Effective Date: 08.20.2021
Information We Collect
We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or that we collect, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:
Information that we collect when a Merchant’s customers make a payment
When a customer makes a payment via the Clover Flex Terminal, we collect information about the transaction, which may include personal data. Information about transactions includes the payment card used, name associated with the payment card, the location of the merchant’s store, date and time of the transaction, transaction amount, and information about the goods or services purchased in the transaction.
In addition, we collect and use several types of information from and about you, including:
- Personal information that we can reasonably use to directly or indirectly identify Merchant’s customers, such as Merchant’s customers name, mailing address, e-mail address, billing information, telephone number, Internet Protocol (IP) address used to connect your computer to the internet, username or other similar identifier, and any other identifier we may use to contact you online or offline (” personal information”).
- Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access Website, and usage details.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
Additional information Merchants’ customers provide through the Odoo POS ancillary to a payment
We may collect additional information ancillary to the payment. This information may include:
- Customers’ email address or phone number, such as when the customer chooses to receive an electronic receipt
- Customers’ marketing preferences, such as whether the customer wishes to receive marketing communications or newsletters
- Information about participating customers’ activity in a merchant loyalty program
- Customers’ physical address, where needed for delivery of goods or services
- Other information the customer provides, such as birthdate, interests or preferences, reviews, and feedback
Information that we collect about Merchants’ personnel
We may collect information about Merchants’ personnel and interactions with the Odoo POS and Invoice, such as clock-in and clock-out time and transactions performed.
Additional information that Merchants provide to us about their customers or personnel
Merchants may provide us with additional information directly, via access they grant to us, or otherwise. The types of information that merchants may provide to us about their customers include email addresses, phone numbers, and purchase history. The types of information that merchants may provide to us about their personnel include email addresses, phone numbers, shifts, and sales history.
How We Use the Information We Collect
We use the personal data we collect for or on behalf of Merchants, to provide our services and the functionality of our application:
We may also use personal data for related internal purposes, including:
- To provide information about the application, such as important updates or changes to the application and security alerts
- To measure performance of and improve the application
- To respond to inquiries, complaints, and requests for customer support
In addition, Company may use personal data as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share Information
We may share personal data that we collect with:
- The Merchant from whom or on whose behalf we collected the personal data
- The platform on which our application runs, the Odoo POS and Invoice. You may view Odoo’s Privacy Notice here.
- With third parties as a Merchant may direct
- With third party service providers that help us manage and improve the application
Company may disclose personal data to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Your Rights and Choices
Data Subject Rights
To the extent that applicable law provides individuals with rights pertaining to their personal information, such as to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of our application. To the extent that Syncoria is responsible for responding to data subject rights requests under applicable law, individuals may contact Syncoria with applicable requests as explained in Syncoria’s Privacy Notice https://www.syncoria.com/privacy-policy/ . Company will assist a Merchant, or Clover, as applicable, in responding to such requests subject to our contract with a Merchant or Clover.
If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.
1200 Bay St., Suite -202, Toronto, ON, M5R 2A5
Phone: + 1(416) 628-5522
Additional Information for Merchants Located in Europe
Company is a data processor acting for and on behalf of the Merchant that has installed our application on their Odoo POS and Invoice. That Merchant is the controller of personal data that we process on its behalf. Clover is also a controller of personal data in some circumstances. Clover’s Privacy Notice is available at https://www.clover.com/privacy-policy.
Legal Bases for Processing
Company processes personal data as directed or permitted by the Merchant that uses our application. The Merchant is responsible for establishing a legal basis for our processing of personal data for or on behalf of the Merchant.
Cross Border Data Transfer
When we transfer personal data outside of Europe to countries not deemed by the European Commission to provide an adequate level of protection for personal data, we make the transfer pursuant to one of the following transfer mechanisms:
- A contract approved by the European Commission (sometimes called “Model Clauses” or “Standard Contractual Clauses”);
- The EU-US Privacy Shield;
- The recipient’s Binding Corporate Rules;
- The consent of the individual to whom the personal data relates; or
- Other mechanisms or legal grounds as may be permitted under applicable European law.
You may contact us with questions about our transfer mechanism.
Subject to our agreement with a Merchant, Company retains personal data for as long as necessary to (a) provide our products and services; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce the terms of any agreement we may have with a Merchant. You may contact us for additional information about our data retention practices in connection with the application.
Data Subject Rights
Under certain circumstances, data subjects in Europe have certain rights relating to their personal data, which include the rights to request from the Controller (a) access to the data subject’s personal data; (b) correction of incomplete or inaccurate personal data; (c) erasure of personal data; (d) restriction of processing concerning the data subject; and (e) that the controller provide a copy of the data subject’s personal data that the data subject provided to the controller in a structured, commonly used and machine-readable format. Data subjects may also object to a controller’s processing of personal data under certain circumstances. Where processing is based on a data subject’s consent, the data subject has the right to withdraw consent at any time; however, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Data subjects may also file a complaint with a supervisory authority. You may view contact information for supervisory authorities at https://edpb.europa.eu/about-edpb/board/members_en. Data subjects in Europe should direct any rights request to the appropriate Controller.