Xenial

��Privacy Notice

Last Updated: December 4, 2024

At Xenial, Inc., a company ("Xenial"), we respect your privacy. ��is a technology platform that offers enterprise-ready restaurant and food service management solutions and customer engagement tools (collectively referred to as the "Services"). Except where otherwise indicated, this Privacy Notice ("Notice") describes how we process the personal information we collect from visitors to our websites, forums and blogs ("Sites") and mobile applications ("Apps") that link to or expressly reference this Notice, subject to the additional information on scope provided below.

For the purpose of this Notice, Xenial, "we" and "us" refer to Xenial, Inc. and its subsidiaries and affiliates, as the context requires, and include but are not limited to RTI and SICOM. Our privacy practices vary depending on the Services we provide and the country-specific requirements for the countries in which we operate. For some products and Services, where required, we will provide additional privacy notices before collecting your personal information. ��maintains specific privacy notices for job applicants, employees, and contractors through its parent company, Global Payments. If you are a job applicant, employee, or contractor of ��and need a copy of the applicable privacy notice, please contact us at privacy@globalpay.com.

Please read this Notice carefully. If you have any questions, you may contact us at privacy@globalpay.com or by the methods provided in the "Contact Us" section, below.

Please note that the ��Sites and Apps collect personal information from our current and prospective Customers, as well as from the end users who engage with our Apps through the Services we provide to our Customers ("Customer End Users"). When ��processes personal information about Customer End Users, we do so for the sole purpose of providing the Services to our Customers, and in accordance with our agreements with our Customers. Our processing of Customer End User personal information is therefore governed by our Customers’ privacy notices, and it is not covered by this Notice. If you are a Customer End User who has a relationship with one of our Customers, and you have a question about how personal information about you is collected, used, or disclosed, or would like to exercise any rights you may have with respect to such personal information, please contact the Customer directly.

Please be aware that not all of the information in this Notice will be directly applicable to our handling of your personal information. This Notice provides an overview of the possible circumstances in which we may interact with your personal information. If you have any questions about our processing of your personal information, please contact us at privacy@globalpay.com.

Select one of the links below to jump to a particular section of this Notice:

Personal Information We Collect

"Personal information" is information that identifies you as an individual or relates to an identifiable individual. Through our Sites and Apps, subject to your consent if required by law, we may collect the following categories of personal information:

Basic Identifying Information, including your full name, postal address, e-mail address, phone number, username, or other similar identifiers.
Device Information and Other Unique Identifiers, including device identifier, internet protocol (IP) address, cookies, beacons, or similar unique identifiers.
Internet or Other Network Activity, including browsing or search history and information regarding your interactions with our Sites and Apps.
Geolocation Data, including information that permits us to determine your precise location, such as if you enable location-based Services through the Apps.
Payment Information, including credit or debit card numbers.
Commercial Information, including your access and purchase history with us, and your preferences regarding products and related services which are of interest to you (see "Managing Your Preferences" below).
Professional and Employment-Related Information, including your role or status with the organization with which you are affiliated.
Information You Provide, including your communications with us and any other content you provide (such as if you report a problem with our Sites and Apps or participate in any blog, community or forum on our Sites).
Audio and Visual Information, including photographs, images, videos, and recordings of your voice (such as when we record calls or videos for quality assurance or other business activities).
Inferences, drawn from or created based on any of the information identified above.
Any other information, as directed by and on behalf of, our Customers., As discussed further above, our collection of Customer End User personal information on behalf of our Customers is covered by our Customers’ privacy notices.

Data anonymization and aggregation. Subject to your consent if required by law, we may anonymize or aggregate personal information about you so that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, we may use anonymized or aggregated data for statistical analysis including to analyze trends, for third-product development, and for risk assessments and cost analysis. We may disclose anonymized or aggregated data to our parent company, subsidiaries, affiliates or with other third parties. This Notice does not restrict Xenial’s use or disclosure of any anonymized or aggregated information.

Where we maintain or use de-identified information, we will continue to maintain and use the de-identified information only in a de-identified fashion and will not attempt to re-identify the information.

Our Use of Personal Information

We may use the information that we collect about you for the following business and commercial purposes:

Providing our Services and related support: including to help fulfill your requests for products and Services; to communicate with you about your use of our Services; to respond to your inquiries; to provide troubleshooting and other technical support; and for other customer service and support purposes.
Protecting the integrity of the Services: including to verify your identity; to repair or improve our Services; to detect and prevent fraud and unauthorized activities; to facilitate software updates; to preserve the integrity of the Services and our systems, and prevent unauthorized access and activities; to enforce our applicable terms; and to protect the rights and safety of others.
Analyzing and improving the Services and our business: including to better understand how users access and use our Services; to evaluate and improve the Services and our business operations; to develop new features, offerings and Services; to conduct surveys and other evaluations; and for other research and analytical purposes.
Personalizing the Services: including to tailor content we send or display on our Sites and Services (e.g., for your geographic area); to offer personalized help and instructions; and to otherwise personalize your experiences with the Services.
Advertising, marketing and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to contact you about our Services, and those of our affiliates, as well as other information we think may interest you. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes.
Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.
Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with users or third parties.
Auditing, reporting, corporate governance, internal operations, and other general business purposes: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.
Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such warrants, subpoenas, court orders, and regulatory or law enforcement requests.

Sources of Personal Information

We collect personal information from several sources including:

Information that you provide to us. We collect personal information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, if you register for an online account with us, we may request your name, contact information and payment information. Providing us with personal information is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Services' features.
Information collected from third parties. We may collect information about you from third parties in the course of providing our Services. For example, we may collect personal information like your name and contact information from our Customer if you are a Customer End User in order to provide the Services to you.
Information collected through technology. When you visit our Sites or Apps (or when you use any of our Services) we may collect certain information about your location, usage, or device through technology such as cookies (see "Cookies and Other Tracking Technologies" for more information). When you download and use our Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. We may collect geolocation in the Apps for the purpose of enabling location-based Services.

How We Disclose the Personal Information We Collect

For each category of personal information we collect, we may disclose such information in the manner and for the purposes described below:

With ��affiliates where such disclosure is necessary to provide you with our Services or to manage our business.
With non-affiliated service providers whose systems, applications, products or Services help us to provide the Services. For example, we disclose personal information to information technology (IT) service providers who help manage our back office systems or administer our Sites and Apps.
With non-affiliated service providers who provide services to us, including (without limitation) legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business.
With our Customer with whom you are also engaging when you use the Services. For example, you may be using a ��Site to log into your account with our Customer. ��will disclose the personal information you provide to the Customer in order to fulfill your request. You may also receive communications from the Customer. Each such Customer operates independently from ��and their collection and use of your personal information is not subject to this Notice but to the Customer’s own privacy notices.
With other non-affiliated entities, including entities that provide advertising, campaign measurement, online and mobile analytics, and related Services. These entities may receive or access browsing and other data about your use of the Services, in order to help us better reach individuals with relevant ads and measure our ad campaigns, or to better understand how individuals interact with our Site and online Services over time and across devices.
With promotional partners if you choose to enter a contest, sweepstakes or promotion. Personal information disclosed in connection with a promotion may include information needed to enable posting your entry with attribution or otherwise as permitted in the official rules for the promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a promotion, we may require you to consent to the use of your personal information or other information, such as name, voice or likeness, in advertising, promotional and marketing materials. In addition, we may offer certain promotional content, such as a sweepstakes, sponsored by or co-branded with a third party, who may obtain the personal information that you submit.
With social media management providers that enable us to manage and analyze our branded social media account content, including tags, mentions, posts, comments, and direct messages.
With social media sites such as Facebook, Instagram and Twitter, through an application programming interface (API) or other software. By allowing the Site to connect with your accounts on such third-party sites, you consent to our accessing the information in those accounts, which information may include personal information. When you access the Sites via your social media account, activity you engage in through the Site may be published on the third-party site. It is your choice whether to use any such third-party sites.
With other non-affiliated entities to whom you direct us to disclose personal information.
When we believe that disclosure is necessary or appropriate to comply with laws and regulations or respond to lawful requests and legal process; to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud or other wrongdoing; to enforce our agreements, policies, and terms of use; and to protect or defend the rights, safety or property of ��and its affiliates, users of the Services, or any person.
To third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).

Cookies and Other Tracking Technologies

A "cookie" is a text file that is stored to your browser when you visit a website.

Unique device identifiers like IP address or UDID recognize a visitor’s computer or other device used to access the internet. Unique device identifiers are used alone and in conjunction with cookies and other tracking technologies for the purpose of "remembering" computers or other devices used to access the Sites and Apps. We also gather statistical information about the use of our services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.

Cookies can be classified by duration and by source:

Duration. The Sites use both "session" and "persistent" cookies. Session cookies are temporary; they terminate when you close your browser or otherwise end your "active" browsing session. Persistent cookies remember you on subsequent visits. Persistent cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to delete them (see below for "How to Delete or Block Cookies").
Source. Cookies can be "first-party" or "third-party" cookies, which means that they are either issued by or on behalf of ��or by a third-party operator of another website. For an example of a third-party cookie, our Sites may contain features like videos hosted by other companies, which would set a cookie that can be read by the host. Our Sites may use both first-party and third-party cookies.

The cookies that we may use fall into the following categories:

Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the Sites.
Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies. These cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some of these services may not function properly.
Targeting Cookies. These cookies may be set by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

How to Delete or Block Cookies

We adhere to the standards set out in this Notice and do not currently monitor or respond to browser Do-Not-Track signals. If you do not want information collected through the use of cookies, you can use the Cookie Settings banner or icon on the Site to make selections about the use of cookies. Additionally, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also refer to . If, however, you do not accept cookies, you may experience some inconvenience in your use of our services. You also may not receive advertising from us that are relevant to your interests and needs. Additionally, some browsers and browser extensions support the Global Privacy Control ("GPC") that can send a signal to the websites you visit indicating your choice to opt out of certain types of data processing. Through our consent management platform, administered by our vendor OneTrust, the Sites recognize and respond to opt-out requests made using GPC.

External Links

��may provide links on our Sites to other third-party websites or services that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such third-party websites or services or regarding the products and Services they offer. We make no representation regarding your use of such websites or services. Please be aware that we are not responsible for the privacy practices of the operators of other websites or services. We encourage our users to be aware when they leave our Sites. You should read any other applicable privacy and cookies notices carefully before accessing and using third-party websites and services.

Our Relationship with Affiliate Companies

Subject to your consent if required by applicable law, we may appoint an affiliate company to process personal information in a service provider role. We will remain responsible for that company’s processing of personal information pursuant to applicable data privacy laws.

Because our affiliate companies are located around the globe, personal information may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence.

We take appropriate steps to transfer personal information in accordance with applicable law, such as transferring personal information to countries that are recognized as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights.

Your Legal Rights

If you are a Customer End User who interacts with our Sites and Apps for the purposes of engaging with our Customers, and have questions about legal rights you may have with respect to personal information collected by or on behalf of our Customer, please consult the Customer with whom you have a relationship.

If you interact with our Sites and Apps or Services for the purpose of engaging in a direct relationship with us, subject to certain exceptions, and in some cases dependent upon the processing activity we are undertaking, you may have the right to:

Know whether we process personal information about you;
Know how the personal information is used;
Access, request and receive the personal information we have collected in a portable manner;
Opt out of having personal information sold, "shared," or used for certain profiling activities;
Request that we correct inaccuracies in personal information about you; and
Request that we delete personal information about you.

You may contact us using the information in the "Contact Us" section of this Notice for additional information about how to exercise your rights. In addition, if you are a resident of California, Colorado, Delaware, Oregon, the European Union, the United Kingdom, Quebec, or other jurisdiction with similar laws, please see the Region-Specific Information section below for further details on how to exercise your privacy rights.

Data Security and Data Retention

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide via the Sites and Apps against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.

Please remember that communications over the internet such as emails are not secure. We seek to keep secure personal information submitted to us through the Sites and Apps in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through the Sites and Apps.

We retain the personal information we collect for different periods of time depending on what it is and how we use it. In some contexts, we will provide additional information about retention as you use the Services. When we collect personal information, we will retain it only for as long as is necessary to complete the legitimate business or legal purposes for which we collected it. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have an account with us or continue to use our Services, and the length of time thereafter during which we may have a legitimate need to reference personal information to address issues that may arise;
Whether there is a contractual obligation to which we are subject, for example, our contracts with our Customers may specify a certain period of time during which we are required to maintain the information on behalf of our Customers;
Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; and
Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

Notice of Financial Incentives/Bona Fide Loyalty Program

Our Services enable our Customers to create loyalty programs. The loyalty programs may provide certain perks, such as rewards and exclusive offers. The loyalty programs may also provide promotional campaigns, alone or in conjunction with third-party partners. The terms and conditions of the loyalty program are set by the Customer. Because the loyalty programs involve the collection of personal information and the offering of discounts or other incentives, however, they may be interpreted as offering a "financial incentive" in exchange for your agreement to permit the processing of your personal information. In that case, the value of your personal information is determined by the Customer in relation to the value of the free or discounted products, services, or other benefits that the Customer chooses to provide as part of the loyalty program, less the expense related to the offering of those products, services, or other benefits to loyalty program participants. You may opt-in to a loyalty program by following the steps explained to you by the relevant Customer, and you may withdraw or opt out of a loyalty program at any time by following the procedures established for that purpose or by contacting the Customer directly. If you ask the relevant Customer to delete your personal information (see "Your Legal Rights" above), please be advised that the deletion of your data may make it impossible for the Customer to provide the benefits associated with the program.

Managing Your Preferences

When we rely on your consent as the legal basis for our processing of personal information, you may withdraw your consent as may be instructed in the Sites, Apps or Services, or by contacting us using the information in the (see "Contact Us"> section, below

Subject to your consent if required by applicable law, we may use personal information to provide you with direct marketing information about our products and Services as well as those of our global affiliates and third parties. Our direct marketing may occur through email, telephone, post or SMS or such other method(s) as may become relevant.

We will take steps to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an "unsubscribe" link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time. Please note that if you opt out of receiving marketing-related communications from us, we may still send you administrative, transactional, or information messages, from which you cannot opt out.

Children

The Sites, Apps, and Services are not directed to or intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 16. Please do not use the Sites, Apps, or Services if you are under the age of 16. Any collection of personal information from persons under the age of 16 by our Customers is governed by our Customers’ policies and privacy notices.

Changes and Updates to this Notice

We reserve the right, in our sole discretion, to modify, update, or otherwise change this Notice. The "Last Updated" legend at the top of this Notice indicates when this Notice was last revised. Any changes will become effective when we post the revised Notice on our Services, including our Sites and Apps. Where required by applicable law, to the extent we make material or significant changes to the Notice, we will notify you of the update via a pop-up, email, other notification in the Services, Sites, or Apps, or other method by which we routinely communicate with you.

Contact Us

If you have questions about this Notice, or if you want to exercise your rights as described in this Notice, you can submit a request by or may contact us as follows:

��Inc.
3420 Toringdon Way, Suite 400
Charlotte, NC 28277
privacy@globalpay.com
800-253-8664

If you make a request to exercise a privacy right, we will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may decline to honor your request where an exception applies. In order to honor any access, deletion, or similar request, we will require you to provide enough information for us to verify your identity. For example, we may ask you for information associated with your account, including your contact information or other identifying information. If you would like your agent to make a request on your behalf, if permitted under applicable law, the agent may exercise those rights as noted above. We will process the agent’s request consistent with applicable law. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in this section or confirm that you provided the agent permission to submit the request.

Region-Specific Information

Information for Residents of the European Union and the United Kingdom

To the extent that the Sites or Apps with which you are interacting are directed at United Kingdom or European Union residents, this section of the Notice applies to you.

	What does this mean?
Right to be informed	You have the right to be provided with clear and easy-to-understand information about how we use your personal information. This is why we are providing you this Notice and we may provide other forms of notice, as appropriate or required by law, in the Services.
Right to access personal information	You have the right to access and receive a copy of personal information we hold about you.
Right to data portability	In some circumstances, you have the right to receive the personal information you request from us in a format that is user-friendly and enables you to transfer it to another provider.
Right to rectification	You have the right to correct or update your personal information if it is outdated, incorrect or incomplete.
Right of erasure ("right to be forgotten")	In some circumstances, you have the right to have your personal information erased or deleted.
Right to restrict/suspend processing of personal information	You may object to processing of personal information that is based on legitimate interest. You may withdraw consent for processing that is based on consent (this includes the right to opt out of direct marketing).
Right to information about information transfers	You have the right to obtain a copy of documents related to the safeguards under which your personal information is transferred outside the EU.
Right to complain to a supervisory authority	You have the right to contact the data protection authority in your country to complain about our data protection and privacy practices.

Information for Residents of California, Colorado, Delaware, Oregon, and Other Similar Jurisdictions

This section supplements the above Notice and further describes how we collect, use, and disclose the personal information we collect about residents of California, Colorado, Delaware, Oregon, and other similar jurisdictions.

Categories of Personal Information We Collect and Our Purposes for Collection, Use, and Disclosure.

The following chart details which categories of personal information we collect and process, as well as which categories of personal information we disclose to recipients for our operational business purposes, including within the preceding 12 months.

Categories of Personal Information (See the "Personal Information We Collect" section for a description of each category of Personal Information)	Disclosed to Which Categories of Recipients for Operational Business Purposes	Processing Purposes
Basic Identifying Information; Device Information and Other Unique Identifiers; Internet or Other Network Activity; Commercial Information; Professional and Employment-Related Information; Information You Provide; Inferences	Please see the "How We Disclose the Personal Information We Collect" section for a list of the categories of third parties to whom we may disclose these categories of personal information.	Please see the "Our Use of Personal Information" section for a list and description of the applicable processing purposes for these categories of personal information.
Geolocation Data	Affiliates; distributors of our products and services; service providers; marketing partners; legal authorities and other third parties in order to comply with laws, regulations, and standards; other parties in litigation	Provide our services and customer support Operations and general business purposes Marketing, promotions, and personalization Improve and develop new products and services Fraud prevention and security Legal and compliance
Payment Information	Affiliates; third parties with whom you have a relationship (i.e. our Customers); regulators; legal authorities and other third parties in order to comply with laws, regulations, and standards	Provide our services and customer support Operations and general business purposes Fraud prevention and security Legal and compliance
Audio and Visual Information	Affiliates; distributors of our products and services; service providers; regulators; legal authorities and other third parties in order to comply with laws, regulations, and standards; other parties in litigation	Provide our services and customer support Operations and general business purposes Improve and develop new products and services Fraud prevention and security Legal and compliance

Do Not Sell or Share My Personal Information

Unless otherwise disclosed in a specific notice, and subject to your consent where required by applicable law, we do not sell your personal information to third parties for monetary compensation. We do not sell or "share" (for purposes of cross-context behavioral advertising) the personal information, including the sensitive personal information, of minors under 16 years of age.

The Sites and Apps use cookies, including some cookies that are created by other companies and placed on your browser when you visit our website. We use those cookies to improve your experience and to gather information about our customers and the performance of our website. However, the companies who provide those cookies to us also have access to the data collected through them, and they may use that data for targeted advertising purposes. Our use of those third-party cookies could therefore be considered a "share" of your personal information under California law or processing for targeted advertising under other privacy laws. If you are a resident of California or another jurisdiction with similar laws, that means you have the right to opt out. If you have not done so already, you can opt out of the placement of all non-necessary cookies by adjusting your Cookie Settings.

You can also use the GPC to indicate your choice to opt out of certain types of data processing, including sales and "shares" of personal information. Through our consent management platform, administered by OneTrust, the Sites recognize and respond to opt-out requests made using GPC.

Collection, Use, and Disclosure of Sensitive Personal Information

Subject to your consent where required by applicable law, we collect, process, and disclose sensitive personal information for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use sensitive personal information beyond these purposes.

Rights and Requests

If you interact with our Sites and Apps for the purpose of engaging in a direct relationship with us, subject to certain exceptions, and in some cases dependent upon the processing activity we are undertaking and/or your state of residence, you may have one or more of the following rights.

Right to know about personal information collected, used, disclosed, sold, and "shared"	You have the right to know whether we process personal information about you, and to access such personal information. If you are a California resident, you may also request that we disclose to you: the categories of personal information we have collected about you and the categories of sources from which we collection such personal information; the business or commercial purpose for which we collected, "shared," or sold the personal information about you; the categories of personal information about you that we "shared" or sold and the categories of third parties with whom we "shared" or to whom we sold the personal information about you; and the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose. If you are a resident of Delaware or Oregon, you may also have a right to request a list of the third parties to whom we have disclosed your personal information.
Right to receive a copy of personal information	You have the right to request that we provide the specific pieces of personal information, including a copy of such personal information in a portable format.
Right to opt-out of the sale of personal information	You may request that we do not sell personal information about you to third parties. See the "Do Not Sell or Share My Personal Information" section for more information.
Right to opt-out of targeted advertising, including the "sharing" of personal information for cross-context behavioral advertising	You may request that we opt you out of targeted advertising, including that we stop "sharing" personal information about you for purposes of cross-context behavioral advertising. See the "Do Not Sell or Share My Personal Information" section for more information.
Right to request deletion	In some circumstances, you have the right to have personal information about you deleted.
Right to equal service and prices ("non-discrimination")	Your choice to exercise your privacy rights will not be used as a basis to discriminate against you in services offered or pricing.
Right to request correction	You have the right to request that we correct inaccuracies in your personal information.
Right to limit the use and disclosure of sensitive personal information	In some circumstances, you may request that we limit the use and disclosure of your sensitive personal information.
Right to appeal	Depending on your state of residence, if we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. To appeal, you can contact us at privacy@globalpay.com or complete this and select "Appeal a decision about a previous request" under "Type of Request."

You can submit a request for any of the above rights by using the contact information in the "Contact Us" section of this Notice.

California Shine the Light

If you are a resident of California, you may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the information provided in the Contact Us section of this Notice.

Information for Residents of Quebec

Cross-Border Transfers of Personal Information

If you are a resident of Quebec and we collect personal information about you in Quebec, that information will be communicated outside of Quebec to other locations in Canada, the United States and other places where we or our service providers process your information, for the purposes described above.

Data Governance

We maintain a governance program for the protection of personal information that we collect. The program includes policies and procedures designed to help us comply with this Notice. This program requires employees to protect the confidentiality of personal information that we handle through the lifecycle of that personal information. The program includes an employee code of conduct, breach reporting procedures, data retention and destruction policies, employee training, and procedures for addressing complaints and providing individuals with access to their personal information in accordance with this Notice.

��has established controls and mechanisms to protect data at each stage of the data lifecycle, from collection or creation, through to disposal.

Data Subject Rights

De-indexation Right or Right to Erasure	You have the right to request that we delete the personal information that we collected from you and retained, subject to certain exceptions. For example, we may deny your deletion request if retaining your information is necessary for us to be able to recover payment, detect security incidents, or protect against illegal activity.
Cessation of Dissemination	You have the right to request that we cease disseminating your personal information if the dissemination is contrary to the law or a court order, or in certain other circumstances.
Right to Data Portability	You have the right to receive computerized personal information that you have provided directly to us, for example, through opening an account, in a commonly-used and machine-readable format. You have this right so that you may transmit your information to another organization without hindrance.

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