SYGNIO PRIVACY POLICY

This Privacy Policy describes the practices of Sygnio and its subsidiaries and affiliates (collectively, “Sygnio”, “we”, “us”, or “our”) and the rights and choices available to individuals, regarding personal data. Sygnio is a member of TSYS. Personal data means any information that relates to an identifiable individual.

Sygnio may provide additional or supplemental privacy notices 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 Statement as needed to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries. This Privacy Notice does not apply to Sygnio’s processing of the personal data of its personnel, such as employees and contractors.

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

1. Personal Data We Collect

We collect personal data about individuals from various sources described below. When applicable, we indicate whether and why individuals need to provide us with personal data, as well as the consequences if they fail to provide such data.

A. Information that we collect when a merchant’s customer interacts with a Sygnio POS

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

When you make a payment at a merchant using a Sygnio Point of Sale system (“Sygnio POS”), we collect information about the transaction, which may include personal data. Information about transactions includes the payment card used, the name associated with the payment card, your 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 you purchased in the transaction.

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

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

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 perspective 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 situations include:

D. Information collected via automated means

Cookies: We may collect information from you through automatic tracking systems (such as information about your browsing preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Website, as described above).

For example, we use cookies to make your browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his or her preferences or the device they are using to access the Internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt the operation of the site to your expectations, offering a more personalized browsing experience and memorizing the choices you made previously.

A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.

Cookies do not record or store any Personal Data. If you want, you can prevent the use of cookies, but then you may not be able to use our Website as we intend. To proceed without changing the options related to cookies, simply continue to use our Website.

Technical cookies: Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the site. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows the safe and efficient use of the site.

You can manage or request the general deactivation or cancelation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the site.

Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Website. These are also considered technical cookies when they operate as described.

Temporary session cookies are deleted automatically at the end of the browsing session - these are mostly used to identify you and ensure that you don't have to log in each time - whereas permanent cookies remain active longer than just one particular session.

Third-party cookies: We may also utilize third-party cookies, which are cookies sent by a third-party to your computer. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising for users.

Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the site. Third-party analytical cookies are used to detect information on user behavior on our Website. This place anonymously, in order to monitor the performance and improve the usability of the site. Third-party profiling cookies are used to create profiles relating to users, in order to propose advertising in line with the choices expressed by the users themselves.

Profiling cookies: We may also use profiling cookies, which are those that create profiles related to the user and are used in order to send advertising to the user's browser.

When these types of cookies are used, we will receive your explicit consent.

Support in configuring your browser: You can manage cookie through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for this Website.

For further information and support, you can also visit the specific help page of the web browser you are using:

Log Data: Like all websites and mobile applications, this Website also makes use of log files which store automatic information collected during user visits. The different types of log data could be as follows:

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Website or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Website and our users. Such information will be treated according to the legitimate interests of the Data Controller.

2. How we use your personal data

We use your personal data for the purposes of:

A. Providing our products and services, which includes:

B. For research and development

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

C. Complying with law

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

D. 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.

E. 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.

F. To create anonymous data

We may create anonymous data from your personal data and from other individuals whose personal data we collect. We make personal data into anonymous 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. Service providers

We may 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, and companies that help us process payments). These third parties may use your information only as directed by Sygnio in a manner consistent with this Privacy Notice and are prohibited from using or disclosing your information for any other purpose.

B. Third-party applications that run on the Sygnio POS

Third-party applications that a merchant has installed on a Sygnio POS may be capable of providing instructions to Sygnio to engage in a transfer of personal data, similar to how a merchant could provide such directions. For example, an application may direct Sygnio 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 Sygnio, and Sygnio’s reliance on those directions. Sygnio is not responsible for the privacy policy or practices of any third-party application.

C. Merchants

When Sygnio performs services for merchants, it may share personal data with those merchants. For example, Sygnio may collect information about a merchant’s customers from or on behalf of the merchant, such as when Sygnio processes payment transactions, and Sygnio may provide personal data about those customers back to the merchant. We are not responsible for the privacy practices of merchants who use our services.

D. Participants in the transaction processing chain

Sygnio 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 and verification agencies

Sygnio 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

Sygnio 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

Sygnio 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 Notice.

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

Sygnio 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 fulfil that contract.

4. Your rights and choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe 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 Sygnio’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. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

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 Sygnio, 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. International transfers

Sygnio is headquartered in the United States, and it maintains offices and has service providers in other countries, such as the countries listed here. Your personal data may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where we or our service providers maintain offices and where privacy laws may not be as protective as those in your jurisdiction. If we make such a transfer, we will require that the recipients of your personal data provide data security and protection in accordance with applicable law. European users should read the important information provided here about transfer of personal data outside of Europe.

6. 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 maintain annual compliance with global Payment Card Industry Data Security Standard (PCI DSS) adopted by the payment card brands for all companies that process, store or transmit cardholder data.

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.

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