Last Updated: 1 August 2019
1o, Inc. and its affiliates (collectively “1o”, “we” and “us”) respect your privacy. We offer services that enable platforms and merchants to run businesses, and to safely conduct online payment transactions.
1o obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “1o User”), or a customer of a User (“Customer”).
2. Personal Data We Collect
a. Personal Data that we collect about you.
“Personal Data” is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:
- When you register for a 1o account we collect your full name, email address, and account log-in credentials.
- When you contact us, we collect your name, email, and anything else you tell us about yourself.
When you respond to 1o 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 1o. If you contact us by phone as a 1o User, we may collect additional information in order to verify your identity.
If you are a 1o User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, we may also receive financial and personal information about you, such as 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).
If you are a Customer, when you make payments or conduct transactions through a 1o User’s website or application, or our 1o Shop, we will receive your transaction information. Depending on how the 1o User implements our Services, we may receive this information directly from you, or from the 1o User or third parties. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The 1o User will determine the payment methods that it enables you to use, and 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 that are offered to you by the 1o User. When you make a transaction, we may also receive your name, email, billing or shipping address and in some cases your transaction history to authenticate you.
When we conduct fraud monitoring, prevention and detection activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may use technology that helps us assess the risk associated with an attempted transaction that is enabled on the 1o User’s website or the application that collects information.
You may also choose to submit information to us via other methods, including but not limited to: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.
b. Information that we collect automatically on our Sites.
- Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.
3. How We Use Personal Data
a. Our products and services.
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our 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 payment transactions and to provide payment-related services to our Users.
Contractual and pre-contractual business relationships. We use Personal Data for the purpose of entering into business relationships with prospective 1o Users, and to perform the contractual obligations under the contracts that we have with 1o Users. Activities that we conduct in this context include:
- Creation and management of 1o accounts and 1o account credentials, including the evaluation of applications to commence or expand the use of our Services;
- Accounting, auditing, and billing activities; and
- Processing of payments using our Services , communications regarding such payments, and related customer service.
Legal and regulatory compliance. We may use Personal Data to verify the identity of our 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. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
Legitimate business interests. We rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process. We:
- Monitor, prevent and detect fraud and unauthorized payment transactions;
- Mitigate financial loss, claims, liabilities or other harm to Users and 1o;
- Respond to inquiries, send service notices and provide customer support;
- Promote, analyze, modify and improve our products, systems, and tools, and develop new products and services;
- Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
- Analyze and advertise our products and services;
- Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
- Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
- Ensure network and information security throughout 1o and our Services; and
- Transmit Personal Data within our affiliates for internal administrative purposes.
Payment transactions and related services. As a facilitator of payment transactions, we use Personal Data of our User’s Customers to process online payment transactions and authenticate Customers on behalf of our Users. All such use is pursuant to the terms of our business relationships with our Users. In addition, we may offer payment-related services to Users who have requested such services, and our delivery of such related services to our Users may involve the use of Personal Data. For example, a 1o User may specify parameters for transactions submitted by its Customers that determine whether the transactions are blocked or allowed by our platform. The entity responsible for the collection and use of Customer’s Personal Data in the context of payment transactions and payment-related services is the User.
If we need to use your Personal Data in other ways, we will provide specific notice at the time of collection and obtain your consent where required by applicable law.
b. Marketing and events-related communications.
We may send you email marketing communications about 1o 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 the consent requirements that are imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
c. Interest-based advertising.
When you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. You may download the AppChoices app to opt out in mobile apps. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.
4. How We Disclose Personal Data
1o does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
a. 1o. We may share Personal Data with other 1o entities in order to provide our Services and for internal administration purposes.
b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
c. Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment providers..
e. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of 1o, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices
You have choices regarding our use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your 1o account or by emailing [email protected]
c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
- The right to request confirmation of whether 1o processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
- The right to request that 1o rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that 1o erase your Personal Data in certain circumstances provided by law;
- The right to request that 1o restrict the use of your Personal Data in certain circumstances, such as while 1o considers another request that you have submitted (including a request that 1o make an update to your Personal Data); and
- The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact 1o as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
If you are a Customer of a 1o User, please direct your requests directly to the User. For example, if you are making, or have made, a purchase from a merchant using 1o’s Shop, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.
6. Security and Retention
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please email [email protected] immediately.
If you are a 1o User, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your 1o account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
7. International Data Transfers
If you are located in the European Economic Area (“EEA”) or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. 1o Inc. is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.
8. Use By Minors.
The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.
10. Links to Other Websites.
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
11. Jurisdiction Specific Provisions
Residents of the European Economic Area (EEA) and Switzerland. The entity responsible for the collection and processing of Personal Data for residents of the EEA and Switzerland is 1o, Inc.., a company incorporated in Delaware.. To exercise your rights, the Data Protection Officer may be contacted at [email protected]
California residents. If you are a California resident, then, subject to certain limits under California law, you may ask us to provide you with (i) a list of certain categories of Personal Data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the Contact Us section below.
12. Contact Us.
35 Black Rock Road
Warwick, NY 10990
Attention: Legal Department