ChargaCard may also collect non-personalized, or non-identifiable information (the “Anonymous Information”) in which we are unable, and do not foresee being able, to tie this data back to you or any particular User. Such data, by way of example, may include technical information regarding your anonymous usage of our website, aggregated data in which the uses of many Users, including your usage, is compiled in the aggregate, an anonymous User’s path through our Website or Services, and similar such data.
Changes to the Policy
From time to time, we may make changes to our Policy. Changes to our Policy may occur without notice to you, and at any time. You may always find an updated version of the Policy at this web location. If you do not agree with any alteration in our Policy, you must discontinue your usage of our Site and our Services. You may also request that your user account, if any, be deleted or permanently disabled, and that we remove any information such as Personal Information, to the extent technologically possible, and consistent with additional provisions in this Policy. Information regarding disabling your user account is available in our Terms of Service (the “Terms”), elsewhere in this document, or may be obtained by contacting us at email@example.com.
We collect the following types of personal information in order to provide you with the use of ChargaCard Services, and to help us personalize and improve your experience.
Information we collect automatically: When you use ChargaCard Services, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, and standard web log data and other information.
Information you provide to us: We may collect and store any information you provide us when you use ChargaCard Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or dispute resolutions, or when you otherwise correspond with us regarding ChargaCard Services.
When you use ChargaCard Services, we also collect information about your transactions and your activities. In addition, if you open a ChargaCard user account or use our Services, we may collect the following types of information:
We may also collect information from or about you from other sources, such as through your contact with us, including our customer support team, your results when you respond to a survey, your interactions with members of the ChargaCard corporate family or other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole). Additionally, for quality and training purposes or for its own protection, ChargaCard may monitor or record its telephone conversations with you or anyone acting on your behalf. By communicating with ChargaCard, you acknowledge that your communication may be overheard, monitored, or recorded without further notice or warning.
Information from other sources: You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and LinkedIn). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your ChargaCard account and authorizing ChargaCard to have access to this information, you agree that ChargaCard may collect, store and use this information in accordance with this Policy.
Authentication and Fraud Detection: In order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with ChargaCard Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.
When you download or use our mobile applications, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.
Cookies are one example of data that we automatically collect from Users, and a manner in which we interact with Users. Cookies may include Personal Information, or may be compiled from or along with Anonymous Information. A cookie is a piece of data stored on your computer that is tied to information about you and your usage of our Website or Services. We may use both session ID cookies (which are cookies that are specific to your usage of our Website or Services during one given browsing session), or persistent cookies (which are cookies that remain on your device beyond a single browsing session).
Session ID cookies are usually deleted when you close your browser, log out, or do a similar action on your device. Your browser’s help file may contain information on affirmatively deleting such cookies.
Persistent cookies are not deleted when you close your browser, but may be deleted manually, or may expire in time. Your browser’s help file may contain information on manually deleting such cookies.
You may also be able to prohibit our Website from placing cookies or similar web beacons on your device, and to limit our collection of your data in general, however this may limit your ability to use our Website and Services, or certain features. Your browser’s help file may contain information on disabling such access.
Cookies and similar data are used for various purposes, which include minimizing load times to our Website and Services, tracking and saving your preferences and those of other uses when you or they log in to or access our Website or Services, tracking your usage for technological or statistical purposes, tracking your usage in an attempt to improve or alter our Website or Services, or for various other purposes.
Certain third-party service providers and websites with whom we may partner, such as, but not limited to, Google Analytics, may also utilize cookies or other, similar web beacons that are loaded onto your device during the navigation of our Website or use of our Services. These third-party services providers may not be disclosed to you prior to your usage of our Website or Services. We may not have control over these cookies. These third-party websites may use these cookies to help provide insight into which areas of our Website and Services are frequently visited by you and other Users. These cookies may also be used to provide targeted advertisement to you and other Users. You may review the applicable privacy policies of these service providers to learn more about how they may use information they collect from cookies and other similar means.
Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient, and customized experience. We may use Personal Information to:
We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about the Services and the services of our corporate family. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. To reach you as efficiently as possible, we may contact you via phone, and may use autodialed or prerecorded calls and text messages as described in our User Agreement. Where applicable and permitted by law, you may decline to receive certain communications.
We do not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. We may combine your Personal Information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising.
If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by logging into your account and going to the Notifications section and updating your preferences, or by following the directions that may be provided within the communication or advertisement, or by contacting us directly.
We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.
Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, the use of third-party service providers. We, and third-party service providers on our behalf, store and process your personal information in the United States and elsewhere in the world. If your information is transferred to other countries, including countries which may not have data protection laws that provide the same level of protection that exists in your country, we will protect the information as described in this Policy.
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers, and information access authorization controls.
We may store your Personal Information for as long as you are an active User of our Services and Website, for, by example, maintaining a user account with us, and for a reasonable amount of time after. We may also continue to store Personal Information to comply with legal, financial reporting, or other compliance obligations, such as to enforce this Policy, or the Terms. In the event you wish to affirmatively ensure that your Personal Information has been deleted or removed, you may send an e-mail request to firstname.lastname@example.org, and we will make reasonable efforts to comply with your request, consistent with any applicable privacy laws, and other requirements as set out in this paragraph.
Anonymous Information may be stored indefinitely.
When transacting with others, we may provide those parties with information about you necessary to complete the transaction, such as your name, account ID, contact details, shipping and billing address, or other information needed to promote the reliability and security of the transaction. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. To facilitate dispute resolution, we may provide a buyer with the seller’s address so that goods can be returned to the seller. The receiving party is not allowed to use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting users with unwanted or threatening messages is against our policies and constitutes a violation of our Terms.
If someone is sending you money and enters your email address or phone number, we will provide them your registered name so they can verify they are sending the money to the correct account.
We work with third parties, including merchants, to enable them to accept or send payments from or to you using ChargaCard. In doing so, a third party may share information about you with us, such as your email address or mobile phone number, to inform you that a payment has been sent to you or when you attempt to pay a merchant or third party. We use this information to confirm that you are a ChargaCard customer and that ChargaCard as a form of payment can be enabled, or to send you notification of payment status. Also, if you request that we validate your status as a ChargaCard customer with a third party, we will do so.
If you link your loyalty or gift card of a ChargaCard merchant to your account, we may share your card number with that merchant when you pay using ChargaCard.
Please note that merchants, sellers, and users you buy from or contract with have their own privacy policies, and although ChargaCard’s user agreement does not allow the other transacting party to use this information for anything other than providing Services, ChargaCard is not responsible for their actions, including their information protection practices.
Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you using ChargaCard, or with the third parties that offer or use Services, except with your express permission or if we are required to do so to comply with credit card rules, a subpoena, or other legal process.
We may share your personal information we collect from you, including, but not limited to, your name, contact details, and transactions and activities, with:
Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in your country.
Please note that third parties can use personal information shared in accordance with their own privacy policies.
If you open a ChargaCard account directly on a third-party website or via a third party application, any information that you enter on that website or application (and not directly on a ChargaCard website) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with personal information. ChargaCard is not responsible for the content or information practices of such third parties.
Log In with ChargaCard allows you to streamline and simplify the account creation and login process when using third-party websites, and it allows these websites to enhance your experience on their sites. Instead of creating multiple usernames and passwords for each website you visit, Log In with ChargaCard allows you to sign in to a participating website using your existing ChargaCard login information. When you use Log In with ChargaCard, you agree that ChargaCard can share the information listed on the Log In with ChargaCard consent screen or in your Log In with ChargaCard account settings with the participating website. Information you allow ChargaCard to share with these third-party websites is subject to each third-party’s terms of service and privacy agreement, so you are encouraged to review their policies.
In the case of our cooperation you will conduct a role of Data processor (under GDPR definition)?
Pursuant to Art. 28 GDPR, the processor shall not engage another processor without prior specific or general written authorisation of the controller. So, in the case of our cooperation, will you disclose a list of sub-processors and can we include this list to our agreement (that will be a general written authorisation)?
In accordance with GDPR definition of Data Controller - Data Processor collaboration and in particular accordance with Art.28 GDPR, Data Processing Agreement shall contain that the processor:
- processes the personal data only on documented instructions from the controller, including with regard to transfers of personal data to a third country or an international organisation, unless required to do so by Union or Member State law to which the processor is subject; in such a case, the processor shall inform the controller of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest;
ensures that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
makes available to the controller all information necessary to demonstrate compliance with the obligations under GDPR and allow for and contribute to audits, including inspections, conducted by the controller or another auditor mandated by the controller.
So, are you agree to include these statements to our agreement?
Will you, as a Data Processor, maintain a record of all categories of processing activities carried out on behalf of us (requirements of Art.30 GDPR)?
In the case of transferring Personal Data from EU to the USA for your processing, is it possible for you to get Privacy Shield Certification or perhaps you already have it?