Privacy Policy

Last Updated June 11, 2023

 

CampaignPay understands the importance of protecting your personal data and we take every precaution to ensure that it is kept safe. This Privacy Policy outlines how we collect, store and use your data in order to provide you with our services. We encourage you to read this policy carefully so that you can make an informed decision about sharing your information with us.

 

By using our products and services, you agree to the collection, storage and use of your personal data as outlined in this Privacy Policy. If you do not agree with any terms stated here, please refrain from using our products or services.

 

If there are any changes made to this privacy policy in the future, we will update this page accordingly. Please check back regularly for the latest version.

Welcome

We provide financial infrastructure for the internet, helping people make purchases and businesses of all sizes accept payments, pay out money and manage their operations online. To ensure that your "Personal Data" is secure when you use our services, we want to be transparent about how we use your data.

 

This Privacy Policy ("Policy") details the information we collect about you, how it is used, shared or stored by us and provides information on your rights in relation to the data you share with us. Please read this policy carefully before using any of our services so that you can make an informed decision about sharing your data with us.

When we refer to “CampaignPay”, “we”, “our” or “us” in this Privacy Policy, we are referring to the CampaignPay entity responsible for the collection and use of Personal Data under this Privacy Policy. It differs depending on your jurisdiction.

 

"Personal Data" means any information that relates to an identified or identifiable individual, and can include information which you provide to us and which we collect from you when using our Services (e.g., device information, IP address).

 

"Services" means the products and services that CampaignPay indicates are covered by this Policy, including any devices or apps provided by us. Our "Business Services" are those Services we provide to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with their own business activities. Our “End User Services” are those Services which CampaignPay provides directly to people (rather than entities) for their own use.

 

This Privacy Policy applies to CampaignPay.com, as well as any other websites, applications and online services that are owned or operated by CampaignPay (collectively referred to as "Sites"). Additionally, it applies to CampaignPay's business services and end user services (together referred to as "Services"). Together, these Sites and Services are the subject of this Privacy Policy.

 

Depending on the situation, "you" can refer to the End Customer, End User, Representative or Visitor.

 

When you take advantage of an End User Service for your own personal needs (for example, if you enroll in Link or make a payment to CampaignPay as an individual user), we refer to you as an "End User". On the other hand, when you do business with, or otherwise carry out transactions with, a Business User (e.g., if you buy products from a merchant who uses CampaignPay Checkout for payment processing), but not directly dealing with CampaignPay, we refer to you as an "End Customer".

 

If you are a business representative with an existing or potential business user, such as a company founder, account administrator for a merchant, or recipient of an employee credit card using CampaignPay Issuing, we refer to you as a "Representative."

 

When a user visits the CampaignPay website without signing into an account, they are referred to as a “Visitor.” This may be when an individual is exploring and considering using our products and services; for example, if they reach out with a message requesting further information.

Depending on the activity, CampaignPay is responsible for handling and managing data in either a “data controller” or “data processor (or service provider)” role. For more information about this, as well as details regarding the CampaignPay entity responsible for upholding this Policy, please refer to the relevant section provided.

 

We collect and utilize Personal Data depending on whether you are an End User, End Customer, Representative or Visitor, and the kind of services we provide. For instance, if you own a business as a sole proprietor, we may need to collect your Personal Data for onboarding purposes. You may also be an End Customer who has purchased goods from another Business User who utilizes CampaignPay's Services to process payments, or you may be a Representative of the business who is overseeing their account. Depending on your role, we use and share your Personal Data in different ways.

 

Transaction Data, as described in this Privacy Policy, includes Personal Data and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location of purchase, purchase amount and date of purchase. In certain cases, it may also include information about items purchased, a phone number and past purchases.

 

We provide End User Services directly to users for their personal use. We collect, use and share Personal Data in accordance with our Privacy Center policy, which includes the legal basis we rely upon for processing your Personal Data. This ensures that all of our activities are conducted in a secure and lawful manner.

 

When you sign up to CampaignPay, you provide your consent for us to store your personal data, such as payment method details. This makes it easier for you to make purchases with our Business Users who use our payment processing Business Services. The types of information we store includes your name, contact details and the particulars related to your chosen payment method (e.g., card number, cvc and expiration date). When you choose to pay with CampaignPay, we will also collect Transaction Data related to your transactions.

 

At CampaignPay, we may collect and process your banking information (including the account owner’s details, account numbers, balances, transactions and in some cases credentials) should you decide to share it with us. With your permission, this Personal Data can be shared with Business Users of your choice. If you wish to stop us collecting or sharing such data at any time, you can contact us and we will be happy to do so.

 

With your explicit consent, we will provide Business Users with your contact details such as delivery address, billing address and phone number. This data sharing will take place only with your permission.

 

If you make a purchase directly from CampaignPay, we will gather data related to that transaction. This includes contact information, payment details and other relevant data. We use this information to process your order and provide the services requested. Additionally, it helps us better understand our customers' needs so we can continuously improve our products and services.

 

We offer identity verification services that use automated technology to compare an identity document with a customer's image, such as a selfie. Customers may opt-in to allow us to store this verification for future use across other merchants and/or give consent to using their biometric data in order to improve our verification technology. Individuals can also request us to cease providing these services at any time.

 

How we use and share Personal Data of End Users

 

We utilize your Personal Data to supply the End User Service to you, including security measures, sanctions screening, delivery, support and customization (e.g. language preferences and settings choices) as well as messages related to the End User Service (e.g. sending Policy updates or information about our Services). For instance, we will draw on Personal Data to affirm whether your use of Link to complete a payment with a merchant is approved by you (as opposed to a malicious entity) and likely to be successfully authorized by the merchant.

 

When linking your financial account with CampaignPay, you may choose to share related data with any Business Users that you're transacting with. These entities will have their own specific privacy policies which explain how they use the information provided.

 

When engaging in transactions with CampaignPay, End User Personal Data is shared with third parties to facilitate or process the payment. For example, if users choose to use a payment method such as credit card, debit card, buy now pay later, or direct debit when making purchases through CampaignPay or Link, then the provider of said payment method will receive Transaction Data that includes relevant Personal Data. Similarly, when Link is used for transactions, the merchant involved in the transaction will receive Transaction Data that includes applicable Personal Data.

 

We collect and use your Personal Data across our Services (e.g. CampaignPay Secure) to detect fraud and mitigate financial losses for you, us, our Business Users, and financial partners. This includes the detection of unauthorized purchases in order to better protect your interests. For this purpose, we may share relevant information about you with Business Users and financial partners (such as card issuers, payment methods and other entities involved in payment processing activities) who use our fraud Business Services.

 

We may use your Personal Data to determine if you are eligible for our End User Services or to promote existing services. Where legally allowed and with your explicit consent, we will use and share End User Personal Data with third parties so that we can advertise our End User Services to you, including through targeted advertising based on your interests.

 

We will not distribute End User Personal Data to third parties for the purpose of marketing or endorsing their products or services without obtaining your explicit permission. We take data privacy seriously and never share personal information without consent.

 

When acting as a service provider for our Business Users (also known as data processors), we will process Personal Data according to the terms outlined in our agreement with them, and also act upon their lawful instructions. For example, when we process payments on behalf of Business Users, or when they request us to carry out specific tasks. We provide Business Services such as processing payments through in-person or online checkout, and processing pay-outs for our Business Users. Our services are designed to ensure our users experience the highest level of security and efficiency when dealing with us.

 

Business Users have a responsibility to make sure their End Customers' privacy is respected and that they are provided with appropriate disclosures about how data collection and usage are handled in relation to their products or services. If you are an End Customer, please refer to the Business User's privacy policy or notice for information on their practices, choices, and controls related to privacy. We provide further information regarding the collection, usage, and sharing of Personal Information.

 

When you make payments to, receive refunds from or take part in any other transaction with a Business User that uses our payment processing services, we will obtain Transaction Data. We may also collect your previous transaction history with the Business User. Furthermore, even if you do not complete the checkout form or go through with the purchase, we can still obtain information entered into the form.

 

CampaignPay provides a verification and fraud prevention Service that allows Business Users to verify certain Personal Data from you. This can include verifying your age when purchasing age-restricted products, or confirming your authorization to use a payment method. As part of these Services, we may ask you to share Personal Data with us for the purpose of verification (e.g., government ID, selfie image, or other personal data input that is visible on the physical payment method like a credit card). To protect your security and privacy, we take reasonable steps to authenticate this data before processing it. Your identity information is collected in accordance with applicable laws and regulations.

 

To ensure our Business Services are provided securely and effectively, we utilize Personal Data of Business Users' End Customers. We also share this data with the applicable Business User in instances where it is allowed. Furthermore, we sometimes use End Customers' Personal Data for CampaignPay's own purposes to improve our services, prevent frauds and losses, and protect against other sorts of harm as specified in detail below.

 

We utilize Transaction Data to offer our Payments and Accounting related services to Business Users. This includes processing online payments, calculating applicable sales taxes, invoicing and billing, helping calculate revenue, paying bills and providing accounting support. We may also make use of Personal Data in order to improve the quality of our Business Services.

 

When you make a payment transaction, we share your Personal Data with several parties to facilitate the process. As service providers or processors for the transaction, it is necessary for us to divulge certain Personal Data in order to carry out the transaction. An example of this would be when you select a particular payment method (e.g., credit card, debit card, buy now pay later, or direct debit), the payment method will be provided with Transaction Data which includes your Personal Data.

 

When you engage in a transaction with a merchant, they will receive Transaction Data that includes your Personal Data. It is possible that the merchant may share this information with third-parties; therefore, we recommend reviewing their privacy policy for more details on how your data is used and protected.

 

Our Business Users may offer financial services to you through CampaignPay or its partners. Such services may include card products that enable you to purchase goods and services, which could be branded with the CampaignPay logo, a bank partner's branding, or a Business User's branding. In addition to any Transaction Data that is produced or received when these cards are used for purchases, we will also process your Personal Data in order to provide these financial services.

 

We use the Personal Data that you provide, including information from our service providers, to perform verification Services for large transactions or those made by Business Users. This is done to reduce fraud and increase security. You may be asked to submit a selfie photograph along with an image of your identity document; this will then be put through technology which will compare them and make calculations as to whether they match, thus verifying your identity.

 

We use the Personal Data collected through our Services to identify and prevent any potential losses for ourselves, you, our Business Users, and other financial collaborators. We provide certain Business Users (including card issuers, payment methods processors, and related parties) with your Personal Data (including attempted transactions) so they can accurately assess the risk of fraud or loss associated with a transaction. You can contact us at any time to find out more about how we use your data for fraud detection and prevention processes.​

 

We may share Personal Data of End Customers with Business Users and parties directly authorised by them. This includes sharing the relevant data with their Authorized Third Parties when a Business User utilizes our CampaignPay Connect service to access its CampaignPay account. As an example, if the Business User makes use of our Identity Services to verify an End Customer’s identity, then we will share the necessary Personal Data with them.

 

When you make a purchase, we share your Personal Data with the related Business User in order for us to provide our Services. They are entitled to use this data to advertise and market their products or services, as per the terms of their privacy policy. To understand more about what they can do regarding your Personal Data, please read their privacy policy - including any rights you may have to stop them using your information for marketing purposes.

 

We specifically do not use, sell or share any personal data from our end customers for our own marketing and advertising activities, or allow third parties which are not the Business User with whom they have transacted or attempted to transact, to use this information.

 

We collect, use and share Personal Information from Representatives of Business Users in order to provide Business Services. Further information about our approach to the collection, use and sharing of Personal Data can be found in our Privacy Center. This information will include details about the legal basis for processing any Personal Data.

 

If you register for a CampaignPay account as a business user (including incorporation of a business), we collect your name and account log-in credentials. If you sign up for an event that CampaignPay organizes or attends, or if you opt in to receiving any communications from us, we require registration and profile information. For potential Business Users, we may receive Personal Data from third-party sources (such as data providers) in order to create and manage accounts. This is necessary in order to provide you with our services and keep your account information up-to-date. By providing this information, you are consenting to us processing it for the purpose of operating and managing your CampaignPay account.

 

We may require you, as an owner or a potential shareholder, officer, or director of a Business User, to provide certain identification information such as your name, postal address, telephone number and email address. This is necessary to comply with our financial partner and regulatory requirements. We will collect personal data from you directly (and through others), including your ownership interest in the Business User, your date of birth and any government identifiers associated with you.

 

This information is necessary to ensure we are meeting legal obligations and protecting our customers' data. We take the security of your data very seriously and will only use it in accordance with our Privacy Policy. If you have any questions or concerns about the collection of your Personal Data please do not hesitate to contact us.

 

We use and share Personal Data of Representatives with Business Users to provide the requested Services. This allows us to fulfill our obligations and ensure that our Business Users are able to benefit from our services in a safe and secure manner. Additionally, we may also use this data for other purposes such as marketing or analytics. We take great care to protect the privacy of those associated with our Business Users and make sure the data is used appropriately.

 

In certain cases, our Business Services may necessitate that we submit your Personal Data to a government organization (e.g. creating a business or paying the applicable sales tax). With regards to our tax Business Services, we may utilize your Personal Data to file taxes for the associated Business User. For our incorporation services, we may use your Personal Data in order to submit required forms to the Internal Revenue Service on your behalf, as well as to file documentation with other relevant governmental entities (e.g. articles of incorporation in your state).

 

We may share Personal Data with parties directly authorized by a Business User to access such information (e.g. financial partners aiding the respective financial product, or third-party apps or services integrated into our Business Services). For instance, providers of payment methods (such as Visa and WeChat Pay) will need merchant onboarding details for the Business Users that accept their payment options, and CampaignPay will provide the necessary onboarding information (which includes Personal Data of their Representatives).

 

As a Business User, if you have chosen to include Personal Data in your business name (for example, a sole proprietorship or family name), then this information will be shared and used by us as part of our Services (for instance, appearing on receipts and other documents related to financial transactions). However, any use of Personal Data by the authorized third party is subject to the third party's privacy policy.

 

We may use and share Representative Personal Data with third parties to advertise and promote our Services, where permitted by applicable law. This includes serving ads through interest-based advertising, as well as measuring the effectiveness of those ads. We take great care to protect your data; we do not sell or share Representative Personal Data with others for their advertising purposes.

 

We gather, utilize and distribute Personal Data for Visitors (who are not End Users, End Customers or Representatives). Our Privacy Center provides more information about how we collect, use and share Personal Data of these visitors. Additionally, the legal foundation on which we base our usage (processing) of your Personal Data is also elucidated in the Privacy Center.

 

When you visit our Sites, we may receive your Personal Data through either your direct input or by way of cookies and other similar technologies. Please refer to our Cookie Policy for more information. Additionally, when you choose to complete a form on the Site - or any third party websites featuring our advertisements (such as LinkedIn or Facebook) - we will collect the relevant data included in the form (e.g. your contact information and any other questions related to our Services). We may also record the location associated with your visit.

 

We use data about you collected from cookies and other technology to evaluate how our content is being used, to make improvements to its relevancy and user navigation, as well as to personalize your experience. This includes customizing the language and relevant geographic area. Additionally, we tailor our responses based on the services that are available in your specific region. This allows us to provide the most relevant information and services for you.

 

We are committed to only using Visitor Personal Data for advertising our Services as permitted by law. We may advertise and promote our Services to you through interest-based ads and email campaigns, with the aim of determining their effectiveness. Please refer to our Cookie Policy for more information. We will not share or sell any Visitor Personal Data to third parties for their own advertising purposes.

 

When visitors interact with CampaignPay.com, we collect data from and through the devices used to access our site in order to offer the chance to communicate with us via conversations or chatbot technology for addressing inquiries. This helps ensure that users have a positive engagement experience on our website.

 

We collect information regarding the devices and browsers used on our sites as well as Third-Party Sites, apps, and other online services. The type of data collected depends on the Service employed and how Business Users choose to implement our Business Services.

 

Our collection of such information is in order to provide targeted content that may be more relevant for users, monitor performance, and analyze trends. We are committed to protecting the privacy of our users in accordance with applicable laws and regulations.

 

We may collect usage data associated with the devices and browsers you use in conjunction with our Services, including your IP address, plug-in types, language settings, as well as time spent on our Sites and Third-Party Sites. This data also includes the pages visited, links clicked, payment methods used, and the page which referred you to our Sites or Third-Party Sites. In addition, we may also record activity indicators like mouse movement to aid in the detection of fraud. Please refer to our Cookie Policy for further information.

 

We may any information you voluntarily provide to us, such as through support tickets, emails or social media. When responding to CampaignPay emails or surveys, we will record your email address, name and other details included in the message or responses. If you contact us by phone, we will save the number used to call CampaignPay and any additional information shared during the conversation. We may also collect data on your engagement with our services, such as the frequency and duration of use. This helps us ensure we are providing you with a high-quality experience. We will use this information in accordance with applicable laws and regulations.

 

When visitors to our Sites are able to post content, we will collect the Personal Data they provide in connection with their post. This Personal Data may include information such as their name, email address, and any other details that might be included in the post itself. We understand the importance of safeguarding this data and take all necessary measures to ensure its security.

 

At our company, we are dedicated to constantly improving and developing our services. We analyse your usage of our websites and services, as well as identify technical issues, with the help of analytics. To learn more about the cookies served on our sites and how you can control their use alongside third-party analytics, please consult our Cookie Policy. Additionally, we gather and process personal data of our users, end customers, representatives, and visitors to help us refine our services and create new ones.

 

We may use the contact information we have about you to provide our Services, which may include sending authentication codes via SMS. For End Users, Representatives and Visitors, we may contact them using the contact information we have for them (e.g. email, phone call, text message or video conference) with information about our services and those of our affiliates', invite them to take part in our events or surveys, or otherwise communicate with them for marketing purposes.

 

We may use Personal Data provided to us or made available through social media in order to promote offers, programs and promotions. This data will be used to administer the program or promotion and for marketing purposes, unless we are legally prohibited from doing so.

 

At CampaignPay, we collect and use Personal Data in order to identify and manage fraudulent activities, as well as other malicious actors, across our services. Furthermore, we use this data to strengthen the security of our Services by helping us detect unauthorized access, modification, use or misappropriation of Personal Data, information or funds. In order to ensure compliance with anti-fraud and security measures, we use data to monitor, prevent and detect potential risks. We strive to ensure the safety of our Services and transactions for all involved.

 

We use Personal Data to ensure we meet our legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and other prohibitions on doing business in certain areas. This is essential for us to be able to provide a secure environment and remain compliant with relevant regulations. To do this, we may monitor patterns of payment transactions and other activities to identify suspicious activity or any potential violations of the law. We take our legal obligations seriously and are dedicated to protecting our customers and services from any unlawful activity.

 

The Services are not directed towards minors, including children under the age of thirteen. We kindly ask that minors do not provide any personal data through our Services. Depending on the country, we may need to set a higher age limit as required by any applicable law.

 

We may share Personal Data with other entities affiliated with CampaignPay in order to achieve the purposes outlined within this policy. These data sharing activities are conducted in accordance with applicable laws and regulations and are subject to safeguards designed to ensure the security of any shared information. Any affiliate entities that receive access to Personal Data have agreed to adhere to data protection standards and best practices when processing it. We take great care to ensure that any data sharing activities are carried out responsibly and in accordance with applicable laws. All affiliates of CampaignPay are required to maintain the confidentiality, security, accuracy and integrity of Personal Data. Additionally, these entities must agree to comply with our privacy policy when using or disclosing such information.​ For more information on how we protect your Personal Data, please review our Privacy Policy.

 

We engage third-party service providers to assist us in providing Services to our Business Users and End Users, as well as to communicate, market and advertise to Visitors, Representatives and End Users. These service providers offer a range of essential services, such as hosting (storing and delivering), analytics to evaluate the rate, accuracy and/or safety of our Services, identity verification, customer service, email and auditing. We authorize these service providers to access, process or store data necessary for the purposes of delivering their services. However, any such third party is prohibited from using this data for any other purpose. We ensure that all our service providers are compliant with applicable laws and regulations and remain accountable to us regarding their security practices.

 

We partner with various financial institutions, known as Financial Partners, to provide our Services. This includes payment method acquirers, banks and payout providers. In order to offer certain Services in partnership with our Financial Partners as well as deliver the Services to Business Users, we share Personal Data of Representatives (such as loan repayment data and contact information) with institutional investors who purchase these services.

 

We may not always be able to provide you with a service, but instead can refer you or enable you to access the services of a third party (for example, those professional firms we partner with for Atlas). In this case, we will disclose to you the identity of the third party and what information will be shared. Your consent must be given before this sharing of information can take place.

 

In the event of a corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer, or change of control in which we would alter our business structure, we may share Personal Data with third parties involved in the process. The entity that acquires us or part of our business will have the right to continue using your Personal Data according to this Privacy Policy. However, we will seek to ensure that any such entity provides an adequate level of data protection. If not, then we will take appropriate steps to ensure that your Personal Data remains protected in accordance with applicable law.

 

At CampaignPay, we take compliance with the law and prevention of harm seriously. To that end, we will share Personal Data when it is necessary to do so in order to meet our obligations under applicable laws or to enforce our contractual rights. Additionally, we may share Personal Data to comply with rules imposed by a payment method connected with use of that payment method (e.g. network rules for Visa). We also may share Personal Data to secure or protect the Services, rights, privacy, safety and property of CampaignPay, you or others, including against other malicious or fraudulent activity and security incidents. Lastly, we may respond to valid legal process requests with necessary Personal Data.

 

We process Personal Data for the purpose of establishing and managing business relationships with potential Business Users and End Users, as well as fulfilling our contractual obligations to them. This includes anything from negotiating terms of agreements to carrying out services that have been agreed upon. Through these actions, we ensure that both parties are held accountable according to their obligations under the contract.

 

We manage the creation and administration of CampaignPay accounts and related credentials, evaluating applications to begin or expand access to our services. We also create and maintain CampaignPay Checkout accounts, conduct accounting, auditing and billing activities, and process payments. This includes activities such as detecting fraud, preventing losses, validating transactions, communicating regarding payments, and providing customer service. All of these activities are essential for ensuring secure and successful access to the services we offer.

 

We collect and process Personal Data to verify the identity of individuals and entities in order to meet our obligations under laws designed to detect, monitor, and prevent fraud. This includes Anti-Money Laundering (AML) regulations and Know Your Customer (KYC) requirements, as well as financial reporting duties. For example, we may be obligated to record and validate a User's identity in line with legislation meant to protect against financial crime.

 

Where deemed lawful, we process Personal Data about you based on our legitimate interests as a business. This is in line with local regulations and laws applicable to us. We ensure that any such uses are proportionate and comply with all other legal obligations. Our aim is to better serve our customers, providing them with tailored products and services that meet their needs. Additionally, it allows us to improve our products and services, promote safety and security within our business, and ensure that we are meeting any legal or regulatory requirements. We take all necessary steps to protect your privacy. We will continue to evaluate these interests on an ongoing basis in order to ensure that any such processing is lawful.

 

We process data for the following legitimate business purposes: detecting, monitoring and preventing fraud and unauthorized payment transactions; mitigating financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and CampaignPay; determining eligibility for and offering new CampaignPay products and services; responding to inquiries; sending Service notices; providing customer support; promoting, analyzing, modifying and improving our Services. By processing this data, we are able to ensure the security and safety of our customers and our services.

 

We may collect and process Personal Data with your consent in order to communicate effectively with you and provide our Services such as Link, Financial Connections, Atlas and Identity. If data is processed based on your consent, you have the right to revoke that consent at any point without impacting the lawfulness of processing which occurred prior to revocation.

 

When submitting an application for CampaignPay services, your personal information may be shared between us and third-party financial institutions that provide relevant services. By agreeing to apply through CampaignPay.com, you consent to the sharing of this information and affirm that your completed application will be used by these external entities, including your signature, business and personal information.

 

You may have certain options regarding the collection, utilization, and disclosure of your Personal Data. If you would like to opt out of receiving electronic communication from us, you are welcome to do so. Please note that opting out of communications may result in some services or offerings becoming unavailable to you. It is important that you make sure that any withdrawal requests are made in writing as soon as possible.

 

If you would like to stop receiving marketing-related emails from us, you may do so via the unsubscribe link provided in such emails or as explained here. We will try our best to adhere to your request(s) in a timely manner. Please be aware that if you opt out of receiving marketing-related emails from us, we still reserve the right to send you messages related to the services you use (e.g. support and legal notices) and our business users may still ask us to send emails on their behalf.

 

Depending on your geographical location and applicable law, you may have certain rights in regards to the Personal Data CampaignPay processes about you. These rights include confirming if we process Personal Data about you, as well as requesting a copy of that data.

 

You have the right to ask CampaignPay to correct any Personal Data that is inaccurate, incomplete or outdated. You also have the right to request that CampaignPay erase your Personal Data in certain circumstances laid out by applicable law.

 

You have the right to request that CampaignPay limit its use of your Personal Data in certain situations, such as when we are considering another related request from you (such as a request for an update to your data). You may also ask us to export any of the Personal Data that we hold about you to another company, where this is technically feasible.

 

If we have obtained your consent to process your Personal Data, you have the right to withdraw that consent at any time. If we are processing your information based on our legitimate interests, you may also be able to object to the processing of your data. Unless there are compelling legitimate grounds or a legal requirement for us to continue with the processing, we will stop when you make an objection.

 

You may have certain legal rights which safeguard you from discrimination for exercising your rights, or the right to appeal any decision made by CampaignPay relating to these rights. Depending on geographical location and applicable law, you may possess further rights in relation to your Personal Data. To learn more, please refer to the Jurisdiction-specific provisions section provided for those living in California.

 

To exercise your data protection rights please also see the CampaignPay Privacy Center or contact us as described below.

 

We make every effort to ensure the safety of your Personal Data. We have implemented organizational, technical, and administrative measures designed to protect it from any unauthorized access, destruction, loss, alteration or misuse. While we strive to guarantee the security of all data transmissions and storage systems, there is no 100% foolproof system available. We continuously evaluate and update our security measures to best protect the data entrusted to us.

 

At CampaignPay, we take the protection of Personal Data seriously. To help safeguard your information, we encourage you to create a secure password and make sure that it is not shared with anyone else. Additionally, please do not use the same login credentials (e.g. passwords) for your CampaignPay accounts as you do for other services or accounts. If you believe that your security has been compromised in any way, please contact us as soon as possible.

 

We will keep your Personal Data for as long as we are providing our Services to you or our Business Users, or while we reasonably expect that we may have to provide the Services. Even after we stop providing the Services directly to you or a Business User with which you are conducting business, and even if you close your account with us or complete a transaction with a Business User, we may still keep your Personal Data.

 

This is to ensure that we are able to fulfil our contractual obligations and comply with legal requirements. We will securely store your Personal Data until it is no longer necessary or relevant for the purpose for which it was collected. After this date, we will delete or anonymize any remaining data in accordance with applicable laws.

We may keep your Personal Data for longer than the period for which we provide Services to you or Business Users, if required by law or other applicable regulations. We may also keep aggregate information about our customers and users indefinitely after such time. This aggregate information does not identify any individual user.

 

We take all reasonable measures to ensure that your Personal Data is securely stored and disposed of in accordance with applicable laws.

 

We reserve the right to change our data retention policy at any time without notice. Please check this page periodically for updates. If you have any questions about our data retention policy, please contact us.

 

We are an international organization and may need to transfer your Personal Data to countries other than where you reside. These countries may have data protection regulations that are not the same as your own country. Whenever we move data across borders, we ensure that we follow all applicable laws related to the transfer of such personal information. In specific scenarios, it might be necessary for us to disclose Personal Data in response to lawful requests from officials such as law enforcement or security agencies.

 

For individuals located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please visit CampaignPay Privacy Center for more detailed information. In compliance with applicable data protection law, we use one or more of the following mechanisms to facilitate data transfers:

 

-Standard Contractual Clauses,

-Approved Codes of Conduct and/or

-Certifications.

 

If you have any further questions or concerns, please do not hesitate to contact us.

 

We may transfer Personal Data to countries or recipients that are recognized as having an appropriate level of protection for such data under applicable law. This includes EU Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office. Copies of these relevant Standard Contractual Clauses can be obtained upon request. Alternatively, any other methods of legal transfer that may be available to us under relevant laws will also be considered.

 

CampaignPay, Inc. is not relying on the E.U.-U.S. Privacy Shield and the Swiss-U.S. U.S Privacy Shield frameworks for the transfer of Personal Data to the United States at this time, despite still being self-certified under these frameworks.

 

We reserve the right to modify this Policy at any time in order to accommodate changes related to our services, privacy practices, or relevant laws. The most recent version of this Policy can be found on the Services and will be marked with the "Last updated" notice. Any updates come into effect when we post the revised Policy online or provide other formal notification as required by law.

 

We may inform you of any amendments or updates to our Policy or any Personal Data collected by posting them on our website. If you are an End User or Representative, we may also contact you directly through your CampaignPay Dashboard, email address or the physical address listed in your CampaignPay account. This is done so that we can ensure that all customers are aware of and comply with any changes to our Policy or data.

 

Please note that it is your responsibility to check for updates from time to time in order to remain informed and compliant. We may notify you of any modifications via the aforementioned communication methods, but we cannot guarantee delivery of all notifications. You must also check our website regularly for any notices or alerts posted there. Failure to do so could result in your failure to comply with the Policy or any applicable laws.

 

For Australian residents, if you are not satisfied with the way we handle your complaint under this Policy, you may choose to contact the Office of the Australian Information Commissioner. Meanwhile, Brazilian residents who fall within the scope of the Lei Geral de Proteção de Dados Pessoais (“LGPD”) have rights stated in Article 18 of said LGPD. For any inquiries regarding these rights, please contact our Data Protection Officer.

 

In Canada, this Privacy Policy is governed by the Federal Personal Information Protection and Electronic Documents Act (PIPEDA). The term "Personal Data" in this document includes any information that could be used to identify a person, as described in PIPEDA.

 

If you are a resident of the European Economic Area (EEA) or CampaignPay Payments Europe Limited is identified as your data controller and you believe our processing of your information does not comply with the General Data Protection Regulation (GDPR), then you may contact our Data Protection Officer to exercise your rights. If you live in the UK, please direct any questions or complaints to the Information Commissioner's Office. For residents of the EEA, you may direct your comments to the Irish Data Protection Commission.

 

For residents of India, if you have any queries or concerns regarding the treatment of your Personal Data, do not hesitate to reach out to our Nodal and Grievance Officer.

Residents of Indonesia, this Privacy Policy is subject to applicable laws including Law No. 11 of 2008 as amended by Law No. 19 of 2016 on Electronic Information and Transactions, Government Regulation No. 71 of 2019 on the Implementation of Electronic Systems and Transactions, and Minister of Communication and Informatics Regulation No. 20 of 2016 on Personal Data Protection.

If you have any inquiries regarding your data protection rights in Indonesia, please reach out to our Nodal and Grievance Officer.

 

When transferring Personal Data of data subjects in Japan to jurisdictions which are not recognized by the Personal Information Protection Commission as 'adequate', we take steps to ensure that appropriate measures are taken. This includes entering into written agreements with any third parties located outside of Japan, which provide rights and obligations equivalent to those provided under the Japanese Act on the Protection of Personal Information.

 

Malaysia: If you have any queries or grievances related to this Policy, please get in contact with our Data Protection Officer.

Switzerland: The term "applicable law" as used in this Policy refers to the Swiss Federal Act on Data Protection (FADP) and its amendments. For exercising your rights under the FADP, reach out to our Data Protection Officer.

Thailand: If we process your Personal Data due to a legal obligation or contractual right and you do not provide us with the personal Information, it may impede our ability to provide services to you in accordance with the law.

 

If you are located in California, USA, we process your personal information in accordance with California law (e.g. the CCPA). For more detailed information on this subject, please see our Cookie Policy page. We employ cookies with the purpose of advertising as stated in our Cookie Policy.

 

As a California consumer, you have certain rights and choices regarding the use and disclosure of your personal information. Under the CCPA, you are entitled to request information about the categories of personal data collected, sold, shared or disclosed; the purposes for which this data was collected, sold or shared; and the categories of third parties with whom it was shared. In addition to these rights, California has other specific laws that protect your data. You can exercise your right to know more about how your personal data is being used for the purposes of making informed decisions regarding its use.

 

Individuals have the right to opt-out of a sale of their "Personal Information" according to the California Consumer Privacy Act (CCPA). We, as an organization, have not sold any Personal Information in the past 12 months and remain committed to upholding this standard. Additionally, we do not sell or share Sensitive Personal Information as defined by the CCPA nor have we done so in the past 12 months. To learn more about how we collect and use Sensitive Personal Information, please visit our website.

 

If you wish to make use of any of the rights listed above, please contact us using the information provided in the Contact Us section. In order to verify your request, we may ask you to submit it from the email address associated with your account or may need additional details such as your name, address, transaction history, photo identification, and other related particulars. We must verify your identity before we can process the request.

 

You may appoint an authorized agent to submit requests to exercise your rights under the CCPA. Such requests can be sent by the agent using the contact methods described in the Contact Us section. You will still need to confirm your identity directly and that you have allowed the given agent permission to make such a request. A written declaration or power of attorney is necessary for this authorization.

 

If you have any queries or grievances about this Policy, please contact us. If you are a customer engaging with a business user, then please refer to the privacy policy of that Business User for details regarding their privacy practices, choices and controls. You can also get in touch with the Business User directly if needed. We honor 'Do Not Track' signals and other similar indications. To learn more about this, please contact us. Thank you.