Last Updated: May 25, 2018
1. The Information We Collect
We may collect information, which includes Personal Information, in various ways. “Personal Information” means any information that relates to an identified or identifiable individual, such as name, address, telephone number, email address or credit card information. If you do not provide the Personal Information necessary to provide you with our products and services, you will not be able to benefit from them.
Information Collected via Automated Means
When you use our Services, some information is automatically collected, such as your IP address, browser type, system type, the content and pages that you access on our Services, “referring URL” (i.e., the page from which you navigated to the Services), the pages you navigate to on the Services, and from which you leave the Services, as well as the time you spend on the Services. We may use IP address to derive your approximate location.
We collect this information via automated means, such as standard server logs, cookies, clear GIFs (also known as “Web beacons”) and similar technologies. We use this information to administer, operate, and improve the Services and our other services and systems, and to provide services, content and advertising that are tailored to you.
Also, please be aware that third parties may set cookies on your hard drive or use other automated means to collect information about your use of their services or content.
Information Provided by You
We collect Personal Information that our users provide to us in a variety of ways on our Services. For instance, when you register for a CeloPay account, provide or update your account information on our Services, upload documents within our Service, or otherwise post or transmit any information or content on or to our Services, request help and support regarding any of our Services, or otherwise communicate with us, we collect the Personal Information that is provided to us. We may collect Personal Information such as name, email address, city, state, country, other demographic information, and your interests and preferences in these manners. We also collect any information that you include in the content of messages you send to us.
Information from Other Sources
We may receive Personal Information about you from third parties, including public databases and industry-standard data vendors, and may combine this information with other Personal Information we maintain about you. In addition, we collect information from our customers and their End Users to provide the Services as described above and in our Terms of Service. We may also obtain information about you from publicly available sources.
2. How We Use Your Information
We use Personal Information for a number of purposes, including to:
- Provide services and information that you request and otherwise provide support to users;
- Enhance, improve, operate, and maintain our Services, our programs, services, website, and other systems, including to protect against and prevent fraud;
- Prevent fraudulent use of our Services;
- Tailor your user experience;
- Maintain a record of our dealings with you;
- Understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, features, and functionality;
- Contact you for administrative and information purposes—this may include providing customer service or sending communications, including changes to our terms and conditions;
- Develop and provide promotional and advertising materials that may be useful, relevant, valuable, or tailored to you, or otherwise of interest;
- Achieve business purposes, such as account verification, audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention;
- Enforce our Terms of Service or as necessary to establish, exercise or defend legal rights;
- Achieve purposes for which we provide specific notice at the time of collection.
If you are located in the European Economic Area or Switzerland, we will rely on a lawful legal ground for the processing of your Personal information, including when:
- You consented to the use of your Personal Information (e.g., for our uses of cookies or similar technologies, to send you marketing communications or personalize our offerings).
- Necessary to provide you with products and services, or to respond to your inquiries.
- The processing is required by applicable law or necessary to comply with a legal obligation.
- We, or a third party, have a legitimate interest in using your Personal Information, such as to ensure and improve the safety, security, and performance of our products and services, to protect against and prevent payment fraud or to carry out data analyses.We will not engage in what is known as “automated decision-making,” which involves making decisions with legal or similarly significant effects solely based on automated processing of Personal Information, unless you explicitly consented to the processing, the processing is necessary for entering into, or to perform a contract, or when authorized by applicable law.
3. How We Disclose Your Information
When providing our Services, We may disclose Personal Information about you to our business customers (e.g., e-commerce merchants and fraud evaluation services), such as whether payment information is legitimate or potentially fraudulent, to help them prevent fraud in the context of online payments.
We also may disclose Personal Information to third-party service providers (e.g., payment processing and data storage and processing facilities) that assist us in our work.
Additionally, we may disclose Personal Information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
In addition, information about our users, including Personal Information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information could be transferred to third parties as one of our business assets.
4. Your Rights and Choices
If you receive promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving promotional emails from us by sending us an email or by writing to us at the address given at the end of this policy.
Additionally, as part of the user account functionality on our Services, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.
Please be aware that if you opt-out of receiving promotional email from us, it may take up to ten business days for us to process your opt-out request, and you may receive promotional email from us during that period. Additionally, even after you opt-out from receiving promotional messages from us, you will continue to receive administrative messages from us regarding our Services.
Cookies and Similar Technologies
CeloPay does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit our Services.
Access and Deletion
As part of the user account functionality on our Services, you may have the ability to access and update many categories of Personal Information that you provide to us by logging into your account and accessing your account settings. If you wish to access or amend any other Personal Information that you have provided to us, you may contact us at email@example.com.
If you request that we delete your user account on any of our Services (via a user settings page, by email, or otherwise), we will do so within a reasonable period of time, but we may need to retain some of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.
If you are located in the European Economic Area or Switzerland, you may have the right to:
- Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
- Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal. Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below.
Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16. If we learn that we have collected Personal Information from a child under the age of 16 on our Services, we will delete that information as quickly as possible. If you believe that we may have collected any such Personal Information on our Services, please notify us at firstname.lastname@example.org.
7. Data Transfers
Our Services are hosted primarily in the United States with most Services globally available. We may transfer your Personal Information to countries other than the country where you are located, including to the United States where we are headquartered.
When we transfer Personal Information from the European Economic Area to the United States, we comply with the EU-U.S. Privacy Shield framework. For more information, see our Privacy Shield Policy. We may also transfer your Personal Information to countries which provide an adequate level of protection under EU law, or in limited situations we may use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses. You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area.
We use reasonable security measures that are designed to protect Personal Information in our control from loss, misuse, unauthorized access, use, disclosure, alteration, or accidental, unlawful or unauthorized destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any Personal Information or other information or that it will not be accessed, viewed, or acquired by unauthorized persons.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
9. Retention Period
To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfill the following:
- the purposes for which that personal information was provided,
- an identifiable and ongoing business need, including record keeping,
- a specific legal or regulatory requirement, and/or
- a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
10. Updates to this Policy
We may occasionally update this policy. When we do, we will also revise the “last updated” date at the beginning of the policy. Your continued use of our Services after such changes will mean that you accept the revised policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose Personal Information.
11. Contacting Us
Attn: Data Protection Officer
5665 Atlanta Highway, Suite 103-403
Alpharetta, Georgia 30004