Effective: 05/24/2018

PRIVACY POLICY

For the purpose of this Privacy and Cookies Policy, “POSPaperCompany.com”, “Cobalt”, “we”, “our”, and “us” refers to Cobalt Payments Inc. and its subsidiaries, as the context requires.  Please read this policy carefully. If you have any questions, please contact us at: Paper@cobaltpays.com

This privacy policy applies to your use of the POSPaperCompany.com software application. It does not apply to your use of other sites, services, or applications, and it does not apply to information we collect through other methods or sources such as sites owned or operated by our affiliates or vendors. Please be sure to review the privacy policy of any site, service, or application that you use as privacy practices often differ. The following statements relate to the use of cookies, collection of data, information security and privacy standards applicable to all users of the Site and/or Services.

Data We Collect

We collect Personal Data from you when you visit our Site or use our Services, when you send us information or communications, and/or when you submit content or enter into transactions in connection with our Services. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.  When you register to use the Services or create a POSPaperCompany.com Account, we may collect certain information, such as your username, password, name, company name, and email address. We also collect Personal Data that you provide to us as you use the Services, including, but not limited to:

  • a list of items from any third-party integration added to POSPaperCompany.com,
  • information related to your sales and inventory, and
  • information that allows us to automatically keep your inventory up to date based on your sales data. In addition, if you provide us feedback or contact us via e-mail, we may collect your name and email address, as well as any other content included in the email that you submit to us, in order to send you a reply.

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 application. IP addresses are used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access our Site and/or Services. For further details, see “Cookies” below.

Analytics & Conversion Tracking:

We collect Personal Data from you based on your use of the Site and Services, directly and indirectly using third party tools. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit our website or access your account on our network. Our servers (which may be hosted by a third party service provider) collect Personal Data  from you, such as browser type and version, operating system, platform, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, a date/time stamp for your visit, and other demographic information. Cobalt use cookies and navigational data like Uniform Resource Locators (URL) to gather Personal Data such as the date and time of your visit, the solutions and information for which you searched and which you viewed, and the sites you visited before and after visiting the Site. We also use cookies to collect, store and sometimes track Personal Data for statistical purposes to improve the Site and Services.

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 (List is subject to change):

  • To improve and personalize your experience when you use this Site and/or Services;
  • 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 our products and services and for the development of future products and services;
  • For internal record keeping and administration of records;
  • For statistical analysis;
  • 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 the Site and/or Services;
  • For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations;
  • to develop and provide our web site and our products for our customers;
  • to fulfill your requests for products or information;
  • to communicate with customers and site visitors, when necessary, and to inform customers of upgrades, as well as of other products available from Cobalt, its affiliates and third parties.
  • to bill accounts and maintain payment records;
  • to comply with any applicable law, regulation, legal process or government request;
  • to respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the Cobalt website, or any Cobalt products or services;
  • to protect the services, products or rights of Cobalt, including but not limited to the security or integrity of the Cobalt site;
  • to identify and resolve technical problems concerning the Cobalt site and its products.
  • Cobalt also uses personal information in an aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes; and
  • If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Privacy Policy Purposes, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us

Disclosures of the Personal Information

Portions of our services may be provided by organizations with which Cobalt has a contractual relationship, including processors, affiliates, vendors, 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 Cobalt, its customers, staff, vendors, affiliates or others; and
  • We do not sell, share, trade or lease 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 Cobalt 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.

Cookies

A “cookie” is a text file that applications 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 application’s uses of cookies includes those cookies that are strictly necessary to enable the features of the application, performance cookies to see how visitors use the application, and functionality cookies that enable the webpage to “remember” machines or devices, personalize application 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 our  Site and/or Services (“Demographics” cookies) and target advertisements to users when they are browsing this application and other applications (“Interest Reporting” cookies), in each case by reference to anonymous identifiers, not personal information. Additional information about the types of cookies we may use is provided below.

Function of Cookies

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

  • Essential (“strictly necessary”) Cookies. These cookies are essential in order to enable you to navigate the Site and/or Services and use its features. They are deleted when you close the browser.
  • Functionality Cookies. These cookies allow us to remember choices you make and provide enhanced, more personal features. For example, we may use cookies to “remember” the machine or other device you use to access our Site and/or Services. We use these functionality cookies to recognize you when you return to our Site and/or Services. This enables us to personalize our content for you and remember your preferences, such as language, text and font size. Interest Reporting and Demographics Cookies. These cookies use anonymous identifiers to track users’ browsing habits on this and other applications as they browse pages, videos and content, which allow us to define our audience so we can make appropriate changes to our Site and/or Services and target advertisements to users on this and other applications.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

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 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, Cobalt 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.

Commitment to Security, Privacy and Standards

Cobalt maintain administrative, technical and physical safeguards designed to protect the personal information you provide via this Use of the Site and/or Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. All data communicated between Cobalt use SSL encryption, electronic access controls, firewalls, system-wide data encryption and strict internal procedures. All communication between Cobalt and our Affiliate Partners API integrations is also encrypted at all times. We encourage all our users to ensure that their browsers are up-to-date with the latest internet security updates from their preferred browser. Cobalt will take all commercially reasonable to ensure that your data is treated securely and in accordance with this privacy policy.

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 the use of the Site and/or Services in accordance with our obligations under applicable laws and regulations. However, like all application operators, we cannot guarantee the security of any data transmitted on our Site and/or Services.

Response to Do Not Track Signals

Certain web browsers may provide an option by which you may have the browser inform websites or internet services you visit that you do not wish to have personally identifiable information about your activities tracked by cookies or other persistent identifiers across time and across third-party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called “do not track” signals.

We do not engage in “tracking” users outside of our service and website. Consistent with this, we do not take any action when a browser sends us a DNT (do-not-track) signal. Use of the Site and/or Services will not result in third parties collecting your personal information across websites and over time.

Links to Other Websites

The Site contains links to third party websites and content from such third parties. Such links and content are not endorsements, authorizations or representations of our affiliation with that third party. We are not responsible for the privacy practices or the content of third parties. Cobalt strongly advise Users to check the privacy policies of these third party websites. This Privacy Policy only covers this Site and the Services and does not have control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party sites or services.

Access to Personal Information

You also may send a request to review the Personal Data we have about you, and to request that we update or correct any out-of-date or inaccurate Personal information you have submitted through our site or services, please send us an e-mail to:  Paper@cobaltpays.com

Once received, requests will be completed within a reasonable timeframe. We reserve the right to use previous personal information to verify your identity. We will retain your information for as long as your account is active. Additionally, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes to this Privacy Policy

We may modify this privacy policy at any time. If we do, we will either; post the revised version here, by a message posted on the landing page of our Site and/or Services, or notify you via email. You should periodically check here for the most up-to-date version of this privacy policy. Any changes to the privacy policy will not be retroactively applied and will not alter how we handle personally identifiable information we previously collected from you. In certain circumstances, however, Cobalt will not inform and obtain the consent of the customer, such as in connection with an investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order. A customer may withdraw his, her or its consent for collection, use and disclosure at any time by sending an e-mail to:  Paper@cobaltpays.com

Please note that, if you do, Cobalt may suspend its provision of products and services to you. Your username and password, both of which you will use to log in to our Site and/or Services, Information you provide if you report a problem with our Site and/or Services; Records of any correspondence we have with you and other information required to establish a merchant processing account with us.

Change of Control

If Cobalt sells all or part of its business, or makes a sale or transfer of assets, or is otherwise involved in a merger or business transfer, Cobalt will provide notice before we transfer your personal information and non-personal information to one or more third parties as part of such transaction.

Children 

The use of the Site and/or Services 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 the Site and/or Services if you are under the age of 18.

Contact Us

If you have any questions about this privacy policy you may contact us at:  Paper@cobaltpays.com , 1.877.444.2559, or Cobalt Payments, Inc. 2075 Silas Deane Hwy Suite 2C Rocky Hill, CT 06067, Attention: Order Fulfillment.