Updated Sept 1, 2020
Your privacy is particularly important to us. At PopCom, we are committed to protecting your personal information and take your privacy seriously. The purpose of this policy is to make you aware of how we collect and use your information that is obtained through our websites, services, applications and hardware. The following explains our policy.
2. Information we collect
Personal Data collected for the following purposes and using the following services:
We collect personal information from you when you visit our Company website or when you interact with any of our Services, to include vending machines, kiosks, or table products. This information includes information you actively provide to us and information that is collected automatically from your devices.
We collect information from you including activity and usage data from the Company website and any e-mail you may send us or that you may respond to one of our e-mail newsletters or other e-mails that we may send to you from time to time related to our Services.
We collect personal information from you every time you enter data into online forms on the Company Website, contact us with questions regarding our Services or to request a demonstration of our product and make other opportunities available that ask individuals to provide personal information such as their name and e-mail address. You may also provide personal information when you request a whitepaper or other information from Company and may provide our employees with your business card or provide information for billing and other business purposes.
If you choose to create an account on the Company website, we collect your username, password, e-mail address, country, preferred account type and may collect billing information when you register. For users that register an account with Company, our server logs also automatically collect user information such as users’ IP addresses, pages users access, browser type and language, and the date and time of visits, which helps Company track use of the website and understand trends.
When you interact with any of our Licensees’ hardware, that has an active PopCom software subscription or conduct transactions through a Licensee’s application, we will receive biometric data from the camera feed along with associated transaction information. Biometric data is anonymized and not associated with you, however if you submit additional information such as an email address, it can appear alongside biometric data. Depending on how the Licensee implements our PopCom Services, we may receive this information directly from you, or from the Licensee or third parties. Different use cases and applications of our PopCom Services require the collection of different categories of information. The Licensee will determine the information it collects and the use of the information according to their policy.
You can also provide us with other optional information, such as your name, picture, postal address, phone number, social network profiles, questionnaire responses, general business information, and other personal, biographical, or demographic info. This optional information is not necessary for you to use the Company Web site or to maintain an account with us, but by sharing this information, we can better serve you and improve your overall website experience.
You may also choose to submit information to us via other methods, including: (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.
We and/or our selected third-party partners may also collect data about visitors’ activities on this website and across the Internet over time for non advertising purposes, including to conduct analytics, measure trends, and streamline Web site usability. The technologies used for this purpose may include log files, cookies, web beacons, and social media plug-ins. One of the service providers we may use is Google Analytics. To learn more about how Google Analytics collects and processes data and the choices you may have to control these activities, you may visit https://www.google.com/policies/privacy/.
3. How we use the information we collect
By licensing one or more of our products and Services, or by viewing content on our Web site, you have consented to us using certain types of tracking and third-party cookies on our Services. For more information, see Section 6 below.
3.2. We or third-party data and advertising platforms that we work with may use or combine multiple technologies, such as cookies, page tags, mobile identifiers and IP addresses to infer users’ common identities across different services and multiple devices such as tablets, browsers, and mobile phones. We may do so, for instance, to tailor ads to users, to enable us to determine the success of our advertising campaigns and to improve upon them. These third-party data and advertising platforms may sometimes use data that we provide to them in order to improve their technologies and their ability to match common devices to users. We also may also use this to measure the performance of e-mail messaging and to learn how to improve e-mail deliverability and open rates.
The above data and techniques are used for personalized marketing, analytics, and related purposes. We may also use this data to personalize online marketing campaigns to be relevant to you and your interests in our Services. By clearing your cookies in your browser settings you will no longer see personalized messages in this way but you continue to see ads over the internet that are not based on information you provided to the Company.
• Contact Information. We use contact information to respond to your inquiries, send you information as part of the Services, and send you marketing information (for as long as you do not opt-out). We use your e-mail address to send you marketing (newsletters), unless you indicate a preference to opt-out and for general updates on your account. You can opt out of marketing communications at any time by contacting our customer service department.
• How you use our Services. We use information about how you use our Services to improve our Services for you and all users. We collect information about the types of documents you generate, the types of plans you purchase and your account transactional behavior to build a profile about you so as to help direct you and your organization to other relevant features and services we offer and help you in using our Services, for example by making recommendations for you to optimize use of our Services.
• Device and browser data. We use device data both to troubleshoot problems with our Services and to make improvements to it. We also infer your geographic location based on your IP address. We collect this to help us improve your service experience through a specific device/browser by optimizing how the Services look in a particular device, how your screen brightness affects your experience and to ensure the service operates optimally and as it should on different devices and browsers.
• Log data. We use log data for many different business purposes to include monitoring abuse and troubleshooting, creating new services, features, content or to make recommendations, tracking
behavior to identify and understand trends in the various interactions with our Services, and fixing bugs and troubleshoot product functionality. Your IP address is also used to determine where an unknown/unauthorized access may have occurred in your account (abuse monitoring).
• Referral information. We use referral information to track the success of our integrations and referral processes.
• Third parties and integrations. We collect and use information from third parties and integration partners to: personalize our Services for you; and ensure you can use our Services in conjunction with other services.
• Service and Marketing uses.
Profiling. We combine information about you from third party sources with information we hold about you to create a user profile, which will help us to make our sales and marketing efforts more relevant to you and to personalize and improve your service experience.
Machine learning. We use machine learning techniques on certain data in order to provide users with useful statistics and more relevant insights from the data we have collected using our Services and to optimize our marketing campaigns and for fraud detection.
To manage our Services, we will also internally use your information and data, for the following limited purposes: to enforce our agreements where applicable, to prevent potentially illegal activities, and to screen for and prevent undesirable or abusive activity.
• Legal uses. To respond to legal requests or prevent fraud, we may need to use and disclose information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
3.4. We collect and use the following on the basis that we have to use this information in order to fulfill our contract with you:
• Your Account Information. We need to use your account information to run your account, provide you with Services, bill you for our Services, provide you with customer support, and contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our Services or policies, a welcome e-mail when you first register). You cannot opt out of these communications since they are required to provide our Services to you.
• Your Profile. We process other aspects of your account information (like the personal information you provide about your job, your job title, and your marketing preferences) as well as information obtained from public sources, for legitimate interests like providing you with a personalized experience and relevant and useful marketing information as well as to make other product, feature and service recommendations to you and your organization to optimize use of the Services we offer. You can object to us using your information as described above but in some cases, our ability to fully and properly provide our Services to you may be impacted if you do not want us to collect or use the above data.
3.5. Company may use data from your constituent management system in order to fulfill our maintenance and support obligations or provide consulting services to you. Such data may include but is not limited to full name, postal address, e-mail address, transaction history and other personally identifiable information. The information collected, in each instance, is the minimal data required in order for us to provide the requested service. Customer Data is not shared with third parties. This data may be stored and or archived for internal reporting services. You may request at any time that such data be purged from our systems by contacting our customer service department.
4. Information you share
Many of our Services let you share information with others. Remember that when you share information publicly, it can be indexable by search engines. Our Services provide you with different options on sharing and deleting your content but we cannot delete content from search engines so you need to be careful about information you make public.
5. Information we share
From time-to-time, we may need to disclose your information to third parties such as to law enforcement authorities or our legal advisers, where it is necessary to comply with the law or regulation; enforce or apply our user terms and conditions; to protect our rights, or to preserve the safety of our users. This may include exchanging information with other companies and organizations for fraud protection.
We may also share your personal information with companies that provide services to help us with our business activities (e.g. processing payments or submitting e-mails to you on our behalf), in connection with any merger, a sale of all or substantially all of the Company’s assets, or a financing or acquisition of all or a portion of our business to another company. Whenever we share your personal information for this reason, we will ensure that the recipient is bound by all appropriate confidentiality obligations and that it commits to using your personal information only for the purposes for which you originally provided it.
You should also be aware that the information submitted to public areas, such as our blogs, may be read, collected, and used by others who access them.
• To provide you with personalized content. We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.
• To advertise to you. We, or our service providers and other third parties we work with, place cookies when you visit our Web site and other web sites or when you open e-mails that we send you, in order to provide you with more tailored marketing content (about our Services or other services), and to evaluate whether this content is useful or effective. For instance, we evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive ads that are tailored to you based on your online activity, you may contact our customer service department and ask to “opt out”. Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.
• Google Analytics. In addition to the above, we have implemented on our web sites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our web sites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.
You can choose to remove or disable cookies via your browser settings.
7. Third Party Web sites
The Company Web site may contain links to and advertisements for web sites operated by third parties whose privacy practices may differ from ours. While we endeavor to associate only with reputable entities, is not responsible for the privacy practices of these other web sites. We encourage you to check the privacy policies of all web sites that you visit.
8. How Do We Keep Information Secure?
The security of your personal and nonpersonal information is important to us. Company uses reasonable physical, managerial, and technical safeguards to prevent loss, misuse, and unauthorized access, disclosure, destruction and alteration of the information that our Web site collects.
Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, Company cannot ensure or warrant the security of collected data or other information. In particular, we cannot guarantee that collected data or other information will not be disclosed, altered, or accessed in accidental circumstances or by unauthorized or unlawful acts of others.
9. How Long Do We Keep This Information For?
Company retains personal information we collect from you as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements, resolve disputes and enforce our agreements).
Company retains nonpersonal information as long as is legitimately necessary or no longer than eighteen (18) months.
Company will delete or otherwise discard customer data or data we collect about you while using our Services at our discretion or when you contact us to do so. You can initiate such a request by contacting our customer service department.
10. Legal Basis For Processing (European Union and Switzerland Visitors Only)
If you are a visitor from the European Union (EU) and Switzerland, our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process information from you only where we have your consent (Art. 6 para 1 lit. a) GDPR), where we need the information to provide our contractual obligation to you (Art. 6 para 1 lit. b) GDPR) or where we have a legitimate interest to do so.
If you wish to learn more about specific legal ground(s) we rely on to process your information for any particular purpose (including any legitimate interests we have to process information), then please contact us using the details provided below under “Contacting Us”. However, by way of example, we rely on our legitimate interests to process information for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms (Art. 6 para 1 lit. f) GDPR).
11. International Transfers
Company complies with the U.S. Children’s Online Privacy Protection Act (COPPA) and does not knowingly collect personal information from children under the age of thirteen (13) or from web sites or online services directed to children under the age of thirteen (13).
If you are a visitor from the European Union (EU) or Switzerland, Company does not process the personal data of a child younger than 16 years old. Company makes reasonable efforts to verify in such cases that consent is given or authorized by the holder of parental responsibility over the child, taking into consideration available technology.
Consumers should not create Company accounts on our Web site or license our Services, unless they are legally old enough to from a binding contract and in any case are 18 years of age or older. In the unlikely event that you are the parent or legal guardian of a child under 18, who has registered with the Company Web site or has licensed services from us, please contact [e-mail address] to have your child’s personal information deleted.
13. Sensitive Personal Data
We do not knowingly collect or obtain from third parties, any personal data, including any “Sensitive Personal Data,” as defined under the GDPR. “Sensitive Personal Data” are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.
14. Your Rights
• You have the right to access the information that maintains about you, request deletion of your data, update your data, object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information and you correct or amend that information if it is inaccurate or has been processed in violation of privacy laws, to the extent allowed by law, including the General Data Protection Regulation (GDPR).
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to opt-out from our marketing communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contacting Us” heading below.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
15. California Consumer Privacy Act (California Visitors Only)
The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access and Deletion Rights
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or deletion once within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
16. Changes In Corporate Structure
18. Impact of EU-U.S. Privacy Shield
19. Contacting Us
997 N. Fourth St
Columbus, OH 43201
Attention: PopCom Legal