corporate.freedompay.com Open in urlscan Pro
151.101.66.159  Public Scan

Form analysis
1 forms found in the DOM

GET

<form role="search" method="get" class="search-form">
  <div class="search-wrap">
    <input type="text" class="search-field" placeholder="Search" name="keyword" id="keyword" onkeyup="fetch()">
    <button type="submit" class="search-submit">
      <img src="https://corporate.freedompay.com/wp-content/themes/freedompay/images/search-icon.svg">
    </button>
  </div>
</form>

Text Content

Manage Cookie Consent


To provide the best experiences, we use technologies like cookies to store
and/or access device information. Consenting to these technologies will allow us
to process data such as browsing behavior or unique IDs on this site. Not
consenting or withdrawing consent, may adversely affect certain features and
functions.
Functional Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose
of enabling the use of a specific service explicitly requested by the subscriber
or user, or for the sole purpose of carrying out the transmission of a
communication over an electronic communications network.
Preferences Preferences
The technical storage or access is necessary for the legitimate purpose of
storing preferences that are not requested by the subscriber or user.
Statistics Statistics
The technical storage or access that is used exclusively for statistical
purposes. The technical storage or access that is used exclusively for anonymous
statistical purposes. Without a subpoena, voluntary compliance on the part of
your Internet Service Provider, or additional records from a third party,
information stored or retrieved for this purpose alone cannot usually be used to
identify you.
Marketing Marketing
The technical storage or access is required to create user profiles to send
advertising, or to track the user on a website or across several websites for
similar marketing purposes.
Manage options Manage services Manage vendors Read more about these purposes

Accept Deny View preferences Save preferences View preferences
Cookie Policy Privacy Statement {title}
Manage Cookie Consent


To provide the best experiences, we use technologies like cookies to store
and/or access device information. Consenting to these technologies will allow us
to process data such as browsing behavior or unique IDs on this site. Not
consenting or withdrawing consent, may adversely affect certain features and
functions.
Functional Functional Always active
The technical storage or access is strictly necessary for the legitimate purpose
of enabling the use of a specific service explicitly requested by the subscriber
or user, or for the sole purpose of carrying out the transmission of a
communication over an electronic communications network.
Preferences Preferences
The technical storage or access is necessary for the legitimate purpose of
storing preferences that are not requested by the subscriber or user.
Statistics Statistics
The technical storage or access that is used exclusively for statistical
purposes. The technical storage or access that is used exclusively for anonymous
statistical purposes. Without a subpoena, voluntary compliance on the part of
your Internet Service Provider, or additional records from a third party,
information stored or retrieved for this purpose alone cannot usually be used to
identify you.
Marketing Marketing
The technical storage or access is required to create user profiles to send
advertising, or to track the user on a website or across several websites for
similar marketing purposes.
Manage options Manage services Manage vendors Read more about these purposes

Accept Deny View preferences Save preferences View preferences
{title} {title} {title}
Skip to content

Read the latest from FreedomPay & Cornell on Gen Z’s willingness to share their
personal data with payments platforms and merchants DOWNLOAD NOW

X
 * Next Level Commerce™
   Next Level Commerce™
    * Philosophy & Approach
      FreedomPay is a creative force in connected commerce and can help you
      achieve Next Level performance.
    * Platform
      Advance beyond chaos and confusion, and reap the benefits of the
      industry’s fully unified and integrated commerce platform.
    * 

 * Industries
   Industries
    * Contract Food Services
      We work with the biggest names in the business. How can we help you?
    * Gaming
      FreedomPay manages the majority of transactions in Las Vegas. What happens
      here can help you.
    * Hospitality
      Change is inevitable. How you respond will help shape your future success.
      Start here.
    * Retail
      In times of transformation, vision, technology and execution are
      everything. We can help.
    * Higher Education
      On-campus, in-store, online…innovation is happening everywhere. Be a part
      of it.
    * eCommerce
      Have the right solutions for your business in these times of changing
      habits and preferences.
    * Unattended
      Be ready as consumers continue to enjoy and demand greater control at
      check-out.
    * 

 * Partners
   Partners
    * Partners
      Join our growing network of 500+ payment system integrators, innovators
      and consultants.
    * ISO Network
      Our fast-growing eco-system enables best in class commerce solutions.
    * Partner Testimonials
      Next Level work is happening now. Hear what our partners are saying.
    * 

 * Company
   Company
    * Our Story
      Since 2000, FreedomPay has grown from a pioneer in payments technology to
      becoming the innovation partner of choice.
    * Newsroom
      Read about our latest news and features in global payments, technological
      innovation, and consumer-centric commerce.
    * Brand Kit
      Looking to collaborate on a marketing initiative with FreedomPay? Find our
      logo, brand guidelines & more here.
    * Careers
      Be a part of the team that’s advancing the future of payments. FreedomPay
      is always looking for talented and smart individuals.
    * Community
      We’re growing as fast as the industry we have pioneered. Here’s what we’re
      up to.
    * 

 * Commerce Academy
   Commerce Academy
    * Insights & Whitepapers
      We’re growing as fast as the industry we have pioneered. Here’s what we’ve
      been doing.
    * Blog
      Read FreedomPay’s insights and features on the latest trends in the
      payments and fintech industry.
    * Case Studies
      Hear from our many partners and customers worldwide on how FreedomPay has
      transformed their payments ecosystem.
    * Events
      See what we’ve been up to this year with our events recap page!
    * Podcasts
      Learn more about various thought-leading topics from experts in the
      industry.
    * Training
      Meet the team to understand more about FreedomPay and why we’re the
      partner of choice.
    * Virtual Next Level Commerce
      Watch and learn from our many partners and customers in the ‘new normal’
      world of commerce.
    * Women in Tech Series
      This series aims to inspire women to consider careers in tech and motivate
      by giving them a platform to share their stories.
    * 

 * 
 * myFreedomPay
 * Contact Us
   How can we help?
    * Sales
      Talk to one of our experts to help you move your business to where it
      wants to be next
    * Technical Support
      Talk to us and let us guide you through any questions you might have.
    * Member Support
      No two businesses are alike. We want to provide the personalized support
      you need
    * Media Relations
      Check-in on what FreedomPay is doing now and next to advance connected
      commerce around the world
    * Press Release Self-Service Hub
      Have a joint media announcement to make? Please get started in our
      self-service hub.
    * 

page
 * Disclaimer
 * Women in Tech Series
 * VIP Networking Breakfast – Thank You For Registering!

post
 * Women in Technology: Laura Pride
 * Women in Technology: Mugdha Vaidya
 * Women in Technology: Laura McGuigan

news
 * FreedomPay and MWC Partners Deliver A Next Level Retail Experience for
   Customers
 * Money20/20 Europe with Chris Kronenthal, FreedomPay
 * An Interview with Retail Technology Innovation Hub

View All Results
Privacy Policy

FreedomPay Privacy Policy

Version: 2.8
Date: August 29, 2022


I. PURPOSE

FreedomPay recognizes the importance of protecting your privacy and we work hard
to safeguard your personal information. Our Privacy Policy is designed to assist
you in understanding how we collect, use and store the information you provide
to us when using any of our Services, regardless of how you use or access these
Services. 

This Privacy Policy will be updated or reviewed, at minimum, yearly. It is
strongly recommended to check this document often. 

Our Privacy Policy explains:

 * What information we collect and its purpose
 * How we obtain, process, disclose, share, retain and protect collected
   information
 * The legal basis for processing collected data
 * Your data protection rights regarding your information
 * Who to contact regarding your data


II. NOTICE


INFORMATION WE COLLECT

FreedomPay reserves the ability to share or permit access to personal
information with persons we employ directly or as contractors or agents,
partners, or affiliates at our direction, for purposes of administering our
Services, processing information, marketing our Service and providing customer
support. We share personal information with certain third parties such as the
merchant of record, banks, processors, card networks, phone centers and other
suppliers and vendors to provide the Services and to help us process the
Services you request. FreedomPay requires such third parties to maintain
confidentiality of your personal information.

Any information that can identify or reasonably link to, directly or indirectly,
a consumer or household may be considered personal information. Anonymized data
or data that is aggregated in such a way as to not be reasonably linkable with a
specific consumer or household is not considered personally identifiable.
FreedomPay reserves the ability to aggregate and disclose aggregated information
that is not personally identifiable. Generally, this aggregated information is
used in statistical analysis. If FreedomPay sells all or substantially all of
its assets, or completes a business transaction such as a merger, acquisition by
a third party or a seal of all or a portion of our assets, this non-identifiable
aggregated information may be one of the transferred assets.


PAYMENT GATEWAY

FreedomPay’s payment gateway solution securely collects and transmits credit
card transaction data between merchants and processors. FreedomPay does not and
will never store data defined as Sensitive Authentication Data (SAD), which
includes CVV security code and PIN/PIN block and will only transmit that data as
part of the credit card authorization process.

In addition to the collection and transmission of credit card transaction data,
FreedomPay has the ability to collect certain information related to the
transaction, including, but not limited to, name, address, occupation and email
address. This information is provided to FreedomPay directly by the customer
through a FreedomPay application, such as a credit application process, or
through a FreedomPay partner that has integrated with a FreedomPay application.
Merchants may define additional data fields which relate to the transaction or
may contain information provided by the customer and pass these data fields
along with the transaction information to FreedomPay for analytical or record
keeping purposes. The data that may be recorded falls under the following
categories: identifiers, customer records information, commercial information,
professional or employment-related information, and geolocation data.


STORED VALUE 

FreedomPay’s Stored Value platform is a white-label, closed-loop payment
solution which is utilized for declining balance accounts or account-on-file
recurrent billing. Stored Value funding options include automated and manual
funding through bank accounts, credit/debit cards, and payroll deduction.
Additional manual funding includes cash and check. For credit card transactions,
FreedomPay utilizes FreedomPay’s Payment Gateway to route and complete the
transaction. Please refer to the Payment Gateway section for more detail
surrounding credit card transaction data.

As part of the enrollment process to the Stored Value solution, FreedomPay
collects information about to the Stored Value account holder, including, but
not limited to name, address, occupation and email address. This information is
provided to FreedomPay directly by the customer during the enrollment process,
maintenance or modification of the customer account during the stored value
account lifecycle, or through a FreedomPay partner that has integrated their
existing stored value solution with FreedomPay. The data that may be recorded
falls under the following categories: identifiers, customer records information,
commercial information, professional or employment-related information, and
geolocation data.


BUSINESS INTELLIGENCE TOOL

FreedomPay’s Business Intelligence Tool is a platform for providing customer
intelligence via business reporting, containing trending, forecasting, market
cluster/segmentation analysis. The scope of the data which will be loaded,
analyzed, visualized, and made available to the end user through the Business
Intelligence Tool is governed by the data being passed to FreedomPay from the
merchant environment. This data includes customer name, customer card number,
and card type along with transaction and merchant specific information unrelated
to the customers identity such as merchant address or location of transaction,
currency type, and transaction totals. This data is combined with publicly
available information (including demographic Census data, weather patterns,
etc.) to generate additional ‘inferred’ or ‘derived’ data, to provide enhanced
analytics throughout the merchant enterprise. The data that may be recorded
falls under the following categories: identifiers, customer records information,
commercial information, and geolocation data.


CORPORATE WEBSITE

HOTJAR

FreedomPay’s corporate website uses Hotjar in order to better understand our
users’ needs and to optimize this service and experience. Hotjar is a technology
service that helps us better understand our users experience (e.g. how much time
they spend on which pages, which links they choose to click, what users do and
don’t like, etc.) and this enables us to build and maintain our service with
user feedback. Hotjar uses cookies and other technologies to collect data on our
users’ behavior and their devices (in particular device’s IP address (captured
and stored only in anonymized form), device screen size, device type (unique
device identifiers), browser information, geographic location (country only),
preferred language used to display our website). Hotjar stores this information
in a pseudonymized user profile. Neither Hotjar nor we will ever use this
information to identify individual users or to match it with further data on an
individual user. For further details, please see Hotjar’s privacy policy by
clicking on this link: https://www.hotjar.com/legal/policies/privacy

You can opt-out to the creation of a user profile, Hotjar’s storing of data
about your usage of our site and Hotjar’s use of tracking cookies on other
websites by following this opt-out link:
https://www.hotjar.com/legal/compliance/opt-out

LEADS AND MARKETING

FreedomPay also uses its corporate website to collect information provided by
potential clients wishing to learn more about FreedomPay solutions. The
information collected includes name, email address, phone number, state, postal
code, country, job title and company name and is used by our sales department
for contact purposes to answer any questions regarding FreedomPay or the
services we provide, and by our marketing department to distribute information
regarding FreedomPay news, events, and webinars. This information is entered by
the user through a form on our website and is imported into an internal
management system for future communication. Once stored, this data may be shared
with FreedomPay partners to assist potential clients with any additional
questions they may have about all possible configurations of FreedomPay
solutions. Individuals may unsubscribe from FreedomPay’s marketing newsletters
and webinar invitations at any time by clicking the unsubscribe link within the
email, or by unsubscribing at the following link:
https://pages.freedompay.com/UnsubscribePage.html

COOKIES

To improve your experience on our corporate website, FreedomPay utilizes
‘cookies’. Cookies are an industry standard and most major web sites use them. A
cookie is a small text file that our site may place on your computer as a tool
to remember your preferences. You may refuse the use of cookies by selecting the
appropriate settings on your browser (refer to your browser or device help
material), however please note that if you do this you may not be able to use
the full functionality of this website.

Our website uses Google Analytics, a service which transmits website traffic
data to Google servers in the United States. Google Analytics does not identify
individual users or associate your IP address with any other data held by
Google. We use reports provided by Google Analytics to help us understand
website traffic and webpage usage. For more information on the cookies used by
Google Analytics you can visit the following link:
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

You may also opt out of Google Analytics by using the browser add-on at the
following link: https://tools.google.com/dlpage/gaoptout/

For a full description of the cookies and services used within our website,
please refer to the FreedomPay cookie policy, found here:
https://corporate.freedompay.com/cookies-policy/


EMPLOYMENT DATA

As an employer, FreedomPay collects personal information of its employees
including name, address, email, date of birth, bank information, work
experience, and education history. This information is provided to FreedomPay by
its employees through an application form distributed once an offer has been
extended. We reserve the ability to share this information with third parties
for the completion of background screenings, payment distribution, and
enrollment in health/financial benefits. FreedomPay requires such third parties
to maintain confidentiality of employee personal information. 

We release account and other personal information when we believe release is
appropriate to comply with the law; protect the rights, property or safety of
FreedomPay, our users or others. This includes exchanging information with other
companies and organizations for fraud protection and credit risk reduction.
Certain federal, state and local laws or government regulations may require us
to disclose non-public personal information about you to respond to court orders
or legal investigations. Note that this does not include selling, renting,
sharing, or otherwise disclosing personally identifiable information from
customers for commercial purposes in violation of the commitments set forth in
this Privacy Policy.

We will ask for your consent before using information for a purpose other than
those that are set out in this Privacy Policy.


CHILDREN’S NOTICE

FreedomPay recognizes how important it is to protect the online privacy of
children. FreedomPay’s services are neither intended for children nor are they
designed to attract child users. FreedomPay does not knowingly collect personal
information from users under 18, would not willingly provide this data to any
third party for any purpose, and any subsequent disclosure would be due to the
user submitting personal information without solicitation from FreedomPay. 


CONTACTING US

In compliance with GDPR, and other various statutes, FreedomPay commits to
resolve complaints about your privacy and our collection or use of your personal
information. European Union or Swiss individuals with inquiries or complaints
regarding their personal data that is transferred into the United States should
first contact FreedomPay at techsupport@freedompay.com. 

If you have any questions about our Privacy Policy, would like to make a data
request, or need to get in contact with our Data Privacy Officer, you may
contact us in the following ways: 

Email: compliance@freedompay.com
Website: https://corporate.freedompay.com/consumer-privacy/
Toll-Free Number: 1-888-495-2446 


INDEPENDENT DISPUTE RESOLUTION

Data subjects under the jurisdiction of GDPR can file a complaint with the
courts of the EU member state where they reside, where they work, or where the
alleged infringement occurred.

If your complaint involves human resources data transferred to the United States
from the EU [and/or Switzerland] in the context of the employment relationship,
and FreedomPay does not address it satisfactorily, FreedomPay commits to
cooperate with the panel established by the EU data protection authorities (DPA
Panel) and the Swiss Federal Data Protection and Information Commissioner, and
to comply with the advice given by the DPA panel and Commissioner, with regard
to such human resources data. To pursue an unresolved human resources complaint,
you should contact the state or national data protection or labor authority in
the appropriate jurisdiction.

Contact details for the EU data protection authorities can be found
at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm 

Contact details for the Swiss Federal Data Protection and Information
Commissioner can be found
at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html


III. CHOICE

As stated in II. Notice, Information We Collect, FreedomPay collects certain
data that is required for performance of its Services. Separate from the
performance of its Services, FreedomPay reserves the ability to aggregate and
disclose aggregate data that is not personally identifiable to its partners or
third parties. This aggregated, non-identifiable data will be used in
statistical analysis or for other similar purposes.

For data defined as sensitive information, such as health conditions, racial or
ethnic origin, political opinions, religious or philosophical beliefs, trade
union membership or information specifying the sex life of an individual,
FreedomPay must obtain written express consent from its customers or employees
to share this data for any purpose outside of performing its Services. Please
note, that FreedomPay does not collect this type of sensitive information as
part of its Services, but this section has been included for transparency.


IV. ACCOUNTABILITY FOR ONWARD TRANSFER


TRANSFER OF PERSONAL INFORMATION

Should FreedomPay enter into an agreement with a third-party organization acting
as a controller, FreedomPay agrees that it will, to the best of its ability,
require the third-party controller to agree to the terms listed in section II.
Notice, III. Choice, and V. Security, as well as meet the minimum security
standards of FreedomPay including, but not limited to, PCI DSS compliance. As
grounds for data transfers from the EU to third countries, FreedomPay relies
upon Standard Contractual Clauses (SCCs), which set out appropriate safeguards
for transfers of personal data. FreedomPay agrees to also require that, if
entering into an agreement with a third-party controller, that the controlling
entity be required to cease processing data that falls within scope of this
privacy policy and/or take immediate steps to remediate should the determination
be made that the entity is unable to abide by this policy. FreedomPay may be
liable for the appropriate onward transfer of personal data to third parties.

FreedomPay utilizes third party organizations as agents to perform its Services.
These agents include:

 * Processors
 * Acquiring Banks
 * Fraud management Providers
 * Dynamic Currency Conversion Providers
 * Chargeback Providers

For each of these providers, explicit consent must be received by the merchant
as part of an overall agreement before this information can be shared.

FreedomPay agrees that for existing and future third-party agents assisting in
performing services its services involving the sharing of personal data it
will: 

 1. Transfer such data only for limited and specified purposes; 
 2. Contractually provide that the agent is obligated to provide at least the
    same level of privacy protection as is required by the Principles; 
 3. Take reasonable and appropriate steps to ensure that the agent effectively
    processes the personal information transferred in a manner consistent with
    the organization’s obligations under the Principles; 
 4. Require the agent to notify the organization if it makes a
    determination that it can no longer meet its obligation to provide the same
    level of protection as is required by the Principles; 
 5. Upon notice, including under (4), take reasonable and appropriate steps to
    stop and remediate unauthorized processing; and 
 6. Provide a summary or a representative copy of the relevant privacy
    provisions of its contract with that agent to the Department of Commerce
    upon request. 
 7. Note that FreedomPay may be required to share personal data in response to
    lawful requests from public authorities including to meet national security
    and law enforcement requirements. 


V. SECURITY

FreedomPay transmits, processes and stores customer and employee data and takes
appropriate measures to protect this data from loss, misuse and unauthorized
access, disclosure, alteration and destruction, taking into due account the
risks involved in the processing and the nature of the personal data. Annually,
FreedomPay undergoes security audits which include, but are not limited to,
Payment Card Industry Data Security Standard (PCI DSS), SSAE16/SSAE18 SOCII Type
II, and Payment Card Industry Point-to-Point Encryption (PCI P2PE). As a service
provider per PCI DSS standards, FreedomPay also undergoes regular security
testing of its environment by independent 3rd party organizations to test the
security of its environments. Upon request, FreedomPay will provide documented
evidence of its compliance with relevant security standards. For questions or
inquiries regarding FreedomPay’s security and compliance requirements, please
contact compliance@freedompay.com.


VI. DATA INTEGRITY AND PURPOSE

FreedomPay’s use of personal information and data collected from its customers
and employees will be limited to data that is 1) required for satisfactory
performances of its Services or 2) collected and utilized to enhance the user
experience of the Services. FreedomPay limits the information that it collects
to data that is relevant for the satisfactory delivery and performance of
FreedomPay’s Services and does not process personal information or data that is
incompatible with its intended use as described above or as required by legal or
regulatory bodies. 

FreedomPay’s use of personal information is retained in an
individual-identifiable form only so long as needed to perform its Services, as
required by legal or regulatory bodies, or as needed for reasonable means such
as statistical analysis. Following that period, stored data is aggregated and no
longer identifiable to a specific transaction or user.


VII. DATA PROTECTION RIGHTS

FreedomPay is obligated through several consumer privacy laws, such as but not
limited to the General Data Protection Regulation (GDPR) and California Consumer
Privacy Act (CCPA), to inform users about their rights as consumers in regard to
their personal data. FreedomPay seeks to inform users about their rights in a
clear and transparent way and create an environment where individuals can share
their information whilst having the value of their privacy upheld. Your specific
rights will be determined either by where your data is procured from, from your
place of residence, or a combination of both. 

For all users outside of GDPR and CCPA jurisdiction, FreedomPay will respond to
user data access, deletion, or rectification requests and the time frames for
those requests in compliance with the varying local, national, or regional data
protection and privacy laws and regulations without undue delay. The time frame
for FreedomPay’s response to the consumer may be extended when additional
reasonable verification of identify of the data subject is required, or if there
are numerous or complex requests. FreedomPay will take every reasonable measure
possible to prevent unauthorized disclosures of personal information. In
general, vexatious or otherwise malicious or excessive requests may be refused
at FreedomPay’s discretion.


GDPR

The European General Data Protection Regulation, which came into effect on May
25th, 2018, provides eight fundamental rights to any data subject, regardless of
citizenship, located within the confines of the European Union. These rights are
as follows: 

 * The right to be informed. FreedomPay seeks to be clear and transparent with
   user information and utilizes this Privacy Policy to communicate about data
   being collected, how the data is used, how long the data will be kept and the
   criteria determining this, and how data is processed. FreedomPay provides
   contact details of the data privacy officer within this
   document. FreedomPay seeks to inform users about their rights to ensure fair
   and transparent processing. 
 * The right to access. Consumers have the right to learn if data is being
   processed by FreedomPay, the business purpose of their processed data, the
   categories of data processed and stored, the time period for storage or the
   criteria used to determine this period, the source of stored data, any
   automated decision making regarding their information, the existence of the
   rights to request rectification, erasure, or restriction of processing of
   information, and the right to lodge a complaint with a supervisory
   authority. Where personal data is transferred to a third country or to an
   international organization, FreedomPay has provided appropriate safeguards as
   required by Article 46 of GDPR through Standard Contractual Clauses. 
 * The right to rectification. Consumers may request that personal information
   that is inaccurate or incomplete regarding the data subject is updated
   without undue delay. FreedomPay allows consumers to exercise this
   right taking into account the purpose of processing the data being requested
   for rectification. 
 * The right to erasure. Consumers may request that FreedomPay erases personal
   data when their personal data is no longer necessary for the purpose of which
   it was collected, where there is no legal ground for processing, no
   legitimate grounds for processing, for compliance with legal obligations to
   which FreedomPay is subject, or when related to processing the information of
   children below the age of 16. FreedomPay allows consumers to exercise this
   right depending on the type of data being requested for erasure.  
 * The right to restrict processing. Consumers can request that FreedomPay
   limits the way they use their personal data and can be used as an alternative
   to the right to erasure when the user believes their data is inaccurate or
   for legal claims regarding the data. 
 * The right to data portability. Any data information provided by FreedomPay
   will be provided in a commonly used and machine-readable format. Consumers
   have the right to transfer their information to another controller, where
   technically feasible. 
 * The right to object. Consumers may object to the processing of their personal
   data being collected by FreedomPay in certain circumstances, such as for
   direct marketing purposes. 
 * Rights related to automated decision making. Consumers are permitted to
   challenge and request a review of data processing regarding automatic
   decision making. 

As defined by GDPR, the data controller is the principal party collecting
personal data from data subjects, who determines the purposes and means of the
processing of personal data. Data controllers have the primary responsibility
for managing consent and data requests.

Data processors process personal data on behalf of data controllers. FreedomPay
is primarily a data processor. For example, if a merchant seeks to use
FreedomPay’s payment gateway to process credit card transactions, the merchant
is the data controller while FreedomPay is the data processor. 

Data subject access requests may be made directly to
FreedomPay only where FreedomPay is the data controller. Data subjects looking
to modify their consent, access or delete their data, or exercise any other
right under GDPR must contact the data controller (merchant) in order to resolve
their request. The data controller (merchant) will contact the data
processor (FreedomPay) as necessary on behalf of the consumer to fulfill the
data request. 

Data subject requests can only be made by the data subject the personal data
pertains to, or by an entity or individual entitled to act on behalf of the data
subject. To prevent unauthorized disclosure, FreedomPay will make reasonable
attempts at verifying the data subject requestor’s identity, or the authority
granted by the requestor on behalf of the data subject. Requests under GDPR will
be replied to without undue delay within 1 month from the date of receipt but
may be subject to extension for up to an additional 2 months depending on the
number and complexity of requests. Extensions will be communicated and justified
to the requester as soon as possible and within the initial 1-month deadline.
Vexatious or otherwise malicious or excessive objections may be subject to
reasonable charges or refused at FreedomPay’s discretion. If FreedomPay does not
comply with a request, FreedomPay will provide reasoning for non-compliance, and
the requestor may seek an internal review of the decision, and subsequently make
a complaint to their local Information Commissioner’s Office, information on
which can be found under section II. Notice, Contacting Us, Independent Dispute
Resolution.


CCPA

The CCPA, which came into effect January 1st, 2020, provides California
residents a number of consumer rights in relation to the collection and
processing of their personal information. These rights are as follows: 

 * The right to access. FreedomPay seeks to be clear and transparent
   with consumer information and utilizes this Privacy Policy to communicate
   about the categories of consumer data being collected, the sources
   of consumer data collection, and the business purpose for
   collecting consumer information. Consumers may make requests to access
   personal information, and FreedomPay shall promptly take steps to disclose
   and deliver, free of charge, the consumers personal information held by
   FreedomPay. FreedomPay will provide this data to the consumer in a portable,
   readily usable format after successfully verifying the consumer’s identity,
   and is not required to provide personal information to a consumer more than
   twice in a 12-month period. FreedomPay collects information during the card
   transaction process, through marketing initiatives, and our website. 
 * The right to request deletion. Consumers may request that their personal
   information may be deleted. Requests for deletion can only be made by the
   data subject the personal data pertains to, or by Authorized Agents acting on
   the individual’s behalf. Requests will be replied to without undue delay but
   may be subject to extension depending on the number and complexity of
   requests, and only after verification of the identity of the consumer or
   entity requesting deletion. Please see the notes on transaction data for
   specific exemptions on data deletion requests. 
 * The right to disclosure. Consumers have the categories of personal
   information collected about the consumer, the categories of sources from
   where the personal information is collected, the categories of third parties
   with whom the business shares personal information, the business purpose
   of collecting the consumer’s data, and the specific pieces of personal
   information it has collected about the consumer. The information within this
   section shall be provided alongside any consumer data request upon successful
   verification of the consumer’s identity. Requests for access can only be made
   by the data subject the personal data pertains to, or by Authorized Agents
   acting on the individual’s behalf. 
 * The right to opt out. Consumers have the right to opt out to the sale of
   personal information to third parties. FreedomPay does not sell personal
   information, and as such has not sold personal information within the last 12
   months. 
 * The right to non-discrimination. Consumers will not be discriminated
   against by FreedomPay if they choose to exercise their rights granted under
   the CCPA. 

As defined by CCPA, a “business” qualifies for CCPA when they i) do business in
the state of California, ii) collects personal information of California
residents (or has such information collected on their behalf iii) determines the
purposes and means of the processing of consumers’ personal information,
and iv) satisfies the following: 

 * Has annual gross revenues in excess of twenty-five million dollars
   ($25,000,000), adjusted for inflation 
 * Annually buys, receives for the business’s commercial purposes, sells, or
   shares for commercial purposes, alone or in combination, the personal
   information of 50,000 or more consumers, households, or devices 
 * Derives 50 percent or more of its annual revenues from selling consumers’
   personal information.

Service providers process data on behalf of a business for a business purpose
pursuant to a written contract which prohibits the service provider from
retaining, using, or disclosing the personal information other than the specific
purpose of performing the services specified in the contract for the business,
or otherwise permitted by CCPA. FreedomPay is primarily a service provider. For
example, if a merchant seeks to user FreedomPay’s payment gateway to process
credit card transactions, the merchant is the business while FreedomPay is
the service provider. 

Consumer access requests may be made directly to FreedomPay only where
FreedomPay is the business. Consumers looking to modify their consent, access or
delete their data, or exercise any other right under CCPA must contact
the business (merchant) in order to resolve their request. The
business (merchant) will contact the service provider (FreedomPay) as
necessary on behalf of the consumer to fulfill the data request. 

Consumer requests can only be made by the consumer the personal data pertains
to, or by an Authorized Agent registered with the California Secretary of
State entitled to act on behalf of the data subject. To prevent unauthorized
disclosure, FreedomPay will make reasonable attempts at verifying
the consumer or Authorized Agent’s identity. Requests under CCPA will be replied
to without undue delay within 45 days from the date of receipt but may be
subject to extension for up to an additional 90 days depending on the complexity
and number of requests. Extensions will be communicated and justified to the
requester as soon as possible and within the initial 45-day deadline. Vexatious
or otherwise malicious, repetitive or excessive objections may be subject to
reasonable administrative charges or refused at FreedomPay’s discretion. The
consumer will be notified of such decisions, and FreedomPay will demonstrate the
reasoning behind actions taken against any verified consumer request. 


TRANSACTION DATA

FreedomPay acknowledges the individual’s right to access the personal data we
hold about them. Customers wishing to review, amend, or correct their personal
data may do so by contacting the merchant that accepted the individual’s payment
card in payment for goods or services. If a customer contacts FreedomPay for
this purpose, FreedomPay will direct that customer to contact such merchant. As
a payment processor, FreedomPay provides its merchants access to customer
transactional data, but only in truncated formats in an effort to protect
customer data from potential breach or compromise. FreedomPay receives customer
data through the normal credit card transaction payment process, and transmits,
stores and processes transactional data to perform its services.

In general customers do not have access to the FreedomPay transaction processing
system due to the security and regulatory requirements required of payment
processors. Providing customers access to their data introduces a
disproportionate risk to both FreedomPay and the customer data, and therefore
FreedomPay does not offer access to this highly sensitive data.


GDPR

Under GDPR, as this transaction data is being collected due to a legitimate
interest and pursuant to the execution of contracts, FreedomPay is not required
to delete, or modify transactional data in response to a data subject access
request. 


CCPA

Under CCPA, as this transaction data is needed to complete transactions for
which it was collected, needed to provide goods or services requested by the
consumer, required to perform a contract, and used in context of the business
relationship with the consumer, FreedomPay is not required to honor deletion
requests for transactional data. 


BUSINESS DATA

Potential or existing clients who wish to review, amend, or delete the contact
information stored in FreedomPay’s marketing and Customer Relationship
Management (CRM) platforms can submit a request
at https://corporate.freedompay.com/consumer-privacy/. Following validation of
the data subject, a member of the FreedomPay compliance team will execute the
request and provide any accompanying documentation. 


HUMAN RESOURCES DATA

FreedomPay Employees wishing to review, amend, or delete their personal data may
do so manually by accessing the appropriate HR web portals. Using these portals,
FreedomPay employees have the ability to view and edit any information provided
to the Human resources department. Some information may be stored in systems
that do not offer an externally facing method for review, amendment, or
deletion. In these instances, employees may contact FreedomPay’s Director of
Human Resources for assistance. Due to financial and legal requirements, as long
as an individual is employed at FreedomPay, not all employee data can be deleted
without terminating the existing employment arrangement.

FreedomPay’s subsidiary, FreedomPay World Europe Limited, located at 40 Bank
ST., 26th Floor, Canary Wharf, London E14 5AB, United Kingdom, also adheres to
the terms and principles of this privacy policy, including the use of personal
data received from the EU. At this location, FreedomPay has designated its EU
representative as SVP of Global Product Delivery, Tony Hammond as required by
GDPR Article 27. 

Next Level Commerce™
Philosophy & ApproachPlatform
Company
Press ReleasesNewsroomBrand KitCareers
Partners
Join Our NetworkPlatform Partners
Commerce Academy
Insights & WhitepapersCase StudiesTrainingBlogPodcastsVirtual Next Level
Commerce
Industries
Contract Food ServicesGamingHospitalityRetailHigher EducationeCommerceUnattended

Copyright © 2020 FreedomPay, Inc. All rights reserved.
 * Cookie Policy
 * Privacy Policy
 * Sitemap

Manage consent Manage consent