Table of Contents

Privacy Policy

This “Privacy Policy” describes the practices of the iPos Internet Point of Sale LLC, also known as iPos, entity identified below and its respective subsidiaries and affiliates (collectively, “iPos”, “we”, “us”, or “our”) and the rights and choices available to individuals, regarding personal data. Personal data means any information that identifies or can reasonably be linked with an identifiable individual.

iPos may provide additional or supplemental Privacy Policys to individuals at the time we collect their data, which will govern how we may process the information provided at that time. We may alter this Privacy Policy as needed to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries. This Privacy Policy does not apply to iPos’s processing of the personal data of its personnel, such as employees and contractors. 

1. The personal data we collect

We collect personal data about individuals from various sources described below. Where applicable, we indicate whether and why individuals must provide us with personal data, as well as the consequences of failing to do so. 

  1. Information that we collect when a merchant’s customer interacts with aiPos POS or other iPos payment method

(i) Information that we collect when individuals make a payment

When you make a payment at a merchant using a iPos Point of Sale system, on the name of all the iPos POS application, referring to, but not limited to iPos OS 3.0, iPos OS 4.0, iPos Pro Customer Display and other related apps all known and referred as “iPos POS”, the Payment Gateway connected to iPos, the iPosEats App, or any other related payment method that iPos makes available, we collect information about the transaction, which may include personal data. Information about transactions includes the payment card used, name associated with the payment card, electronic signature, name and location of the merchant at which the transaction occurred, date and time of the transaction, transaction amount, and information about the goods or services purchased in the transaction.

(ii) Additional information merchants’ customers may provide through the iPos POS

We may collect additional information, depending on how a merchant configures its iPos POS. This information may include:

  • Your email address or phone number, for example, if you choose to receive an electronic receipt or opt-in to receive marketing communications
  • Your marketing preferences, such as whether you wish to receive marketing communications or newsletters
  • Information about your participation in a merchant’s loyalty program, if offered and if you choose to participate
  • Other information you choose to enter into the iPos POS, such as your birthdate, interests or preferences, reviews, and feedback.

(iii) Additional information you may provide through the iPos branded applications

  • When you use the iPos POS, iPosEats or other iPos branded applications, you may provide your name, email address, phone number, account password, bank account information, payment card information, billing address, or other information you may choose to provide, such as your birth date, in order to collect rewards or set up an account. If you consent to the iPos Apps accessing your location information, we will collect information about your precise location in accordance with your device settings. 

B. Information that we collect from merchants about their customers

Our merchants may provide us with information about their customers. This information may include uploaded email addresses, phone numbers, and purchase history, for instance when we manage promotions or marketing communications or perform other services on behalf of a merchant.

C. Information that we collect about merchants and their personnel

  • We may collect personal data directly from merchants (including prospective customers) about themselves and their personnel. We may collect information from these parties in a variety of contexts, such as when completing one of our online forms, making an application for one of our products or services, interacting with us on social media, or corresponding with us. The types of information we obtain in these contexts include:
  • Contact information of the business entity and its personnel who interact with us, such as name, job title, address, telephone number, and email address
  • Profile information, such as username and password that an individual may establish on one of our websites or mobile applications, along with any other information that an individual enters into their account profile
  • Demographic details, such as date of birth, country of citizenship and/or country of residence
  • Information about individuals’ affiliation with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorized signatory
  • Government-issued identification numbers (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), and a copy of your government-issued identification card 
  • Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services
  • Financial account information, such as payment card or bank account details 
  • Information about merchants, such as merchant name, merchant ID and category code, merchant location where a transaction occurred, and information about transactions processed by the merchant, including transaction volume, velocity, amounts, types of goods or services sold, and chargeback ratios
  • Information about merchants, such as merchant name, merchant ID and category code, merchant location where a transaction occurred, and information about transactions processed by the merchant, including transaction volume, velocity, amounts, types of goods or services sold, and chargeback ratios
  • Information related to a merchant’s use of iPos products or services, such as account information, spending thresholds, spending activity and patterns, and information about the transactions we process 
  • Information about a merchant’s personnel and their interaction with the iPos POS, such as clock-in and clock-out time, tips earned, and additional job-related information depending on how the merchant configures its iPos POS 
  • Marketing information, such as your preferences for receiving marketing communications, merchant surveys, and details about how you engage with our marketing communications 

D. Information collected via third-party applications

A merchant may choose to connect third-party applications on its iPos Apps, much like an individual can install applications on their mobile phone or tablet device. iPos may receive personal data about merchants, merchant’s customers, or merchant’s personnel as a result of the merchant’s use of the third-party application, such as when the application enhances or performs services related to the personal data and returns information to the merchant’s account. We are not responsible for the privacy practices of third-party applications that are connected to the iPos Apps or the scope or quality of the data that such an application transmits to us; however, we will treat the data we receive from the third-party application in accordance with this Privacy Policy. 

E. Information that we collect about job applicants to iPos

We collect information about job applicants, such as name and contact information, professional credentials and skills, educational and work history, and other information of the type included on a resume or curriculum vitae. We may collect this information when an individual provides it to us directly or when another party, such as a recruiter, provides it.

F. Information that we collect from private and publicly accessible sources

We and our service providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet. We and or our third-party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference and fraud prevention agencies to the extent permitted under applicable law. We may also maintain pages for our company and our products and services on a variety of third-party platforms, such as LinkedIn, Facebook, Twitter, YouTube, Instagram, and other social networking services. When individuals interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them (e.g. for lead generation purposes), we will treat that information in accordance with this Privacy Policy.

G. Information collected via automated means

When you access our websites or use our mobile applications, we, our service providers, and our partners may automatically collect information about you, your computer or mobile device, and activity on our websites or mobile applications. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites or mobile applications, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Certain products or services that we provide or which merchants may incorporate into their websites or mobile applications may automatically collect additional information, as may be further described in a separate Privacy Policy. 

Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected via various mechanisms, such as via cookies, pixels, tags, web beacons, embedded scripts, through our mobile applications, and similar technologies. This type of information may also be collected when you read our HTML-enabled emails. You can choose to disable cookies or to opt out of the use of your browsing behavior for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Policy.

H. Sensitive personal data

In limited circumstances and when permitted by law, we may collect a merchant’s and/or their employee’s biometric data to confirm a merchant’s and/or their employee’s identity, such as when they authenticate a payment or sign into their iPos device using their fingerprint and/or Face ID. In some circumstances, we may collect information that may reveal health or medical information, such as when we process transactions at health or medical facilities or pharmacies. In the context of processing employment applications, we may also request sensitive information, such as racial or ethnic origin, where required or permitted by law of the country in which you are applying for employment. 

Outside of these contexts or otherwise as we specifically request, we ask that you not provide us with any sensitive personal data (meaning information revealing racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic, health, or biometric information, information about sex life or sexual orientation, or criminal convictions or offenses) through our websites or mobile applications, or otherwise to us. 

2. How we use your personal data

We use your personal data for the purposes of:

A. Providing our products and services, which includes:

  • Operating, evaluating, maintaining, improving, and providing the features and functionality of our products and services
  • Fulfilling a payment or return transaction initiated by you 
  • Delivering electronic receipts to consumers who request them via email or text message
  • Managing our relationship with you or your company
  • Carrying out our obligations, and exercising our rights, under our agreement with you or your company
  • Communicating with you regarding your account with us, if you have one, including by sending you service-related emails or messages (e.g., messages regarding account verification, changes or updates to the functionality of our products or services, technical and security notices and alerts, and support and administrative messages)
  • Facilitating communications between merchants’ customers and merchants regarding marketing messages and preferences 
  • Personalizing the manner in which we provide our products and services 
  • Maintaining records for merchants regarding their personnel’s interaction with and use of the iPos POS (e.g., clock-in and clock-out time)
  • Maintaining records for merchants of their customers’ purchase activity and history
  • Checking for fraud or money laundering and/or managing either our or merchants’ risk 
  • Administering and protecting our business 
  • Providing support and maintenance for our products and services, including responding to your service-related requests, questions, and feedback

In connection with the food delivery ordering services described above, including to process and fulfill your food orders, to communicate with you and the merchant regarding your orders and respond to your inquiries.

B. For research and development,

We use the information we collect for our own research development purposes, which include:

  • Developing or improving our products and services 
  • Developing and creating analytics and related reporting, such as regarding industry and fraud trends

C. Marketing

We may use your personal data to form a view on what products or services we think you may want or need, or what may be of interest to you.

We may present opportunities when you use aiPos POS to provide your personal data to iPos and merchants to facilitate marketing communications between you and the merchant, and we will send such marketing communication if you agree to receive them. 

We may contact merchants and merchant’s personnel with marketing communications using the personal data that the merchant provided to us if the merchant actively expresses interest in making a purchase of iPos products or services or have made a purchase from us and, in any case, have not opted out of receiving that marketing, to the extent permitted by applicable law. 

Where required by law, we will get your express opt-in consent before we share your personal data with any company outside the iPos for marketing purposes. 

You can ask us to stop sending you marketing messages at any time by contacting us using the details in the Contact us section or clicking on the opt-out link included in each marketing message. 

Should you choose to opt out of receiving our marketing messages, we will continue to carry out our other relevant activities using your personal data, including sending non-marketing messages.

D. Managing our recruiting and processing employment applications

We process personal data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

E. Complying with law

We use your personal data as we believe necessary or appropriate to comply with applicable laws, regulations, lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities. 

F. Compliance, fraud prevention and safety

We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern our products and services; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

G. With your consent

In some jurisdictions, applicable law may require us to request your consent to use your personal data in certain contexts, such as when we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal data, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly. 

H. To create anonymous data

We may create anonymous or aggregated data from your personal data and from other individuals whose personal data we collect. We make personal data into anonymous or aggregated data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes. 

3. The parties with whom we share your personal data

A. Companies within the iPos

We may disclose your personal data to our subsidiaries and corporate affiliates – including those in the iPos of companies – for purposes consistent with this Privacy Policy. 

B. Service providers

We employ third party companies and individuals to administer and provide services on our behalf (such as companies that provide customer support, companies that we engage to host, manage, maintain, and develop our website, mobile applications, and IT systems, companies that help us process payments, companies that assist with food delivery on behalf of our Merchants, and companies that help us analyze your usage of our services for product improvement purposes). These third parties may use your information only as directed by iPos in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

C. Merchants and Applications that run on the iPos POS Used by Merchants

When iPos performs services for merchants, it may share personal data with those merchants. For example, iPos may collect information about a merchant’s customers from or on behalf of the merchant, such as when iPos processes payment transactions, and iPos may provide personal data about those customers back to the merchant. When you place a food order via iPos’s “iPosEats”, or when iPos receives your information in connection with an order placed on another company’s website, app or service, we may share that information with the Merchant in order to fulfil your order. We are not responsible for the privacy practices of merchants who use our services. 

Third-party applications that a merchant has connected to iPos Apps may be capable of providing instructions to iPos to engage in a transfer of personal data, similar to how a merchant could provide such directions. For example, an application may direct iPos to export data or reports to a third-party cloud storage system. Merchants are responsible for their use of third-party applications, the directions that the application provides to iPos, and iPos’s reliance on those directions. iPos is not responsible for the privacy policy or practices of any third-party application. 

D. Participants in the transaction processing chain

iPos shares personal data with companies in the transaction processing chain in connection with processing a payment transaction, such as merchants, banks or other card issuers, card associations, debit network operators and their members.

E. Credit reference, fraud protection, risk management, and identity verification agencies

iPos shares personal data with credit reference, fraud protection, risk management, and identity verification agencies to help guard against, detect, and respond to fraud or money laundering, and/or manage our or merchants’ risk, and ensure we comply with contractual, legal, or regulatory requirements. 

F. Professional advisors

We may disclose your personal data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us. 

G. To comply with laws and law enforcement; protection and safety

iPos may disclose information about you to government or law enforcement officials (including tax authorities) or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to: 

(i) Comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities; 

(ii) Enforce the terms and conditions that govern our products and services;

(iii) Protect our rights, privacy, safety or property, and/or that of you or others; and 

(iv) Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. 

H. Business transfers

iPos may sell or transfer some or all of its business or assets, including your personal data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy. 

I. To other parties with your permission or to fulfill a contract they have with you

iPos may transfer your personal data to any third party who is not otherwise covered by the other listed categories above where you have given us permission to do so, or with whom you have entered into a contract when we need to transfer your personal data to that party in order to fulfill that contract.

4. Your rights and choices

In this section, we describe the rights and choices available to all users. Users subject to additional jurisdiction-specific disclosures may read additional information about their rights below. 

A. Marketing communications

You can ask us to stop sending you marketing messages at any time by contacting us or clicking on the opt-out link included in each marketing message. You may continue to receive service-related and other non-marketing messages. You may unsubscribe from a specific merchants’ communications sent to you via iPos’s technology by clicking “Unfollow” (or a similarly-titled opt-out link). 

B. Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals

C. Choosing not to provide your personal data

Where we request personal data directly from you, you do not have to provide it to us. If you decide not to provide the requested information, in some circumstances we, or merchants who use iPos, may be unable to provide products or services to you. For example, we may be unable to process your transaction.

D. Accessing, modifying or deleting your information

In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete their personal data. You may contact us directly to request access to, or modification or deletion of, your information. We may not be able to provide access to, or modify or delete, your information in all circumstances.

E. Complaints

If you have a complaint about our handling of your personal data, you may contact our data protection officer using the contact information below. We request that a complaint be made in writing. Please provide details about your concern or complaint so that our data protection officer can investigate it. We will take appropriate action in response to your complaint, which may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also may have a right to file a complaint with a national or local regulatory agency.

5. How we keep your data safe

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

6. Links to other websites

We may link to third-party websites, mobile applications, and other content. iPos is not responsible for the privacy practices of any third party, and this Privacy Policy does not apply to such third party’s websites, mobile applications, or other content. iPos does not guarantee, approve, or endorse any information, material, services, or products contained on or available through any linked third-party website, mobile application, or other content. iPos is not responsible for any content on third-party properties to which we link. iPos provides links to third-party properties or content as a convenience, and visiting or using linked third-party properties or content is at your own risk.

7. How long will you use my personal data

We will use your personal data for as long as necessary based on why we collected it and what we use it for. This may include our need to satisfy a legal, regulatory, accounting, or reporting a requirement.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In general terms, we will retain your personal data for as long as is necessary for the purposes identified in this Privacy Policy, including to provide our Services, to comply with legal obligations, to enforce and prevent violations of our Terms, to protect against fraudulent activity, and to defend our legal rights, property and users.

9. Information for California Residents

The information provided in this “Information for California Residents” section only applies to California residents. This notice describes how we collect, use and disclose your Personal Information (as defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, or “CCPA”), and your rights with respect to that Personal Information.

Your California privacy rights

As a California resident, you have the rights listed in the section above titled Accessing, correcting or deleting your information. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

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. 

How to exercise your rights

If you are a California resident, you may exercise your access, correction, and deletion rights as follows: 

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 will require the authorized agent to have a written authorization confirming that authority. 

Sale or Sharing of Personal Information for cross-context behavioural advertising

Our websites and online services may use analytics and advertising tools that enable our analytics and marketing partners to collect and disclose internet or other electronic network activity information based on your activity across our services and sites, including to analyze your usage of our services and to serve you advertisements that are relevant to you (collectively, “cross-context behavioural advertising”). However, please note that we do not knowingly sell or share the Personal Information of consumers under 16 without consent. 

You have the right to opt-out of our sale or sharing of your Personal Information using our opt-out tool located in the bottom right-hand corner of your screen. 

Personal information that we collect, use and disclose

The chart below summarizes our collection, use and disclosure of Personal Information during the last 12 months. We describe the sources through which we collect your Personal Information in the section above titled The Personal Data We Collect and describe the purposes for which we collect, use, and disclose this information in the section above titled How We Use Your Personal Data and The Parties With Whom We Share Your Personal Data.

Category
Do we collect this information?
Do we share this information for business purposes?
The examples of categories of third parties to whom we disclose this information
Identifiers
From you directly;From our merchants;Third party developers via Clover’s app market;From companies providing online food delivery services;Recruiters; References and background checks; Bank, ISO, or referral partners.
To deliver to you e-receipts or transaction information or confirmations; To create and manage your account/profile; To provide you with our applications; To create and manage your merchant account; To receive food deliveries or process food orders.; To process and consider your application to become a merchant or employee; When a merchant enters or makes available your information in our system; For merchant recruitment, marketing purposes and surveys; For our Everyday Business Purposes.
You, e.g. to provide receipts and information about your orders; Our vendors and service providers; Our merchants to provide the services; Social networks; Credit Reporting Bureaus; Our affiliates.
Online Identifiers
From you directly
To record and maintain your interactions with our services; To keep you logged in; For security purposes; To measure, understand and analyze how our products are used and improve our products; For advertising and marketing purposes; For our Everyday Business Purposes.
Our vendors and service providers; Marketing partners under certain circumstances.
Protected Classification Characteristics (We may collect your age.)
From you directly; From our merchants; Recruiters; References and background checks;
To fulfil applications or otherwise handle related to the purpose for which you share this information; For our Everyday Business Purposes.
Our vendors and service providers.
Commercial Information
From you directly; Bank, ISO, or referral partners.; Advertising networks; Government entities; Data brokers.
To fulfill our business relationship with you, including customer service; For recordkeeping and compliance, including dispute resolution; For internal business purposes, such as finance, quality control, training, reporting and analytics; For risk management, fraud prevention and similar purposes; For our Everyday Business Purposes.
You, e.g. to provide receipts and information about your orders; Our vendors and service providers; Our merchants to provide the services; Credit Reporting Bureaus; Data analytics providers. Our affiliates.
Biometric Information
From you directly
For our Everyday Business Purposes.
No
Internet or Network Information
From you directly
For our Everyday Business Purposes.
Our vendors and service providers;
Geolocation Data (We may collect your precise geolocation data in some scenarios.)
From you directly
To provide location-based information, such as where your nearest Clover merchants are; For our Everyday Business Purposes.
Our vendors and service providers;
Professional or Employment Information
From you directly; Social networks; Recruiters; References and background checks;
To process and consider your application to become a merchant or employee; For our Everyday Business Purposes.
Our vendors and service providers; Our advisors and attorneys.
Education Information
From you directly; Social networks; Recruiters; References and background checks; n/a
To process and consider your application to become a merchant or employee; For our Everyday Business Purposes.; To better understand you and to understand our customers generally; To design products, services and programs that help our customers; To identify prospective customers; For internal business purposes, such as quality control, training and analytics; For our Everyday Business Purposes.
Our vendors and service providers; Our advisors and attorneys.; Our vendors and service providers; Data analytics providers.
Financial Information
From you directly; From our affiliates with whom you do business.
To fulfill our business relationship with you, including customer service; For recordkeeping and compliance, including dispute resolution; For internal business purposes, such as finance, quality control, training, reporting and analytics; For risk management, fraud prevention and similar purposes; For our Everyday Business Purposes.
Our vendors and service providers; Data analytics providers.
Medical Information
n/a
n/a
N

Please note that we may also disclose personal information for our Everyday Business Purpose and to comply with law, for compliance, fraud prevention, and safety purposes; in the event of business transfers; and to our professional advisors, and as further described above in Section 3 of this Privacy Policy. 

We will retain your Personal Information as set forth above. 

Glossary

Categories of Personal Information

Examples of Elements Within the Category

Biometric Information

An individual’s physiological, biological or behavioral characteristics, including information pertaining to an individual’s DNA, that is used or is intended to 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.

Commercial Information

Commercial information, including records of personal property, 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.

Inferences

Inferences drawn from any personal information collected to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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.

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). Racial or ethnic origin, religious or philosophical beliefs, genetic data, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation are considered to be sensitive personal information under the CCPA.

Sensory Information

Audio, electronic, visual, thermal, olfactory, or similar information.

Every-day Business Purposes

This means the use of personal information for our operational purposes, or other notified purposes, which may include: auditing relating to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards, helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes, debugging to identify and repair errors that impair existing intended functionality, short-term transient use including, but not limited to, non personalized advertising shown as part of a consumer’s current interaction with us, performing services on behalf of a business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business, providing advertising and marketing services (other than cross-contextual behavioral advertising), undertaking internal research for technological development and demonstration, and undertaking activities to verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our products and services.

We do not use or disclose Sensitive Personal Information except for purposes for which you do not have a right to limit the use and disclosure of Sensitive Personal Information under the CCPA. For example, we may use Sensitive Personal Information to provide you products or services you have requested. 

10. Information for Residents of Virginia

The information provided in this “Information for Virginia Residents” section only applies to residents of the Commonwealth of Virginia acting in an individual or household context. It does not apply to the data or Virginia residents acting in a commercial or employment context. This notice describes the rights you may have with respect to your personal data under the Virginia Consumer Data Protection Act, or “VCDPA”). We describe the categories of personal data that we process and disclose to third parties,the purposes for which we process personal data, and the categories of third parties that we disclose personal data to in the sections above titled The Personal Data We Collect, How We Use Your Personal Data, The Parties With Whom We Share Your Personal Data, and the Personal information that we collect, use and share sub-section of the Information for California Residents section. 

As a Virginia resident, you may have the rights listed in the section above titled Accessing, correcting or deleting your information. However, these rights are not absolute, and we may decline your request as permitted by the VCDPA. 

How to exercise your rights

If you are a Virginia resident, you may exercise your access, correction and deletion rights as follows, by: 

You can also appeal a denial of your request through the requests portal, or by email to support@ipointofsale.com

11. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website and in app stores where our mobile applications covered by this Privacy Policy are available for download. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our website or mobile applications. 

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes (or as otherwise indicated at the time of posting). In all cases, your continued use of our products or services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. 

12. Contact us

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, or to request access to your personal data, you may contact our Data Protection Officer at support@ipointofsale.com

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