WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?
WHICH CATEGORIES OF PERSONAL INFORMATION DO WE PROCESS?
Verde Payments may process online personal information that may indirectly identify you, as well as offline information that may directly identify you.
WHERE DO WE SOURCE YOUR PERSONAL INFORMATION?
Verde Payments obtains data from third party sources, including from advertising agencies, website operators, retail stores, and third-party data providers.
WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?
We use personal information about you to enable Verde Payments Advertising customers and partners to market products and services to you, to develop and improve Verde Payments products and services, and for security and compliance purposes.
HOW CAN WE SHARE OR SELL YOUR PERSONAL INFORMATION?
Your personal information is shared throughout Verde Payments’ organization and sold or shared to third parties such as Verde Payments Advertising customers and partners, service providers, and others as described in Section 9.
WHAT ARE YOUR PRIVACY RIGHTS?
You have privacy rights for the information we process about you. You can request to opt-out of third party sharing or selling, and object to our use of your personal information for online behavioral marketing and advertising purposes, delete your personal information, or access your personal information (See Section 13)
HOW TO CONTACT VERDE PAYMENTS IF YOU HAVE ANY QUESTIONS, COMMENTS OR COMPLAINTS?
Data collected for Verde Payments’ own direct marketing purposes. For information about Verde Payments’ processing activities with regard to your personal information collected on Verde Payments websites and applications, and used for Verde Payments’ own direct marketing purposes, please refer to the privacy-policy.
3.WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?
4.WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS?
Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. Personal information that is collected offline and that can directly identify you may include, for example:
name, physical address, email addresses, and telephone numbers;
demographic attributes, when tied to other information that identifies you;
transactional data based on your purchases, when tied to other information that identifies you;
company data such as the name, size, and location of the company you work for and your role within the company;
data from marketing opt-in lists, consumer surveys, or publicly available information;
derived latitude/longitude from a physical address.
Verde Payments Advertising only processes offline personal information about individuals located in the United States.
Personal information that is collected online and that may indirectly identify you may include, for example:
unique IDs such as your mobile device identifier, or a cookie ID on your browser;
a connected device identifier such as an ID from a smart television or streaming device (US only);
IP addresses and information derived from IP addresses, such as geographic location;
information about your device, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, or the preferred language;
obfuscated personal information such as hashed email addresses (direct identifiers are removed);
demographic information such as gender, age, and income range when not tied to information that directly identifies you;
behavioral data of the internet connected computer or device you use when interacting with websites, applications, or other connected devices, such as advertisements clicked or viewed, websites and content areas, date and time of these activities, or the web search used to locate and navigate to a website.
We may associate personal information about you with interest segments or profiles as part of the provision of Verde Payments Advertising services to our customers and partners.
5.FOR WHAT COMMERCIAL OR BUSINESS PURPOSE DO WE USE YOUR PERSONAL INFORMATION?
We use personal information for the following commercial purposes:
- a) to help enable Verde Payments Advertising customers and partners to market products and services to you based on your interests;
- b) to analyze, develop, improve, and optimize the use, function and performance of Verde Payments products and services;
We use personal information for the following business purposes:
- c) to manage the security of our sites, networks, and systems;
- d) to comply with applicable laws and regulations and to operate our business.
These purposes are described below in further detail.
- a) To help enable Verde Payments Advertising customers and partners to market products and services to you based on your interests
We process personal information about you for marketing purposes to help enable Verde Payments Advertising customers and partners to advertise products and services to you via online and offline marketing activities based on your interests. “Marketing purposes” means the processing of offline and online personal information, as defined in Section 4: (i) to solicit or induce a purchase, rental, lease, or exchange of products or services directly to consumers or businesses via offline and online advertising campaigns; (ii) to develop market research or market surveys or to provide verification services to marketers; (iii) to create, communicate, deliver, and exchange offerings that have value for customers, clients, partners, and society at large; or (iv) to encourage safe practices and trends and the provision of factual information, including, by way of example, providing product or automotive recall notices.
More specifically, Verde Payments can process information about you:
- For online interest-based advertising delivered through Verde Payments Advertising partners that display online advertising to you on behalf of Verde Payments Advertising customers.
- For offline and online campaign measurement, analytics, and development of insights on behalf of our Verde Payments Advertising customers.iii. For enabling our Verde Payments Advertising customers to personalize their products and services, including site optimization, email personalization, and dynamic marketing and advertising optimization.
For enabling our Verde Payments Advertising customers to personalize their products and services, including site optimization, email personalization, and dynamic marketing and advertising optimization.
For creating modelled online and offline “lookalike” audiences for Verde Payments Advertising customers’ products and services.
For enabling our Verde Payments Advertising customers to associate first-party information to certain Verde Payments Advertising identifiers in order to deliver marketing and advertising services to you.
6.CATEGORIES OF SOURCES OF PERSONAL INFORMATION
Verde Payments may process both offline and online information about you, including information from publicly available sources or third-party data providers.
- Offline information about you is obtained by Verde Payments from its offline partners such as brick-and-mortar retail stores, grocery stores and their associated loyalty card programs, payment card brands, catalog orders and consumer survey programs, and third parties who may not have a relationship with you and collect offline information from their offline partners.
- Online information about you originates from your activities on sites operated by our online partners, such as advertising agencies and website operators (for example, online retail stores or travel sites). Verde Payments also obtains online information from third parties who may not have a direct relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites. For more information on cookies and similar technologies used in connection with Verde Payments Advertising services, please refer to Section 12 below.
7.FOR INFORMATION ABOUT YOU COLLECTED IN THE EU/EEA, WHAT IS OUR LEGAL BASIS?
Verde Payments Advertising only collects limited third-party data about users located in the EU/EEA, Switzerland, or the UK and only for legal compliance purposes, including for data minimization and to avoid using data from these regions. Specifically, upon initial collection, Verde Payments Advertising segregates, obfuscates, and purges the data from users in these regions so as to prevent using the data for the commercial purposes described above in Section 5 of this Policy. Customers are responsible for their own first-party data collection and processing practices. Please see “First-party information collected about you by Verde Payments customers” under Section 2 for more information.
8.FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?
Verde Payments maintains information about you for the following retention periods:
- a) Online information about you is retained for up to 13 months.
Certain online information may be retained up to 18 months. For example, Verde Payments customers’ seasonal or cyclical interest-based advertising campaigns or internal analytics and model development may be retained for up to 18 months.
- b) Online information about you for linkage purposes (cross device/cross-context technology) is retained for up to 12 months.
- c) Offline information about you may be retained for as long as relevant for the purposes for which it was collected (see Section 5 above).
Personal information necessary to preserve opt-out preferences is retained for 20 years, unless you delete it or otherwise prevent its collection as further described in Section 13 below.
9.WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?
Sharing within Verde Payments
Verde Payments employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.
Sharing with or selling with third parties
We may share personal information with or sell personal information to the following third parties for a commercial purpose:
- Verde Payments Advertising customers and partners, including digital marketers, ad agencies, web publishers, connected TV providers, demand side platforms, data management platforms, supply-side platforms, and social media networks; and third-party service providers as necessary to perform Verde Payments Advertising services on behalf of Verde Payments.
- third-party service providers as necessary to perform Oracle Advertising services on behalf of Verde Payments.
We may share personal information with the following third parties for a business purpose:
- relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings; and
- public and government authorities, including public and government authorities outside your country of residence (to the extent legally required to respond to their mandatory requests in connection with national security and/or law enforcement purposes).
10.HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?
If personal information is transferred to a Verde Payments recipient in a country that does not provide an adequate level of protection for personal information, Verde Payments will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to the terms of the EU Model Clauses or other adequate transfer mechanism as required under relevant data protection laws.
11.HOW IS INFORMATION ABOUT YOU SECURED?
Verde Payments has implemented appropriate technical, physical, and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as other forms of unlawful processing.
12.WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?
Cookies and similar technologies (e.g., pixel tags and device identifiers) are used by Verde Payments and our advertising technology partners to recognize you and/or your device(s) on, off, and across different services and devices for the purposes specified in Section 5 above.
Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising, but do not track an individual to provide relevant online advertising.
You can opt out of cookies using the opt-out tools.
13.WHAT ARE YOUR PRIVACY RIGHTS?
Pursuant to the E.U. General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable laws and regulations, individuals in certain jurisdictions may have data subject rights enabling them to request to opt-out of third party sharing or selling, delete or remove, or request to access and receive a copy of their personal information in Verde Payments’ possession or for which Verde Payments is otherwise responsible.
Opt-out and object to our use of information about you
Verde Payments offers multiple ways for you to opt out of third party sharing or selling and object to our use of information about you:
Verde Payments Advertising Opt-out.
Verde Payments will opt you out of Verde Payments’ use of information about you for Verde Payments Advertising services involving both first-party use of your information as well as any third-party sharing or selling of your information. See Section 2 above for more information on the distinction between first-party and third-party information.
Do Not Track. Verde Payments honors “Do Not Track” browser settings, meaning we will not track your browser for marketing purposes while you have “Do Not Track” turned on in your browser settings.
Please note, you may still temporarily see interest-based advertising from Verde Payments Advertising customers due to advertising campaigns from those customers already underway. However, you will be opted-out of all future advertising campaigns from customers that use Verde Payments Advertising services.
Also note that opt-out tools are currently cookie-based and prevent Verde Payments from using, sharing, or selling your personal information for interest-based advertising on the browser on which they are installed. As a result, these opt out tools will only function if your browser is set to accept third-party cookies and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again. Verde Payments does not use persistent, unique identifiers to revive a previously opted-out profile or deleted cookie.
If you want to opt-out of Verde Payments’ use of information about you for Verde Payments Advertising services, and do not want to receive third-party cookies, you can also change your browser settings on your computer or other device you are using to connect to the internet. Most browsers also provide functionality that lets you opt-out of all advertising cookies, including Verde Payments cookies.
We cannot provide offline first-party information that is collected and maintained by our customers. If you have questions in regards to first-party information, Verde Payments recommends that you contact directly the company that collected it from you.
Deceased Do Not Contact Registration with the DMA. We recognize that receiving mail for a deceased loved one can be difficult for family members, friends, or caretakers. We recommend using the DMA Deceased Do Not Contact Registration to remove the names of your deceased loved ones from commercial marketing lists for all companies that ingest this list, available here: https://www.ims-dm.com/cgi/ddnc.php.
14.DOES VERDE PAYMENTS ADVERTISING COLLECT SENSITIVE PERSONAL INFORMATION?
Verde Payments does not create any online interest segments that reflect personal information that we consider sensitive. We also have operational procedures in our platform designed to prevent our partners and customers from using personal information provided to them by Verde Payments to create interest segments that we consider sensitive. While the types of personal information considered sensitive may vary among consumers and applicable law, we treat the following types of personal information as sensitive:
- precise health, biometric, or genetic information, such as a certain sensitive medical condition like cancer or diabetes;
- pregnancy, such as pregnancy choices, pregnancy termination, reproductive rights, and traveling to exercise reproductive rights;
- certain aspects linked to personal life, such as religious, political, or sexual orientation;
- interest in “adult” activities, such as drug use, an interest in weapons, or pornographic material; and
- information considered sensitive based on applicable law.
In addition, Verde Payments prohibits all segments in the EU/EEA, Switzerland, and the UK that fall into any of the following categories: health/biometric/genetic, sex life or sexual orientation, race or ethnicity, religious /philosophical beliefs, political affiliations and opinions, any information related to children under 16, criminal offenses or convictions, or membership in a union. Similar or additional restrictions may apply in other regions.
We do not allow Verde Payments Advertising customers or partners to use data provided to them by Verde Payments: (i) to make decisions related to an individual’s eligibility for employment, credit, healthcare, insurance, tenancy, or education purposes; (ii) to make decisions solely by automatic means where the decision has a significant effect on the individual; or (iii) in any way that may or does discriminate against any person or promote bigotry, racism, or harm. For these purposes, Verde Payments considers harm to be inclusive of the use of data provided by Verde Payments to target vulnerable individuals or groups with fraudulent or deceptive marketing campaigns or to be used in any manner that causes vulnerable individuals harm.
As noted above, Verde Payments Advertising does not create interest segments that reflect sensitive medical conditions. For a list of Verde Payments Data Cloud’s non-sensitive health and wellness segments, please see this link (PDF).
15.DOES VERDE PAYMENTS ADVERTISING COLLECT PERSONAL INFORMATION FROM CHILDREN?
We do not intentionally collect or share personal information of children under 16 years of age or allow the creation of segments targeting children under 16 years of age. Further, we prohibit our Verde Payments Advertising partners from providing Verde Payments with personal information from sites directed to children under the age of 16 or from consumers whose age these companies know to be under the age of 16.
16.WHAT ARE YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)?
If you are a California resident, you may request that we:
- disclose to you the following information covering the 12 months preceding your request:
- the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 4);
- the categories of sources from which we collected such personal information (see Section 6);
- the business or commercial purpose for collecting or selling personal information about you (see Section 5); and
- the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 9).
- delete personal information we collected from you (see Section 13); or
- opt-out of any future sale of personal information about you (see Section 13).
Verde Payments will not discriminate against you if you exercise these rights under the CCPA.
We will respond to your request consistent with applicable law. If you are an authorized agent making an access or deletion request on behalf of a Californian resident, please reach out to us via the inquiry form and indicate that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a Californian resident.
If you are a California resident, you may obtain information about exercising your rights, as described above, by contacting us at 1-305-614-0742.
17.HOW TO CONTACT VERDE PAYMENTS IF YOU HAVE QUESTIONS, COMMENTS, OR COMPLAINTS?
Written inquiries to the Data Protection Officer may be addressed to:
Verde Payments Corporation
Global Data Protection Officer
2001 Broadway, Suite 600
Riviera Beach, FL 33404
18.FILING A COMPLAINT
19.VERDE PAYMENTS CORPORATE HEADQUARTERS
Verde Payments’ corporate headquarters are located at:
2001 Broadway, Suite 600
Riviera Beach, FL 33404