Privacy Notice

EFFECTIVE DATE: January 1, 2020

Privacy Notice

EFFECTIVE DATE: January 1, 2020

This “Privacy Notice” describes the practices of SBM Technology Corp. and its subsidiaries and affiliates (collectively, “SBM”, “we”, “us”, or “our”) and the rights and choices available to individuals, regarding personal data.  Personal data means any information that relates to an identifiable individual.

SBM 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 SBM’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.

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

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

When you make a payment at a merchant using a SBM Point of Sale system (“SBM POS”), 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 SBM POS

We may collect additional information, depending on how a merchant configures its SBM 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 SBM POS, such as your birthdate, interests or preferences, reviews, and feedback

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 related to a merchant’s use of SBM POS 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 SBM POS, such as clock-in and clock-out time, tips earned, and additional job-related information depending on how the merchant configures its SBM 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 install third-party applications on its SBM POS, much like an individual can install applications on their mobile phone or tablet device. SBM 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 run on the SBM POS 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 SBM POS

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, Google+, 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, we will treat that information in accordance with this Privacy Notice.

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 notice.

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, 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. Please refer to our Cookies Disclosure for more details. You can choose to disable cookies or to opt out of the use of your browsing behaviour for purposes of targeted advertising. For opt out instructions, please review the “Targeted online advertising” portion of the “Your Choices” section of this Privacy Notice.

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 SBM POS device using their fingerprint. 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 SBM 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

B. For research and development

We use the information we collect for our own research and 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 a SBM POS to provide your personal data to SBM POS 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 Clover 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 First Data group for marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us using the details at 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, 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 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.

I. Not Sales Your Data

We  will not sell and has not in the last 12 months sold any user data.

3. 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 unauthorised 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.

4. Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice 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 Notice, we will notify you by updating the date of this Privacy Notice and posting it on our website and in app stores where our mobile applications covered by this Privacy Notice 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 Notice 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 Notice indicates your acceptance of the terms of the modified Privacy Notice.

5. Children Under Thirteen

We does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use SBM website. SBM will not collect data from minors.

6. Contact us

If you have any questions, concerns, or complaints about this Privacy Notice or our privacy practices, or to request access to your personal data, you may contact us at info@sbmtec.com.