Notice of Privacy
INTRODUCTION
Please read this notice carefully to understand our policies and practices regarding your information and how we will treat it. For a short summary, click here. California residents can find more specific information about the California Consumer Privacy Act (CCPA) and their rights in the “CCPA” section below. The details of the Contact section are provided at the end of this notice, so that you can provide comments or make any type of privacy query you may have.
This notice applies to companies, which use different trade names in different territories, and the list of companies that collect or process personal information in accordance with this notice can be found at the end of this document.
References to “You” in this notice refer to the person who is accessing, or requesting to use, the Services (as defined below), either on their own account or on behalf of a company. This includes, in relation to a client or to any sole proprietorship and any director, including managing and financial directors, as well as any other director and authority, shareholder, partner and active beneficiary of a client, along with any member of staff accessing or use the Services on behalf of a client.
Zosxo is committed to protecting your privacy and we will take all necessary steps to ensure that your personal information is treated securely and that it is collected, used, stored and disclosed in accordance with this notice. This notice (along with our terms of use that applies to any specific service you purchase or use) applies to:
the functions and services of the website / portal that can be provided when you visit our websites, portals or our payment panels that our customers can use on their web pages;
when you request the use of Zosxo products and services (including any loyalty or reward system, whether based on points or otherwise ("Loyalty"), as well as when you request changes in the services you are using;
your use of the software, including terminals, as well as mobile and desktop applications provided by Zosxo and
email, other electronic messages, including SMS, telephone, web chat, website / portal and other communications between you and Zosxo.
They are all referred to collectively as "Services" in this notice.
INFORMATION WE MAY COLLECT ABOUT YOU
Personal and non-personal information
We collect personal and non-personal information about you.
Personal information is information that can be used to uniquely identify an individual person, either directly or indirectly.
Zosxo also collects non-personal information, or may anonymize personal information to make it non-personal. Non-personal information is information that does not identify a specific individual person, either directly or indirectly. Zosxo may collect, create, store, use and disclose such non-personal information for any reasonable business purpose. For example, Zosxo may use combined transaction information for business purposes, such as trend analysis and use of analytical data, to gain insights and insights about payment transaction usage and patterns.
To the extent that Internet Protocol (IP) addresses (or similar identifiers) are clearly defined as personal information under any local regulations and where such local regulations apply to the Services, we will treat such identifiers as personal information.
Please note that Zosxo provides services to consumers and private businesses, this privacy notice applies to both and should be read and interpreted accordingly.
COLLECTION OF YOUR INFORMATION
We collect your information through the following means:
Information you provide to us: we receive and store any information, including personal and financial information that you provide to us, including when you (or your business); view or make a request for the Services; register to use any Service; uploads and / or stores information with us using the Services and when you communicate with us via email, SMS, a website or portal, or by phone or any other electronic means, for example, in the context of contacting us about your account or transactions. Such information may refer to or be related to you or your clients, and includes:
the name, including the first and last names, date of birth, age, email address, billing address, username, password and / or photograph, biometric information, address, occupation, nationality and country of residence, a copy of your identification, such as your driver's license or passport, your social security number and / or other government identification or registration data;
Main card account number, card expiration date, CVC details (card security code), account numbers, account balances and the time that you have kept those accounts, bank and / or issuer details;
Information related to any item purchased, including purchase location, value, time, and any comments provided in connection with such purchase, including personal information related to travel when you or your customer are conducting airline ticket transactions or any other service related to travel;
Information about your use of the Services, such as information about how often you transact with us, the average volume of your transactions, account balances, and the people and merchants you send money to and from whom you receive it;
Points or rewards earned or redeemed in any loyalty system;
Photos and videos that have been obtained during Zosxo events for which you have registered, for distribution among the event participants and in our promotional materials for future events; Y
Any other information that you or your client provide or that is generated in the context of using the Services.
Information We Collect About You Automatically: Paysafe receives and stores certain information automatically whenever you interact with Zosxo, whether or not you open an account or conduct a transaction with us; for example, through "cookies" or similar technologies. We also obtain certain information when your browser accesses the Services or advertisements or other content provided by or on behalf of Paysafe on other web pages, or when email messages are clicked. Collecting this information makes it possible for us to better understand the visitors and customers who use and interact with Zosxo, where they come from, and how they use our services. We use this information for our analytical purposes and to improve the quality and relevance of our services to our visitors and customers. This information includes:
Technical information, including the Internet Protocol (IP) address used to connect your system or device to the Internet, your login information, version, browser type and version, computer type, time zone setting, browser add-on types and versions, operating system platform, frequency and duration of visits, and the links in which it clicks;
Information about your visit or whether you opened an email message, including your geolocation, the full Uniform Resource Locators (URL) clickstream, to and from our page (including date and time); products or services you have seen or searched for; Page response times, download errors, duration of visits to certain pages, information on interaction with pages (such as scrolling, clicks and mouse scrolls) and methods used for navigation outside the web page and any telephone number used to call our customer service number.
Information collected through our applications: if you download or use mobile or desktop applications provided by Zosxo, we may receive information about your location and your device or the service you are using (including the place where a payment transaction is made). Some devices allow applications to access real-time location-based information (for example, GPS). Our mobile and desktop applications may collect such information from your mobile device or computer at any time while you download or use our applications if your device has access to real-time location data enabled. When required to do so, we will always try to notify you if it is our intention to collect location information in real time and, also when required by law, to obtain your consent. We may use such information for regulatory purposes, our own due diligence checks, fraud and risk management, to better understand transaction patterns and to optimize your experience.
Email and other communications: We may receive information about you and your use of the Services when we communicate, including when you open messages from us and from the use of electronic identifiers (sometimes known as "device fingerprints"), such as addresses Internet Protocol or phone numbers.
Information from other sources: We may receive information about you from other sources and add it to our account information, including when you request to use the Services. For example, we work closely with and receive information from third parties such as business partners, banks and other financial institutions, merchants, subcontractors in technical, payment and delivery services, advertising networks, analytical data providers, search information providers, government lists and databases, social media sites (including posts made by or about you or us), credit reference agencies, and fraud prevention. The explanation of the use of credit reference and fraud prevention agencies is expanded later. We may also review public opinions and comments made on social media sites (eg, Facebook and Twitter) to better understand our customers and provide and develop the Services.
Information about other people: If you provide us with information about other people, you must have informed them in advance (for example, by providing this privacy notice) and you must ensure that you have the right to do so.
WHAT WE USE YOUR PERSONAL INFORMATION FOR
We may use and share the personal information we collect for the following purposes:
To provide our Services to you and your business, including the fulfillment of Zosxo's obligations to you or to financial and other institutions in connection with the Services we provide to you (and / or your business). In this context, we record and track data relating to transactions that you (and / or your customers) carry out in relation to the Services; we analyze and report on the use that you (and / or your clients) make of any loyalty service; we facilitate the collection or redemption of any points or other reward currency related to any loyalty program; we notify you of important changes or developments on our website or in our goods and services;
To improve and develop our business, including but not limited to optimizing our websites / portals, products and services. This may include the use of information that you insert into forms but that you do not submit to us, such as the use of that information to optimize our web pages and to contact you for customer service purposes in relation to that form. . We may also use your personal information to develop and test new products and services, including in our secure and controlled testing environment, or occasionally that of our suppliers;
To manage and exercise our rights, terms of use or any other contract with you (and / or your business), including to manage any circumstance in which transactions, rewards or points are in dispute; manage, investigate and resolve complaints; o recover debts or in connection with your insolvency;
To manage and mitigate our credit risks and business conditions. If you order one of our financial products, we may evaluate your financial position (and / or that of your business), to the extent established by the applicable terms of use. The credit check will also affect any related third party such as directors, shareholders and officers. We may do so by receiving and sharing information from and with credit reference agencies and fraud prevention agencies. The credit check will also affect anyone with whom you have a joint account or similar financial association. If it is a joint application and that link does not exist yet, one can be created. These links will remain until you file a “dissociation notice” with the credit reference agencies to the extent such dissociation is permissible. For your information, the agencies will record our inquiries that other companies that make their own credit inquiries can see, and a “fingerprint” may be placed on your credit file, whether or not you are accepted as a customer. If you are a director, in relation to the services we provide to your business, we will seek confirmation from credit reference agencies that the residence address you provide is the same one hosted in the relevant business registry (as long as proceed). In addition, when you receive services from us, we will provide the credit reference agencies with information about how you manage your accounts. If you do not repay funds on time and in full, the credit reference agencies will record the outstanding debt and may share this information with other organizations that perform checks similar to ours. Generally, records remain on file with such agencies for a period of 6 years after closing, whether paid for by you or by default, although the retention period may differ between agencies and territories. For additional information about our use of credit reference agencies, please contact us;
To prevent and / or detect fraud, financial crime, manage risk, and better protect themselves, our customers, and the integrity of the financial system, it may be necessary to process and disclose sensitive personal information (sometimes known as special category personal data). , including biometric data to third parties that help us manage these risks, including identity verification. This may include software and services that we use to verify your identity / age by determining if a selfie taken by you matches your ID photo;
During the identification process, we may use a facial recognition process to compare your selfie with your uploaded identification document. During this process, biometric data is generated by creating a digital map of your face in order to better compare your identification photo and that of your selfie. This helps reduce fraud and, therefore, it is in the great public interest. But any biometric information generated is deleted immediately after a match. Zosxo does not generally store or retain biometric data because, in general, this information is generated using secure third-party anti-fraud systems. If your biometric information is stored, preserved or used directly by Zosxo in any way, you will be notified at the point of collection. If you want to know more about our policies and processes regarding your biometric data, or even about our use of any other type of confidential or special category personal data, you can contact us through the data provided in the Contact section ;
To prevent, detect and prosecute fraud and other crimes and abuses of the financial system, or to help others to do so, including the breach of any commercial conditions and that may involve the exchange with third parties of any pertinent or necessary information that we have collected or inferred for such purposes. Zosxo participates in anti-fraud initiatives, which involve evaluating you (and / or your clients), and monitoring your transactions and / or locations, to detect patterns that require investigations or profiling and evaluating in any other way the probability of their occurrence. a fraud or the breach of our commercial conditions or those of others. We can do this by using third party products and services. On the other hand, if you give us false or inaccurate information about yourself, or we identify or suspect fraud or a crime, we may pass your information on to fraud prevention agencies and organizations, and to law enforcement and the like, and we may decide to take legal action against you;
To contact you about your account, to alert you to potential problems, and to answer your questions;
To manage risks, such as credit risks and currency risks, as well as to prevent or mitigate information security risk;
To send marketing messages, to provide you with information about products and services that you have requested or that we think may be of interest to you; to obtain your opinions about our goods, services and our website (s); Regarding marketing, market research and similar activities, we may use your personal information for such purposes, regardless of whether or not you are accepted as a customer or continue to receive the Services. If you no longer wish to receive marketing or promotional information from Paysafe, you can always interrupt it. You will find more information on this in the section "Your data protection rights";
To comply with national and local laws;
To comply with requests from regulatory authorities and law enforcement agencies based on public interest reasons or from commercial organizations with which you have or have had agreements, to establish, exercise or defend legal claims, or to protect your vital interests or those of other people; for example, to assist those authorities or other organizations in the fight against crime and terrorism; Y
To comply with the rules of the card system or any commercial conditions.
If you provide information to be published or displayed in public areas of the website / portal or transmitted to other users of the website / portal or third parties, you understand that said information may be used by third parties who access the information to any purpose. This information is published by you at your own risk and you must comply with the conditions of use of said site.
DISCLOSURE OF YOUR INFORMATION
We do not disclose information that can personally identify you to anyone, except as described in this notice, as permitted or required by law, and / or for the purposes described in this notice, including:
Within Zosxo, to help us provide our services and for our own internal customer relationship management, analytics and reporting purposes;
To the recipients / senders of a payment in the context of the specific relevant transaction (generally the information is limited to the full name and email address);
Credit reference agencies (as long as allowed under the terms of use or other contract) as described above. For additional information about our use of credit reference agencies, please contact us;
Fraud prevention agencies, as described above, including Action Fraud, Financial Fraud Action, and Financial Fraud Bureau, as well as other organizations that help us manage fraud and business risk;
Credit institutions and external financial institutions (as long as it is allowed according to the conditions of use or another contract): including the credit institution in which the sender or the recipient (and their businesses, respectively) maintain their account (s) ( s) bank (s) and card systems that govern the issuance and use of credit, debit, charge, purchase or other payment cards, alternative payment systems and any other financial institution that can process payments and that is not operating under the control of Zosxo nor for whose actions or omissions Zosxo has responsibility;
When we provide services through third parties such as banks and other organizations, we may be required to disclose your information (including any information about "know your customer" and "source of wealth") to those organizations to help them comply with their own regulatory obligations or risk assessments;
Third-party service providers, including vendors who assist us with the provision of Services, including order processing, order fulfillment, payment processing, credit management, security, industry security and fraud, verification identity, and marketing, market research and survey activities conducted on behalf of Zosxo. From time to time, we may use the services of third-party providers to assist in the provision of services that may require the use of your personal information, including for the purpose of conducting live data testing and to which appropriate security provisions will apply;
To third parties who do not act under our instructions as service providers (but who will be subject to their own legal obligations to maintain data security), in order to facilitate the provision of the Services. For example, banks and organizations that facilitate the trading of their stocks, cryptocurrencies and other financial instruments;
To prevent and / or detect fraud, financial crime, manage risk, and better protect themselves and our customers, it may be necessary to process and disclose sensitive personal information (sometimes known as special category personal data), including biometric data to third parties who help us manage such risks, including identity verification;
When required or permitted to do so by law, Zosxo may be required by law to pass information about you to regulatory authorities and law enforcement agencies around the world, or for us to conclude that it is appropriate or necessary to do so. Such disclosures may also include requests from government or public authorities, or with commercial organizations with which you may have agreements and that seek to mitigate fraud or credit risk, or the breach of commercial conditions, or for the purpose of litigation or legal process, national security, when we consider that it is in the national or public interest or it is legitimate to do so. Zosxo will not normally challenge court orders or similar that require disclosure;
Business transfers. Zosxo may sell or buy business units or affiliates. In such circumstances, we may transfer or receive customer information as a business asset. Without limiting ourselves to the foregoing, if our business enters a partnership of companies or is sold or merged with another business entity, your information may be disclosed to our new business partners or owners. In these circumstances, we will inform the recipient that their information must be treated in accordance with the standards described in this notice; Y
With your permission, your information may also be used for others purposes for which you grant your specific permission.
Except when necessary for the execution of its services as described above, Zosxo does not sell, rent, share or otherwise disclose personal information about its customers to third parties for their own third-party marketing use without complying with obligations legal requirements (for example, consent, opt-out, or as permitted by law). The California Consumer Privacy Act uses a very broad definition of data "sale" and California residents should read the "CCPA" section below regarding the sale of data.
TRACING
We monitor or record phone calls, email messages, Internet chat sessions, or other communications with you for regulatory, security, quality assurance, customer service, or training purposes. When you visit our offices, access control systems, CCTV and / or other monitoring systems may be in operation for security reasons and for office health and safety management purposes.
WHERE WE STORE YOUR PERSONAL INFORMATION
We, our service providers, and other parties with whom we may share your personal information (as described above), may process your personal information in territories outside the US Space ("USA") or within the territory in the one you reside in. It may also be processed by personnel (ours or that of our suppliers) who operate outside the United States or the territory in which the personal information was collected. Such personnel may be responsible, among other things, for fulfilling orders, processing payment details and providing assistance services in the provision of the Services. These countries may have different data protection standards (and, in some cases, lower) than the territory in which you reside.
In these circumstances, we will take appropriate measures to protect your personal information in accordance with this privacy notice and the relevant laws regarding data protection; including the use of any appropriate protection measures required by law to ensure that all international data transfers are lawful. Zosxo normally uses "Model Clauses" approved by United States law when contracting with external data recipients outside the United States who are receiving data from within the United States for the purposes of processing personal information transferred outside the United States.
HOW WE KEEP YOUR PERSONAL INFORMATION SECURED
We have implemented technical, physical and organizational / administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. These measures include:
Written information security program;
Appointment of a Chief Information Security Officer (CISO) to oversee, implement and enforce the information security program;
Appointment of a Chief Privacy Officer (CPO) to oversee, implement and enforce the privacy program;
Continuous assessment and monitoring of vulnerability;
Have risk management policies and procedures for information security;
Have an established incident response plan;
Access controls to information systems, designed to authenticate users and allow access only to authorized persons;
Restrict access to physical places that contain personal information only to authorized persons;
Secure all personal information, both in transit and at rest;
Multi-factor authentication for all personnel accessing personal information;
Maintain audit records related to internal and external access to personal information and its modifications;
Adoption of secure development practices for internally developed applications;
Perform information security due diligence on external service providers;
Regularly conduct security awareness training.
The security and protection of your information also depends on you. If we have assigned you (or you have chosen) a password or an access code to access certain parts of our website / portal or mobile applications and the like, you are responsible for keeping this password and / or access code confidential. . You must not share your password and / or access code with anyone. You must ensure that there is no unauthorized use of your password and / or access code. Zosxo will act by following instructions and information it receives from anyone who enters their user ID or and your password and you understand that you are fully responsible for all use and any actions that may take place during the use of your account, unless otherwise provided by law. You must immediately notify Zosxo of any information you have provided to us that has changed.
The transmission of information over the Internet is not completely secure. While we do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, unless you are communicating with us through a secure channel that we have provided. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
The periods for which we retain your personal information are determined based on the nature and type of information, the Zosxo Service and the country in which it is provided, as well as any relevant local legal or regulatory provisions. In general, once it is no longer needed for a legitimate business purpose or reason, your information will be deleted or we may anonymize it or combine it with other information to make it non-personal.
If you use the Services, we will retain your personal information for as long as is necessary to provide you with the services of your choice and any linked legitimate business purposes. Generally, this would mean that we retain your personal information for as long as you are our customer (or initiate such a request) and for a period of time thereafter. This will also include the use and retention of your personal information when you begin completing an application for Services, regardless of whether you complete that application process or are accepted as a customer.
The retention period may also depend on the legal and regulatory requirements of the country you are in. We will retain personal information as proof of our agreements with you (including whether or not there were financial transactions), to handle any queries or disputes, including to defend or initiate any legal claim. For example, we will retain your information for as long as local laws allow to initiate a legal claim (the so-called "statute of limitation") or for as long as we are instructed to by virtue of a court order, or by law enforcement agencies. of the law or our regulators; or as required or permitted by law (for example, withholding information about Know Your Customer, records under anti-money laundering regulations, or the like).
We may also continue to send you our direct marketing, subject to local laws and provided that you have not objected to such marketing.
YOUR DATA PROTECTION RIGHTS
You have a number of rights that you can exercise in relation to your personal information. These rights may apply under a number of different regulations, for example, the General Data Protection Regulation (GDPR), which generally applies to EEA residents, and the California Consumer Protection Act (CCPA, California Consumer Protection Act), which generally applies to California residents. If you want to access, correct or update your personal information. In certain circumstances, you can also request that we delete your personal information, object to its processing, or temporarily restrict its processing while exercising the rest of your rights. In addition, you can request that certain personal information about you be transferred to another service provider (known as data portability). You may also have the right to "opt out" of certain uses of your personal information, including asking us to limit the sharing of your personal information with affiliated and unaffiliated third parties. Privacy laws continue to develop and if you think or are not sure if any rights may apply to you, please contact us so we can evaluate and advise.
Insofar as the GDPR applies, when you give us your consent to use your personal information, you can withdraw it at any time. Withdrawing your consent will not affect the legality of any processing that we have carried out prior to its withdrawal, nor will it affect the processing of your personal information that takes place under legal processing assumptions unrelated to your consent. For example, you can interrupt any marketing communication that we send you by clicking on the "unsubscribe" or "abandon" link that appears in the communications you receive, or by following the instructions that we provide each time, but we will continue to send you messages of the type operational or service related to your Services.
Please note that, depending on the country from which you are using the Services, not all of the rights set forth above may be available to you. In addition, there may be cases in which these rights cannot be exercised: for example, you cannot object to the use of your information by us if this is due to a legal requirement, or to handle a claim; similarly, you may not request that we delete your information if you wish to continue to use our Services or as long as such information is necessary to record our contractual agreements, required by law (for example, retention of anti-fraud identification and verification requirements or " meet your client "), or in order to defend or enforce legal rights and actions.
You always have the right to lodge a complaint with the relevant data protection authority regarding the collection and use of your personal information. For more information, contact your local data protection authority. In addition, you can initiate legal action to claim compensation for damages or problems caused by our breach of data protection legislation.
If you want to know more about your rights, or want to exercise them, you can contact us using the information we provide in the Contact section.
AUTOMATED DECISION MAKING
In some cases, our use of your personal information may result in automated decisions being made (including profiling) that legally or similarly affect you.
The name of automated decisions means that a decision concerning you is made automatically based on a computer determination (using software algorithms), without our human review. For example, we use automated decisions to complete credit assessments about you when you request certain Services or to carry out anti-fraud checks, as explained in the "What we use your personal information for" section. We have implemented measures to protect the rights and interests of individuals whose personal information is subject to automated decision-making. Additionally, if you are using the Services in the US, when we make an automated decision about you, you have the right to challenge the decision, to express your point of view, and to request a human review of the decision. You can exercise this right by communicating with us through the information that appears below. Privacy laws continue to develop and if you think or are not sure if such a right may apply to you, please contact us so we can evaluate and advise.
LEGAL BASIS FOR THE PROCESSING
Zosxo will only process your personal information in accordance with the law. These laws vary between the various territories and specific information is available upon request. In general, Zosxo will process:
Based on your consent, for example to send you marketing messages about products and services in accordance with your interests and preferences, provided that such consent is required by law;
As long as it is necessary for the performance or conclusion of any contract with you, for example to provide you with the Services that you have subscribed; in that context, we need that information because otherwise we would not be able to provide the Services to you. For example, if we are asked to verify your identity and you do not provide us with the relevant information, we may not be able to open an account for you;
As long as Zosxo has a legitimate interest to process data, and such processing does not invalidate its own rights and freedoms to object to such processing. For example, to keep you informed about your use of the Services, improve and develop the Services, conduct online advertising or other marketing activities, and manage and enforce any claims;
When Zosxo has a legal obligation to collect, use and / or disclose your personal information or otherwise needs your personal information to protect your vital interests or those of another person. For example, when necessary to comply with standards imposed by our or other applicable regulators; or
Exceptionally, we may share your information with a third party when necessary for reasons of public interest, for example, when law enforcement agencies or other third parties with whom you may have agreements request information to investigate a crime or non-compliance. of the commercial conditions of a third party.
If you have any questions about this or need additional information about the legal basis on which we collect and use your personal information for any specific processing activities, please contact us through the Contact section below.
DO NOT FOLLOW UP
Some browsers can send "do not track" signals. However, there is no current industry standard for what websites and other online services should do when receiving such signals. In the event such a standard is developed, we will revise our policy, but we are currently not taking any action upon receiving such signals.
COOKIES
Please also see our Cookie Policy for details on how we collect, use or disclose information regarding cookies. Otherwise, please contact us.
CHANGES TO OUR PRIVACY NOTICE
We may, from time to time, change our privacy notice. If we make material changes in the way we treat your information, we will notify you through a notice on this website / portal. The date of the last modification of the privacy notice is indicated in this notice. Please be sure to periodically visit our website / portal and this privacy notice to check for any changes. However, if we are required by law to notify you in advance of any changes to this privacy notice and / or to request your consent to changes in our uses of your personal information, then we will do so.
LINKS TO EXTERNAL PAGES
Our page may, from time to time, contain links to the web pages of our partner networks, advertisers and affiliates. If you follow any of these links, please note that these web pages have their own privacy and cookie policies and Zosxo does not accept any responsibility or liability for such external web pages.
GLOBAL NOTICE
This notice is global in scope, but it is not intended to override any legal right or prohibition in any territory where such rights or prohibitions prevail. In such case, the rights and obligations set forth in this notice will apply, subject only to corrections from any applicable local legislation that takes precedence.
REPRESENTATIVE IN THE USA
Zosxo llc companies that are based in the US and. You can reach the representative at Zosxo through the contact details provided in the Contact section below.
CONTACT
All comments, inquiries and requests related to our use of your information are welcome. If you wish to exercise any of your rights or receive more information about the Zosxo companies to which this notice applies, you must write to the following email address zosxoinfo@gmail.com or to the contact link on the website.
California Consumer Privacy Act (CCPA)
If you are a California resident and use our Consumer Services, you may have certain rights under the California Consumer Privacy Act (CCPA) described below.
WHAT INFORMATION WE COLLECT
In the last 12 months, we collected the following personal information:
Identifiers, such as your name, age, date of birth, address and other contact details, a copy of your identification (such as your driver's license or passport), as well as your social security number and / or other government identification or information from record;
Professional or employment-related information, such as your occupation;
Internet activity, as set out in our Cookie Notice, but including the history of visits and interactions with our Services, IP address, browser type, browser language, and other automatically collected information;
Geolocation data to the extent that we need to verify your location for regulatory or anti-fraud purposes, depending on the Services provided and your use of them (for example, some laws may require us to identify your location if use of any Service involves bets);
Business information, such as information about your banking relationships, including account numbers, credit and debit card numbers, account balances, and how long you have held those accounts.
We collect this personal information to subscribe and configure your account and in order to provide our Services to you.
EXCHANGE OF PERSONAL INFORMATION WITH THIRD PARTIES
In the last 12 months, we shared any information described above with third parties for our business purposes, for example, with our affiliates or in connection with using a service provider to help us provide Services to you. The categories of such service providers are described in the Disclosure of your information section.
We do not "sell" personal information in the traditional sense, but we do sell personal information as that term is used in the CCPA. In the last 12 months, we have sold individual identifiers through the use of cookies and similar technology to users who do not exclude themselves from the use of such data. We sell these identifiers to ad technology providers (adtech) and advertisers who provide targeted online marketing.
You can "enable" or "disable" the use of cookies in the online consent panel available through the "Cookie settings" link on all of our web pages and portals.
Don't sell my personal information
YOUR CCPA PRIVACY RIGHTS
You have rights that you can exercise in relation to your personal information. In particular:
Right of access: You can request information about the categories of personal information that we have collected about you, the categories of sources from which your personal information has been collected, the business or commercial purpose for collecting or selling your personal information, as well as the categories of third parties with whom we may share or sell your personal information and the categories of personal information that have been provided to such third parties. You can also ask us for a copy of the specific personal information that we have collected about you in a machine-readable format;
Right to erasure: you have the rights to request the erasure of your personal information;
To the extent that we sell your personal information, you have the right to request that we stop selling personal information about you to third parties or you can "disable" your cookie settings here (which will have the same effect as if you chose not to sell your information personal);
Right to non-discrimination: you have the right not to be discriminated against for having exercised any of the consumer rights mentioned above. In other words, we will not provide you with a different quality of services for having chosen to exercise one of your rights.
You can authorize a person to act on your behalf in relation to the exercise of these rights, but we may have to take certain measures to verify that the request made is legitimate, that is, that it really comes from you and that it is made in your name. For example, we may require your signed permission to show that you have authorized the representative to submit the request on your behalf.
Please note that when we use and disclose personal information for security, fraud detection and other similar purposes, some of your rights may be limited. Therefore, consider that there may be cases in which your request cannot be honored. For example, as permitted by CCPA, it is We may not comply with a request to delete your personal information if we need that information in order to detect security incidents, or to protect against malicious, deceptive, fraudulent or illegal activities, when such information is necessary to record our contractual agreements or your transactions, or when required or permitted by law.
If you want to know more about your rights, or want to exercise them, you can contact us using the information we provide in the Contact section.
CONTACT
California residents can also communicate through the Contact details provided above.
This notice was last revised on 05/19/2021.