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STRIPE LOGO * Stripe Services Agreement * Stripe Connected Account Agreement * Stripe Payments Company Terms * ACQUIRER TERMS * Acquirer Disclosure * Cross River Bank * Deutsche Bank * Goldman Sachs Bank USA * PNC Bank * Wells Fargo Bank * Issuing Bank Terms * Payment Method Terms * User Bank Debit Authorizations * Prohibited & Restricted Businesses * OTHER PRODUCTS AND PROGRAMS * Stripe Terminal Device EULA * Stripe Terminal Purchase Terms * Stripe Terminal Reseller Terms * Stripe Atlas Agreement * Stripe Climate Contribution Terms * STRIPE APPS * App Developer Agreement * App Marketplace Agreement * PRIVACY * Privacy Policy * Cookies Policy * Privacy Shield Policy * Service Providers List * Data Processing Agreement * Data Transfers Addendum * Stripe Privacy Center * INTELLECTUAL PROPERTY * Intellectual Property Notice * Marks Usage * E-SIGN Disclosure * Licenses * Consumer Terms STRIPE PRIVACY CENTER WELCOME TO THE STRIPE PRIVACY CENTER Stripe respects the privacy of everyone that engages with our platform, and we are committed to being transparent about our privacy processes and policies. We are a platform that enables millions of businesses, and in order to provide our services to our Business Users and End Users, we collect and process personal data. The Stripe Privacy Center contains the answers to frequently asked questions about how we collect and use personal data, the rights that individuals have in relation to personal data held by Stripe, and how Stripe complies with international data protection laws. All materials have been prepared for general information purposes only. The information presented is not legal advice, is not to be acted on as such, may not be current and is subject to change without notice. Below is a list of terms that will help “you” navigate the Privacy Center: “YOU” MEANING STRIPE EXAMPLES Business User Stripe provides services to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Stripe user or merchant Platform User Connect Accounts End Customer When you do business with, or otherwise transact with, a Business User (typically a merchant using Stripe Checkout, e.g. when you buy a pair of shoes from a merchant that uses Stripe for payment processing) but are not directly doing business with Stripe, we refer to you as an “End Customer.” Individual using Identity Cardholder using Checkout End User When you directly use an End User Service (such as when you sign up for Link, or make a payment to Stripe Climate in your personal capacity), for your personal use, we refer to you as an “End User.” User of Link Personal contributor to Stripe Climate Representative When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.” Beneficial owner Shareholder, officer, director Account representative Visitor When you visit a Site without being logged into a Stripe account or otherwise communicate with Stripe, we refer to you as a “Visitor.” (e.g. you send Stripe a message asking for more information because you are considering being a user of our products). Stripe Sessions attendee Stripe Site visitor CONTENTS HOW WE COLLECT, DISCLOSE, AND USE PERSONAL DATA * Is Stripe acting as a data controller or a data processor? * Which Stripe entities are involved? * What are your data controller activities? * How does Stripe use personal data to improve its products and services? * As a Stripe User and as a data controller, what does GDPR mean for me? * Who are Stripe’s sub-processors and how are they vetted? * From where does Stripe collect information used for fraud prevention and security purposes? * How does Stripe use Personal Data to prevent fraud? * I heard that Stripe is collecting additional information about my account from a third party and/or my other Stripe account(s). Why is Stripe collecting this information? * Does Stripe collect precise location data? * In addition to its sub-processors, what other third parties does Stripe share information with? * What Business User and Representative data does Stripe share with a payment method to facilitate Business Users’ enabling the payment method? * What data about End-Customers and their transactions is used by Radar and what data does Stripe share with its Radar Business Users? * As a Business User, what notice do I provide to my End Customers about Stripe? * Are there any jurisdictional nuances to Stripe’s use of service providers in verifying the identity of Stripe’s business users? * Data Obtained from Third Parties * Does Stripe Record Calls? U.S. PRIVACY DISCLOSURES * Categories of Personal Information Collected and Disclosed Under the CCPA * What sensitive personal information under the California Consumer Privacy Act (CCPA) does Stripe collect and for what purposes does Stripe use that data? * Does Stripe “sell” or “share” my personal information under the CCPA? * How long will Stripe keep my data? * California Privacy Rights Metrics STRIPE LEGAL BASES TABLES * What legal basis does Stripe rely on to process personal data as a data controller? * End Users * End Customers * Representatives * Visitors DATA PROCESSING AGREEMENT * What is a Data Processing Agreement (DPA) and how can I get one with Stripe? INFORMATION ABOUT STRIPE PRODUCTS * How do you implement Privacy by Design at Stripe? * Stripe Identity * Stripe’s Card Image Verification * Stripe Connect At a Glance * I am a user with a Custom connected account. Does Stripe also collect information about my Custom connected account from a third party? * What responsibilities do Connect platforms with custom accounts have to allow their users to update or correct information associated with their accounts? * I am a user with a Custom connected account. Will data collected from a third party be visible to my customers? * What are Stripe ACS, Transaction Authentication, and Behavioral Biometrics? * Promotional Emails Feature * Stripe Delegated Authentication * Link * Stripe Capital * Financial Connections * Are there instances when Stripe receives non-Stripe transaction history? * Refunds to End Customer Bank Account * Stripe Frontier DATA PROTECTION OFFICER * Does Stripe have a Data Protection Officer (DPO)? * Quebec Act INTERNATIONAL DATA TRANSFERS * How is Stripe dealing with its international data transfers? * Is Stripe certified under the EU-U.S Data Privacy Framework? * How does Stripe’s certification under the EU-U.S. DPF impact my organization? * How do the SCCs and UK Addendum impact my organization? * How to get a copy of the SCCs or UK Addendum? YOUR RIGHTS AND CHOICES * How do I exercise my data protection rights? * When does Stripe continue to process data after it has received a deletion request or objection to the processing? * What data may be shared or made available to enable me to see Stripe ads on other sites? * Does Stripe honor the Global Privacy Control (GPC) opt-out preference signal? * Can I turn off tracking and advanced fraud signals? * How do I delete my account? * How do I delete my Custom Connect account? * How do I delete my Express Connect account? * How long will Stripe keep my data? * What is the Privacy Policy for Stripe Media Services? * Does Stripe localize storage of data in India? * Where can I lodge my complaint on data handling in India? * Notification IT Rules 2021 COOKIES & OTHER TECHNOLOGY * How does Stripe use cookies? * What is Stripe.js? * What are advanced fraud signals? * Why are advanced fraud signals not ad tracking? * What obligations should merchants keep in mind relating to cookie technology on their sites? * How does Stripe remember payment method details for Link? * What obligations should Link users keep in mind relating to cookie technology on their sites? * Does Stripe use CAPTCHA to protect its website from fraud and abuse? CONTACT US * Contact our Privacy Team * Where can I learn more about Stripe’s security practices? HOW WE COLLECT, DISCLOSE, AND USE PERSONAL DATA IS STRIPE ACTING AS A DATA CONTROLLER OR A DATA PROCESSOR? The answer is both. The “data controller” is the entity which determines the purposes and means of the data processing taking place. The “data processor” is an entity acting on behalf and under the instructions of a controller in processing personal data. Stripe is a data controller when it determines the purposes and means of the processing taking place. These data processing activities include (1) providing the Stripe products and services, (2) monitoring, preventing and detecting fraudulent payment transactions and other fraudulent activity on the Stripe platform, (3) complying with legal or regulatory obligations applicable to the financial sector to which Stripe is subject, and (4) analyzing, developing and improving Stripe’s products and services. Please see this Privacy Center article for more information on Stripe’s controller activities. Stripe is a data processor where it is facilitating payment transactions on behalf of and at the direction of a Business User. Our Business Users direct us to take payment from cardholders / End Customers. Stripe is considered a processor when directed to process payments (i.e., Stripe receives instructions about whom to pay, how much to pay, when to pay). As a platform provider, we need to ensure consistency across our platform, and that includes consistency with respect to the commitments that we give about how we operate our platform. We contract with all of our Business Users (including some of the world’s largest companies) on this basis. WHICH STRIPE ENTITIES ARE INVOLVED? For most of our services, it is either Stripe, Inc., the US parent company operating under US law, or Stripe Payments Europe, Limited (“SPEL”), an Irish company operating under Irish law, the data controller responsible for Personal Data collected and processed in relation to Stripe Services. The Stripe entity responsible for your data will depend on your location, the product or service you use with us and whether Stripe is acting as a controller and/or data processor. If you are located outside of the Americas (e.g., European Economic Area (“EEA”), Switzerland or the United Kingdom, countries located in Asia Pacific (“APAC”)), SPEL is the primary entity responsible for the processing of your personal data. Some of the payment processing services offered by Stripe are services that may be only provided for by an authorised payment services provider or electronic money institution. In this case, SPEL and the Stripe local regulated entity (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) will act as joint controllers of your Personal Data. Please see our table below for more information on who is your controller in these jurisdictions: LOCATION OF USER PURPOSE OF PROCESSING NAME OF STRIPE ENTITY LOCATION OF STRIPE ENTITY EEA Provision of certain authorised payment services in the EEA and Switzerland Please see https://stripe.com/ie/ssa Stripe Technology Europe, Limited (the e-money licensed entity with the Central Bank of Ireland) Ireland EEA All other activities. SPEL Ireland United Kingdom & Switzerland Provision of authorised payment services in the UK. Please see https://stripe.com/gb/ssa Stripe Payments UK, Ltd. (the e-money licensed entity with the UK FCA) United Kingdom United Kingdom & Switzerland All other activities. SPEL Ireland United Kingdom Provision Stripe Capital product and related services to Stripe users in the UK. Stripe Capital Europe, Limited Ireland Stripe affiliates also provide local support services in certain countries where Stripe operates. These entities act as data processors on behalf of Stripe, Inc. or SPEL, depending on the jurisdiction. You will find the most up-to-date list of the Stripe affiliates on this page. For certain products, Stripe may act as an independent controller (e.g. Stripe Capital), a data processor or both (e.g. Stripe Identity). Please see the Privacy Center article for each specific product for more information. WHAT ARE YOUR DATA CONTROLLER ACTIVITIES? * Providing the Stripe products and services to Business Users and End Users, including determining the third parties (banks and payment method providers) to be utilized; * Monitoring, preventing and detecting fraudulent payment transactions and other fraudulent activity on the Stripe platform; * Complying with legal or regulatory obligations applicable to the financial sector to which Stripe is subject, including applicable anti-money laundering screening and compliance with know-your-customer obligations; and * Analyzing, developing and improving Stripe’s products and services. HOW DOES STRIPE USE PERSONAL DATA TO IMPROVE ITS PRODUCTS AND SERVICES? Stripe collects data, including personal data, while providing services to its users. Stripe uses some of the data it collects to improve its products and services, including by training the models it employs for fraud and loss prevention and to analyze the performance of Stripe’s products as permitted by applicable law and agreements. Personal data is required to train Stripe’s fraud and loss prevention models, including those employed by Stripe Radar and Stripe Identity. These products rely in part on their ability to recognize certain characteristics that help determine whether a transaction is fraudulent or unlikely to complete. For example, they compare Personal Data presented in a specific transaction to Personal Data collected in the past to identify when a fraudster is attempting to perpetrate fraud, including to impersonate a Stripe User or their End Customers. In addition to using Personal Data to train its fraud and loss prevention models, Stripe also uses transaction data to assess the functioning of its current products and proposed product improvements. For instance, Stripe uses data collected by its java script library stripe.js to assess the performance of the checkout surfaces it provides to Business Users, and payment authorization data to evaluate ways to improve authorization rates for Business Users. Stripe uses Personal Data, such as IP address, to identify which pages and features a user interacted with during a checkout session, so that it can assess the effect different features have on the outcome of a checkout session. Stripe uses pseudonymized or aggregated transaction data for these purposes in certain circumstances. When Stripe communicates the results of its product performance analytics to Business Users or for advertising purposes, it does so only in aggregated or de-identified form that does not permit third-parties outside of Stripe to associate that data with any particular End Customers. You should consult your legal counsel regarding how best to disclose Stripe’s data usage to your customers. But, here is a paragraph you could add to your privacy policy if it doesn’t already include such a disclosure: * We use Stripe for payments, analytics, and other business services. Stripe may collect personal data including via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. AS A STRIPE USER AND AS A DATA CONTROLLER, WHAT DOES GDPR MEAN FOR ME? As a data controller, Business Users are responsible for the relationship with the data subject (i.e., your End Customer). You may instruct a third party (like Stripe) to process the data, but it is your job to set the purpose (or objectives) and legal basis for the processing. The GDPR requires data controllers to use third parties who agree to abide by certain contractual terms. To be sure of this, the data controller must have Data Processing Agreements (“DPAs”) with each third party. Our DPA has been designed to serve this purpose for you; it is strongly aligned with payment transactions, so it should establish that you are compliant with GDPR from a payments perspective. WHO ARE STRIPE’S SUB-PROCESSORS AND HOW ARE THEY VETTED? Please see our service providers page where we have a list of our most common sub-processors, service providers and affiliates. Stripe identifies, evaluates, and engages sub-processors through our vendor management program. We enter into a contract with each sub-processor prior to sharing data with the sub-processor, and each contract contains terms that provide for monitoring and audit. In addition, all potential vendors are vetted and approved through Stripe’s security review process before we begin using their services. FROM WHERE DOES STRIPE COLLECT INFORMATION USED FOR FRAUD PREVENTION AND SECURITY PURPOSES? To prevent fraud and strengthen our security, we may collect information from Business Users, End Customers, End Users, financial parties, and in some cases third parties. For example, we collect and analyze information that helps us identify bad actors and bots, including both transactional data (such as amount, customer shipping address, date, and so on) and advanced fraud detection signals (device and activity signals). Learn more. Stripe also receives information from third parties to prevent and respond to security incidents, and for protecting against other fraudulent activity. For example, we may receive information from third parties about IP addresses that malicious actors have compromised. Stripe may use Representatives' Personal Data provided at onboarding to query third party databases regarding fraud and risk signals associated with that data. The third party providers operating these databases may use Stripe’s experience with the Personal Data queried to inform their fraud and risk signals. HOW DOES STRIPE USE PERSONAL DATA TO PREVENT FRAUD? The Stripe products that use Personal Data to enable Stripe’s Business Users to detect and prevent fraud include Stripe Radar, Stripe Identity, and Stripe Merchant Risk Tooling. Stripe also employs internal risk models and other product features, such as 3D Secure incorporated into Stripe’s Issuing product, to prevent its products and services from being used for fraudulent activity. Stripe Radar processes personal data as described here using its machine learning model to produce scores indicating the likelihood that a payment method is being offered by someone other than an authorized user. These scores are designed to identify fraudulent transactions, they do not rate the character or creditworthiness of the individuals involved in a particular transaction. Based on the service selected by the Business User, Stripe may provide the Radar scores to its Business Users to help them to combat fraud and provide a mechanism for them to set rules to better manage transactions based on Radar scores and other indicators of fraud. Stripe Identity uses Personal Data, as described here, to combat fraud by enabling Business Users to verify whether the person they are transacting with is who they say they are. Identity compares biometric identifiers in a selfie against government issued ID. Identity can also validate Personal Data, such as name, date of birth, and government ID number, that an End Customer types into a web form against government and third-party databases to determine if the identity presented matches the government issued ID number. Stripe’s internal risk models seek to combat fraud by recognizing when a fraudster is attempting to use Stripe’s services for fraudulent purposes. For instance, Stripe uses Radar scores internally to determine whether a payment method offered to Stripe products such as Link, Frontier, Crypto Onramp, and Bill Pay should be accepted or rejected as likely fraudulent. Stripe’s internal risk models also use aggregated cardholder features to recognize when a large number of transactions are likely being conducted by the same individual for purposes of testing or cashing out stolen payment methods. Where Stripe recognizes such activity, it will block transactions to prevent harm to itself, its users, and others. Stripe Merchant Risk Tooling leverages Stripe’s internal risk models to help Stripe Connect Platforms identify indicators of potential fraud associated with their Connected Accounts. Merchant Risk Tooling produces reasoned scores that identify to Platform’s internal fraud teams when there are indicators consistent with a Connected Account attempting to use the Platform’s services (and Stripe) for fraudulent purposes. These scores are designed to supplement the Platforms’ due diligence related to their Connected Accounts and their business activities. They do not score the character or creditworthiness of the individuals involved in the Connected Accounts’ operations. The data factored into Merchant Risk Tooling includes payments transaction data, business representative details (such as IP address, physical address, and e-mail address) business website content, and other information regarding the businesses Business Users operate on Stripe. Along with attempting to combat fraud at the merchant and Stripe-wide levels as described above, Stripe also incorporates features in its individual products that use Personal Data to prevent fraud. One such feature is 3D Secure authentication, incorporated in Stripe Issuing. This feature is required by law in certain jurisdictions and requires cardholders to authenticate using one or more factors before they can complete an online transaction. Stripe and its service providers use and store personal data including cardholder PANs, contact information, and transaction history to authenticate cardholders using one time passcodes and knowledge of past transactions. These measures help combat fraud by increasing the likelihood that the person offering a card for payment is an authorized user. I HEARD THAT STRIPE IS COLLECTING ADDITIONAL INFORMATION ABOUT MY ACCOUNT FROM A THIRD PARTY AND/OR MY OTHER STRIPE ACCOUNT. WHY IS STRIPE COLLECTING THIS INFORMATION? Stripe may collect additional information about your account to allow Stripe and its financial partners to detect fraud and/or fulfill financial compliance requirements. These requirements come from our financial partners or regulatory obligations and are intended to prevent abuse of the financial system. Examples of missing data fields include your address, phone number, social security number, date of birth, employer identification number, or website URL. Stripe may be able to fill in some of this information by leveraging data we have collected from one of your other Stripe accounts or by obtaining data from a third party. We will show Business Users the information that we are associating with their account on your dashboard, and Business Users may update or correct that information via your dashboard. Please see Stripe’s Privacy Policy for additional information. DOES STRIPE COLLECT PRECISE LOCATION DATA? Devices such as mobile phones or computers may collect precise location data using GPS technology. Stripe does not collect GPS data from devices and browsers. Depending on the Services you use and the Business Users’ implementation of our Business Services, we will collect information (including IP addresses) through cookies and similar technology. We will collect your IP address when you visit our Sites. Please see our Cookie Policy to learn more. Stripe may use location information, including approximate latitude and longitude, derived from End Customers IP addresses to detect potentially fraudulent transactions. We also receive approximate location information (such as country, city or state) from third party providers such as MaxMind to help us determine the approximate location of visitors to our website for marketing purposes (for example, inviting you to local Stripe events). IN ADDITION TO ITS SUB-PROCESSORS, WHAT OTHER THIRD PARTIES DOES STRIPE SHARE INFORMATION WITH? When we work with service providers in our capacity as a data processor for our Business Users’ and End Users’ personal data, the GDPR calls these third-party service providers a sub-processor. Sub-processors are service providers who have or potentially will have access to or process personal data on behalf of Stripe. These third parties are disclosed on our Stripe Service Providers List. In addition to Stripe’s sub-processors, we may also share Business Users’ onboarding data and payment instrument information with third party business partners when this is necessary to provide our services to our Business Users. We do so, for example, for the purposes of offering payment processing services to our Business Users or facilitating payment settlements. Third parties to whom we may disclose personal data for this purpose are banks, payment method providers and payment processors, including, but not limited to, the following entities: * American Express Payment Services Limited and American Express Payments Europe S.L. * Banking Circle S.A. * Barclays Bank PLC * Citibank Europe plc * Credit Mutuel Arkea and Arkea Banking Services * Currence iDEAL B.V. * Klarna AB * Mastercard Europe S.A. * Polski Standard Płatności * PPRO Financial Ltd. * Swisscard AECS GmbH * Visa Europe Limited The data shared with payment method providers will depend on the payment method(s) enabled on the Business User’s account. In addition, Stripe shares personal data as we believe necessary to, among other things, protect Stripe’s services, rights, privacy, safety and property of Stripe, our users or others. For example, to protect our services, Stripe may receive or disclose information about IP addresses that malicious actors have compromised. Please note that if you provide us with your payment method information (e.g. a card number and expiration date) to store on file, Stripe will update your card information if your information has changed or been updated to ensure your transactions go through smoothly, including by working with your card issuer. If you would prefer to not have your updated payment method details shared with us, please reach out to your card issuing bank. TRANSFER Stripe will pass on personal data to affiliates and service providers or sub-processors, if deemed strictly necessary to carry out contractual obligations or for the data to be processed. Depending on the enabled payment method(s), data may be transferred to the jurisdiction(s) of the respective payment method(s). Before we engage any third party, we perform due diligence, including a vendor security assessment. All of our service providers are subject to contract terms designed to ensure that these service providers process personal data only for the purposes of providing services to Stripe and in accordance with our commitments to Users and applicable data protection laws. Moreover, Stripe maintains and enforces a security program that addresses the management of security and the security controls employed by Stripe, which includes third party risk management. In addition, Stripe employees, agents, and contractors acknowledge their data security and privacy responsibilities under Stripe’s policies. FINANCIAL CONNECTIONS If you are an End Customer who has been asked to link your financial account using Stripe, please visit the support webpage here to learn more about our privacy practices. Or you can jump to the specific topics linked here: * Linking my financial account and consent * Data collected, stored, and shared from my linked account * How Stripe accesses data from my linked account * Relationship between Stripe and its service providers * Data security * Who can access data from my linked account and for what purposes * Who will obtain my login credentials * Requesting disconnection or data deletion * Correcting my financial account information WHAT BUSINESS USER AND REPRESENTATIVE DATA DOES STRIPE SHARE WITH A PAYMENT METHOD TO FACILITATE BUSINESS USERS’ ENABLING THE PAYMENT METHOD? Stripe makes it possible for its Business Users to enable payment methods including card networks such as Visa and MasterCard, mobile and online payment methods such as WeChat Pay and Alipay, and buy now pay later providers such as Klarna and Afterpay. Certain payment methods are enabled by default when you onboard with Stripe. After onboarding, for eligible users, Stripe may enable additional payment methods after notifying you. Your Stripe dashboard allows you to enable or disable payment methods at any time. Stripe may share information regarding a Business User and the Business User’s Representative with a payment method provider when a payment method is enabled and when Stripe processes transactions involving the payment method. The payment method provider may require Business Users’ and their Representatives' Personal Data for a number of purposes, including complying with know your customer (KYC), anti-money laundering, and other legal and compliance requirements, preventing fraud, facilitating transactions, providing services to Business Users, and servicing the payment method’s platform. For these purposes, Stripe may provide payment method providers with Business User data, including but not limited to business name, business type, merchant category codes, merchant ID, transaction history, bank account information, and other transaction specific information such as product type and tax amount that Stripe ascertains from that data. Stripe may also provide payment methods with Business Users’ Representatives’ personal data, including name, address, contact information, date of birth, tax identification number, and other government issued ID information. The information Stripe shares with payment method providers is data that Stripe has collected from the merchant or ascertained from data provided by the merchant. WHAT DATA ABOUT END-CUSTOMERS AND THEIR TRANSACTIONS IS USED BY RADAR AND WHAT DATA DOES STRIPE SHARE WITH ITS RADAR BUSINESS USERS? When processing payments, it’s valuable to Stripe, Business Users and End Customers to enable legitimate transactions while also trying to prevent fraudulent transactions, making online purchases safer for everyone involved. Radar helps detect potentially fraudulent transactions for Stripe’s Business Users (i.e., merchants) through machine learning and other techniques. To do this, Radar leverages data collected across our Services. Radar’s machine learning model produces transaction “scores” indicating the model’s assessment of the likelihood that a transaction is fraudulent. Business Users can leverage this score and use it to implement automated rules to determine whether to allow, block, or flag transactions for additional review. Business Users can use Radar as one of multiple inputs in making decisions with respect to the potential for fraud in a transaction. Radar uses data collected about the End Customer from various sources, including payments transaction data, advanced fraud detection data, Bank Connections data, IP address, and physical address information. Radar uses this data to assess whether the payment method offered by the End Customer is likely unauthorized. Stripe may share with the Business User and allow them to export (where allowed by Law) certain information relevant to fraud detection, including: * a transaction score that assesses the likelihood of the transaction becoming a fraudulent charge-back, * risk insights for that transaction, * related payments made by the End-Customer to the Business User, * other transaction data related to that End-Customer’s transaction with that Business User (e.g., cardholder name, card information, and the payment amount and date), * device and browser information for the device used to make the transaction with that Business User, and * aggregated benchmarks. AS A BUSINESS USER, WHAT NOTICE DO I PROVIDE TO MY END CUSTOMERS ABOUT STRIPE? Under the terms of our agreements, Business Users are required to provide all necessary notices and obtain all necessary rights and consents from their End Customers to enable Stripe to lawfully collect, use, retain and disclose the Personal Data as part of the Stripe Services. Business Users, as data controllers, are responsible for the contents of their privacy notice and cookie banner. As an example, here is a paragraph that you can consider adding to your privacy notice (if you don’t already have such a disclosure): We use Stripe for payment, analytics, and other business services. Stripe collects and processes personal data, including identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and prevention. You can learn more about Stripe and its processing activities via privacy policy at https://stripe.com/privacy. Please be aware that the disclosure above is for illustrative purposes only and is not legal advice. Please talk to your legal advisor to understand how to comply with your obligations under applicable law. To comply with our transparency obligations, we explain how our cookies are used in our Cookie Policy and our Cookies Settings Dashboard sets out our list of cookies. We remind our Business Users to review the cookies placed on their website and to update their cookie banners accordingly. ARE THERE ANY JURISDICTIONAL NUANCES TO STRIPE’S USE OF SERVICE PROVIDERS IN VERIFYING THE IDENTITY OF STRIPE’S BUSINESS USERS? GERMANY Stripe, through its service providers, may use information from infoscore Consumer Data GmbH to verify the identity of Stripe Business Users in Germany. Information about infoscore Consumer Data GmbH is available here. DATA OBTAINED FROM THIRD PARTIES If you have been notified by Stripe that we obtained your data from a third party, the following applies: * Your Personal Data will be processed in accordance with Stripe’s Privacy Policy, which describes: * the identity and the contact details of Stripe; * the contact details of Stripe’s Data Protection Officer; * the purposes of the processing for which the Personal Data are intended as well as the legal basis for the processing, which includes prospecting and direct marketing, as permitted under applicable law; * the recipients or categories of recipients of the Personal Data. In addition to the recipients mentioned in the Stripe Privacy Policy, Personal Data may be shared with Salesloft, Inc. as a processor of Stripe; * that Stripe intends to transfer Personal Data to a recipient in a third country and a reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available (see here and here for more information); * the period for which the Personal Data will be stored and/or the criteria used to determine that period; * the existence of the right to request from Stripe access to and rectification or erasure of Personal Data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability or any other applicable rights under data protection laws (see also here); * the right to lodge a complaint with a supervisory authority. * We may have obtained the following Personal Data from third parties: name, business contact details (e.g., email, phone number, social media handle), business address, company/employer information, role and position, and industry. * We use a number of third parties to obtain Personal Data from, including Cognism Limited, ZoomInfo Technologies Inc., API Hub, Inc. dba Clearbit, Crunchbase Inc., PitchBook Data, Inc., infoAnalytica, Inc., People Data Labs, Inc., and Dealroom.co. These third parties collect Personal Data as separate controllers in accordance with their own privacy policies. If you wish to have your data removed from their respective database(s), please contact those parties directly. Some of these parties may have obtained your data from publicly accessible sources. * We do not use Personal Data we have obtained from third parties for automated decision-making. * Where Stripe relies on legitimate interest to process your Personal Data, such legitimate interest may be: * B2B market research and analysis; * B2B prospecting and selling; and * B2B marketing and advertising. DOES STRIPE RECORD CALLS? In some situations, we may record voice or video calls we have with you. At the start of the call, we disclose the fact that a call is being recorded and, unless we are required to record the call, will ask for your consent to record the call and/or offer you the option to decline the call being recorded. We may use third-party systems to record calls, including Zoom and Salesloft. The call recordings will be processed for the purposes stated at the start of the call, typically for quality and training purposes, and in accordance with Stripe’s Privacy Policy. We enable you to exercise your rights as a data subject under applicable law with respect to these recordings as set out in Stripe’s Privacy Policy. In the event that you request a copy of the recording, Stripe may provide you with a redacted copy of the recording, or a (redacted) transcript of the recording, where appropriate, and as permitted under applicable law. We normally retain call recordings for up to 1 year, and for Zoom recordings, 180 days. User support related phone calls are normally retained for 5 years as Stripe is under a legal obligation to keep this data for 5 years. After this, call recordings will be deleted, unless we have a valid legal ground to keep the call recordings for a longer period of time. U.S. PRIVACY DISCLOSURES CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED UNDER THE CCPA Below are the categories of data we collect and how that information is used in the last 12 months. We also disclosed this data for a business purpose within the preceding 12 months. CATEGORIES OF PERSONAL INFORMATION COLLECTED PURPOSES: DISCLOSED FOR A BUSINESS PURPOSE WITHIN THE PRECEDING 12 MONTHS TO: Identifiers (e.g., a device identifier) Identity verification, fraud prevention and security, to provide and advertise our services, and to comply with law. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers, financial partners servicing the financial product), third parties like ad partners that help us advertise our products and services, the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Characteristics of protected classifications under California or federal law (e.g., gender and age noted in ID documents that you submit so that Stripe can verify your identity on behalf of your merchant - a.k.a. our business user) Identity verification, fraud prevention and security, to provide our services, and to comply with law. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers and financial partners servicing the financial product), the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Commercial information (e.g., the merchant that you choose to do business with - a.k.a. our business user may receive your transaction data) Fraud prevention and security, to provide our services, to comply with law, enforce our terms of services, and for other purposes consistent with your consent and applicable law. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers and financial partners servicing the financial product), the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Biometric information (e.g., biometric identifiers from photo IDs used to confirm your identity) Identity verification, fraud prevention and security, and for other purposes consistent with your consent and applicable law, such as to improve our verification systems. Learn more. We may disclose the data, pursuant to applicable law, to: a service provider - i.e., Amazon Web Services ("AWS"), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Online activity information (e.g., information about devices and browsers across certain business user sites that use Stripe and IP addresses associated with those devices and browsers, and usage data) Fraud detection and security, to comply with law, and to provide and advertise our services. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers, financial partners servicing the financial product), third parties like ad partners that help us advertise our products and services, the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Location Data (Learn more) Fraud detection and security, in furtherance of compliance with legal obligations, and to provide and advertise our services. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers, financial partners servicing the financial product), third parties like ad partners that help us advertise our products and services, the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Audiovisual (e.g., visual, audio, or similar information, like photos you submit so that Stripe can verify your identity on behalf of your merchant – a.k.a. our business user) Identity verification, fraud prevention and security, to provide our services, and to comply with legal obligations. We may disclose the data, pursuant to applicable law, to: service providers, the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Professional or Employment-Related Information Recruiting and employment, and to comply with legal obligations. We may disclose the data, pursuant to applicable law, to: service providers, an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. Categories of personal information described in Cal. Civ. Code 1798.80(e)(such as name, address, telephone number, credit card or debit card number) See above. Identity verification, fraud prevention and security, to provide and advertise our services, and to comply with legal obligations. We may disclose the data, pursuant to applicable law, to: service enablers (including service providers and financial partners servicing the financial product), the merchant that you do business with (a.k.a. our business user), an entity engaged in a business transfer/merger, law enforcement, courts, governments and regulatory agencies. WHAT SENSITIVE PERSONAL INFORMATION UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) DOES STRIPE COLLECT AND FOR WHAT PURPOSES DOES STRIPE USE THAT DATA? Stripe only processes sensitive personal information for the purposes specified in section 7027(m) of the California Consumer Privacy Act Regulations, or without the purpose of inferring characteristics about a consumer. Sensitive Personal Information Categories Purposes include: Identification documents, including driver’s license, passport, and social security (including any underlying sensitive information in the identity card, such as racial or ethnic origin) Identity verification, fraud prevention and security, to provide our services, and to comply with legal obligations. Biometric information Identity verification, fraud prevention and security, and for other purposes consistent with your consent and applicable law, such as to improve our verification systems. Learn more. Location Data Learn more. Fraud detection and security, to comply with law, and to provide our services. Learn more. Account log-in, financial account in combination with any required security access code, password, or credentials allowing access to an account To provide our services (e.g., Financial Connections), comply with law, enforce our terms of services, and for other purposes consistent with your consent and applicable law. DOES STRIPE “SELL” OR “SHARE” MY PERSONAL INFORMATION UNDER THE CCPA? We do not transfer your personal data to third parties in exchange for payment. However, as noted above, we may provide your personal data to third party partners, such as advertising partners, analytics providers, and social networks, who assist us in advertising our products and services to you. Because these third parties may use the data Stripe provides for their own purposes (such as to improve their ad delivery), Stripe's provision of data to these parties may be considered a data “sale” or “sharing” as those terms are defined under the CCPA and other applicable US privacy laws. To our knowledge, Stripe does not sell personal information of minors under 16 years of age. Within the past 12 months, the following categories of Personal Information described in section 1798.80(e) of the California Civil Code have been “sold” or “shared” (as defined under the CCPA) to third parties (including advertising partners) who assist us in advertising our services: Identifiers (e.g., a device identifier) * Online activity information (e.g., information about devices and browsers across certain business user sites that use Stripe and IP addresses associated with those devices and browsers, and usage data) * Geolocation Data (e.g., IP addresses) You can opt out of targeted advertising and any related data “sales” or “sharing” here. HOW LONG WILL STRIPE KEEP MY DATA? Stripe keeps Personal Data as necessary to achieve the purposes listed here. To determine the appropriate retention periods for different categories of Personal Data, we consider various criteria such as the jurisdiction you are located in, the nature of our relationship with you, the types of products or services being offered or provided to you, the nature and sensitivity of your Personal Data, retention requirements under applicable laws and regulations, and other legitimate interests we may pursue through retaining your Personal Data, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, complying with valid legal process requests from courts or competent authorities, improving the quality of our services, and promoting our products and services as appropriate and as permitted by applicable law and agreements. For most jurisdictions, Stripe will generally keep Personal Data we obtain from our Business Users for a period of five or more years from the end of the business relationship with you, or the date of the last transaction, whichever is later. The table below outlines different categories of personal data collected, along with the retention period or the criteria used to determine that period. CATEGORIES OF PERSONAL DATA COLLECTED RETENTION PERIOD OR THE CRITERIA USED TO DETERMINE THAT PERIOD Non-sensitive Identifiers (e.g., name, postal address, email address, account name) Categories of personal information described in Cal. Civ. Code § 1798.80(e) (such as name, address, telephone number, credit card or debit card number) Characteristics of protected classifications under California or federal law (e.g., gender and age noted in ID documents that you submit so that Stripe can verify your identity on behalf of your merchant - a.k.a. our business user) Commercial information (e.g., transaction data that the merchant you choose to do business with - a.k.a. our business user - may receive) Online activity information (e.g., certain information about devices and browsers across certain business user sites that use Stripe, and usage data) Audiovisual (e.g., visual, audio, or similar information, like photos you submit so that Stripe can verify your identity on behalf of your merchant – a.k.a. our business user) For the duration necessary for Stripe to: (1) comply with law; (2) provide the Stripe services, and; (3) pursue our legitimate interests, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, complying with valid legal process requests from courts or competent authorities, improving the quality of our services, and promoting our products and services as appropriate and as permitted by applicable law and agreements. Biometric information (e.g., biometric identifiers from photo IDs and selfies used to confirm your identity) No longer than 1 year, or upon revocation of your consent, whichever is earlier. Geolocation Data (e.g., IP addresses) For the duration necessary for Stripe to: (1) comply with law; (2) provide the Stripe services, and; (3) pursue our legitimate interests, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, and complying with valid legal process requests from courts or competent authorities. Professional or Employment-Related Information Education information that is not publicly available as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g) For the duration necessary for Stripe to: (1) comply with law; (2) make certain employment and performance-related decisions; (3) address future hiring needs; (4) ensure health and safety in the workplace; (5) conduct certain administrative tasks, including to administer benefits; and (6) pursue our legitimate interests, including enforcing and defending our legal rights and complying with valid legal process requests from courts or competent authorities. Sensitive personal information, as defined by California law (Learn More) For information regarding your government IDs (including the sensitive data therein) and your location data, Stripe will retain that data for the duration necessary to: (1) comply with law; (2) provide the Stripe services, and; (3) pursue our legitimate interests, including detecting and preventing fraud and financial crimes, enforcing and defending our legal rights, complying with valid legal process requests from courts or competent authorities. For biometric data, see above. Where we rely on consent to collect your other sensitive personal information (e.g, financial account login credentials), Stripe will no longer retain this data upon your revocation of consent. CALIFORNIA PRIVACY RIGHTS METRICS The following includes aggregate metrics of data subject rights requests received in the 2023 calendar year. This data reflects requests received from individuals in California and may also include requests from individuals who do not reside in California. * Number of “request to know” received and complied with in whole or in part: 7 * Number of “requests to delete” received and complied with in whole or in part: 7719 * Number of “request to correct” received: 0 * Average number of days taken to respond to a request to know or delete: 1 Due to the nature of Stripe’s products and services, when we receive a general “request to delete,” our process is to direct the requestor to a page to action their request depending upon the relationship they have with Stripe. We also offer data subjects the opportunity to contact us, should they have any questions or concerns. Stripe may retain personal data where permitted by law, including to comply with our legal obligations. For example, as a provider of payment services, Stripe is required to comply with many regulations, including anti-terrorism and anti-money laundering laws. These laws require Stripe to retain certain information associated with Stripe users for a prescribed period of time after account closure. Learn more about our retention obligations in our Privacy Policy. STRIPE LEGAL BASES TABLES WHAT LEGAL BASIS DOES STRIPE RELY ON TO PROCESS PERSONAL DATA AS A DATA CONTROLLER? We rely upon a number of legal grounds to enable our use of your Personal Data. In short, we use Personal Data to facilitate the business relationships we have with our Business Users and End Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete transactions and to provide payment-related services to our Business Users. Our table below provides a detailed overview of why and how we use your Personal Data. For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. END USERS When you directly use an End User Service (such as when you sign up for Link, or make a payment to Stripe Climate in your personal capacity), for your personal use, we refer to you as an “End User.” PROCESSING PURPOSE CATEGORIES OF PERSONAL DATA LEGAL BASES Provide our Services. To provide services to you, including delivery, support, personalization and messages related to the service. Your name, contact information, payment information including Bank Account Information and Bank Payments, and/or payment card number, CVC code and expiration date. Our contractual necessity to perform our contractual relationship with you, under applicable data protection laws. For the provision of our services including Link, Atlas and Identity. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. If you choose to use Link you agree to let Stripe store your payment method and related information so that you can more readily make purchases with Business Users who use Stripe to provide payment processing services (e.g. Stripe Checkout). Based on consent in processing this personal information. Card Products and Financial Products including Issuing and Treasury Direct Services. We use your Personal Data to offer you card products and financial products and services under the Stripe brand and/or under the brand of a Business User. Your name, email address, phone number, postal address, transaction information, password, PIN or similar credentials, card PANs, age, DOB, credit card number, drivers license number, tax ID, cookie data, tags and beacons, IP address. Our legitimate interests in promoting our products and in determining eligibility for and offer new Stripe products and services. Provide cryptocurrency-related services, including enabling End Users with Link accounts to purchase cryptocurrency from licensed third-party cryptocurrency exchange providers using a variety of payment methods and save certain personal information to facilitate subsequent cryptocurrency-related transactions. Your name, email address, date of birth, billing address, IP address, information related to your cryptocurrency wallet (including wallet identifier, access times, and IP address used to create and access the wallet), and information related to your cryptocurrency purchases, including your transaction history. Based on consent in processing this personal information. Offer our Services and Alert you of Changes to our Services. For example, through Stripe Capital we offer capital loans to certain users who can satisfy particular criteria and to help determine if you qualify for a loan or not. Such information will be processed prior to the offer of a loan in order to determine eligibility. The name of the representative of business, physical address of business, and the borrower's Stripe ID. The rest of the data processed concerns business information and not personal data. Our legitimate interests in promoting our products and in determining eligibility for and offer new Stripe products and services. Fraud Detection Services. We use your Personal Data collected across our Services (e.g. Stripe Radar) to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorized log-ins using your online activity. Transaction information. This includes: name, email address, billing and/or shipping address, payment method information (such as credit or debit card number, bank account information or payment card image), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased, phone number and tax-related ID. This includes web browsing information, usage data, referring URLs, location, cookies data, device data and identifiers. IP address and physical address. Our legitimate interests in monitoring and detecting fraud to ensure we detect activity that can have a harmful effect on our End Users. Marketing and Advertising. We may use your Personal Data to assess your eligibility for and offer you other Services. We use End User Personal Data for interest-based advertising and marketing purposes. We do not share End Customer Personal Data to third parties for their marketing purposes unless you give us or the third party permission to do so. Contact information including: name, email address, work phone number, and job title. Connection data such as IP address, and web behavior (page visited, length on page, etc.) Based on consent in processing this personal information. Our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. Compliance and Harm Prevention. We process and share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) for compliance with rules imposed by payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Stripe, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. Any Personal Data we process, including information necessary for identity verification such as government-issued IDs or selfie images. Where these processing activities or disclosures are necessary to comply with our legal obligations, for the protection of a person's vital interests, for reasons of public interest, for reasons of substantial public interest, or for the purposes of Stripe’s or a third party’s legitimate interest in keeping Stripe secure, preventing a breach of the law, harm or crime, enforcing or defending legal rights, claims, or obligations, facilitating the collection of taxes and prevention of tax fraud or preventing loss or damage. END CUSTOMERS When you do business with, or otherwise transact with, a Business User (typically a merchant using Stripe Checkout, e.g. when you buy a pair of shoes from a merchant that uses Stripe for payment processing) but are not directly doing business with Stripe, we refer to you as an “End Customer.” PROCESSING PURPOSE CATEGORIES OF PERSONAL DATA LEGAL BASES Provide our Services to Business Users, including to process online payment transactions or in-person checkout, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. If you are an End Customer, when you make payments to, send shopping cart reminders, get refunds from, begin a purchase or otherwise transact with a Business User through Stripe’s Services or a Stripe-provided device, Stripe will receive your transaction information. Depending on how the Business User has integrated our Business Services, we may receive this information directly from you, the Business User or another service provider to you or the Business User. Transaction Information (including from Checkout, Payment Processing and Treasury/Issuing Use). Your name, email, billing and/or shipping address, payment method information (such as credit or debit card number, bank account information or payment card image), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased, phone number and tax-related ID. The payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods offered by the Business User as part of the “checkout” process for your purchase. We may also receive your transaction history with the Business User. Transaction-Related Information / Purchase Interests. Information typed into a checkout field that is not ultimately submitted to the Business User. Our legitimate interests in providing the Stripe products and services. Stripe processes this personal data given its legitimate interest in improving the Services and where it is necessary for the adequate performance of the contract with the Business Users. Provide our Services to Business Users, to order payment methods on a per-customer basis on behalf of the Business User, to implement fraud thresholds chosen by the Business User, and to verify your payment method. Verification Information. Your age (when purchasing age restricted goods) or information about you being the person who is authorized to use a payment method. The information collected will be the information that you choose to share for these purposes, which may include your government ID, your photo, your live image, and Personal Data apparent from the physical payment method (e.g. credit card image). Our legal obligations in respect of our financial and regulatory obligations. Reduce fraud and enhance security. We will use Personal Data about your identity, including information that you provide, to perform verification Services for Stripe or for the Business Users that you are doing business with and to reduce fraud and enhance security. In some cases you may provide a “selfie” along with an image of your identity document, and we will use technology to compare and calculate whether they match and can be “verified.” We will use information from our service providers and our Services to help verify your identity and fraud prevention. Based on consent in processing this personal information. Our legitimate interests in detecting, monitoring and preventing fraud and unauthorized payment transactions. Radar and Card Verification Services. We use Personal Data of End Customers to detect and prevent fraud for Business Users, including to detect fraudulent payment cards using payment card images and unauthorized log-ins using online activity. In providing such services, we may provide Business Users that have requested such services with limited Personal Data about End Customers so that the Business Users can assess the fraud risk associated with an attempted transaction by its End Customer. We may also use payment card images to improve our Business Services. Transaction information. This includes: name, email address, billing and/or shipping address, payment method information (such as credit or debit card number, bank account information or payment card image), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased, phone number and tax-related ID. This includes web browsing information, usage data, referring URLs, location, cookies data, device data and identifiers. IP address and physical address. Our legitimate interests in detecting, monitoring and preventing fraud and unauthorized payment transactions. Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by payment method in connection with use of that payment method; (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Stripe, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. Any Personal Data we process. Our legal obligations where disclosures are necessary to comply with our legal obligations. Our legitimate interest in keeping Stripe secure, preventing a breach of the law, harm or crime, enforcing or defending legal rights, claims, or obligations, facilitating the collection of taxes and prevention of fraud or preventing loss or damage. REPRESENTATIVES When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.” PROCESSING PURPOSE CATEGORIES OF PERSONAL DATA LEGAL BASES Reduce fraud and enhance security. We will use Personal Data about your identity, including information that you provide, to perform verification Services for Stripe. Onboarding and verification information that you choose to share for these purposes, which may include your government ID, photo, live image, and Personal Data apparent from the physical payment method (e.g. credit card image). Our legal obligations in respect of our financial and regulatory obligations. We process Personal Data to verify the identity of the Representatives of our Business Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. Advertising. We may use and share Representative Personal Data with others so that we may advertise and market our products and services to you, including through interest-based advertising subject to any consent requirements under applicable law. Contact information including: name, email address, work phone number, and job title. Connection data such as IP address, and web behavior (page visited, length on page, etc.) Based on consent in processing this personal information. Communications.We may send you email marketing communications about Stripe products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. Contact information such as your name, email address, phone number. Based on consent in processing this personal information. Our legitimate interests in responding to inquiries, sending Service notices, ensuring compliance with applicable laws, preventing fraud, improving our services and providing customer support. Tax and Atlas (Incorporation) Services. We may use your Personal Data to file taxes on behalf of your associated Business User. If your Business User uses Atlas, we may use your Personal Data to submit forms to the IRS on your behalf and to file documents with other governmental authorities. Your contact details, such as name, postal address, telephone number, and email address; and financial and personal information about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your organization (such as your social security number, tax number, or Employer Identification Number). You may also choose to provide bank account information. Our compliance with legal obligations in respect of our financial and regulatory obligations. We process Personal Data to verify the identity of the Representatives of our Business Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. Our contractual necessity to perform our contractual relationship with you, under applicable data protection laws. VISITORS When you visit a Site without being logged into a Stripe account or otherwise communicate with Stripe, we refer to you as a “Visitor.” (e.g. you send Stripe a message asking for more information because you are considering being a user of our products). PROCESSING PURPOSE CATEGORIES OF PERSONAL DATA LEGAL BASES Communications. We use any contact information that you provide to us to respond to any inquiries or requests for information you made; and if you have asked about us or our Services, to send you marketing emails by either asking for your consent or providing you an opt out in any messages we send. Contact information such as your name, email address, phone number. Information you have provided to us, such as the products you are interested in. Based on consent in processing this personal information. Our legitimate interests in responding to inquiries, sending Service notices and providing customer support. Advertising. When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Stripe Services to you on our Sites and other sites you visit (“interest-based advertising”). Information collected from cookies such as your device, browser ID, and pages on our website which you have visited. Based on consent in processing this personal information. Our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. Fraud Detection. We use your Personal Data collected across our Services to detect and prevent fraud against Stripe, our Business Users and financial partners. Advanced Fraud Signals information collected via cookies. This includes web browsing information, usage data, referring URLs, location, cookies data, device data and identifiers. Our legitimate interests in detecting, monitoring and preventing fraud and unauthorized payment transactions. DATA PROCESSING AGREEMENT WHAT IS A DATA PROCESSING AGREEMENT (DPA) AND HOW CAN I GET ONE WITH STRIPE? A Data Processing Agreement (“DPA”) is a contract between a data controller and a data processor that describes the roles and responsibilities of the parties when personal data is processed. If you are a Business User, please visit our FAQs page here to learn more about our DPA. Please contact us or your account manager if you have any questions. INFORMATION ABOUT STRIPE PRODUCTS HOW DO YOU IMPLEMENT PRIVACY BY DESIGN AT STRIPE? Privacy by design aims at building privacy and data protection up front and into the design specifications and architecture of information and communication systems and technologies to facilitate compliance with privacy and data protection principles. We rely on our internal privacy team and a review process for any new product launch. We are dedicated at every level of product development —from engineering to product management—to making privacy a key consideration. This helps ensure that people can trust the Stripe products that they enjoy every day. STRIPE IDENTITY END CUSTOMERS If you have been asked to verify your identity or have verified your identity using Stripe Identity, please visit the support web pages here and here to learn more about our privacy practices for Stripe Identity. Alternatively, you can jump to the specific topics linked here: * Stripe’s role in controlling and processing identity data in the US * Understanding Stripe Identity * Biometric verification * Consent to use my identity information * Security of my identity data * What data is collected * Identity data retention * How I delete my identity data BUSINESS USER THAT REQUESTED VERIFICATION If you are a Business User that is using or intends to use Stripe Identity, please visit the support web page here for additional guidance on what you can tell your users and here and here for additional guidance on privacy considerations for your business. STRIPE’S CARD IMAGE VERIFICATION If you have been asked by your merchant (i.e., a Stripe Business User) to scan your credit card before completing your requested transaction, please visit the support webpage here to learn more about Stripe’s Card Image Verification. STRIPE CONNECT AT A GLANCE DESCRIPTION Stripe Connect is a payment software your third party platform provider (Platform) may use to enable you to receive Stripe services (including payment processing) and/or receive payouts. DATA CONTROLLER/ DATA PROCESSOR Stripe acts as both a data controller and data processor for the Platform. The Stripe entity that acts as data controller/ data processor for data processed in Europe is Stripe Payments Europe Limited (“SPEL”). PERSONAL DATA The personal data transmitted to Stripe usually involves first name, last name, address, identification number, e-mail address, IP address, telephone number, and other data necessary for payment processing. PURPOSE The transmission of the data is aimed at payment processing, ledger management, and fraud prevention. The Business User / Platform will transfer personal data to Stripe. The personal data exchanged between Stripe and the Business User / Platform may be transmitted to verification agencies, and Business User data may be shared with Platforms. This transmission is intended for the Platform to manage its ledger and for Stripe to conduct identity and risk checks. TRANSFER Stripe will pass on personal data to affiliates and service providers or sub-processors, if deemed necessary to carry out contractual obligations or for the data to be processed. PRIVACY POLICY For full details please see the applicable Privacy Policy of Stripe. I AM A USER WITH A CUSTOM CONNECTED ACCOUNT. DOES STRIPE ALSO COLLECT INFORMATION ABOUT MY CUSTOM CONNECTED ACCOUNT FROM A THIRD PARTY? If you are a user with a Custom connected account, Stripe may collect additional information about your account to enable fraud detection and fulfill financial compliance requirements. These requirements for additional information come from our regulators or financial partners and are intended to prevent abuse of the financial system. Examples of missing data fields include your address, phone number, social security number, date of birth, employer identification number, or website URL. Stripe may leverage data we already have from one of your Stripe accounts or Stripe may fill in some of this information by receiving data from a third party. You may view the information that we are associating with your account and update or correct that information by contacting the platform or business that created your Stripe payment account. Please see Stripe’s Privacy Policy for additional information. WHAT RESPONSIBILITIES DO CONNECT PLATFORMS WITH CUSTOM ACCOUNTS HAVE TO ALLOW THEIR USERS TO UPDATE OR CORRECT INFORMATION ASSOCIATED WITH THEIR ACCOUNTS? You, the Platform, are responsible for all interactions with your Custom accounts and for collecting all of the information needed to verify the Custom account-holders. Since Custom account holders cannot log into Stripe, it is up to you to build the user dashboard and communication channels. You are responsible for actioning any request by a user to update or correct their Stripe Custom account information. I AM A USER WITH A CUSTOM CONNECTED ACCOUNT. WILL DATA COLLECTED FROM A THIRD PARTY BE VISIBLE TO MY CUSTOMERS? Card networks and issuers use statement descriptors to identify payments on a cardholder’s bank statement. Statement descriptors usually include information about the payment, such as the name and phone number of the seller. However, the exact information displayed is ultimately up to a cardholder’s bank. If Stripe updates your account’s business address, phone number, or email address, these fields may be displayed on the statement descriptor within the cardholder’s bank statement. However, the exact information displayed is ultimately up to the card network or the cardholder’s bank. If any information is incorrect, please reach out to the platform through which you receive charges to ensure you have provided them with the most accurate information about you and your business. WHAT ARE STRIPE ACS, TRANSACTION AUTHENTICATION, AND BEHAVIORAL BIOMETRICS? WHAT IS STRIPE ACS? Stripe ACS is Stripe’s transaction authentication solution for card issuers (e.g., banks). Stripe ACS helps card issuers to authenticate transactions of cardholders when they are making payments online using their cards. WHAT IS BEHAVIORAL BIOMETRICS? Behavioral biometrics is an innovative technology that can be used for the purpose of preventing fraud and identifying legitimate transactions. Behavioral biometrics leverages a combination of personal data and device characteristics to distinguish between legitimate customers and fraudsters or bots. HOW IS BEHAVIORAL BIOMETRICS DATA COLLECTED AND USED IN STRIPE ACS? This processing is designed to verify a cardholder’s identity based on their behavioral biometric data which is modeled based on data collected during each authentication attempt. This type of transaction authentication will typically observe interactions within a system or device to verify a cardholder’s identity for the purposes of authenticating online payments. The following elements may be processed during the authentication process: * Length of text field inputs * Location of mouse pointer * Modifier key details (e.g., CTRL, SHIFT) * Timing and location of mouse clicks * Timing and location of touch events * Timing between keystrokes * Window scroll position For the purpose of fraud risk mitigation, this processing involves use of a device identifier cookie (Ndcd, Device ID, DID) that aims to accurately analyze biometrics data observed on a specific device. This cookie facilitates device detection in order to enhance fraud detection and prevention as well as to identify suspicious devices or devices that are behaving abnormally. This is a first party, strictly necessary cookie that is active on the touch.tech and touchtechpayments.com domains, and has a duration of 12 months. For more information on how we use cookies, please see Stripe’s Cookie Policy. PURPOSE OF PROCESSING AND STRIPE’S ROLE Stripe may process biometric data relating to cardholders in order to assist card issuers to authenticate payment transactions. This is done as part of Stripe’s payment transaction authentication services provided to card issuers (including for the purposes of meeting Strong Customer Authentication requirements). In providing these services to card issuers, Stripe acts as a data controller in relation to cardholder data. Please see Stripe’s Privacy Policy to learn more about our use of personal data. As part of providing this authentication services to card issuers, Stripe engages with a third party provider, Mastercard, which also acts as a data controller. See Mastercard’s Privacy Notice for details on Mastercard’s processing activities in this context. CUSTOMERS RIGHTS AND CHOICES Upon initiating a transaction, cardholders will have the option of providing their consent to processing their behavioral biometrics data as part of the transaction authentication flow. This will be presented to the cardholder during the checkout flow on the merchant’s website or app when authentication is requested from the card issuer. Cardholders will have the option to withdraw their consent during each subsequent transaction flow. To withdraw consent outside of a transaction flow, you can email privacy-acs@stripe.com with the subject matter line “Stripe ACS - withdraw consent”. In your email to withdraw consent, please provide: (a) the first 6 digits of your card number as this enables Stripe to identify your issuing bank (please do not provide any digits other than the first 6 digits); and (b) the phone number (including the country code) registered with your bank account that is used for one-time passcodes. We will action this withdrawal request as soon as possible after it is verified, but please note that this can take up to 10 working days as we may need to verify the request with your card issuer. You may also contact the card issuer in order for the issuer to implement this withdrawal of consent by engaging with Stripe. To submit a request to exercise any of the other rights described in our Privacy Policy, you may contact Stripe at privacy-acs@stripe.com. PROMOTIONAL EMAILS FEATURE FOR END CUSTOMERS AND PROSPECTIVE END CUSTOMERS OF OUR BUSINESS USERS WHAT IS THE PROMOTIONAL EMAILS FEATURE? Promotional Emails is a feature that gives Business Users who use “Stripe Checkout” services a new tool to enable sending email promotional content to their customers and prospective customers. When you visit a Business User’s checkout page (that is powered by Stripe Checkout services), the Promotional Email feature will enable Stripe to collect information about your preferences to receive promotional emails from that merchant. Promotional email preferences are collected whether or not you complete the purchase or are just a prospective End Customer. “Prospective End Customer” means you visited a Business User’s site and expressed an intent to make a purchase by starting a purchase on the Business User’s checkout page, but did not complete that purchase during that session. To be a “prospective End Customer” for the promotional email feature, you also need to have started to input your contact information into the checkout form, and then not delete that information prior to the end of the session. If you, prospective End Customer, indicate permission to receive news and personalized offers by virtue of the opt-in/opt-out checkbox on your Business User’s checkout form, the following personal data is provided to your Business User so that your Business User can contact you to remind you of the items you left in the checkout or to provide you news and personalized offers: * Email (if provided by you). * Items in your cart with that merchant (if any). “Personalized offers” means promotional or marketing materials tailored to you, such as coupons or advertisements based on the items in your cart or (in some cases) your prior purchases from that Business User. Even if you opt-out of personalized offers by a Business User, if you do business with that Business User, they may still need to contact you in order to enable a purchase (e.g., for delivery or billing purposes) or in connection with customer support. Please see your Business User’s privacy policy for more information. WHAT IS STRIPE’S ROLE (DATA PROCESSOR/CONTROLLER) IN THE PROCESSING OF MY PERSONAL DATA? For the Promotional Emails feature, Stripe acts as a data processor or service provider, meaning that Stripe is acting at the direction of the Business User that has implemented this Stripe provided feature. The Stripe entity that acts as a data processor for personal data is: * Stripe Inc. in the United States. * Stripe Payments Europe Limited outside of the United States, including Europe WHAT PERSONAL DATA IS STRIPE COLLECTING? Stripe’s Privacy Policy describes in more detail the personal data that Stripe collects in connection with payment transactions. WHAT PERSONAL DATA IS SHARED BY STRIPE WITH THE BUSINESS USERS I USE? Whenever you complete a transaction on a Business User’s website that uses Stripe services, as a service provider to that Business User, Stripe will share your contact information with that Business User. Business Users use the information that Stripe provides in accordance with its own privacy policy, including in connection with your purchase. WITH THE PROMOTIONAL EMAILS FEATURE: * If you complete a purchase with a Business User, in addition to the transaction-related information identified in our Privacy Policy (e.g., your contact and billing information and the details of your transaction), Stripe will also share with your Business User your personalized offers and news preferences as determined by the opt-in/opt-out checkbox from your checkout form. * If you are a prospective End Customer (you start a purchase with your Business User on their checkout form but do not complete that purchase), the personal data that we share with your Business User depends on the following: * If you have not inputted any personal data into your Business User’s checkout form, then we will not share any personal data with that Business User. * If you have inputted personal data into your Business User’s checkout form: * If the checkbox for receiving news and personalized offers is not enabled when you leave your Business User’s checkout session, we will not share any of that personal data. * If the checkbox for receiving news and personalized offers is enabled when you leave your Business User’s checkout session, we will share the following information with that Business User: * Email (if provided by you). * Items in your cart with that merchant (if any). End Customers and prospective End customers should always review the privacy policy or notice of the Business Users they visit and do business with for information about the Business User’s data collection practices and purposes outside of this Stripe feature. DOES STRIPE SHARE MY PERSONAL DATA WITH OTHER BUSINESS USERS? No. Stripe does not share personal data collected in connection with purchases (or attempted purchases) from one Business User’s checkout with another Business User. Please see our Privacy Policy to learn more about our practices. HOW DO I STOP PROMOTIONAL EMAILS FROM A MERCHANT? Any offers or promotional emails that you receive as a result of a Business User’s use of the Promotional Emails feature are sent by Business Users (or others identified in the message), and not by Stripe. I If you do not find value in receiving these emails, please contact the Business User you are receiving the messages from. Stripe requires that Business Users that choose to implement the Promotional Email feature also provide the option to unsubscribe or opt-out of receiving further promotional messages. It would be a breach of Stripe’s terms of service for a Business User to not promptly comply with opt-out requests. HOW DOES THE DATA COLLECTION AND TRANSFER WORK? The Promotional Email feature does not use cookies or track you across Business Users. Information collected from the Business User’s checkout page is transferred only to the Business User via API calls or webhooks. Webhooks are a way for Stripe to send the information to the Business User automatically upon their request. Your information provided at checkout is encrypted in transit using HTTPS and TLS. See Security at Stripe for more information. HOW DO I STOP THE SALE OF MY PERSONAL DATA IN CONNECTION WITH THIS FEATURE? Stripe does not sell your personal data. See our Privacy Policy for more information. The Promotional Emails feature is not the sale of personal data. Rather, Stripe acts as a processor (or service provider) to Business Users for the Promotional Email feature. Please contact your Business User to learn about their personal data practices and how you can exercise rights to stop the sale or processing of personal data provided under applicable law and/or their privacy policy. Stripe requires that Business Users that choose to implement the Promotional Email feature also provide the option to unsubscribe or opt-out of receiving further promotional messages. It would be a breach of Stripe’s terms of service for a Business User to not promptly comply with opt-out requests. FOR BUSINESS USERS HOW TO USE THIS SERVICE AS A BUSINESS USER If you are a business that is using or intends to use Stripe’s Promotional Emails feature, please visit the support webpage for tips and guidance on information to share with your End Customers and prospective End Customers regarding privacy considerations in connection with the Promotional Emails feature for your business. STRIPE DELEGATED AUTHENTICATION CARDHOLDERS You may be given the option to enable on-device biometric verification and provide your consent for Stripe to store your payment method details for future transactions that use the same card. Please visit our support site to learn more about our privacy practices for Stripe Delegated Authentication. Alternatively, you can jump to a specific topic here: * Why does the cardholder see Stripe when asked to authenticate a payment? * What is Stripe Delegated Authentication? * How is personal data used in Stripe Delegated Authentication? * How can cardholders provide and withdraw their consent for the storage of their payment method details? LINK We offer you the opportunity to store your payment methods with us so that you can conveniently use it across certain merchants who are our Business Users – we call this “Link” (formerly known as “Remember Me”). When you choose to use Link, you agree to let us store your payment method so that you can more readily make purchases through Link with Business Users of our payment processing Business Services (e.g., name, card number, cvc, and expiration date). We will also collect other Transaction Data, including billing address, shipping address, email and phone number. Your payment method data is secured using PCI-DSS standards. Should you not have used Link and receive an SMS in error due to an inaccurate number being inserted at the authentication flow stage you can opt out here and your personal data will be deleted. STRIPE CAPITAL Stripe Capital provides Business Users with access to fast, flexible funding so businesses can manage cash flows and invest in growth. Depending on your business’s corporate structure, eligible Business Users may apply for one of two Stripe Capital products: a loan or a merchant cash advance (“MCA”). Loans are provided by Celtic Bank in partnership with Stripe Capital. WHAT INFORMATION DOES STRIPE PROCESS FOR STRIPE CAPITAL? We use existing data linked to your Stripe Account to evaluate your business’s eligibility for Stripe Capital. You may also be asked to link additional data sources, such as business bank accounts or business credit information, for Stripe to evaluate in order to receive funding through Stripe Capital. The following information may be considered prior to the offer of a loan or a MCA in order to determine eligibility, including: * Payment processing volume * Payment processing growth * Chargeback rate * Customer base * Duration of relationship with Stripe * Bank account balances * Transaction history * Business credit history Where Stripe is satisfied that a Business User meets particular criteria established by Stripe and bank partners (as applicable), we will send the Business User an email and dashboard notification notifying them of their business’s eligibility for potential funding and invite them to apply for a loan or a MCA. Once you have received an offer and submitted an application to receive your financing, we will use this above listed information to verify your business’s eligibility and where your application is approved, to disburse the loan or the MCA to your linked bank account. THE LEGAL BASIS FOR USING YOUR INFORMATION We will use your data where its use is in accordance with our legitimate business interests. Analysis of our Business User’s information helps us to manage our business for our legitimate interests. It allows us to: * Verify the identity of our Business Users in order to comply with fraud monitoring, prevention and detection obligations, applicable laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. * Assess the level of financial risk to us, financial partners and to Business Users involved in offering Business Users a loan or MCA. * Enhance our learning models to allow us to better tailor our loans or MCAs to, and decrease the risk to, you and other Business Users. We will also process your data where it is necessary for a loan or MCA agreement that you have entered into or because you have submitted an application to receive funding so that you can enter into a loan or MCA agreement with us. We may send you email marketing communications about Stripe Capital offers, provided we do so in accordance with applicable law, including any consent requirements. WHO DOES STRIPE SHARE INFORMATION WITH? Stripe does not share any Personal Data collected for Stripe Capital related to Business Users in the UK. In the future, Stripe may share your agreement data with third parties who purchase the right to receive repayments on your loan or MCA. WHAT IS STRIPE’S ROLE? Stripe, Inc., or a wholly-owned subsidiary of Stripe, is the controller of your data. For Business Users located in the UK, the joint controllers of your data are Stripe Payments Europe, Limited. (“SPEL”) and Stripe Capital Europe Limited, Ltd. (“SCEL”). The loan or MCA provided under the loan agreement is solely provided by SCEL. HOW DO I OPT-OUT OF RECEIVING CAPITAL OFFERS? Business Users have the option to unsubscribe or opt-out of receiving Capital offers via the link included in Stripe Capital emails. Business Users may also opt-out of dashboard notifications via the settings page of the Stripe Dashboard. If you have any questions, please contact us. FINANCIAL CONNECTIONS If you are an End Customer who has been asked to link your financial account using Stripe, please visit the support webpage here to learn more about our privacy practices. Or you can jump to the specific topics linked here: * Linking my financial account and consent * Data collected, stored, and shared from my linked account * How Stripe accesses data from my linked account * Relationship between Stripe and its service providers * Data security * Who can access data from my linked account and for what purposes * Who will obtain my login credentials * Requesting disconnection or data deletion * Correcting my financial account information ARE THERE INSTANCES WHEN STRIPE RECEIVES NON-STRIPE TRANSACTION HISTORY? Yes. For example, Stripe enables the Business User to import non-Stripe data through the Stripe Dashboard to consolidate their revenue data in one place. Learn more. Separately, Stripe may also obtain your account transactions from your financial account with your consent. Learn more. REFUNDS TO END CUSTOMER BANK ACCOUNT END CUSTOMERS If you have been asked to provide your bank account and other information to process a refund on behalf of your merchant (i.e., our Business User), please visit the webpage here to learn more about our privacy practices for end customer bank account refunds. BUSINESS USER THAT USES STRIPE TO PROCESS REFUNDS If you are a Business User that is using or intends to use Stripe to process refunds, please visit the webpage here for additional guidance on privacy considerations for your business. STRIPE FRONTIER WHAT IS STRIPE FRONTIER? Frontier is an advance market commitment (AMC) that aims to accelerate the development of carbon removal technologies by guaranteeing future demand for them. It facilitates purchases from high-potential carbon removal companies on behalf of buyers. Learn more at https://frontierclimate.com/. WHAT INFORMATION DOES STRIPE FRONTIER COLLECT? We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Stripe emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Stripe, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Stripe events and other interaction with Stripe personnel. See our privacy policy for more information. WHAT IS THE LEGAL BASIS FOR PROCESSING STRIPE FRONTIER INFORMATION? We rely on consent to process your data. Where you proactively reach out to Stripe and provide your data, Stripe will process your data based on Stripe’s legitimate business interests (e.g. help answer your queries, and provide customer support). With your permission or where allowed by law, we use your personal data to market our services to you, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. IS MY DATA RELATING TO STRIPE FRONTIER TRANSFERRED? We are a global business. Personal Data may be stored and processed in any country where we do business. We may transfer your Personal Data to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities). See our privacy policy for more information. WHAT ARE MY RIGHTS AND CHOICES WITH RESPECT TO THE INFORMATION COLLECTED FOR STRIPE FRONTIER? You may have choices regarding our collection, use and disclosure of your Personal Data. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described here. We will try to comply with your request(s) as soon as reasonably practicable. Depending on your location and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you. HOW DO I EXERCISE MY RIGHTS AS TO STRIPE FRONTIER? EEA and UK . To exercise your rights, you may contact our DPO. If you are a resident of the EEA or we have identified Stripe Payments Europe Limited as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. California . If you are a consumer located in California, please review the California Consumer Privacy Act (“CCPA”) section of our Privacy Policy. See our privacy policy for additional jurisdiction-specific provisions. ANY QUESTIONS ABOUT STRIPE FRONTIER AND THE PROCESSING OF YOUR DATA? If you have any questions or complaints, please contact us. DATA PROTECTION OFFICER DOES STRIPE HAVE A DATA PROTECTION OFFICER (DPO)? Yes, Stripe has appointed a Data Protection Officer (“DPO”), who can and they can be reached via email. QUEBEC ACT RESPECTING THE PROTECTION OF PERSONAL INFORMATION WHO IS STRIPE’S PERSON IN CHARGE OF PERSONAL INFORMATION UNDER THE QUEBEC ACT RESPECTING THE PROTECTION OF PERSONAL INFORMATION IN THE PRIVATE SECTOR, AND HOW DO I CONTACT THEM? Stripe’s Chief Privacy Officer is the person in charge of personal information. You may contact them via email. We are committed to protecting personal information and have established policies and procedures that govern our treatment of personal information. These policies and procedures include, among other things, the following: * policies and procedures to protect personal information in our custody and control from unauthorized access, use or disclosure. * processes to respond to data subject requests and complaints in a timely and effective manner. * a framework for the retention and destruction of personal information to ensure compliance with legal obligations, and to securely destroy personal information once no longer required. * a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of personal information. * providing our employees with regular privacy training and awareness. INTERNATIONAL DATA TRANSFERS The detail below is provided for informational purposes. It is not intended to provide legal advice. Stripe urges Business Users to consult with counsel to familiarize themselves with the requirements that govern their specific situations. HOW IS STRIPE DEALING WITH ITS INTERNATIONAL DATA TRANSFERS? As a global business, Personal Data may be transferred to, and processed, in any country where we do business, where our service providers do business or if you use an international payment method or financial partner service, the countries in which that payment method or financial partner operates. We may transfer your Personal Data to countries other than your own country, including to the United States. Stripe relies on a number of data transfer mechanisms to legalize the transfer of Personal Data around the globe. Stripe continues to have appropriate safeguards and compliance measures to ensure an adequate level of protection of Personal Data transferred outside the UK, EEA and Switzerland. Stripe’s measures may include: * Transferring Personal Data from the originating to a country or recipient that has been deemed to have an adequate level of data protection by relevant privacy authorities, including the European Commission. * The EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), which allows personal data to flow freely between the EEA and certified organizations in the U.S. The European Commission has adopted an adequacy decision confirming that personal data can be transferred from the European Economic Area (“EEA”) to certified U.S. organizations. The UK Government similarly confirmed that organizations can rely on the UK Extension to the EU-U.S. DPF to transfer data from the UK to certified U.S. organizations. Stripe’s parent entity, Stripe, Inc, is certified under the EU-U.S DPF, the Swiss-US Data Privacy Framework (“Swiss-U.S. DPF”) and the UK Extension to the EU-U.S. DPF (“UK Extension”). Stripe relies on the DPF to transfer personal data from the EEA and the UK to the US. The Swiss-U.S. DPF will not be relied upon by Stripe until Switzerland recognises its adequacy consistent with Swiss law, but we adhere to its required commitments in anticipation of their doing so. To learn more about the DPF program, please visit https://www.dataprivacyframework.gov/, and to view our certification, please see here. * The Standard Contractual Clauses (“SCCs”) approved by the European Commission. SCCs are a transfer mechanism (in the form of a legal contract) used by Stripe to provide a legal mechanism to transfer EU personal data outside of the EEA/UK. These are required under EU data protection law (known as the GDPR) and are incorporated into our agreements. * The UK International Data Transfer Addendum (“UK Addendum”) issued by the UK’s Information Commissioner’s Office to provide a legal mechanism to transfer Personal Data from the UK. This mechanism is required under UK data protection law (known as UK GDPR) and is incorporated into our agreements. * Other alternative data transfer mechanisms approved by relevant privacy authorities to enable the transfer of Personal Data to a third country. Stripe respects the privacy of everyone that engages with our products and services, and we are committed to being transparent about our privacy processes and policies. To learn more about our commitment to privacy and data security, please see our Privacy Policy, the rest of the Stripe Privacy Center, and the Stripe Security Center. We also want to highlight some of our supplementary measures to protect our Business Users’ data from unauthorized access. Stripe employs security controls and maintains and enforces a security program that addresses the management of security. We also perform risk assessments and implement and maintain controls for risk identification, analysis, monitoring, reporting, and corrective action. Stripe maintains and enforces an asset management program that appropriately classifies and controls hardware and software assets throughout their life cycle. In addition, Stripe employees, agents, and contractors acknowledge their data security and privacy responsibilities under Stripe’s policies. Stripe applies technical and organizational measures that include the following: * Virtual access control to prevent data processing systems from being used by unauthorized persons. * Data access control to ensure that persons entitled to use a data processing system gain access only to such Personal Data in accordance with their access rights, and that Personal Data cannot be read, copied, modified or deleted without authorization. * Disclosure control to ensure that Personal Data cannot be read, copied, modified or deleted without authorization during electronic transmission, transport or storage on storage media (manual or electronic), and that it can be verified to which companies or other legal entities Personal Data are disclosed. * Entry control to audit whether data have been entered, changed or removed (deleted), and by whom, from data processing systems. * Stripe relies on third party service providers to host its production infrastructure. Those third parties apply physical access control to prevent unauthorized persons from gaining access to the data processing systems available at premises and facilities (including databases, application servers, and related hardware), where Personal Data are processed. * Availability control to ensure that Personal Data are protected against accidental destruction or loss (physical/logical). * Separation control to ensure that Personal Data collected for different purposes can be processed separately. By default, Stripe encrypts data at rest and data in transit. We further protect your data with tools like audit logs, access management policies and certifications as described on our Payments page in the section “Security and compliance at the core”. Security controls implemented at Stripe include TLS 1.2 configuration of endpoints for data in transit, TLS and/or SSL encryption for HTTPS and regular testing of infrastructure components. Two-step authentication is available for an extra layer of security at Dashboard login. We get requests for access to data from law enforcement, and we review each request with the goal of responding with the minimum amount of required information in response to legitimate, legally mandated requests. If you have any questions, please contact us. IS STRIPE CERTIFIED UNDER THE EU-U.S DATA PRIVACY FRAMEWORK? Stripe has certified its participation in the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework. Stripe relies on the DPF to enable international transfers. In case the DPF is invalidated or Stripe is otherwise prevented from relying on the DPF, we incorporate multiple transfer mechanisms to ensure that data transfers can continue. If more than one data transfer mechanism applies, the DPF takes precedence. Stripe will not rely on the Swiss-U.S. Data Privacy Framework until each enters into force. You can learn more about our certification and read the Stripe Data Privacy Framework Policy at https://stripe.com/legal/data-privacy-framework. HOW DOES STRIPE’S CERTIFICATION UNDER THE EU-U.S. DPF IMPACT MY ORGANIZATION? The EU-U.S. DPF is a legal framework that allows organizations to transfer EEA Personal Data to certified organizations in the U.S. Stripe’s Data Transfers Addendum sets out the data transfer mechanisms that Stripe may rely on to carry out international transfers of personal data, including the EU-U.S. DPF. You can learn more about our certification and read the Stripe Data Privacy Framework Policy at https://stripe.com/legal/data-privacy-framework. If you are a Business User and would like to transfer data to us under the DPF, please contact us or your account manager if you have any questions. HOW DO THE SCCS AND UK ADDENDUM IMPACT MY ORGANIZATION? SCCs are legal contracts entered into between parties that are transferring EEA Personal Data outside of the EEA. Stripe may rely on the SCCs for transfers of EEA data in our services. We have updated our Data Transfer Addendum and agreements to incorporate the SCCs (where applicable). HOW TO GET A COPY OF THE SCCS OR UK ADDENDUM? You can review our Data Transfers Addendum which includes the latest data transfer mechanisms, including the SCCs, the UK addendum and the Swiss addendum here. YOUR RIGHTS AND CHOICES HOW DO I EXERCISE MY DATA PROTECTION RIGHTS? Depending on your location and subject to applicable law, you may have the followings rights: * Right to access * Right of rectification * Right to data portability * Right to restrict processing * Right to object to processing * Right to withdraw consent (where it is relied upon) * Right to erasure/deletion * Right to opt-out of receiving electronic communications from us * Right to non-discrimination for exercising your rights * Right to opt-out from a sale of personal information * Right to opt-out of “sharing” under California privacy law (learn more) * Right to limit the use or sharing of sensitive personal information (learn more) * Right to appeal Stripe’s response to your data subject request Please read this section to find out more about specific rights. To submit a request to exercise any of the rights described above, please reach out to us by email, or via our form or by physical addresses listed in Contact Us. You have the right to complain to your local data protection authority if you are unhappy with our privacy practices. HOW DO I ACCESS MY DATA? If you are a Business User or Representative, you may login in to the Stripe Dashboard to view personal information shared with Stripe. If you are the End Customer of a Business User that uses Stripe services, the Business User would be the correct party to respond to a data subject access request related to your transactional information. Depending on your location and subject to applicable law, you may have the right to request confirmation of whether Stripe processes Personal Data relating to you, and if so, to request a copy of that Personal Data. If you are an End User or otherwise have a direct relationship with us, you may submit your access request by email, or through our form. Please note that we may need to verify your identity and your relationship with us before we can proceed with your request. In addition, Stripe's Data Access Tool provides self-service access to some of the data from integrated Stripe products. HOW DO I UNSUBSCRIBE FROM MARKETING EMAILS? If you are a Business User or Visitor, you may unsubscribe from Stripe marketing emails here. If you have any questions about how to opt-out of Stripe marketing communications, please contact us here. If you are a Link user, you may opt-out from marketing-related emails by using the unsubscribe link in any marketing email you receive, or by managing your subscription preferences in the Link website. To manage your preferences log into your Link account, then navigate to your account settings. Turn “Marketing emails - Receive updates and deals from Link and its partners” on or off. Your email address will be opted out of email marketing communications as soon as possible. WHEN DOES STRIPE CONTINUE TO PROCESS DATA AFTER IT HAS RECEIVED A DELETION REQUEST OR OBJECTION TO THE PROCESSING? In certain circumstances, Stripe may be required by law to retain and process your Personal Data even after a deletion request or objection to the processing. For instance, Stripe is required to retain certain Personal Data it receives from its Business Users to satisfy legal obligations under Know Your Customer (KYC) and Anti-Money Laundering (AML) laws. Stripe may also rely on compelling legitimate grounds to continue processing your Personal Data. Stripe may act on such grounds, for instance, when it takes steps to prevent fraud and financial crimes. When Personal Data is necessary to enable or maintain the integrity of Stripe’s fraud detection and financial models, Stripe may not be able to honor requests to delete or stop processing that data. If Stripe honored such requests, fraudsters might take advantage of its willingness to do so to seek deletion of data related to their past fraudulent activities. Without such data, Stripe would be less able to recognize similar activities in the future. WHAT DATA MAY BE SHARED OR MADE AVAILABLE TO ENABLE ME TO SEE STRIPE ADS ON OTHER SITES? To enable visitors of Stripe.com to see Stripe ads on other sites, we use advertising cookies. The data that Stripe shares or makes available to enable this advertising includes identifiers, internet or other similar network activity, IP addresses, and device characteristics. Click the below links to learn more about the data that may be shared or made available to enable this feature. You can disable the toggle in the “advertising” section of our cookie settings page at any time. Third Party Service Data that we may share or make available Service Description Learn more Facebook Purchase Information, Web Activity, Sign-up information, IP address, device and browser characteristics, timestamps of visits The Meta Pixel is a snippet of JavaScript code that allows Stripe to track visitor activity on your website. It works by loading a small library of functions which we use whenever a site visitor takes an action (called an event) that we want to track (called a conversion). https://developers.facebook.com/docs/meta-pixel Reddit Purchase Information, IP Address, Web clicks, Sign-up information. The Reddit Pixel is a tool that helps Stripe better understand the customer journey so we can measure, optimize and re-engage audiences for Stripe ad campaigns. The Reddit Pixel is used to leverage website insights and optimize ad campaigns to reach qualified users and drive conversions. https://redditinc.force.com/helpcenter/s/article/About-Reddit-Ads-conversion-tracking Marketo Web traffic, Web clicks, Marketo allows for tracking of end-user page visits and clicks to Stripe landing pages and external web pages. These are recorded in Marketo as “Visit Web Page” and “Clicked Link on Web Page” activities. https://experienceleague.adobe.com/docs/marketo-measure/using/home Yahoo Unique identifier, Web clicks, timestamp of visits Yahoo pixels are used to record many different types of events for conversion tracking across Stripe sites. These can include clicks or page visits. https://developer.yahooinc.com/native/guide/native-dsp-migration-guide/pixels/ Linkedin URL’s, referrer, IP address, device and browser characteristics, timestamps of visits. The LinkedIn Insight Tag is a lightweight JavaScript tag. It is used on Stripe websites to enable features like website retargeting, conversion tracking, and website demographics. https://www.linkedin.com/help/lms/answer/a423304/enable-first-party-cookies-on-a-linkedin-insight-tag?lang=en YouTube Web Activity, Sign-up information, IP address, device and browser characteristics, timestamps of visits YouTube cookies track end-user page visits on Stripe sites in order to serve a more personalized ad experience on YouTube. N/A DOES STRIPE HONOR THE GLOBAL PRIVACY CONTROL (GPC) OPT-OUT PREFERENCE SIGNAL? Yes. Global Privacy Control (GPC) is a signal that is sent by a web browser on your behalf that communicates your choice to opt-out of sharing for targeted advertisements. If you have enabled GPC on your browser, you will automatically be opted out of any “sharing” when you interact with our site. You can learn more about how to use opt-out preference signals by visiting the Global Privacy Control website. CAN I TURN OFF TRACKING AND ADVANCED FRAUD SIGNALS? Your web browser may allow you to manage your cookie preferences, including deleting or disabling Stripe cookies. If you choose to disable cookies, keep in mind that some features of our Site or Services may not operate as intended. Disabling cookies will not disable the collection of advanced fraud signals, which we use to prevent fraud on Stripe. The collection of this data is controlled by the Business User that integrated with Stripe. If a Business User seeks to disable this data collection, they can find instructions to do so through Stripe’s documentation. You can take a look at the help section of your web browser or follow the links below to understand your options for disabling cookies. * Google Chrome * Microsoft Internet Explorer * Microsoft Edge * Safari * Firefox * Opera You can learn more about how businesses can disable collection of advanced fraud signals in our documentation for disabling advanced fraud detection. HOW DO I DELETE MY ACCOUNT? You can close your Stripe account from the Settings page on the Dashboard. You can read more about that on our support page: Close a Stripe account. Please be aware that we will delete some, but not all, of the information that we hold, for the reasons explained below. As a provider of payment services, Stripe is required to comply with many regulations, including anti-terrorism and anti-money laundering laws. These regulations and laws may require Stripe to retain transactional records associated with Business Users for a prescribed period of time after the close of the business relationship. You can read more about our underwriting obligations in our Privacy Policy. HOW DO I DELETE MY CUSTOM CONNECT ACCOUNT? If you have a Custom Connect account, your account is managed by a Platform / Business User. They are the party responsible for managing payments for you and responding to your query; therefore we recommend reaching out to them for assistance. HOW DO I DELETE MY EXPRESS CONNECT ACCOUNT? If you have an Express Connect account, your account is managed by a Platform / Business User. They are the party responsible for managing payments for you and responding to your query; therefore we recommend reaching out to them for assistance. WHAT IS THE PRIVACY POLICY FOR STRIPE MEDIA SERVICES? The Privacy Policy for Stripe Media Services (Media Privacy Policy) describes how Stripe collects and processes personal data in order to provide the Stripe Media Services, including Stripe Press, Increment, and Works in Progress. We encourage you to read our Media Privacy Policy to learn more. DOES STRIPE LOCALIZE STORAGE OF DATA IN INDIA? Personal Data may be processed either locally in India or in any other country where we have operations or where we engage service providers, to the extent permitted under applicable laws of India. The entire payment system data will be stored only in India in accordance with the RBI data localization guidelines. WHERE CAN I LODGE MY COMPLAINT ON DATA HANDLING IN INDIA? If you have any questions or complaints regarding the treatment of your Personal Data in India, please contact our Nodal Officer and Grievance Officer: Name - Yogender Singh Email Address - complaints-in@stripe.com Address - Prestige Tech Pacific Park, 10th Floor, Building 2, Kadubeesanahalli Village, Varthur Hobli, Bangalore East Taluk, Bangalore-560103 Karnataka, India For more information about complaint handling, please visit here. Separately, for law enforcement requests, please contact LERequests@stripe.com. NOTIFICATION IT RULES 2021 We are required to inform you that in case of non-compliance with rules and regulations, our Privacy Policy or user agreement, we have the right to terminate your access or usage rights immediately or remove non-compliant information or both, as the case may be. COOKIES & OTHER TECHNOLOGY HOW DOES STRIPE USE COOKIES? We use cookies to (1) ensure that our services function properly, (2) prevent and detect fraud and violations of our terms of service, (3) understand how visitors use and engage with our website and (4) analyze and improve our services. Depending on your relationship with Stripe and the domain you are visiting, different cookies apply. For instance some cookies are set on a public Stripe or Link domain, some on the Stripe Dashboard or a Link settings page, and some on the payment page available to end users who make payments using Stripe services, including Link. Cookies play an important role in helping Stripe provide personal, effective and safe services. Please be mindful that we change the cookies periodically as we improve or add to our services. For more information, please see our Cookie Policy. WHAT IS STRIPE.JS? Stripe.js is a JavaScript library that businesses use to integrate Stripe and accept online payments (corresponding iOS and Android SDKs enable the same use cases). Stripe uses Stripe.js to facilitate fraud prevention technologies and the use of its Link payment services on the websites of Business Users. For fraud detection, Stripe.js uses cookies, including `__stripe_mid`, `__stripe_sid`, and `m`, to collect signals differentiating legitimate behavior from fraudulent behavior. For example, fraudsters and bots often spend less time on Business Users’ pages than legitimate End Customers. We are able to detect this behavior and use it in evaluating the risk that a transaction is fraudulent. When you visit a site that uses Stripe, you might see this fraud prevention activity in a privacy report or tracker list on your web browser. Stripe doesn’t—and won’t—share or sell the fraud data it collects using Stripe.js to advertisers. Stripe works to keep this fraud detection data secure and ensure it does not leave Stripe infrastructure. It is exchanged between the following Stripe-controlled hosts:js.stripe.com, m.stripe.network, and m.stripe.com, and access to this data is tightly restricted to a small number of Stripe employees whose security permissions are regularly reviewed. You can read more about how Stripe uses data for fraud prevention in our Privacy Policy. Stripe also uses the Stripe.js library to implement cookies and similar technology such as `pay_sid`, `link.auth_session_client_secret`, and `elements_session` to enable Link to remember users’ information for faster checkout across Stripe merchant sites and to collect analytics related to Link’s implementation on checkout pages. You should regularly review the Stripe cookies that are placed on your website and other data collected by Stripe.js. You should consult your counsel regarding how best to disclose this data collection to your customers, including by updating your cookie banner. But, here is a paragraph you could add to your privacy disclosures if they do not already include such information: We use Stripe for payments, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services, including via cookies and similar technologies. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection, authentication, and analytics related to the performance of its services. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. WHAT ARE ADVANCED FRAUD SIGNALS? Stripe’s advanced fraud detection looks at signals about device characteristics and user activity indicators that help distinguish between legitimate and fraudulent transactions. These signals are highly indicative of fraud and power Stripe’s fraud prevention systems, such as Radar. The signals are securely transmitted to Stripe’s backend by periodically making requests to the m.stripe.com endpoint. You can learn more in our documentation for advanced fraud detection. WHY ARE ADVANCED FRAUD SIGNALS NOT AD TRACKING? Stripe only uses these advanced fraud detection signals to enable secure payments and prevent fraud. We don’t use this data to build individual profiles or share or sell it to third-party advertisers. You can read more about how we use this data in our Privacy Policy. WHAT OBLIGATIONS SHOULD MERCHANTS KEEP IN MIND RELATING TO COOKIE TECHNOLOGY ON THEIR SITES? This article aims to provide information about the use of cookies and similar technologies (“cookies”) on the websites where you as a merchant may use Stripe services and how the cookies support the functions and features of Stripe's services for merchants. For example, your use of certain Stripe services may load stripe.js. Stripe.js is a javascript library provided by Stripe, and in one of its functions it uses cookies for various purposes including fraud prevention, authentication, and analytics (for the avoidance of doubt, the elements_session analytics cookie is only set in some US states). Please refer to https://stripe.com/cookie-settings for more information. The specific cookies used by stripe.js depend on your configuration with the related Stripe products. For example, one of the key features of stripe.js is the fraud prevention system provided by Stripe's Radar product. Radar uses cookies to help businesses reduce chargebacks and losses from fraudulent transactions. Please note that the use of cookies may have legal implications depending on the geographical location of your business and customers. As a result, you may need to take appropriate action to ensure compliance with local regulatory requirements related to cookies. You should regularly review the Stripe cookies that are placed on your website to ensure that your own privacy disclosures tell your end users about this type of data collection, and also update your cookie disclosure and/or consent banner accordingly after reviewing the cookies placed on your website. Here is a paragraph you could add to your privacy disclosures if it does not already include such a disclosure: We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services, including via cookies. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and authentication. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. Below is an overview of the specific cookies associated with each product and their respective functions for Embeddable Checkout, Elements, Radar, and Link. Cookie Name Category Description Cookie in use when using: m Fraud Prevention Set for fraud prevention purposes and helps us assess the risk associated with an attempted transaction. Learn more about advanced fraud detection. Radar stripe_mid Fraud Prevention Set for fraud prevention purposes and helps us assess the risk associated with an attempted transaction. Learn more about advanced fraud detection. Radar __stripe_sid Fraud Prevention Set for fraud prevention purposes and helps us assess the risk associated with an attempted transaction. Learn more about advanced fraud detection. Radar pay_sid Authentication Provide a logged-in experience when a consumer uses link.com to make purchases on a merchant site. Link, Embeddable Checkout, Checkout & Elements __Host-LinkSession Authentication Stores consumer credentials to provide a one-click payment experience at checkout. Link & Elements link.auth_session_client_secret Authentication Provide a logged-in experience when a consumer uses Stripe-hosted payment UIs to make purchases and Crypto Onramp to purchase crypto. Link elements_session Analytics The `elements_session` US-only cookie allows us to measure the result of changes we make to the Stripe Elements product and ensure that the performance of the product continues to improve over time. Embeddable Checkout, Elements & Link HOW DOES STRIPE REMEMBER PAYMENT METHOD DETAILS FOR LINK? Link (formerly known as “Remember Me”) lets end users save and reuse their payment information for faster checkout at thousands of online businesses that use Stripe. When an end user makes a purchase via a Business User (i.e., merchant) that enables Link, the end user can ask Stripe to remember their payment method details, such as credit and debit card details. If an individual chooses to be remembered, Stripe will remember the end user’s email address, phone number, shipping address, and payment method details for future Link transactions. The payment method details for future transactions may be remembered across multiple Stripe Business Users. Generally, once the cookie is set, the end user may make “1-click” purchases using Link when you check out, which means that Stripe will automatically populate the end user’s saved information into their checkout on their behalf, and use the information to complete the transaction faster. If the end user enters their phone number or email address during a future Link transaction, Stripe will authenticate the end user by sending the end user a One Time Passcode (OTP), e.g. via an SMS message or email. If the end user correctly enters the OTP, Stripe or the Business User will set a cookie in the end user’s browser, indicating that the end user has been authenticated. If the end user does not enter the OTP, or elects to “log out” of their Link session then the cookie won’t remember the end user. A cookie is only stored in a specific browser on a specific device. If an end user wishes to make 1-click purchases in a different browser or on a different device, they must go through the OTP authentication process for the new browser or device combination. After 90 days, it will be necessary for the end user to re-complete the OTP process. The end user may also proactively remove the cookie by clearing cookies in their browser or by selecting the “log out” option when this option is presented in checkout. If an end user no longer wishes for Stripe to remember their payment method details when they check out in the future, the end user may use the self-service deletion tool. Alternatively, the end user may also contact Stripe support to make this request. The description above describes how an end user may control how their information is stored and used to check out. However, this does not affect the other contexts in which Stripe may store and use end user information. In particular, Stripe may store and use such information as described elsewhere on this Privacy Center - including for purposes such as for advanced fraud detection. WHAT OBLIGATIONS SHOULD LINK USERS KEEP IN MIND RELATING TO COOKIE TECHNOLOGY ON THEIR SITES? Based on your integration choice (e.g., for Link in Elements), you may have legal responsibilities associated with cookies and similar technology that Stripe uses for fraud detection and/or authentication purposes. You should always check with your legal counsel to understand how you should comply with applicable legal obligations with setting cookies and similar technology. This section has information to keep in mind. Stripe cookies or similar technology are set on your domain (e.g. on your checkout flow) from the Stripe.js library. The current Stripe cookies from the Stripe.js library include fraud prevention cookies like `__stripe_mid`, `__stripe_sid`, and `m`, and also end-user authentication cookies like`pay_sid` and `__Host-LinkSession`. You should regularly review the Stripe cookies that are placed on your website to ensure that your own privacy disclosures tell your end users about this type of data collection, and also update your cookie banner accordingly after reviewing the cookies placed on your website. Here is a paragraph you could add to your privacy disclosures if it does not already include such a disclosure: We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services, including via cookies. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and authentication. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy. DOES STRIPE USE CAPTCHA TO PROTECT ITS WEBSITE FROM FRAUD AND ABUSE? Yes, some of the Stripe sites may implement Google reCAPTCHA Enterprise to help prevent fraud and abuse. Information collected by Google is used to provide and improve reCAPTCHA Enterprise and for general security purposes. Use of reCAPTCHA Enterprise is subject to Google’s Privacy Policy and Terms of Use. We may also use hCAPTCHA Enterprise to help protect Stripe’s sites and services from fraud and abuse, including by bots impersonating human beings. When you access Stripe’s sites and services protected by hCAPTCHA, we may share data, including browser features and certain hashed identifiers with our hCAPTCHA provider Intuition Machines, Inc. To the extent that this data is Personal Data, Intuition Machines processes it on Stripe’s behalf as a Data Processor. CONTACT US CONTACT OUR PRIVACY TEAM If you have any outstanding privacy questions after reviewing the privacy policy, please don’t hesitate to reach out to us by email, or through our form. If you’d like to send us physical mail, please send to: Stripe, Inc. 354 Oyster Point Boulevard South San Francisco, California, 94080, USA Attention: Stripe Legal Stripe Payments Europe Limited 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland Attention: Stripe Legal WHERE CAN I LEARN MORE ABOUT STRIPE’S SECURITY PRACTICES? Visit our security page to learn more about Stripe’s security practices. You should contact us immediately if you become aware of any unauthorized use or any other breach of security regarding the Stripe services. 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