Canadian Privacy Statement

Global Payments Direct, Inc. (“Global Payments”) is committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information ("Personal Information"). As part of this commitment, the following Ten Privacy Principles govern our actions as they relate to the collection, use and disclosure of Personal Information. The principles have been built upon the values set by the Canadian Standards Association's Model Code for the Protection of Personal Information and Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”).

Privacy Principles

Principle 1 - Accountability

Global Payments is responsible for maintaining and protecting the Personal Information under its control. Global Payments has designated an individual or individuals who is/are accountable for its compliance with these Ten Privacy Principles.

Principle 2 - Identifying Purposes

The purposes for which Personal Information is collected will be identified before or at the time the information is collected.

Principle 3 - Consent

Knowledge and consent are required for the collection, use, or disclosure of Personal Information except where such collection, use, or disclosure is required or permitted by law.

Principle 4 - Limiting Collection

The Personal Information collected will be limited to those details necessary for the purposes identified by Global Payments.

Principle 5 - Limiting Use, Disclosure and Retention

Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when such other usage or disclosure is required or permitted by law. Personal information will only be retained for the period of time required to fulfill the purpose for which it was collected or as required by law.

Principle 6 - Accuracy

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Principle 7 - Safeguarding Customer Information

Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8 - Openness

Global Payments will make information available to our customers concerning the policies and practices that apply to our management of Personal Information.

Principle 9 - Customer Access

Except where limited by law, customer shall be informed of the existence, use and disclosure of their Personal Information and shall be given access to such Personal Information upon request. Consistent with their rights under law, customers may verify the accuracy and completeness of their Personal Information, and may request that it be amended, if appropriate.

Principle 10 - Handling Customer Complaints and Suggestions

Customers may direct any questions or enquiries with respect to the privacy principles outlined above or about our practices by contacting:

Privacy Office
Global Payments Direct, Inc.
c/o P.O. Box 4010, Station B
Etobicoke, ON M9W 7H8
Privacy.Office@globalpay.com

If you have questions or concerns regarding our organization's privacy policy and practices, you should first contact Global Payments directly at the contact above. If you do not receive acknowledgment of your inquiry or complaint or you do not feel it has been satisfactorily addressed within 30 days, you may contact the Office of the Privacy Commissioner of Canada by writing to:

Scope and Application of this Policy

Payment processing and pricing approvals provided by Global Payments Direct, Inc. Terminals & terminal services provided by Global Payments Canada GP.

Global Payments has relationships with card issuers and merchants, providing products and services which include payment card processing, point-of-sale terminal management and support, merchant accounting and funds transfer.

Unless the context clearly indicates otherwise, the term “individual” refers to merchants who use Global Payments products and services, as well as any visitors to our web site.

The website governed by the provisions and practices stated in this privacy policy are:
http://www.globalpaymentsinc.com/canada

The foregoing website may contain links to other third party sites that are not governed by this privacy policy. We are not responsible for the privacy practices employed by other third party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

Types of Information We Collect

Personal Information

Global Payments may collect the following types of Personal Information from you:

• Personal Information including contact information (name, address, telephone numbers, e-mail) and Social Insurance Number (SIN)
• Financial information including credit information and information related to business activity
• Merchant Information (business name, address, contact information)
• Anonymous/non-personal information that we do not associate with or trace back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit our website. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address.

Cookies

A cookie is a small computer file or piece of information that may be stored in your computer's hard drive when you visit our website. Some web browsers are configured to accept cookies automatically. If you prefer not to accept cookies, you may adjust your browser settings.

Cookies may be used by the Global Payments website to improve functionality and in some cases, to provide visitors with a customized online experience. If you would like to browse the Global Payments website, you may do so without accepting cookies. However, you should understand that if you choose not to accept cookies, some areas of the Global Payments website may not function properly or optimally. Additional information about the types of cookies we may use is provided in the Cookie Statement on this page.

Consent

Your provision of Personal Information to us means that: (a) you agree and consent that we may collect, use and disclose your Personal Information for the purposes described in this policy; (b) you or your representatives are authorized to provide us with your Personal Information. Should you choose not to provide us with required Personal Information, we may not be able to provide certain services; and (c) you acknowledge and consent that Global Payments may retain service providers to perform certain services and that in the event that a service provider is located in the United States or another jurisdiction, personal information may be processed and stored in that jurisdiction, and that foreign courts or law enforcement or regulatory agencies may be able to obtain disclosure of personal information through the laws of those jurisdictions.

You have the right to withdraw your consent for Global Payments to process your Personal Information; however this may limit our ability to provide certain services. Global Payments will collect explicit consent from you prior to using or disclosing your Personal Information for new purposes.

Collection and Use of Personal Information

At Global Payments, we collect, use and disclose Personal Information to provide you with the services you have requested, to respond to your inquiries, and to offer you additional products and services we believe you might be interested in.

Global Payments uses your personal information for the following purposes:

• to determine your financial situation by collecting credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you;
• to facilitate the provision of our services by sharing your information with our third party service providers, credit and debit card issuers, credit and debit card associations, credit agencies and similar parties connected to credit or debit card services;
• to investigate potentially fraudulent or questionable activities regarding your merchant account(s) or the use of our services;
• for reporting purposes under credit or debit card association rules or regulations and to credit and debit card issuers, financial institutions, consumer reporting agencies or other credit or debit card related entities;
• to offer you related products and services that might benefit you; and
• in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business.

Monitoring of Telephone Calls

We may monitor and/or record in-bound and out-bound telephone calls as permitted by law for training and quality assurance purposes, to detect and prevent fraud or other losses and to enforce our contracts. Any recording obtained from monitoring telephone calls is treated as confidential.

Disclosure to Third Parties

At Global Payments, we sometimes contract with third parties to perform services related to the purposes noted above. Our service providers may, at times, be responsible for processing and handling some of the information we receive from you. We provide only the information necessary to perform the services, and providers are prohibited from processing personal information for purposes other than to carry out the service they have been contracted to provide. Furthermore, as part of our agreements, our service providers are contractually obliged to protect your information in a manner that is consistent with Global Payments’ privacy policies and practices.

We may also be required to disclose personal information in response to requests by legal, governmental, or regulatory agencies with proper jurisdiction.

How We Safeguard Your Information

We use industry standard technologies and maintain current security standards in an effort to ensure that your Personal Information is protected against unauthorized access, disclosure, inappropriate alteration or misuse

Accessing and Amending Your Information

You have the right to be informed of the existence, use and disclosure of your Personal Information and to challenge the accuracy and completeness of the information and have it amended as appropriate.

Accessing Your Information

To obtain access to your records or to request a correction to a record you must make a written request. Please describe the records you are requesting, being as specific as possible so that we can ensure our response meets your needs. We will respond to your request within 30 days or we will notify you the need for additional information or the reasons your access is denied.

Changing, Updating, or Amending Your Information

To help us keep your Personal Information up-to-date, we encourage you to change, update, or amend inaccuracies and make corrections as often as necessary.

To make a change or update to your Personal Information, you may do one of the following:

1. Submit a request in writing to [address]
2. Call the relevant Customer Care Centre at 1 800.263.2970 for Global Payments merchant related matters, where one of our operators will be available to receive your request for a change in your personal contact information; or
3. Send a facsimile to us 416.847.4222 to request a change in your personal contact information.

Dear Global Payments Merchant:

Global Payments is required to comply with the Protection of Personal Information and Electronic Documents Act (PIPEDA) which governs the use, collection and disclosure of personal information, and we have implemented a corporate Privacy Policy in order to do so. Our Privacy Policy addresses the collection, use and disclosure of your personal information. Personal information is information about an identifiable individual and does not include information about corporations, partnerships or other non-individuals. The personal information we may ask you for, and the personal information that we currently have, would depend upon the nature of the services we provide to you.

We may collect, use and disclose personal information to respond to applications for our services and to provide our services to you, as well as in the following ways:

• to determine your financial situation by collecting credit and related financial information from our affiliates, strategic partners, credit agencies, other financial institutions and from references provided by you;
• to facilitate the provision of our services by sharing your information with our third party service providers, credit and debit card issuers, credit and debit card associations, credit agencies and similar parties connected to credit or debit card services;
• to investigate potentially fraudulent or questionable activities regarding your merchant account(s) or the use of our services;
• for reporting purposes under credit or debit card association rules or regulations and to credit and debit card issuers, financial institutions, consumer reporting agencies or other credit or debit card related entities;
• to offer you related products and services that might benefit you; and
• In the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business.

In addition we may also collect, use and disclose personal information when required or permitted by law.

If you have any questions or concerns about the Privacy Policy or the information in this statement, please contact:
Attn: Privacy Office
Global Payments Direct, Inc
c/o P.O. Box 4010, Station B
Etobicoke, ON M9W 7H8
Privacy.Office@globalpay.com

If you would like more information on PIPEDA, please refer to the website of the Office of the Privacy Commissioner of Canada at www.priv.gc.ca/en/.

Copyright

^© 2012 Global Payments Inc. All rights reserved.

Personal Information We Obtain

Through this website, subject to your consent if required by law, we may collect the following personal information, as relevant and as is voluntarily supplied to us by you (this is not a definitive list):

• Names and contact details including telephone number, email address and postal address;
• Your username (currently, your email address) and password, both of which you will use to log in to this website (see “Login Details and Your Responsibility” below);
• Products and related services which are of interest to you, as relevant to your preferences (see “Managing Your Preferences” below);
• Information you provide if you report a problem with our website; and
• Records of any correspondence we have with you.

 

How We Use the Personal Information We Obtain

Subject to your consent if required by law, we may use your personal information for the following reasons (this is not a definitive list):

• To contact you regarding any inquiry you make or to fulfil a request, such as, for example, a request for information about our products and services;
• To improve and personalize your experience when you use this website;
• To improve our products and services and for the development of future products and services;
• For internal record keeping and administration of records;
• For statistical analysis (see “Data Anonymization and Aggregation” below);
• To contact you by email and, if you have signed up for the service, to share e-newsletter or any other updates, communications or publications;
• For direct marketing purposes subject to your consent if required by applicable law (see “Managing Your Preferences” below);
• As necessary to set up and administer your sign up to, and use of, the log in facility available on this website; and
• For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations.

 

Disclosures of the Personal Information We Collect

We are a multinational business headquartered in the United States, with subsidiaries and affiliates in various countries around the world. Your personal information may be disclosed to recipients located outside of your country, including our global subsidiaries and affiliates (see “Our Relationship with Affiliate Companies” below), as well as other types of third parties engaged to help us run our business, subject to your consent if required by law. These types of third parties may include distributors of our products and services, service providers retained to perform functions on our behalf or to 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. Portions of our services may be provided by organizations with which Global Payments has a contractual relationship, including subcontractors, and, accordingly, your personal information may be disclosed to them. We take steps aimed at ensuring that all such persons process your personal information as disclosed by us only as necessary for their service delivery and for no other purpose.

We also may disclose your personal information in order to obtain commercial and credit information to establish, maintain or renew a customer’s contract(s), as may be required to provide any of the services for which a customer has subscribed, to comply with the rules and regulations of any credit or debit card payment network or otherwise in accordance with this policy.

We may also disclose your personal information:

• In response to a court order or a request for cooperation from a regulatory, law enforcement or other government agency; to establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;
• When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend the rights, property or safety of Global Payments, its customers, staff, suppliers or others; and
• To purchasers and, subject to local legal requirements, prospective purchasers in the event that Global Payments and/or its global affiliate companies (as applicable) disposes of, or considers the disposition of, any of its/their business or assets.

We do not make a practice of selling, sharing, trading or renting your personal information to others in ways different from what is disclosed within this policy, agreed to contractually by our customers or otherwise with their permission; provided, if you were referred to Global Payments for services via a third party, such as another independent services provider, we may share information with such third party in accordance with our business relationship with you and that third party.

 

Our Relationship with Affiliate Companies (Including Disclosures and Transfers)

Subject to your consent if required by law, we may appoint an affiliate company to process personal information in a service provider role for and on our behalf. This could be the case if, for example, we permit customers to access electronic statements for their accounts. In that scenario, if there is a charge for the service, customers will pay us for the online access service, but it may be an affiliate company which processes the relevant personal information. In most cases, we will remain responsible for that company’s processing of your personal information pursuant to applicable data privacy laws.

 

Login Details and Your Responsibility

Subject to your consent if required by law, we will collect and process your personal information as necessary to set up and administer your sign up to, and use of, the log in facility available on this website. We will use “cookies” to “remember” the machine or other device you use to access this website (see “Cookies” below). Please remember that if we contact you, we will never ask you for your password in an unsolicited email, message or phone call. If you choose to use the log in facility available on this website, you are required to adhere to the following security procedures in relation to your username (currently, your email address) and password, which are referred to as “login information”:

• Keep your login information secret and secure at all times and do not disclose it to any other person or allow any other person to use it;
• Do not write down or record in any form your login information or store it on any software, including a password save feature;
• Destroy any notice from us concerning your login information as soon as you have read and understood it;
• Should you become aware or have reason to suspect that your login information has been lost or disclosed to, or seen or accessed by, someone other than yourself, immediately notify Global Payments at the email address provided above;
• Do not leave your computer or other device unattended while you are using the log in facility available on this website or let anyone else use your computer or other device unless and until you have logged out; and
• Use particular caution if you access the log in facility available on this website from a public or shared computer, to ensure that other people are not able to see seen your login details.

 

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your 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, and we may permit those affiliates or other third parties to send their own direct marketing to you. Our direct marketing may be by email, telephone, post or SMS or such other method(s) as may become relevant. In addition, Global Payments may provide direct marketing information and permit others to do that as allowed by our customers’ respective contracts.

We will take steps to seek 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.

 

Obtaining Copies of or Access to Your Personal Information and Updating Us

You may have the right to obtain copies of or access to your personal information from us. Please contact us for further details. We may request payment of a small fee, in accordance with applicable law. If you believe that any information we have about you is incorrect or incomplete and should be updated, please inform us as soon as possible.

 

Data Anonymization and Aggregation

Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data, for example, for statistical analysis and administration including analysis of trends, to carry out actuarial work, to tailor products and services and to conduct risk assessment and analysis of costs and charges in relation to our products and services. We may share anonymized or aggregated data with our global affiliates and with other third parties. This policy does not restrict Global Payments' use or sharing of any non-personal, summarized, derived, anonymized or aggregated information (i.e., volumes, totals, averages, etc.).

 

Commitment to Security, Privacy and Standards

We take seriously our responsibility to protect the security and privacy of the information we receive via this website. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide via this website 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 all confidential information and personal information submitted to us through this website 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 this website.

 

IP Addresses

An IP address is a number which recognizes the computer or other device used to access the internet. Typically, a web server automatically collects IP addresses and uses them to administer a website. IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access this Website. For further details, see “Cookies” below.

 

Cookies

A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. This website’s uses of cookies includes those cookies that are strictly necessary to enable the features of the website, performance cookies to see how visitors use the website, and functionality cookies that enable the webpage to “remember” machines or devices, personalize website content and tailor user experience. In addition, cookies may be used to help us define our audience so that we can make appropriate changes to this website and target advertisements to users when they are browsing this website and other websites, in each case by reference to anonymous identifiers, not personal information. Additional information about the types of cookies we may use is provided in the Cookie Statement on this page.

In addition to the cookies Global Payments sets when you visit our websites, third parties may also set cookies when you visit Global Payments sites. In some cases, that is because we have hired the third party to provide services on our behalf, such as site analytics. In other cases, it is because our web pages contain content or ads from third parties, such as videos, news content or ads delivered by ad networks. Because your browser connects to those third parties’ web servers to retrieve that content, those third parties are able to set or read their own cookies on your device and may collect information about your online activities across websites or online services.

External Links

Global Payments may provide links on this website to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites. We make no representation regarding your use of such websites. Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personal information. This policy applies solely to information collected by us. You should read any other applicable privacy and cookies policies carefully before accessing and using such other websites.

Please be aware that we are not responsible for the privacy practices of the operators of other websites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every website that collects personal information. This policy applies solely to information collected by us. You should read any other applicable privacy and cookies policies carefully before accessing and using such other websites.

 

Changes and Updates

We may change this policy from time to time by updating this page. We will not necessarily bring changes or updates to your attention, so please revisit this page periodically to re-read this policy and to ensure you are aware of any changes when you visit the website. If there are substantive changes, including to the cookies we use, at our discretion, we may bring those to your attention, for example, by a message posted on the landing page of this website, which all users see on their next visit, or by a repeat cookies banner.

 

Children

This Website is not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18. Please do not use this website if you are under the age of 13.

 

Region-Specific Information

Users in the following regions and countries should read the sections below, which contain additional information about regional-specific privacy laws and regulations. In the event of conflict between the information above and the sections below, the sections below will prevail for the regions and countries specified.

Users in the European Economic Area

Your personal information may be processed in countries outside the European Economic Area (“EEA”) which may not have data privacy laws equivalent to those in the EEA. This includes transfers between Global Payments and its global affiliates and to the other third parties as described in the previous paragraphs (as relevant). The relevant Global Payments companies will take the necessary measures to ensure protection of your personal data collected through this website in accordance with applicable data privacy laws.

European Union: Data Controller Identification

The relevant Global Payments subsidiary in your country will be responsible under applicable privacy laws to the extent it uses your personal information for its own purposes. If Global Payments Inc. or any of its other subsidiaries uses your personal information for its own purposes, for example, to provide payment processing services to you, that entity may also be responsible under any privacy laws applicable to it. Below is a list of the Global Payments subsidiaries, by country in the European Union, that are responsible for processing your personal information collected through this website. A list of all other Global Payments subsidiaries in all other countries that may use your personal information for its own purpose is available upon request. You may contact our European Union subsidiaries to receive additional information about the third-parties to whom your personal data is shared as well as the legal basis for processing such data and specific information about exercising your data subject rights under the General Data Protection Regulation (GDPR).

Country	Subsidiary
Czech Republic	Global Payments Europe, s.r.o.
Ireland	Pay and Shop Limited
Malta	Global Payments Limited
Romania	Global Payments s.r.o. Praga Sucursala București
Slovakia	Global Payments s.r.o., organizačná zložka
Spain	Comercia Global Payments Entidad de Pago, S.L.
United Kingdom	GPUK LLP(1)

(1) Registered with the U.K. Information Commissioner’s Office as a “data processor” under the identifier Z1374314.

Australia

Under the Privacy Act 1988 (Cth) (the “Australia Act”), you have the right to (i) request access to your personal information; (ii) request the correction of your personal information; and (iii) complain about a breach by us of the Australian Privacy Principles (in Schedule 1 of the Australia Act) or any binding registered APP Code. We will handle any complaints or requests for access to or correction of personal information in accordance with our obligations under the Act. All complaints are taken seriously and will be assessed by appropriate personnel with the aim of resolving any issue in a timely and efficient manner and in accordance with the Act.

California

If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes by contacting us at privacy@globalpay.com.