Effective Date: March 2, 2022
We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or that we collect, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:
When a customer makes a payment via a Clover POS, we collect information about the transaction, which may include personal data. Information about transactions includes the location of the merchant’s store, date and time of the transaction, transaction amount, and information about the goods or services purchased in the transaction.
3. Information that we collect about Merchants’ personnel
We may collect information about Merchants’ personnel and interactions with the Clover POS, such as clock-in and clock-out time.
Merchants may provide us with additional information directly, via access they grant to us, or otherwise. The types of information that merchants may provide to us about their personnel include email addresses, phone numbers, shifts, and sales history.
We use the personal data we collect for or on behalf of Merchants, to provide our services and the functionality of our application: Sync all the settings between devices and provide better support.
6. We may also use personal data for related internal purposes, including:
- To provide information about the application, such as important updates or changes to the application and security alerts
- To measure performance of and improve the application
- To respond to inquiries, complaints, and requests for customer support
In addition, Company may use personal data as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may share personal data that we collect with:
- The Merchant from whom or on whose behalf we collected the personal data
- The platform on which our application runs, the Clover POS. You may view Clover’s Privacy Notice here.
- With third parties as a Merchant may direct
- With third party service providers that help us manage and improve the application
Company may disclose personal data to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To the extent that applicable law provides individuals with rights pertaining to their personal information, such as to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of our application. To the extent that Clover is responsible for responding to data subject rights requests under applicable law, individuals may contact Clover with applicable requests as explained in Clover’s Privacy Notice, https://www.clover.com/privacy-policy. Company will assist a Merchant, or Clover, as applicable, in responding to such requests subject to our contract with a Merchant or Clover.
If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.
Company processes personal data as directed or permitted by the Merchant that uses our application. The Merchant is responsible for establishing a legal basis for our processing of personal data for or on behalf of the Merchant.
When we transfer personal data outside of Europe (or the UK) to countries not deemed by the European Commission to provide an adequate level of protection for personal data, we make the transfer pursuant to one of the following transfer mechanisms:
- A contract approved by the European Commission (sometimes called “Model Clauses” or “Standard Contractual Clauses”);
- The recipient’s Binding Corporate Rules;
- The consent of the individual to whom the personal data relates; or
- Other mechanisms or legal grounds as may be permitted under applicable European law.
You may contact us with questions about our transfer mechanism.
Subject to our agreement with a Merchant, Company retains personal data for as long as necessary to (a) provide our products and services; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of any agreement we may have with a Merchant. You may contact us for additional information about our data retention practices in connection with the application.
Under certain circumstances, data subjects in Europe and the UK have certain rights relating to their personal data, which include the rights to request from the Controller (a) access to the data subject’s personal data; (b) correction of incomplete or inaccurate personal data; (c) erasure of personal data; (d) restriction of processing concerning the data subject; and (e) that the controller provide a copy of the data subject’s personal data that the data subject provided to the controller in a structured, commonly used and machine-readable format. Data subjects may also object to a controller’s processing of personal data under certain circumstances. Where processing is based on a data subject’s consent, the data subject has the right to withdraw consent at any time; however, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Data subjects may also file a complaint with a supervisory authority. You may view contact information for supervisory authorities at https://edpb.europa.eu/about-edpb/board/members_en. Data subjects in Europe or the UK should direct any rights request to the appropriate Controller.
You have the rights listed below.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient.
- Whether we’ve sold your Personal Information; and, if so, the categories of Personal Information received by each category of recipient.
- Access. You can request a copy of the Personal Information that we maintain about you.
- Deletion. You can ask us to delete the Personal Information that we maintain about you.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as by denying you goods or services, increasing the price/rate of goods or services, decreasing the service quality, or suggesting that we may penalize you as described above for exercising your rights.
You may exercise your California privacy rights as follows:
You can request to exercise your information, access and deletion rights in the following ways:
- Call +1 743-800-4077
- Identity verification. The CCPA. requires us to verify the identity of the individual submitting the request before providing a substantive response to the request. A request must be provided with sufficient detail to allow us to understand, evaluate and respond. The requester must provide sufficient information to allow us to reasonably verify that the individual is the person about whom we collected information. A request may also be made on behalf of your child under 13.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We may require the authorized agent to have a written authorization confirming that authority.
We do not sell your Personal Information to third parties. In the preceding twelve (12) months, we have not sold any personal information.
11.10 Prohibition of collecting information provided by minors.
We do not collecting Information provided by minors.
11.11 Personal information that we collect, use and share
|Category (see the glossary below for definitions)||Do we collect this information?||Do we share this information for business purposes?|
|Protected Classification Characteristics||No||No|
|Internet or Network Information||No||No|
|Professional or Employment Information||No||No|
|Categories of Personal Information||Date Elements within the Category|
|Biometric Information||An individual’s physiological, biological or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish an individual’s identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a face print, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.|
|Transaction History||Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Financial Information||Bank account number, debit or credit card numbers, insurance policy number, and other financial information.|
|Geolocation Data||Precise location, e.g., derived from GPS coordinates or telemetry data.|
|Identifiers||Real name, alias, postal address, unique personal identifier, customer number, email address, account name other similar identifiers.|
|Government-issued ID||Social security number, driver’s license, passport, or other government-issued ID, including an ID number or image.|
|Medical Information||Personal information about an individual’s health or healthcare, including health insurance information.|
|Internet or Network Information||Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.|
|Online Identifiers||An online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.|
|Physical Description||An individual’s physical characteristics or description (e.g., hair color, eye color, height, weight).|
|Professional or Employment Information||Information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations), and educational background.|
|Protected Classification Characteristics||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|Sensory Information||Audio, electronic, visual, thermal, olfactory, or similar information.|
You have the right to access, correct, update or request deletion of the PII we collect about you. Please send such requests to Jane Pak - firstname.lastname@example.org. You have the right to opt out of marketing communications we send you at any time.
We will respond to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
In addition, if you reside in the European Economic Area or Switzerland, you also have the following rights: You have the right to object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. You can exercise these rights by contacting Jane Pak - email@example.com.
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 the data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here:http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
12. European Economic Area
For the purposes of the Data Protection Act (‘DPA’) and in-line with the European Union General Data Protection Regulation (the ‘GDPR’), Keinex, LLC is your ‘Data Controller’ and is responsible for your personal data.
13. 1What Are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used,letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience.
Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. time-zone, notification preferences), and to personalise your content (eg. advertising, language).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognise your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third party cookies can be used for a variety of purposes, including site analytics, advertising and social media features.
13.2 Types of cookies and how we use them:
Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management and shopping carts.
Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns,identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use performance cookies on our site.
Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time-zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you're visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.
Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you're visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third- party service. We use targeting/advertising cookies on our site. (Google Analytics, Facebook, Twitter, LinkedIn, Google Ads).
Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here.
Third-party cookies on our site
13.3 Our Third-party privacy promise:
We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.
13.4 How You can control or opt out of cookies?
Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If You do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European Users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link).Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the App Choices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
14. Contact Us
If you have any questions or concerns about this Privacy Statement, please contact us by email addressed to firstname.lastname@example.org and/or by post to data Protection Officer: Jane Pak - email@example.com. 8 The Green, STE, Dover, DE, The United States, 19901