institution, we process and maintain personal information provided to us for the following purposes:

  1. To perform our contractual obligations to your financial institution.
  2. To retain or employ another service provider as a subcontractor, subject to the same limitations on collection and use of personal information as apply to us;
  3. For internal use to build or improve the quality of our services;
  4. To detect data security incidents;
  5. To comply with federal, state or local law; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; to cooperate with law enforcement concerning conduct or activity that we or our client reasonably and in good faith believes may violate federal, state or local law; and
  6. To exercise or defend legal claims.

How We Share Your Personal Information 

We do not share or disclose personal information for any purpose other than: 

  1. To retain or employ another service provider as a subcontractor, subject to the same limitations on collection and use of personal information as apply to us;
  2. To comply with federal, state or local law; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; to cooperate with law enforcement concerning conduct or activity that we or our client reasonably and in good faith believes may violate federal, state or local law; and
  3. To exercise or defend legal claims.

We do not sell personal information.

Information Security 

We build security into our all of our services in order to protect your information.  We use commercially reasonable and appropriate safeguards, including the encryption of personal information, to secure and protect the privacy, accuracy, and reliability of your information and to protect it from unauthorized access, alteration, disclosure, or destruction. 

If you have an account with us or use our software, please do your part to help keep personal information secure by choosing passwords carefully, signing out after using our Services, and changing your password from time to time.

Data Retention

We retain the personal information we process only for as long as needed to perform our contractual obligations to the financial institution that collected the information or as needed to comply with legal requirements (including financial record-keeping regulations), for security purposes, or to prevent fraud or  abuse. 

Public Forums 

Our website offers publicly accessible thought leadership blogs, including those available at https://legacy.gomarquis.com/resources/.  Please be advised that we generally do not control or remove content from public forums on our website, and that any information you provide in these areas may be read, collected, and used by the public.  If you encounter any inappropriate or illegal conduct, please contact us at [email protected].    

Email Communications

Your financial institution may use our software to send you communications by email.  Emails generated by our software include an “unsubscribe” link at the bottom.  Please note that if you opt-out of receiving marketing email communications generated by our software, you may still receive email messages related to your accounts or transactions from your financial institution as well as communications generated through other systems and software used by your financial institution.  Please consult your financial institution’s privacy notice for more information.

Text Messages and Alerts

If you have opted-into receiving text messages and alerts from your financial institution, our software may enable your financial institution to send you messages (i) regarding your accounts; (ii) to offer new products or services to you; (iii) to investigate or prevent fraud; (iv) to alert you in the event of an emergency, and for other purposes related to your relationship with your financial institution.  Our software uses autodialing technology to send these types of messages and alerts, and your financial institution will obtain your consent before using it. Standard text messaging charges may apply.

You may opt-out of the receipt of text messages and alerts at any time by using any reasonable means to inform your financial institution of your wish to opt-out.  Please consult your financial institution’s privacy notice for more information.

Email and Text Tracking Technology

Some of our software allows financial institutions to track whether you opened an email or text message they sent you, whether you clicked on any links contained within the email or text, and to identify you by name, email address or IP address.  Not every financial institution uses this technology, and in most cases, we do not have access to the data.  Please check your financial institution’s privacy notice to see if it uses this type of technology, and to obtain information on how you can opt-out of email or text communications.

Do Not Track

Some of our technology may allow your financial institution to track your internet browsing activity through the use of cookies.  We also employ tracking technology on our website.  You may limit this type of tracking by disabling cookies in your web browser.

We do not currently have the technology to automatically respond to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms; nor does the software we license to our clients have this capability.

Your California Privacy Rights

Marquis is a “service provider” and not a “third party,” as those terms are defined under California Consumer Privacy Act of 2018 (the “CCPA”).  This means that, we process and maintain personal information provided to us for the following purposes:

  1. To perform our contractual obligations to your financial institution;
  2. To retain or employ another service provider as a subcontractor, subject to the same limitations on collection and use of personal information as apply to us;
  3. For internal use to build or improve the quality of our services;
  4. To detect data security incidents;
  5. To comply with federal, state or local law; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; to cooperate with law enforcement concerning conduct or activity that we or our client reasonably and in good faith believes may violate federal, state or local law;
  6. To exercise or defend legal claims.

Please note that because laws such as the federal Gramm-Leach-Bliley Act and the California Financial Information Privacy Act govern much of the personal information we process, the CCPA may not apply in all cases or to all of the information we process.

Requests to Know or Delete Information.  Should you wish to exercise your right to know or delete your personal information under the CCPA, please contact your financial institution.  If we receive a request to know or delete from a consumer, we will inform the consumer that the request cannot be acted upon because the request has been sent to a service provider.

Requests to Opt-Out of the Sale of Personal Information.  Under the CCPA, you have the right to opt-out of the sale of your personal information.  However, because we do not sell personal information, there is no need to submit such a request to us.

Your Right Not to Receive Discriminatory Treatment.  If you choose to exercise any of your rights under the CCPA, we will not deny our products or services to you, charge a different price for our products or services, or provide a different level or quality of products or services unless those differences are reasonably related to the value of your personal information.

If you have additional questions related to how we process your personal information or your rights under the CCPA, you can contact [email protected] or call us at 1-800-365-4274.

Nevada Privacy Notice

If you are a Nevada resident, you have the right to opt-out of the sale of your personal information.  However, because we do not sell personal information, there is no need to opt-out.  Should you have any questions, please do not hesitate to contact us at [email protected].

Additional Information for Non-U.S. Individuals

We operate exclusively within the United States, and do not knowingly collect personal information of people who reside in other countries.  If you are a non-U.S. resident who believes we have come into possession of your personal information, please contact us at [email protected].

Children’s Privacy

Our Services are neither intended for, nor targeted to, children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.  If we learn that we possess information from a child under the age of 13, we will delete such information. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without your consent, please contact us at [email protected].

Changes to This Privacy Policy

We may update this Policy from time to time, in our sole discretion to reflect our current privacy practices. When we do so, we will post the new Policy on our website.  Our use of personal information we collect is subject to the Privacy Policy in effect at the time of collection.  You should consult this Policy regularly for any changes.  Continued use of our Services following the effective date of any modification to the Privacy Policy constitutes your acknowledgement of such changes and agreement to be bound by them.

How to Contact Us

If you have any questions about our collection or processing of personal information, please contact us using the Contact tab on our website , emailing us at [email protected], or calling us at 1-800-365-4274.

Federal Transparency in Coverage Rule

This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.