Privacy Policy

PRIVACY POLICY

33 Operations Inc, dba PayBlox (“PayBlox, we”, “us”, or “our”) might collect and process personal data of users of PayBlox’s website and online services. Our Privacy Policy explains what data we process, how we do that and how the data subjects, i.e. Users, may use their rights. This Privacy Policy applies to personal data we obtain from our customers and their representatives (each a “User” and collectively, “Users”) through our websites and online services when the relevant User registers to use or otherwise utilizes PayBlox’s services (collectively, the “Services”). In addition, some of our Services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular Service, we will post it on the relevant website or otherwise in connection with the Service in question. This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website payblox.com/privacy. This Privacy Policy only covers data collection, maintenance and processing carried out by PayBlox. The Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties. PayBlox disclaims all responsibility for activities carried out by third parties, also in cases where Services include hyperlinks to third parties’ websites. Please note that this Privacy Policy applies to collection, maintenance and processing of personal data carried out by PayBlox. Privacy, security and online safety are of the utmost importance for us, and we collect, maintain and process all personal data with due care and in accordance with applicable laws and regulations.

1. PERSONAL DATA COLLECTED, MAINTAINED AND PROCESSED; SOURCES OF DATA

We collect two types of information from the Users; User Data and Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data can also be considered to be personal data under applicable laws and we will treat the combined data as personal data. PayBlox may collect and process, for example, the following User Data from Users: (i) name and contact details; (ii) e-mail address; (iii) phone number; (iv) Social Security Number, (v) invoicing and billing information; (vi) business and financial data, including but not limited to credit histories, credit scores, transaction history, and credit rates; and (vii) other personal data Users provide themselves. The specific kind of User Data collected will depend on the Services used by the User. Some of the User Data is received directly from Users at the point of registration or otherwise at beginning of and during the customer relationship, and the rest is based on the data they provide to PayBlox that is processed. Technical Data we gather in connection with the use of our Services may include, for example, the following data: (a) User’s IP address; (b) browser type and version; (c) preferred language; (d) geographic location using IP address or the GPS, wireless, or Bluetooth technology on your device; (e) operating system and computer platform; (f) the full Uniform Resource Locator (URL) clickstream to, through, and from our Services, including date and time; (g) products or services User viewed or searched for while using our Services; (h) areas of our Services User has visited; and (i) historical data regarding the use of our Services.

1. Information provided by Users

We collect information from Users when Users enter it or otherwise provide it in connection with an inquiry into, or use of, our Services.  This information could be provided via an online form, over the phone, or via other means through which the User interacts with our Services.

1.2 Web analytics services

Our Services use several web analytics services to compile Technical Data and reports on visitor usage and to help us improve our Services.

1.3 Cookies

We use various technologies to collect and store Technical Data and other information when Users visit our Services, including cookies. Cookies allow us to calculate the aggregate number of people visiting our Services and monitor the use of the Services. This helps us to improve our Services and better serve our Users. We may also use cookies that make the use of the Services easier, for example by remembering usernames, passwords and preferences. We may use tracking and analytics cookies to see how well our Services are being received by our Users. Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. This can usually be done through Internet browser’s settings. Information about how to manage cookies can be found online. Please note that some parts of our Services may not function properly if use of cookies is refused.  Further, our Services may not respond to Do-Not-Track requests or headers from some or all browsers.

1.4 Persons under 18 years of age

We do not knowingly collect or maintain personal information of persons under 18 years of age.  If we learn we have collected such information, we will delete such information.  To notify us that we might have any information from or about a person under the age of 18, please contact us at su*****@pa*****.com

2. SCOPE AND CONSENT

By signing up for, accessing, or using our Services and/or website, you accept this Privacy Policy and consent to our collection, use and disclosure of your Personal Information as described in this Privacy Policy. This Privacy Policy only covers data collection, maintenance and processing carried out by PayBlox. The Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties. PayBlox disclaims all responsibility for the collection, maintenance and processing carried out by third parties, also in cases where Services include hyperlinks to third parties’ websites. Privacy, security and online safety are important for us, and we process all personal data with due care and in accordance with applicable laws and regulations.

3. PURPOSES AND LEGITIMATE GROUNDS FOR COLLECTION, MAINTENANCE AND PROCESSING OF PERSONAL DATA

There are several purposes for the collection, maintenance and processing of personal data by PayBlox. We collect, maintain and process personal data to perform our contractual obligations to certain Users and to comply with legal obligations. Furthermore, we collect, maintain and process personal data to pursue our legitimate interest to run, maintain and develop our business. Personal data is collected, maintained and processed by PayBlox for managing the relationships with customers, performing our Services, and for managing, developing and analyzing our customer service. Personal data is also used to direct marketing at special customer groups, and other business activities related to any of these activities. User Data and Technical Data are also used or processed by PayBlox for some or all of the following purposes:

3.1 For quality improvement and trend analysis.

We may process information regarding the use of the Services to improve the quality of our Services e.g. by analyzing any trends in the use of our Services. When possible, we will do this using only aggregated, non- personally identifiable data.

3.2 To provide our Services and carry out our contractual obligations.

We collect, maintain and process personal data in the first place to be able to offer the Services to our customers and Users and to run, maintain and develop our business, including providing personal data to affiliates and third party provides necessary to provide the Services. In some cases, personal data may be collected, maintained and processed in order to carry out our contractual obligations to the User. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If a User contacts our customer service, we will use the provided information for answering questions and solving possible issues.

3.3 For customer communication.

We may collect, maintain and process personal data for the purpose of contacting Users regarding our Services and to inform Users of changes in our Services. Data may also be used for research and analysis purposes in order to improve our Services.

3.4 For adding value-added functionality to our Services. In all instances, we use data solely to the extent permitted by applicable laws, rules and regulations.  Provided the following are done in full compliance with this Privacy Policy, applicable laws, rules and regulations, PayBlox may (a) process, analyze, and manage data to provide services to its customers; and (b) use data to analyze, develop and improve its products, systems, and tools.

3.5 Create anonymized or aggregated data that dose not identify third parties or Users.  We may share information with third parties that is not personally identifying, such as aggregated or anonymized data that does not identify you or our third parties, in our discretion, where not prohibited by law.

3.6 Comply with applicable laws, regulations and legal requests.  We may share personal information in response to a subpoena or similar investigative demand, court order, requests for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency to establish or exercise our legal rights, to defend against legal claims, or as we reasonably believe is required by law.  In such cases, we may raise or waive any legal objection or right available to us. 

3.7  Prevent or detect fraud or other misuse.  We may share personal information when we believe that disclosure is appropriate in order to investigate, prevent, or take action regarding any actual or suspected illegal activity or other wrongdoing, to protect and defend the rights, property, or safety of our business, our users, our employees, or others or to enforce our Terms and Conditions or any of our agreements or policies.

4. STORAGE PERIOD

PayBlox does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes for collecting it. The maximum period may therefore vary per use. Typically, we will store a User’s personal data for as long as the User or the relevant customer the User represents is a registered subscriber or a registered user of our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law or reasonably necessary for internal reporting and reconciliation purposes. In general, personal data of a User is deleted within a reasonable time after the User no longer uses any part of the Services or when the User makes a request regarding deletion of its personal data. The data will be deleted within reasonable time after you’ve stopped using our Services or request your personal data to be deleted.

5. USER RIGHTS

5.1 Right to withdraw consent.

In case the collection, maintenance or processing of data is based on a consent granted by User, User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use, or the complete termination of, our Services.

5.2 Right to correct.

A User has the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about the User corrected or completed.

5.3 Right to object.

A User may object to certain use of personal data if such data is collected, maintained or processed for other purposes than purposes necessary for the performance of our Services to the User or for compliance with a legal obligation. A User may also object to any further collection, maintenance or processing of personal data after previously giving consent. If a User objects to the further collection, maintenance or processing of personal data, this may lead to fewer possibilities to use, or the complete termination of, our Services.

5.4 Right to access.

PayBlox offers access for the Users to the personal data maintained or processed by us. This means that a User may contact us and we will inform what personal data we maintain regarding the User and the purposes such data are used for.

5.5 Right to data portability.

Users have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

5.6 Right to deletion.

A User may also ask us to delete the User’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. We may not immediately be able to delete all residual copies from our servers and backup systems after the active data have been deleted. Such copies shall be deleted as soon as reasonably possible.

5.7 Right to restriction of maintenance or processing.

Users may request us to restrict certain maintenance or processing of personal data, this may however lead to fewer possibilities to use our Services.

5.8 How to use the rights.

The above mentioned rights may be used by sending a letter or an e-mail to us at the addresses set out below, including the following information: the full name, company name (if applicable), address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. As a User you have the right to access, correct, and delete your personal data. Contact us for any requests to exercise your rights.

5.9 Lodging a complaint.

In case a User considers our collection, maintenance or processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

6. INFORMATION SECURITY

We will take all reasonable and appropriate security measures to protect the personal data we store and process from unauthorized access or unauthorized alteration, disclosure or destruction. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. We maintain all personal data collected through industry standard safe mechanisms. We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our websites, data centers, systems, and other assets for security vulnerabilities. If a security breach occurs despite our security measures that is likely to have negative effects to the privacy of Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible. We use appropriate security measures to keep your personal data safe; however, we cannot guarantee that your personal data will always remain secure. If a breach that might affect your privacy should occur, we’ll inform the relevant authorities and let you know.

7. RECIPIENTS

We only share personal data within the organization of PayBlox if and as far as reasonably necessary to perform and develop our Services. We do not share personal data with third parties outside of PayBlox organization other than in connection with the performance of our Services (including, without limitation, with third party providers of transaction processing services sought by Users) unless one of the following circumstances applies:

7.1 With explicit consent

We may share personal data with third parties outside PayBlox’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to withdraw this consent at all times. We do not share your personal data with third parties unless necessary to provide you with our Services or for legal reasons.

7.2 It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to perform the Services, PayBlox has taken appropriate contractual and organizational measures to ensure that personal data are maintained and processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

7.3 To authorized service providers

We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and customer support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

7.4 For legal reasons

We may share personal data with third parties outside PayBlox’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of PayBlox’s Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.

7.5 For other legitimate reasons

If PayBlox is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

7.6 Additional Information

More information regarding the transfers of personal data may be obtained by contacting us at addresses stated in this Privacy Policy.

8. CHANGES TO THIS PRIVACY POLICY

PayBlox reserves the right to modify or amend this Privacy Policy at any time and for any reason. If we make any changes, we will notify you by posting it on our website and revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the information we collect.  By using our Services, you acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of any modifications.  If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy periodically to stay informed about our information practices and the ways you can help protect your privacy. Your continued access or use of our website and Services following a change means you consent to the collection, maintenance, use and disclosure of your Personal Information as set out in this Privacy Policy.

9. Use of Services from Outside of the United States

Our Services are intended to be provided within the United States.  Our Services are governed by the laws of the United States and are intended for use by Users connected to the internet from a physical location within the United States only.  We make no representation that our Services are governed by, or operated in accordance with, the laws of any other nation.

10.  Online Tracking Opt-Out Guide

Like many companies online, we use services provided by Google, Facebook, and other companies that use tracking technologies.  These services rely on tracking technologies, such as cookies and web beacons, to collect information directly from your device about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet.  There are a number of ways to opt out of having your online activity and device data collected through these services, which are summarized below:

10.1  Blocking Cookies in your browser. 

Most browsers let you remove or reject cookies, including cookies used for internet-based advertising.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

10.2  Blocking advertising ID use in your mobile settings.

Your mobile device settings may provide functionality to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.

10.3  Using privacy plug-ins or browsers. 

You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers.

10.4  Platform opt-outs.  The following advertising partners offer opt-out features that let you opt out of the use of your information for interest-based advertising:

Google: https://adsettings.google.com

Facebook: https://wwww.facebook.com/about/ads

Twitter: https://twitter.com/personalization

10.5  Advertising industry op-out tools.

You can use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance: http//optout.aboutads.info

Network Advertising Initiative: http://optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser you use.

11.  Notice to California Residents

We are required by the California Consumer Privacy Act of 2018 (“CCPS”) to provide this CCPS Notice to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their personal information.  This CCPA Notice apply only to California residents whose interactions with us are limited to:

•  Visiting our consumer websites;
• Signing up for email alerts;
• Commenting on or contributing to our blogs;
• Establishing an account that does not include financial products or services; or
• Applying for our job openings on our websites (however, note that the CCPA limits some of the privacy rights for job applicants).

This CCPA Notice does not apply to the personal information we collect, us, or disclose about consumers who initiate or complete the process of applying for financial products or services.  This is because this information is subject is subject to the federal Gramm-Leach-Billey Act (“GLBA”) and implementing regulations of the California Financial Information Privacy Act (“FIPA”), or representatives of businesses that seek to obtain our products or services, or to provide products or services to us.

11.1  Privacy Practices.

We do not sell personal information.  As explained in our Privacy Policy, we use cookies and other tracking technologies to analyze website traffic and facilitate advertising.

How You Interact With Us	Personal Information Collection	Business Information Collection	CCPA – Defined Categories	Sources of Personal Information	Sharing
Sign up as a user/authorized business representative	Name or Alias	Business Industry	Identifiers	You	Shared with Processors
Interact with Our Blogs	Email addresses	Average Ticket	Online Identifiers	Operations	We never share personal information unless an officer is accepted on our platform
Establish an account	DOB	High Ticket	Internet and network information	Communications	Non-identifying business data is shared at our direction
Inquire about consulting services or other services we provide	Address or Information	Monthly Volume		Marketing	Collected directly by or shared with our service providers
	Contact Information	Business Payment Processing Information		Advertising	Collected directly by advertising partners
	Device Data	Locations, State		Research and Development
	Online Activity Data	EIN and or business credit		Payment Processors and Payment Service Companies
	Information Derived from device data and online activity data	Business payment preferences from payment processors
	Any information you voluntarily provide	Business corporation information
	Professional Information	Years in business
	Payment information (for our rebate program)	Business contact information
		Payment Information (for our rebate program)

Please note that we may also disclose personal information as described in Section 3 of the Privacy Policy.

11.2  Privacy Rights

The CCPA grants individuals the following rights:

• Information

You can request information about how we have collected, used, and shared your personal information during the past 12 months.

• Access

You can request a copy of the personal information that we maintain about you.

• Deletion

You can ask us ti delete the personal information that we collected or maintained about you.  Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request.  We will respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request.  If we deny your request, we will communicate our decision to you.  You are entitled to exercise the rights described above free from discrimination.  To request access to or deletion of personal information please contact us as set forth in Section 12.

• Opt-Out

You may request us to stop sharing your personal information (“op-out”, including via a user-enabled global privacy control.  We cannot share your personal information after we receive your opt-out request unless you later authorize us to do so again.

• Right to non-discrimination

We cannot deny you the Services, charge you a different price, or provide a different level or quality of the Services just because you exercised your rights under the CCPA.  However, if you refuse to provide your personal information to us or ask us to delete or stop sharing your personal information, and that personal information or the sharing of the personal information is necessary for us to provide you with the services, we may not be able to complete that portion of the Services or the Services in its entirety.

• Right to correct

You have the right to ask us to correct any inaccurate information that we may have about you.

• Right to limit

You can direct us to only use your sensitive personal information (i.e. your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the Services.

• Identity verification

The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request.  We will ask you to verify your identity when you submit a request.\

• Authorized Agents

California residents can empower an “authorized agent” to submit a request on their behalf.  We will require the authorized agent to have a written authorization confirming that authority.

• Notice of collection of personal information 

We list the categories of your information that we collect and the business and commercial purposes for our use as described in the detailed chart above. 

12.  CONTACT US

If you have additional questions about this Privacy Policy, or wish to access or change your Personal Information, please contact our customer support team, by email at Su*****@Pa*****.com, online through our website, or mail us at:

PayBlox

PO Box 1982

North Eastham, MA 02651