Privacy Policy

LegalSimpli Software, LLC. doing business as PDFSimpli, (hereinafter “PDFSimpli”) website (the “Site”) and other plug-ins exchanging information with PDFSimpli (“Applications”). (The Site and Applications are sometimes collectively referred to as “Online Services”) PDFSimpli takes your privacy seriously, and has implemented this privacy policy (the “Privacy Policy”) to keep your personal and financial information secure.

The Privacy Policy covers PDFSimpli’s treatment of the Personally Identifiable Information we collect when you use the Online Services. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy is incorporated into our Terms of Service. By using PDFSimpli Online Services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, please contact Customer Service at support@PDFSimpli.com.

Contents

  1. Information Collected
  2. Use of Information
  3. Links
  4. Accessing and Changing Your Account
  5. How Secure Is the Personal Information We Collect?
  6. Privacy Policy Revision History

Information Collected

Traffic Data. PDFSimpli may collect a variety of visitor data such as IP addresses, browser settings, internet service provider (ISP) information, referring/exit pages, operating systems, date/time stamps, and clickstream data (collectively “Visitor Data”). The PDFSimpli internal servers and software automatically recognize Visitor Data. The Site may use Visitor Data to compile traffic data about the types of visitors who use the Site at specific intervals (collectively “Traffic Data”). We may use Traffic Data to analyze Site traffic, but this information is not examined for Personally Identifiable Information. We may also use Traffic Data to diagnose problems with our server, administer our Site, or display content according to your preferences. Visitor Data and Traffic Data may also be shared with business partners, affiliates, or advertisers on an aggregated and anonymous basis.

Cookies. PDFSimpli and its partners may use the standard cookie feature of major browser applications and third-party providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow PDFSimpli to store a small piece of data on a visitor’s computer, or any other device a visitor uses to access Online Services, about his or her visit to the Site or use of Applications. PDFSimpli does not capture Personally Identifiable Information in cookies or use cookies to mine Personally Identifiable Information. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited. To manage Flash cookies, please click here:www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Web Beacons. We employ a software technology called clear gifs (a.k.a. web beacons), that help us track referrals from our partners and affiliates and better manage content on our site. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ Personally Identifiable Information.

3rd Party Tracking. The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media links) on the site is not covered by our Privacy Policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers’ or Users’ Personally Identifiable Information.

Privacy Policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies. We do not tie the information gathered to our Customers’ or Users’ Personally Identifiable Information.

Personal Information. PDFSimpli requires each customer to provide us with personal information (collectively “Personally Identifiable Information”) to access and use PDFSimpli products and services. Personally Identifiable Information is captured when a visitor accesses Online Services, or speaks on the phone with a PDFSimpli employee, and willingly discloses that information. This disclosure may occur when a visitor registers with an Online Service, engages in transactions, contacts customer service, or participates in contests, promotions, surveys, forums, content submissions, requests for suggestions, or other aspects of services offered by PDFSimpli.

Personally Identifiable Information includes but is not limited to: (i) “Contact Data” (such as your name, address, city, state, zip code, phone number, and email address); (ii) “Financial Data” (such as your credit card number, expiration date, and verification code or bank account information); (iii) “Demographic Data” (such as your zip code and sex); and (iv) other “Legal Data” (such as your social security number, mortgage information, automobile information, marital information, trade secrets, inventions, and idea submissions and other sensitive information necessary to generate legal documents).

We may collect the information of 3rd party individuals as necessary, such as to ask our customers to indicate beneficiaries of a will, record shareholders of a company, or register authorized contacts to access their PDFSimpli account. PDFSimpli uses this information for the sole purpose of administering its services for our customers, and does not use such information for any other reason.

If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at support@PDFSimpli.com.

Testimonials and Reviews. We display personal testimonials of satisfied customers received through email surveys. We ask for your specific consent as part of the survey. If you wish to update or delete your testimonial, you can contact us at support@PDFSimpli.com. We also display customer reviews. If you provide a review that we display and wish to update or delete it, you can also contact us at support@PDFSimpli.com.

Calls/Electronic Communications. In the regular course of our business, PDFSimpli may monitor and record phone conversations or email communications between you and PDFSimpli employees for training and quality assurance purposes. We may receive a confirmation when you open or click on content in an email from us, which helps us make our communications to you more useful and interesting. If you do not wish to receive email from PDFSimpli, you may unsubscribe from our mailing list by using the “Unsubscribe” link on any of the emails we send.

Use of Information

We use information we collect from the Online Services to communicate with you, process your orders, facilitate your transactions with our third-party marketing partners, and inform you of offers and discounts. For example, you may receive a welcome email that confirms your username and password, and later receive communications responding to your inquiries, providing services you request, and managing your account. We occasionally send service-related announcements, for example, to alert you if we need to temporarily suspend the Site for maintenance.

Opting Out. We send promotional emails and newsletters from time to time to users who have registered on the site and to those who have opted in to receive such emails. Generally, you may not opt-out of service-related or transactional communications, which are not promotional. If you do not wish to receive service-related communications, you may terminate your account by contacting customer service at support@PDFSimpli.com. However, you can opt-out of promotional communications by using the “Unsubscribe” link and following the unsubscribe instructions in any electronic communication or by emailing us at support@PDFSimpli.com.

You may choose not to provide PDFSimpli with Personally Identifiable Information or you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to use the Online Services and browse its pages. However, PDFSimpli cannot process orders without Personally Identifiable Information.

Surveys, Sweepstakes, and Contests. We may provide you the opportunity to participate in surveys on our site, to measure customer satisfaction. If you participate, we may request certain personally identifiable information from you. Participation in these surveys, sweepstakes, or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes name, email address, and mailing address.

We use this information to notify contest winners and award prizes, to monitor site traffic or personalize the site, and/or to send participants an email newsletter.

We may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personal information for any other purpose. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.

We share customer information with third parties only as follows:

Order Processing. PDFSimpli, sometimes with the assistance of a third party or PDFSimpli subsidiary, may use your Personally Identifiable Information to process your payment through merchant account services, and to generate the products and services you order. Your Contact Data may be used to follow up with you on transactions you initiate through Online Services, respond to inquiries made through Online Services, inform you of changes to Online Services, and send you additional information about PDFSimpli and its products and services.

Third Party Marketing. Unless specifically authorized by you, we do not provide Personally Identifiable Information to third parties for marketing purposes. If you express interest in a third party offer or purchase a package that includes a third party offer, we may provide your Personally Identifiable Information to that third party solely in connection with the offer you have selected.

Required by Law. We may also disclose your personal information: as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.

Visitor Demographics. Contact Data and Traffic Data are used to gather general statistics about our customers and visitors. We may use Demographic Data to generate collective information about our users, but not in a way that identifies any user specifically. For example, we may inform third parties about the number of registered users and unique visitors, and the pages most frequently browsed.

Service Providers.We may share your Personally Identifiable Information with companies that provide support services to us (such as a printer or email service provider), help us market our products and services, or for training purposes. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.

Partner and Affiliate Tracking.Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect non-personally identifiable information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visits to our site. Together with our partners and affiliates, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to our site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at aboutads.info/choices.. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also visit Google Analytics’ Ads Settings to opt out of Google’s use of cookies and customize Google Display Network ads, and Google Analytics’ Opt Out Browser Add-on for the web.

Other Transfers. We may share Personally Identifiable Information and other data with businesses controlling, controlled by, or under common control with PDFSimpli. If PDFSimpli is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer Personally Identifiable Information and other data in connection with the associated transactions.

Bankruptcy. In the event of a PDFSimpli bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. If such an event occurs, your Personally Identifiable Information may be treated like any other PDFSimpli asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Links

Third-Party Websites. PDFSimpli may maintain links to other websites and other websites may maintain links to the Online Services. This Privacy Policy applies only to PDFSimpli.com and not to other websites accessible from PDFSimpli or that you use to access PDFSimpli, each of which may have privacy policies materially different from this Privacy Policy. If you visit other websites, PDFSimpli is not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of non-PDFSimpli websites to confirm that you understand and agree with them.

Social Media Widgets. Our website includes social media features, such as the Facebook “like” button and widgets, such as the “Share this” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Disclosure

Information we collect can be shared with:

a) The Provider Corporate Family and Other Third Parties: We can share the information that we collect about you with the Provider's corporate family (our affiliates), as well as with third-party suppliers. The information can be disclosed (i) to provide joint content and our products and services (e.g. registration, transactions, employment or education opportunities, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our Provider or third party's products, sites, applications, services, tools and communications. Members of our corporate family will use this information to send you marketing communications, and you will have the opportunity to opt out of email communications.

b) Service Providers and Other Third Parties: We can disclose your information to service providers under contract, which help with our business operations (such as, but not limited to, fraud investigations, bill collection and payment processing, and site analytics and operations). Also, we share information with our third-party payment processors. With your authorisation, we can also share your information with potential employers and career/job-posting websites.

c) Other Entities, with your Consent: We can share your Personal Information with third parties to whom you explicitly ask us to send your information (such as CV editors, employers, recruiters or job-posting third-party websites, or others about whom you are otherwise explicitly notified and consent to when using a specific service). These third party services are governed by their own terms of service and privacy policies, as set forth by the third parties that provide them. We do not necessarily endorse, nor are we responsible or liable, directly or indirectly, for those services. On the Site, you have opportunities to express an interest in, or register for, other products and services. If you do, we will provide information about you to these third parties, or parties working on their behalf, to implement your request.

d) Legal and Law Enforcement: Law enforcement, governmental agencies or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity, or any other activity that can expose us, you or any other Provider user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, county, postcode, telephone number, email address, user ID history, IP address, fraud complaints and anything else that we deem relevant to the investigation.

e) Change of Control – New Owners: Other business entities, should we plan to merge with, or be acquired by, that business entity. Should such a combination occur, we will make reasonable efforts to request the new combined entity to follow this Privacy Policy with respect to your Personal Information. If your Personal Information were to be used contrary to this policy, we will request that the new owner provide you with prior notice and, depending on the circumstances, an opportunity to opt in to or opt out of the new use.

f) Ad Networks: On the Site, we can work with third parties to serve advertisement, provide us with data collection, reporting, ad-response measurement and site analytics, and assist with the delivery of relevant marketing messages and advertisements. These third parties can view, edit or set their own tracking technology/cookies. The use of this technology by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. They can also obtain information about other applications that you have downloaded to your mobile device, the mobile websites that you visit and other information about you or your device, in order to analyse and serve anonymous, targeted advertising on the Site and elsewhere. For more information about third-party ad servers on our Site and your ability to opt out of targeted advertising from such third parties, please visit https://www.aboutads.info/choices/ which provides information about certain companies that we may use to serve advertising on our Site.

g) Companies In The Mobile App Industry: If you access the Site through a mobile device or app, we can also share your information with operators, operating systems and platforms.

Your Choices

a) Opting Out of Promotional Messages: You can choose not to receive our promotional communications by clicking the 'My account' tab and clicking the 'My settings' and 'Preferences' tabs. You can also click the Unsubscribe link in the footer of any email or newsletter that you receive. You can also email us at privacy@legalsimpli.com.

b) Update/Delete or Change Your CV or Cover Letter: To change or delete your CVs or cover letters, log in to your Provider account, click the 'CV' and 'Cover letter' tabs and select Edit or Delete.

c) Site Privacy Settings: Information that you disclose while participating on the Site can be public and subject to redistribution by us and any third party that reviews your profile or the information that you post. You can change preferences for other Provider services as set forth in section 8 or by contacting us as set forth in Section 15. Please be aware that the Provider is not responsible for the use, disclosure or copies of your public postings on or through the Site that you make public and that are downloaded by third parties.

d) Administrative Messages Cannot Be Turned Off: As the Provider provides an online service, you cannot opt out of administrative emails (for example, emails about your transactions or policy changes) for your registered account.

e) Deactivation or Deletion of Your User Content/Account: You can request that we delete your account by logging in to your account and clicking the 'My settings' and 'Overview' tabs. You can also email us at privacy@legalsimpli.com. When you request that your account be deleted, your Personal Information, including your CV and profiles, will be deleted and no longer available to you or visible to users from Provider applications. However, if any of your information, including your Personal Information, was previously accessed by others using Provider applications, we are unable to delete the information from their systems. When you delete your information on Provider applications, we will retain logs and non-personally identifiable information about you, along with an archival copy of your information, which is not accessible by you or third parties on Provider applications, but which might be used by us for record keeping and internal purposes, including enforcing this Policy and demographic, reporting and research purposes.

f) Timing and Third Parties: We will endeavour to comply with your requests as soon as reasonably possible, but please note that changes requested of us are not always effective immediately. Unless required by law, we are not responsible for informing third parties (including, without limitation, our third-party service providers, potential employers, job-posting sites that you authorise us to contact on your behalf, or strategic or marketing partners) with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from, or causing information to be removed from, the databases or records of such entities.

6. Information You Share on the Site.

If you participate in Provider services (e.g. CV posting, profile creation and job alerts) that permit you or the Provider, on your behalf, to post information on third-party sites (e.g. websites, bulletin boards and personal URLs), and if you post information or content, such as by posting photos, or participating in online forums or communities, when you interact with our Site through social media sites, plug-ins or other applications, depending upon your privacy settings, this information can become public on the Internet. We cannot prevent the further use of this information. You can control the data that you share through privacy settings available on some social media sites. Please refer to these third-party sites' privacy policies and terms of use to learn more about their privacy practices, which we do not control.

a) Other services: If you use the Site, the Provider can create a universal application derived from the information you provide on the Site that will be visible to potential employers who have immediate needs for prospects, as well as visitors to the Site. Therefore, your Site Profile can be publicly viewable. You can elect to have your Profile restricted to registered users only by following the instructions on the Site for that particular setting. You agree that employers and the Provider will use the contact information you have provided to contact you by email and/or SMS text, and you understand that this consent is not a condition to having access to the Site or the Provider's services. Messaging and data rates can apply. If you opt in to our SMS alert service, you acknowledge that message or data charges may apply. If you do not wish to continue with the SMS alert service, you may opt out by replying 'STOP' to the SMS text that you have received, or you may contact our customer service. Please allow three to five working days for us to process your request. The Provider reserves the right to terminate the SMS alert service, at its sole discretion, for any reason and at any time.

7. Tracking Technologies (Cookies)

When you visit the Site, we and our business partners can use tracking technology to enhance your online experience or customise our offerings. Here are a few additional important things that you should know about our use of tracking technology (cookies):

  • We can offer certain features that are available only through the use of tracking technology.

  • We use both session and persistent tracking technology. Tracking technology (e.g. cookies) can either be persistent (i.e. they remain on your computer until you delete them) or temporary (i.e. they last only until you close your browser). You are always free to decline tracking technology if your browser permits this, although doing so can interfere with your use of the Site. Refer to the Help section of your browser, browser extensions or installed applications for instructions on blocking, deleting or disabling tracking technology such as cookies.

  • We encode and protect the types of tracking technology that the Provider sets so that only we can interpret the information stored in them. You can encounter tracking technology/cookies from the third-party service providers allowed on our Site, such as Google Analytics, which assist us with various aspects of our Site operations and services.

  • You can also encounter tracking technology from third parties on certain pages of the websites that we do not control and have not authorised. (For example, if you view a web page created by another user, there can be a cookie placed by that web page).

  • We can target and track the videos that you view on the Site. You consent to our trackingof your video viewing through the Site, or on third-party social media, for up to two years or as permitted by applicable law.

For more information about the use of cookies and similar technology on our Site please review this Privacy Policy and our Tracking Technology Policy.

Accessing, Reviewing, and Changing Your Personal Information

Registered members can review and change Personal Information at any time by accessing their accounts on the Site (through the My Account and My Settings tabs). You should update your Personal Information promptly if it changes or becomes inaccurate. We can retain some information from closed accounts so that we can comply with the law, prevent fraud, assist with investigations, resolve disputes, analyse or troubleshoot programs, enforce our Terms of Use or take other action permitted by law. Likewise, if your account or membership is terminated or suspended, we can maintain some information to prevent re-registration. For non-registered members, you can update or request access to your Personal Information by contacting us as set forth in Section 15. We will endeavour to comply with your requests as soon as reasonably possible, but please note that changes requested of us are not always effective immediately. Unless required by law, we are not responsible for informing third parties (including, without limitation, our third-party service providers, potential employers, job-posting sites that you authorise us to contact on your behalf, or strategic or marketing partners) with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from, or causing information to be removed from, the databases or records of such entities.

Notice to California Residents

a) California Civil Code Section 1798.83, known as the 'Shine the light' law, permits those of our customers who are residents of California to request and obtain from us a list of what Personal Information (if any) we have disclosed to third parties for direct-marketing purposes in the preceding calendar year, and the names and addresses of these third parties. Requests can be made only once a year and are free of charge. To make such a request, please contact us at californiarequest@legalsimpli.com. For all requests, you must put the statement 'Your California privacy rights' in the body of your request, as well as your name, street address, city, state and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a resident of California and provide a current address in California for our response. Please note that we will not accept requests via the telephone, by post or via facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not contain complete information.

b) California Business & Professions Code Section 22575 (b) provides that California residents are entitled to know how the Provider responds to 'Do not track' browser settings. The Provider does not currently take action to respond to Do not track signals because a uniform technological standard has not yet been adopted. We continue to review new technology and may adopt a standard once one is universally accepted.

Notice to residents of the European Union

The Provider complies with the General Data Protection Regulation ('GDPR'). As such, the Provider affords to all European data subjects their respective data privacy rights to the extent that they are applicable, including: (i) the right to rectify inaccurate data; (ii) the right to erasure (deletion of your Personal Information); (iii) the right to restrict processing of your Personal Information; (iv) the right of data portability; and (v) the right to object. You can exercise any of these rights by contacting us at privacy@legalsimpli.com or contact-us. In order to safeguard your Personal Information from unauthorised access, we can ask that you provide sufficient information to identify yourself prior to providing access to your Personal Information.

In certain situations, and subject to applicable law, the Provider will not be able or obliged to comply with part or all of your individual requests. Please note that we have the right to refuse and/or charge a monetary fee for requests that are manifestly unfounded or excessive, for example due to their repetitive character. If you have unresolved concerns, you have the right to complain to an EU supervisory authority.

Providing your information to us is optional, but it can affect our ability to offer you the Service. For example, if you do not provide your complete Personal Information, we will not always be able to respond to your request in a timely manner.

Third Parties

Our Site can contain links to other third-party websites, and the Provider can provide products and services that share information with third-party sites for your job search. We are not responsible for the privacy practices or the content of these third-party sites, so it is important to familiarise yourself with their privacy policies before providing your Personal Information.

Information security

We maintain technical, physical and administrative security measures designed to protect the security of your Personal Information against loss, misuse, unauthorised or accidental access, disclosure, copying, use or alteration. Some of the safeguards that we use are firewalls, data encryption, physical access controls to our data centres, information access authorisation controls and other measures in accordance with industry standards. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, we cannot guarantee its absolute security.

Children's Privacy

The Site is a general-audience site and it is not intended for children under the age of 16. We do not knowingly collect Personal Information via our websites, applications, services or tools from users in this age group. If you are a minor and want to remove the information that you have posted to the Site, please contact us via the email or postal address listed in Section 16 below. Removal of the information that you have posted does not ensure its complete or comprehensive removal.

14. Storage and International Transfer

As we operate internationally, and many of our computer systems are currently based globally, for the purposes set out in this Privacy Policy, your Personal Information can be stored and processed elsewhere by us, our affiliates or an unaffiliated service provider. The data protection and privacy regulations do not always offer the same level of protection as in other parts of the world, such as the European Economic Area ('EEA'). When you create an account/profile or otherwise provide us with Personal Information, you consent to the collection, storage and/or processing, in the United States and other countries, of your Personal Information and tracking technology/cookies as described in this Policy. We take appropriate measures to ensure adequate protection of the privacy rights of EEA data subjects with respect to Personal Information that we transfer outside the EEA to a country that is not subject to an adequacy decision by the EU Commission. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to contact-us.

Notification Regarding Updates.

From time to time, we can choose to update this Privacy Policy. The Privacy Policy posted at any time, or from time to time, via this Site shall be deemed to be the Privacy Policy then in effect. You agree that we can notify you about material changes in the way that we treat Personal Information by placing a notice on the Site. You should check the Site frequently for updates. In addition, we have provided the Privacy Policy Highlights section to offer a summary of the main points of our full Privacy Policy for your convenience. In the event of a conflict between the Privacy Policy Highlights and the full Privacy Policy, the full Privacy Policy will control.

Changes to this Policy. We may update this privacy policy to reflect changes to our information practices. If we make any material changes a notice will be posted on this page along with the updated Privacy Policy prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us. If you have any questions regarding our Privacy Policy, please contact us on the information below.

Mailing Address

Attn: LegalSimpli Software, LLC
1223 Calle Luchetti #10
San Juan, PR 00907, USA
support@PDFSimpli.com

Privacy Policy Revision History

Last updated on July 31, 2018

BlueSnap Privacy Policy v.2.0 Date: 25th May 2018

 

BlueSnap Respects Your Privacy

Introduction
This website and related services are owned and operated by BlueSnap, Inc. (“BlueSnap”) a global company providing payment gateway services and enabling eCommerce, marketing and payment processing, together with various subsidiaries including a European Union subsidiary BlueSnap Payment Services Limited, Canadian subsidiary BlueSnap Enterprise Canada ULC and Australian subsidiary BlueSnap Australia Pty Limited. References to BlueSnap in this policy also include these subsidiaries unless otherwise stated. Additional subsidiaries may be added over time and shall be governed by the terms of this policy.

 

We understand that you care about how your information is used and shared when you enter it on our websites, www.bluesnap.com, or use BlueSnap’s payment services as a merchant or shopper, and this notice describes our privacy policy and practices.

BlueSnap respects each individual’s right to personal privacy. We will collect and use information through our website including registration forms, inquiry forms, product transaction forms, mobile and API services only in the ways disclosed in this statement.

 

Online payment transactions involve transfer of data across international borders, as well backing up of data at our secured data centers in the EU and USA. This means that data may be transferred, processed and stored outside the EU, the European Economic Area (EEA) and Switzerland. By submitting your data directly or through a third party such as a merchant you are agreeing to such transfer, processing and storage.

 

BlueSnap is committed to maintaining the principles of transparency, accountability and choice regarding the collection and use of your personal information. BlueSnap Inc., is certified with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework full details of which appear in the dedicated section below.

 

When using BlueSnap’s services, technologies, functions, web site or applications, the terms of this policy will apply.

 

BlueSnap Services and You

BlueSnap acts as a technology provider supplying secure online and mobile digital payment processing services to businesses known as merchants so that they can sell their goods and services to their shoppers both domestically and worldwide.

 

The personal information collected by BlueSnap depends on how you are using our services.

 

Individuals typically interface with BlueSnap in one of the following ways:

 

Site Visitor: If you are visiting our website for details about our products and services, you may be asked to enter your personal details on an online form to receive more information. Cookies may be used to track site usage to assist in product development or monitor behavior for marketing purposes. Visitors from the EU/EEA may initially be asked to expressly consent to cookie usage.

Merchant: you may be a business customer that has consented to BlueSnap’s terms of service under a merchant or other formal agreement and use BlueSnap to conduct secure online sales. To set up a merchant account you will need to provide personal details, business data and identifying documentation.

Shopper: You may be a business or consumer using BlueSnap’s secure online payment technologies to complete the purchase of goods and services from a merchant that has selected BlueSnap as its payments solution. Your own choice of payment method will usually determine what personal data is passed to BlueSnap to enable your payment transaction to take place. It could be name, address and credit/debit card details, electronic bank transfer information, or pay-wallet credentials if using a service such as PayPal.

While such secure transactions may be completed in just a few seconds they are often complicated by the fact that live anti-fraud checks need to be conducted. Data also has to be passed to the relevant payment processors; banks, payment card and payment account services may need to be notified; legal tax invoices generated, and transaction confirmations delivered. Some or all of these steps may all involve the transfer and sharing of personal data down a chain of service providers, as well as the use of tracking cookies.

 

The Information BlueSnap Collects

 

The types of personal information we may obtain or you may choose to provide include:

  • Contact information (such as name, postal address, email address, phone number)
  • Business contact information, job function, title, department, name and size of organization
  • Username and password
  • Payment account data
  • Content provided (includes social media submissions – comments, articles, ratings)
  • Mobile and device unique identifiers
  • Geo-location data
  • Business records and identification documents
  • IP address, browser type, operating system
  • Other information (such as tracking behavior, cookie preferences, language preferences, age, date of birth, gender and family status), time stamps, device details

 

Some of this information may be collected automatically by using technologies such as cookies and web beacons, when you interact with advertisements, mobile applications, sales pages, website pages and other digital applications. Often shoppers will provide information themselves when interacting with merchants to purchase goods and services.

 

Use of Information Collected

The information is collected to perform the following functions:

  • Process payment transactions (including authorization, clearance, invoicing, tax calculation, currency exchange, shipping, delivery, processing refunds, chargebacks, provision of customer support and dispute resolution processes)
  • Generation of invoices, transaction confirmation notices, delivery of licenses, access keys, product download files and associated documentation, subscription accounts, instant notifications relating to transactions, refunds and refund notices, warranty and dispute records, customer profiles, tax payments
  • Communicate with you, respond to inquiries and send service notices, issue notices about functions and services you are registered to use including significant developments about the website and/or eCommerce services. (Users cannot normally op-out of this kind of email communication without cancelling the relevant service).
  • When BlueSnap acts as payment service provider, merchant and/or reseller for product suppliers, we may need to share relevant customer information with the specific merchant/product supplier involved in the transaction in order for them to fulfill the transaction. Such information is supplied on the condition that it will not be used for spamming or direct marketing by another party. Occasionally such product suppliers may sell, transfer or assign their business to new owners and in such circumstances data records may be accessible to the new owners subject to such parties satisfying the underwriting requirements of BlueSnap and assuming the ongoing responsibility for the proper protection of such data by committing to relevant contractual provisions
  • Check applications for use of BlueSnap services, perform account underwriting and KYC reviews, protect against and prevent customer and transaction fraud, unauthorized transactions, claims, manage risk exposure, conduct periodic risk reviews and credit checks
  • Evaluate business, product development, improve services, perform marketing activities, run billing, invoicing and account reconciliation functions
  • Compliance with legislation, regulations, legal requirements and law enforcement measures, orders and subpoenas from judicial and governmental authorities, enforcement and defense of contractual and legal rights and claims, generation of reserves, guarantees and sureties
  • Perform data analysis and generation of aggregated data reports based on anonymized information for benefit of BlueSnap, Merchants, processing partners, regulators and customers, auditing practices, conducting business intelligence, performance reporting
  • Compliance with internal policies, card industry and payment scheme requirements, Payment Card Industry (PCI) assessment and validation
  • Provide you with content, data and advertising tailored to your individual interests, enabling you to access BlueSnap services such as the Merchant or Shopper Control panel, support, chargeback management services
  • Review employment and business development applications
  • Consensual storage of shopper payment information for subsequent or recurring transactions
  • Track and identify sales referred by merchants’ sales affiliates and marketplace sellers

 

We may also use information in other ways for which we provide specific notice of at the time of collection.

 

Site Visitor: As a guest we may set tracking and behavioral cookies when accessing BlueSnap site and landing pages. These may include IP, device, technical usage, time, language and geolocation data. If you decide to request more information, sign up for newsletters, set up a sales call or use support facilities you may be asked to provide name and contact details.

Shopper: To process payment and delivery of products and services BlueSnap receives your transaction information – this may include name, ID info, address, email, phone number, delivery details, card/bank/pay wallet data, currency, transaction amount, gender, gift recipients, donations, IP, technical usage, language, geolocation and relevant affiliate tracking details. Support and post purchase services, refund and chargeback processes may require the use of similar information. You might have access to a shopper account generated by your merchant seller that is powered by or accessed through BlueSnap, to review purchases and set preferences for instance related to subscription and recurring charge transactions and payment card details.

Merchants: Business-related information is collected including corporate structure, tax numbers, beneficiaries, ID info, social security numbers, name, address, email, phone, banking details, references, financial information, locations, nationality, web site ownership, signatory information, staff access, PCI records, technical details, IP, verification and data relating to PCI/ KYC/AML/Transaction fraud checks, affiliate referral tracking details.

 

International Entities

BlueSnap’s services enable merchants to sell to shoppers across the world. This sometimes requires BlueSnap to provide services through specific legal entities. BlueSnap Inc., is based in the USA, and its affiliate BlueSnap Payment Services Ltd., is a regulated UK payments institution offering payment services across the EU/EEA. BlueSnap Enterprise Canada ULC offers payment services to Canadian merchants. BlueSnap Australia Pty Limited offers payment services to Australian merchants. Additional BlueSnap entities may be added and shall automatically be covered by this Privacy Policy.

 

How and Where Information is Stored

BlueSnap maintains administrative, technical and physical safeguards designed to protect the personal information provided or collected against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or misuse. Data is also routinely backed up at secure locations in Europe and the US in accordance with standard industry practice. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any further questions about privacy or security, or have reason to believe your data security has been compromised please contact us immediately by sending an email to: Security@bluesnap.com.

 

The international nature of BlueSnap’s services means that personal data may be transferred beyond your national borders when you use BlueSnap’s services or purchase from or sell to persons or entities outside your country. By using such services you are deemed to understand and accept that data may be subject to cross-border transfers.

 

How long data is retained

BlueSnap stores personal information for as long as necessary to fulfill the purpose for which the personal information was collected and as required or authorized by law. We take measures to delete or permanently de-identify personal information as required by law or if no longer required for the purpose for which it was collected. Certain data relating to transaction records particularly billing and invoice information may be required to be safeguarded for significant periods of time in accordance with standard tax and accounting practices, or to enable the refund and chargeback requests to be processed on behalf of shoppers.

 

Sharing of Personal Information

BlueSnap does not sell or otherwise disclose personal information we collect about you except as disclosed in this Privacy Policy or as may be disclosed to you at the time information is collected.

 

BlueSnap may share personal information collected with its subsidiaries and other BlueSnap entities that process payment transactions as well as relevant merchants, fraud prevention services, card and payment services, and payment processors/acquirers.

 

BlueSnap may share certain information with service providers who provide or perform services on behalf of BlueSnap. We authorize such services providers to use or disclose such information only as necessary to perform services on our behalf or to comply with legal requirements. Such entities are required by contract to safeguard the privacy and security of personal information processed on our behalf. We may also share personal information with other parties with your express consent.

 

Personal data used with respect to payment transactions involving individuals of the EU/EEA often needs to be passed to other parties as part of the transaction process. Transfers of data may be through APIs, email, and other formats, and may be bi-directional. BlueSnap takes steps to ensure that such parties are committed to compliance with applicable data law including the GDPR and that any additional Data Processors or Sub-Processors used are retained under a contractual duty of compliance and are able to respond to data subject access requests. In certain situations, BlueSnap and its subsidiaries might be deemed to be acting on the instruction of other transaction services or together with such parties, in which case BlueSnap shall itself be obligated to act in a manner compliant with applicable data law.

 

Certain Merchants might use checkout and other systems as part of the payment transaction process that might be integrated with BlueSnap. Accordingly personal information that you provide to such services either directly or through your selected Merchant might be passed to BlueSnap. BlueSnap treats such personal information in accordance with this Privacy Policy, however other entities might have their own policies and these should be thoroughly checked by you.

 

BlueSnap may use third-party service providers, for example to provide you with support when using our site and including the use of live chat software. When you sign up for our services we will share your personal information only as necessary for the third party to provide that service. Personal information collected relating to marketing and Merchant underwriting functions may be stored and processed on secure compliant cloud-based services provided by third parties to BlueSnap. Such service providers are contractually required by BlueSnap to act in compliance with relevant data law.

 

Merger, sale and/or transfer of corporate assets or reorganization

BlueSnap may transfer information as part of any corporate merger, sale, acquisition, transfer or assets or reorganization without notice. Such transfer will be on the basis of the continuation of all privacy rights set out in this document. You will be notified via email and/or a prominent notice on our website of any change in BlueSnap ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

 

Compliance with court orders & law enforcement agencies

BlueSnap may be required to disclose personal information without notification in response to a lawful request by public authorities, including to meet national security requirements, or in order to comply with a legal requirement, legislation, regulation, court order or subpoena, or when we believe in good faith that disclosure is necessary to protect our rights, prevent harm of financial loss, protect your safety or the safety of others or investigate fraud or cooperate with law enforcement or government agencies, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

 

EU/EEA Data Privacy Law

With respect to data protection legislation in the European Economic Area, including the GDPR, BlueSnap acts as ‘Data Processor’ concerning shopper information of EU/EEA-based persons that is transmitted to BlueSnap either through a merchant or directly in order to process a purchase transaction.

 

When BlueSnap sets up an account for a merchant we are required to conduct to various payment security, anti-money laundering, credit and KYC checks. When managing such personal data with respect to EEA-based individuals BlueSnap acts as a ‘Data Controller’.

 

The UK-based subsidiary, BlueSnap Payment Services Limited is authorized by the UK’s Financial Conduct Authority (FCA) under the Payments Services Regulations 2009 reference no. 629580, for the provision of payment services. This company is a relevant establishment with a branch office in the EU, and is subject to the Payment Services Regulations 2017.  BlueSnap Payment Services Limited is the representative for all other BlueSnap entities with respect to the provisions of the GDPR. Privacy matters concerning this company should be directed to BlueSnap through email at: PrivacyOptions@bluesnap.com

 

EU/EEA-based users will be asked to expressly consent to provision of personal information or initial setting of cookies when visiting BlueSnap web properties so that there is a clear legal basis for processing such data. In other cases personal information will be processed legally by virtue of the performance of the contractual obligations relating to a merchant and/or shopper, BlueSnap’s legitimate interest, or the defense or preservation of BlueSnap’s legal rights.

 

BlueSnap complies with legal requirements to provide adequate safeguards for the transfers of personal data outside the EU/EEA and Switzerland, and is certified under the EU/EEA-US and Swiss-US Privacy Shield schemes.

 

Individual users from the EU/EEA or other regions with laws governing data collection and use, should note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which BlueSnap may operate. By providing your personal information with respect to a transaction or express consent mechanism, you consent to any transfer and processing in accordance with this Policy.

 

Individuals based in the EU/EEA have additional statutory data subject rights as shown below under the heading: EU/EEA Data Subject Rights

 

Automatic Processing & Profiling

Anti-fraud checks may involve the automatic processing and profiling of personal data.

 

EU-US Privacy Shield & Swiss-US Privacy Shield

 

BlueSnap Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. BlueSnap Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

 

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, BlueSnap Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

 

EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to PrivacyOptions@bluesnap.com.  If requested to remove data, we will respond within a reasonable timeframe.

 

Your right to access your personal data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

 

We will also provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To limit the use and disclosure of your personal information, please submit a written request to PrivacyOptions@bluesnap.com

 

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

BlueSnap Inc.’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, BlueSnap remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless BlueSnap proves that it is not responsible for the event giving rise to the damage.

 

In compliance with the EU-US and Swiss-US Privacy Shield Principles, BlueSnap Inc., commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield.  European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact BlueSnap at: PrivacyOptions@bluesnap.com.

 

BlueSnap Inc., has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

 

 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

 

BlueSnap Inc., and its UK subsidiary BlueSnap Payment Services Limited are also contractually committed to handling such data transfers from the EU/EEA to other countries in accordance with the requirements of the European Union as set out in Set II of the model clauses published by the European Union in respect of Controller to Controller and Processor to Controller situations.

 

EU/EEA Data Subject Rights

Individuals from the EU/EEA may have the right to exercise additional data subject rights under data privacy laws including the following:

 

The right to request information about the purpose of the processing; the categories of personal data concerned; who else outside BlueSnap might have received the data from BlueSnap; what the source of the information was (if you did not provide it directly to BlueSnap); and how long it will be stored.

 

You have a right to correct the record of your personal data maintained by BlueSnap if it is inaccurate. You may also request that we cease using your data for direct marketing purposes.

 

Right of erasure: this is a right to erasure of personal information that we hold about you if it is no longer necessary in relation to the purpose for which it was originally collected. Please note that BlueSnap may need to retain certain data to complete transactions, perform refunds, maintain underwriting records or comply with legal obligations, tax and accounting requirements, etc.

 

Right to restrict processing of your personal information in certain circumstances, for example where such data is inaccurate or unlawfully held.

 

Right to data portability: this right is available in certain circumstances to receive your personal information in a structured, commonly used format and to have such data transferred to another service.

 

In order to exercise any of these rights please contact us as follows:

Shoppers should contact us at shoppers@bluesnap.com and Merchants should contact us at merchants@bluesnap.com

 

Please note that in situations where you are shopper your request to exercise a statutory right may need to be referred to the merchant who supplied the product.

 

Where you have provided consent to passing of personal information or cookie information to BlueSnap through an online consent form, you have the right to withdraw such consent, usually through a similar method as the original consent was given.

 

You may also have the right to complain to an EU/EEA data protection authority about our collection and use of your personal information.

 

Payment data

Personal payment information such as credit card numbers, bank account information, name, email address and phone number is routinely collected and passed on to authorized payment processors, banks, acquirers, and credit card companies in order to make payments sanctioned by BlueSnap customers. Such information is handled through industry standard secure protocols and where appropriate in accordance with relevant Payment Card Industry (PCI) compliance standards. Such data may also be passed when making payment through mobile devices.

 

Payment data may also be encrypted and securely stored by BlueSnap and appropriate merchants and product suppliers in accordance with PCI standards. When expressly directed and approved by a customer it may be used to generate recurring or new transactions as requested by such customer. Transaction details may also be passed to relevant taxation authorities in respect of sales taxes, VAT, GST, withholding tax, and other relevant taxes and duties.

 

Minors

BlueSnap does not actively market to children and we never knowingly ask a child under 13 to divulge personal information. Services and Information available to registered users on this site are NOT INTENDED FOR USE BY ANY PERSON UNDER THE AGE OF 18.

Please note that if it comes to our attention through reliable means that a registered user is under 18, we will cancel that user’s account. Online payment transaction forms are not provided for use in any event by persons under 18 years of age.

 

External links

BlueSnap offer links to other websites. Please note: when clicking on links to other websites, we encourage you to read their privacy policies. Their standards may differ from ours.

 

Social Media Widgets

Our online properties may include social media features, such as the Facebook and Twitter buttons and widgets, such as a ‘Share this’ button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

 

Forums and Group Boards

The BlueSnap website may offer comment facilities, forums and message boards. Please be advised that information voluntarily posted in these venues becomes public knowledge. To request removal of your personal information from our blog or community forum, contact us at PrivacyOptions@bluesnap.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

 

Changes in this policy & notification

BlueSnap reserves the right to change this policy as and when it sees fit. If our policy on information collection or uses changes, we will advise you by posting a dated copy here and you are advised to visit this page regularly to check for updates. If you are a registered BlueSnap merchant then you will also be advised via email. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site prior to the change becoming effective.

 

Opt out process

You have the option not to be added to mailing lists operated by BlueSnap or a merchant/product supplier. In the case of opt out, such decision will be relayed to the relevant product supplier. To exercise your opt out rights, please send an email to PrivacyOptions@bluesnap.com requesting that your personal information be deleted from any mailing lists operated by BlueSnap or your product supplier. BlueSnap will act on your request and inform your merchant/product supplier of your request in order to fully respect your decision. You may also follow the unsubscribe instructions located at the bottom of the emails you receive.

 

California privacy rights

Residents of the State of California under the California Civil Code have the right to ask companies with whom they have an established business relationship with to provide certain information about the sharing of personal information with third parties for direct marketing purposes during the past year. If you want a copy of the information disclosure provided by this site, please send your request to: BlueSnap, Inc., 800 South Street, Suite 640, Waltham, MA 02453, USA

 

Australian privacy rights

BlueSnap complies with The Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles. Further information is available here

 

Cookie Policy and Tracking Technologies

Please click here to review our Cookie Policy and learn about our use of tracking technologies.

 

BlueSnap’s policy on privacy and personal information use

(Ver. 1.13 Date: April 12th, 2017)

Introduction
This website is owned and operated by BlueSnap, Inc. (“BlueSnap”) a global company providing payment gateway services and enabling eCommerce, marketing and payment processing, with various subsidiaries including a European Union subsidiary BlueSnap Payment Services Limited and Canadian subsidiary BlueSnap Enterprise Canada ULC. References to BlueSnap in this policy also include these subsidiaries unless otherwise stated.

We understand that you care about how your information is used and shared when you enter it on our websites, www.bluesnap.com, or use BlueSnap’s payment services as a merchant or shopper, and this notice describes our privacy policy.

BlueSnap respects each individual’s right to personal privacy. We will collect and use information through our website including registration forms, inquiry forms, product transaction forms, mobile and API services only in the ways disclosed in this statement.

Online transactions involve transfer of data across international borders, as well a backing up of data at our secured data centers. This means that data may be transferred, processed and stored outside the EU, the European Economic Area (EEA) and Switzerland. By submitting your data you are agreeing to such transfer, processing and storage.

BlueSnap is committed to maintaining the principles of transparency, accountability and choice regarding the collection and use of your personal information.

EU-US Privacy Shield & Swiss-US Privacy Shield Frameworks

BlueSnap Inc. complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. BlueSnap Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

EU-US Privacy Shield & Swiss-US Privacy Shield – Inquiries & Complaints

In compliance with the EU-US and Swiss-US Privacy Shield Principles, BlueSnap Inc., commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact BlueSnap at: PrivacyOptions@bluesnap.com.

BlueSnap Inc., has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

If your complaint is not resolved through the above channel, in certain limited circumstances you may qualify to invoke binding arbitration before the ‘Privacy Shield Panel’ set up by the US Department of Commerce and the European Commission.

BlueSnap is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In addition to the EU-US and Swiss-US Privacy Shield frameworks, BlueSnap Inc., and its UK subsidiary BlueSnap Payment Services Limited are also contractually committed to handling such data transfers from the EEA to other countries in accordance with the requirements of the European Union as set out in Set II of the model clauses published by the European Union.

BlueSnap follows strict security features and procedures in its effort to prevent unauthorized access to your data, however the nature of the Internet is such that we cannot guarantee the absolute security of your data transmission, and so any transmission made by you is at your own risk.

Minors

BlueSnap does not actively market to children and we never knowingly ask a child under 13 to divulge personal information. Services and Information available to registered users on this site are NOT INTENDED FOR USE BY ANY PERSON UNDER THE AGE OF 18.

Please note that if it comes to our attention through reliable means that a registered user is under 18, we will cancel that user’s account. Online payment transaction forms are not provided for use in any event by persons under 18 years of age.

Part I. Information collection

BlueSnap collects information through its website and related eCommerce services at several points.

  • We also collect user registration data such as name, email address, phone number and address when merchants, product suppliers or affiliates register to use BlueSnap eCommerce services by means of voluntary submission forms for the purpose of providing such users with our services. Information is also collected from online forms completed by people wishing to learn more about the BlueSnap product or from emails sent to BlueSnap.
  • When underwriting new merchants BlueSnap routinely collects ‘Know Your Customer’ and Anti-Money Laundering data from merchants, information relating to business structure, financial/accounting reports, corporate management, ultimate beneficiaries, contact information, ID documentation, tax details, bank references, bank account data and credit reports. Merchant details may be checked against government/ commercial lists and search libraries to verify that such details are correct and not subject to blacklisting or service prohibitions.
  • BlueSnap also collects personal and payment information from online transaction forms including those generated through BlueSnap APIs and completed by end customers using BlueSnap’s eCommerce services to buy products, subscriptions and services (“Products”) from product suppliers selling their products through BlueSnap.
  • To receive Products sold through BlueSnap and eCommerce services provided by BlueSnap, personal information is required because it is used to accurately build a customer profile and for ongoing communication with customers and product suppliers. Other information we request is optional.
  • We may also provide you the opportunity to add additional users to your account. When you add a user to your account we will collect personal information such as name and email address. If you have been added to an account and wish to access your personal information in order to update or delete it you should first contact the account administrator. You may also contact us at PrivacyOptions@bluesnap.com

Tracking Technologies

Important Note: Please click here for further cookie information applicable to certain European Union countries.

  • BlueSnap employs cookies. A cookie is a small text, graphic or flash file that our Web servers place on a user’s computer hard drive or other web-based device to act as a unique identifier. Cookies may also enable BlueSnap to automatically login a user back to our services provided he/she choose to enable such option. BlueSnap cookies do not have an expiration date. Our cookies may collect personally identifiable information, including the username and password to support optional automatic logon. Cookies may also be used to identify and track transactions introduced by recognized BlueSnap affiliates and also to support optional choices by users to save and make available for reuse certain payment information for future transactions. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
  • Technologies such as: cookies, beacons, tags and scripts are used by BlueSnap and our marketing partners, merchants, affiliates, or analytics or service providers, including online customer support providers, online transaction processors. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
  • Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 or Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here.
  • As is true of most web sites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may link this automatically collected data to other information we collect about you.
  • We may from time to time partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here(or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Part II. Information usage

  • The information collected by BlueSnap, Inc. will be used by BlueSnap in conjunction with the terms specified in this document. Users who provide information may receive email announcements regarding BlueSnap’s services from time to time.
  • BlueSnap will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.
  • Registered product suppliers may receive additional announcements from BlueSnap about transactions generated through BlueSnap eCommerce services, instant notifications, BlueSnap service changes, revisions and updates, affiliate product opportunities, services, legal notices, special offers, and a newsletter.
  • BlueSnap may also use personal information to provide announcements about functions or services that users are registered to use, about any user account they may create, about fulfillment of a specific transaction that may be requested, or about other significant developments that may affect use of the Site and or eCommerce services. Users cannot normally opt-out of this kind of email communication.
  • Information we collect from customers may be used to create online invoices, transaction confirmation notices, delivery of licenses, access keys and product download files and associated documentation, subscription accounts, instant notifications relating to such transactions, refunds and refund notices, warranty and dispute records, and customer profiles based on browsing or purchasing history. As BlueSnap is acting as payment service provider, merchant and/or reseller for product suppliers we need to share relevant customer information with the specific product supplier involved in the transaction in order for them to fulfill the transaction. Such information, if provided to product suppliers, is supplied on the condition that it should not be used for spamming or direct marketing by another party. Occasionally such product suppliers may sell, transfer or assign their business to new owners and in such circumstances data records may be accessible to the new owners subject to such parties satisfying the requirements of BlueSnap and assuming the ongoing responsibility for the proper protection of such data.
  • Out of respect for the privacy of our Customers we present the option to opt out of any mailing lists operated by BlueSnap or relevant product suppliers as set out in the Opt Out section of this policy.
  • Where customer data is passed to a relevant product supplier the use of such information may be subject to the privacy policy of such product supplier and their standards may differ from those of BlueSnap.

Payment data

Personal payment information such as credit card numbers, bank account information, name, email address and phone number is routinely collected and passed on to authorized payment processors, banks, acquirers, and credit card companies in order to make payments sanctioned by BlueSnap customers. Such information is handled through industry standard secure protocols and where appropriate in accordance with relevant Payment Card Industry (PCI) compliance standards. Such information may also be passed when making payment via BlueSnap through mobile devices.

Such data may also be encrypted and securely stored by BlueSnap and appropriate merchants and product suppliers in accordance with PCI standards. When expressly directed and approved by a customer it may be used to generate recurring or new transactions as requested by such customer. Transaction details may also be passed to relevant taxation authorities in respect of sales taxes, VAT, withholding tax, and other relevant taxes and duties.

Certain data may be subject to analysis and checking by third-party fraud prevention services in accordance with payment industry practice.

Service Providers.We may share your Personally Identifiable Information with companies that provide support services to us (such as a printer or email service provider), help us market our products and services, or for training purposes. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.

We use other third parties such as a service provider to provide you with support when using our site and including the use of live chat software. When you sign up for our services we will share your personal information only as necessary for the third party to provide that service. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US Privacy Shield and Swiss-US Privacy Shield frameworks, BlueSnap is potentially liable.

Affiliate tracking information

Certain product transactions may have taken place following a valid referral by a recognized affiliate introduction. In such cases basic non-personal information about the transaction will be tracked and passed to the relevant affiliate so that their role in the sale can be recorded and any due affiliate commission paid over at the relevant time.

Forums and Group Boards

The BlueSnap website may offer forums and message boards. Please be advised that information voluntarily posted in these venues becomes public knowledge. To request removal of your personal information from our blog or community forum, contact us at PrivacyOptions@bluesnap.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

External links

We offer links to other websites including those of product suppliers. Please note: when clicking on links to other websites, we encourage you to read their privacy policies. Their standards may differ from ours.

Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook and Twitter buttons and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Compliance with court orders & law enforcement agencies

BlueSnap may be required to disclose an individual’s personal information without notification in response to a lawful request by public authorities, including to meet national security requirements, or in order to comply with a legal requirement, court order or subpoena, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others or investigate fraud or to cooperate with law enforcement or government agencies.

Merger, sale and/or transfer of corporate assets or reorganization

BlueSnap may transfer information as part of any corporate merger, sale, acquisition, transfer or assets or reorganization without notice. Such transfer will be on the basis of the continuation of all privacy rights set out in this document. You will be notified via email and/or a prominent notice on our website of any change in BlueSnap ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Changes in this policy & notification

BlueSnap reserves the right to change this policy as and when it sees fit. If our policy on information collection or uses changes, we will advise you by posting a dated copy here or if you are a registered BlueSnap user then you will also be advised via email. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this site prior to the change becoming effective.

Opt out process

Customers have the option not to be added to mailing lists operated by BlueSnap or the product supplier. In the case of opt out such decision will be relayed to the relevant Product Supplier. To exercise your opt out rights please send an email to us at PrivacyOptions@bluesnap.com requesting that you personal information be deleted from any mailing lists operated by BlueSnap or your Product Supplier. BlueSnap will act on your request and inform your Product Supplier of your request and of the need to fully respect your decision. You may also follow the unsubscribe instructions contained in each of the emails you receive.

California privacy rights

Residents of the State of California under the California Civil Code have the right to ask companies with whom they have an established business relationship to provide certain information about the sharing of personal information with third parties for direct marketing purposes during the past year. If you want a copy of the information disclosure provided by this Site then send your request to: BlueSnap, Inc., 800 South Street, Suite 640, Waltham, MA 02453, USA

Part III. Access to information

BlueSnap, Inc. maintains the accuracy of our information by acknowledging the right of users to access their personal information and allowing updates to take effect immediately. Registered users may access their own personal information via our login pages, both for customers and merchants and update any inaccuracies they may find. Users may choose to remove their information from our database by contacting us in writing at: BlueSnap, Inc., 800 South Street, Suite 640, Waltham, MA 02453, USA. We will respond to your request to access within 30 days.

BlueSnap will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal and tax obligations, resolve disputes, and enforce our agreements.

Part IV. Problem resolution

If problems arise, customers and merchants may contact BlueSnap by, email or mail, see here for more information. We are committed to resolving disputes within 5 business days. For customers based in the European Union certain additional standard statutory rights may apply with respect to resolution of customer and merchant complaints as set out in the BlueSnap information page at: https://home.bluesnap.com/ecommerce/legal/dispute-resolution/

Part V. Data storage and security

BlueSnap protects user information both in our servers and on the users computer with the following industry standard security measures: registry data encryption, data file encryption, secure servers, firewalls, encryption of sensitive information such as your payment information and other proprietary technologies and procedures used to protect consumer privacy. Data is also routinely backed up at secure international locations in accordance with standard industry practice. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any further questions about privacy or security, please contact us by sending an email to: Security@bluesnap.com.

Note: BlueSnap UK-based subsidiary, BlueSnap Payment Services Limited is authorized by the UK’s Financial Conduct Authority under the Payments Services Regulations 2009 reference no. 629580, for the provision of payment services. This company is a relevant establishment with a branch office in the EU. Privacy matters concerning this company should be directed to BlueSnap at the US office address appearing in section III above and through email at: PrivacyOptions@bluesnap.com

Previous Versions:

v1.13 Date: April 12, 2017

v1.12 September 14, 2016

v1.11 January 28, 2016

v1.10 December 21, 2014
v1.9 July 10, 2014
v1.8 July 7, 2013
v1.7 December 2, 2012
v1.6 November 12, 2012*
v1.5 April 10, 2012
v1.4 March 1, 2010
v1.3 February 12, 2007
*References to BlueSnap Inc. added April 3rd, 2012