Effective as of August 15, 2018.
PayPerse, Inc. and its operating divisions, subsidiaries, affiliates and branches (collectively, "PayPerse," the "Company," "we" or "us") are committed to protecting the privacy of information you provide to us. Accordingly, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information ("Privacy Statement").
Except as where otherwise indicated, this Privacy Statement applies to individuals who visit PayPerse’ websites (the "Sites"), individuals who register to attend the PayPerse’ online or offline events, use the PayPerse big data platform, PayPerse’ mobile applications, mobile wallet, or other programs, services or offerings of PayPerse (together with the Sites and any and all future online and offline offerings operated by or on behalf of PayPerse, the "Services").
Transparency/Notice-What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with PayPerse and the requirements of applicable law. Below are some of the ways we collect information and how we use it.
INFORMATION PAYPERSE COLLECTS
In general, PayPerse collects information from you based upon our business relationship, your use of our Sites and Services, and includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, Internet Protocol address, and billing and payment information related to payments for Services or programs.
HOW PAYPERSE COLLECTS PERSONAL INFORMATION
Some of the ways that PayPerse may collect your Personal Information include:
INFORMATION FROM THIRD-PARTY SOURCES
PayPerse may collect information about you from Third-Party sources to supplement information provided by you, including Internet Protocol addresses, cookies, navigational data and advertisements clicked. This supplemental information allows us to verify information that you have provided to PayPerse and to enhance our ability to provide you with information about our business, products and Services. PayPerse’ agreements with these Third Party-sources typically limit how the Company may use this supplemental information.
From time to time, PayPerse may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
HOW PAYPERSE USES YOUR PERSONAL INFORMATION
Depending on how you interact with PayPerse, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:
Generally, online social media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.
PayPerse may collect Personal Information to enable individuals to use online social media resources offered either by PayPerse or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.
If you use on online social media resource offered by a Third Party ("Third Party SMR") through the Services, you acknowledge that PayPerse may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit PayPerse to access. PayPerse will comply with the terms of this Privacy Statement and the privacy policies applicable to the social media resources it uses.
DIRECT MAIL AND EMAIL MARKETING
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters or mailings from us with information on PayPerse or our business partners' products and Services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.
ALL INTERNET USERS - COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
Like many other websites, PayPerse or its business partners may employ a cookie, or small piece of computer code that enables Web servers to "identify" visitors, each time an Individual initiates a session on the Company's Sites. A cookie is set in order to identify visitors; tailor our Sites to you; measure and research the effectiveness of our Sites' features, offerings and advertisements; and authenticate users for registered Services. Cookies can only access Personal Information that you have provided on our Sites and cannot be accessed by other sites. Individuals also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser. However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of PayPerse’ Sites.
PIXEL TAGS/WEB BEACONS
PayPerse may use "pixel tags," also known as "web beacons," which are small graphic files that allow us to monitor the use of our Sites. A pixel tag can collect information such as the Internet Protocol ("IP") address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our Third Party-service providers may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our email.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit?www.google.com/policies/privacy/partners/?. You can opt out of Google's collection and processing of data generated by your use of the Services by going to?http://tools.google.com/dlpage/gaoptout?
Through our Sites, PayPerse may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-PayPerse related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising."
PayPerse may provide websites, applications and online resources that are specifically designed to be compatible and used on mobile devices. PayPerse will collect certain information that your mobile device sends when you use such websites, applications or online resources, like a device identifier, location, user settings and the operating system of your device.
Mobile versions of PayPerse’ Sites may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, PayPerse may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to PayPerse to enable you to access user accounts and to enable PayPerse to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. PayPerse may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Statement or in other notices PayPerse provides.
ANONYMOUS AND AGGREGATED INFORMATION
PayPerse may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Sites or other online Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors' interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and PayPerse may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within PayPerse and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Choice/Modalities to Opt Out
You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Statement.
Where you have consented to PayPerse’ Processing of your Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. Note that, due to the nature of the Services, you may have to provide the email or other identifying value that is associated with your Personal Information in order for PayPerse to segregate out the use and retention of such Personal Information.
Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the individual, PayPerse will endeavor to obtain each individual's explicit consent (opt-in). Where consent of the individual for the Processing of Personal Information is otherwise required by law or contract, PayPerse will comply with the law or contract.
"DO NOT TRACK"
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. At this time, there is no general agreement on how companies like PayPerse should interpret DNT signals. Therefore, PayPerse does not recognize or respond to browser-initiated DNT signals, whether that signal is received on a computer or a mobile device. For information about "do-not-track", visit?http://www.allaboutdnt.org
INFORMATION WE SHARE
PayPerse does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Statement or as you explicitly consent. PayPerse endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by PayPerse (and at least the same level of privacy protection as is required by the Privacy Shield Principles and this Privacy Statement).
PayPerse may share Personal Information with our service providers that we have retained to perform Services on our behalf including (i) provision of IT and related Services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.
PayPerse has executed appropriate contracts with our service providers that prohibit service providers from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
From time to time, PayPerse may partner with other companies to jointly offer products, services or programs (such as webinars, events or downloadable content). If you purchase, specifically express interest in or register for a jointly-offered product, service or program from or through PayPerse, the Company may share your Personal Information collected in connection with your purchase or expression of interest with our business partners. PayPerse does not control our business partners' use of shared Personal Information and their use of such information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.
INFORMATION DISCLOSED FOR OUR PROTECTION AND THE PROTECTION OF OTHERS
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce PayPerse policies or contracts; (v) to collect amounts owed to PayPerse; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes - e.g., to detect unauthorized activity on the Services. In such cases, server log data containing Personal Information may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
INFORMATION DISCLOSED IN CONNECTION WITH BUSINESS TRANSACTIONS
We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, PayPerse will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Statement.
PayPerse primarily stores Personal Information sent or collected via or by PayPerse in the cloud, our servers, the servers of our affiliates or the servers of our service providers. To facilitate the Company's global operations, the Company may transfer, store and access such information from around the world. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to PayPerse, you consent to the storage of your Personal Information in these locations.
DATA PROTECTION ADDENDUM
While the data protection, privacy and other laws of the Republic of Korea might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a Data Protection Addendum (DPA) to our agreement.
Rights of Access, Rectification, Erasure and Restriction
YOUR PERSONAL INFORMATION
You may seek confirmation regarding whether PayPerse is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of applicable data protection laws. Where otherwise permitted by applicable law, you may use the email address set forth in Section 8 of this Privacy Statement to request access to, receive (port), restrict Processing, seek rectification or request erasure of Personal Information held about you by PayPerse. Such requests will be Processed in accordance with local laws. Although PayPerse makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which PayPerse is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual's privacy in the case in question or where it is commercially proprietary. If PayPerse determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, PayPerse will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
As a data processor for our Customers, PayPerse Processes data that may include Personal Information of Users ("Customer Data"). PayPerse will not review, share, distribute or reference any such Customer Data except as provided in the agreements between us and our Customers, or as may be required by law. If Personal Information pertaining to you as an individual has been submitted to us by a Customer as Customer Data and you wish to exercise any rights you may have to access, correct, amend or delete such data, please inquire with the relevant Customer directly. Because PayPerse personnel have limited ability to access Customer Data, if you wish to make your request directly to PayPerse, please provide the name of the relevant PayPerse customer. We will refer your request to that Customer, and will support them as needed in responding to your request within a reasonable timeframe.
PayPerse retains the Personal Information we receive as described in this Privacy Statement for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
The security of all Personal Information provided to PayPerse is important to us, and PayPerse takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while PayPerse strives to protect your Personal Information, we cannot ensure or warrant the security of information you transmit to PayPerse. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company firstname.lastname@example.org
Redress/Compliance and Accountability
If after reviewing this Privacy Statement, you would like to submit a request or you have any questions or privacy concerns, please contact:
PayPerse will address your concerns and attempt to resolve any privacy issues in a timely manner.
If you are an EU or Swiss citizen and feel that PayPerse is not abiding by the terms of this Privacy Statement, please contact PayPerse at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.
Other Rights and Important Information
INFORMATION REGARDING CHILDREN
Due to the nature of PayPerse’ business, Services are not marketed to minors. PayPerse does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). This applies to any Personal Information directly collected by us, but does not apply to the Personal Information provided to us by Third Party services and organizations or from our Customers regarding Users (please refer to the terms of their respective Privacy Policies). If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16) in relation to the Services, we will promptly delete that information.
LINKS TO THIRD-PARTY DIGITAL PROPERTIES
CHANGES TO THE PRIVACY STATEMENT
PayPerse may update this Privacy Statement from time to time as it deems necessary in its sole discretion. PayPerse will provide notification of any material changes to this Privacy Statement through the Company's Sites or as otherwise required by applicable law. PayPerse encourages you to review this Privacy Statement periodically to be informed regarding how PayPerse is using and protecting your information and to be aware of any policy changes. Your continued relationship with PayPerse after the posting or notice of any amended Privacy Statement shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by PayPerse.
This Privacy Statement shall be implemented by PayPerse and all its operating divisions, subsidiaries and affiliates. PayPerse has put in place mechanisms to verify ongoing compliance with this Privacy Statement. Any Employee that violates these privacy principles will be subject to disciplinary procedures.
"Personal Information" is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Process" or "Processing" means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"Sensitive Data" or "Sensitive Personal Information" is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a "Special Category of Personal Data" under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual's sex life; or (8) information relating to the commission of a criminal offense.
"Third Party" is any natural or legal person, public authority, agency or body other than the Individual, PayPerse or PayPerse’ agents.