Privacy Policy
Revised April 4, 2024
This Privacy Policy explains how Pagos Solutions, Inc. and its affiliates (collectively, “Pagos”, “we”, “us” or “our”) collects, uses, shares, and otherwise processes personal information in connection with our websites, including https://www.pagos.ai and other websites we own and operate that link to this Privacy Policy (the “Sites”), and the related content, platforms, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Pagos employees and other personnel.
1. HOW WE COLLECT AND USE PERSONAL INFORMATION
The categories of information we collect submitted to us through the Services can include:
• Contact Information, including first and last name, company name, and email address for you and your end users. We may collect your contact information when you submit a request or communicate with us, including through the “Request a Demo” form on our Sites. We may collect some or all of the same information if necessary to provide our Services. We use contact information to provide you with Services that you request or in which you express interest, and to communicate with you about our Services.
• Account Information, including user ID and password, and any other such information you provide to us or that is necessary to create and maintain an account with us. We use this information to administer your account, provide you with the relevant Service and information, communicate with you regarding your account and your use of the Service, and for customer support purposes.
• Payment Information: Your Payment for Our Services. If you sign up for one of our Services that requires payment of fees, we collect your payment information as necessary to process your payment, which may include payment card or bank account information (for direct debit). We use third party payment processors to process card and ACH payments made to us, and we do not retain any personally identifiable financial information in connection with your payments to us. All such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy policy. We currently use Stripe for card payments; to view Stripe’s Privacy Policy, please click here.
• Payment Information: Required for Use of Our Services. If you use one of our Services that requires payment data, we collect any payments-related data that you provide or otherwise make available to us and as necessary for the performance of such Service. The nature of our Services means that you control the type of data provided or otherwise made available to us from your designated data source. We may anonymize or de-identify and aggregate some or all such payment information and we may use such aggregated payment information to improve our Services, including benchmark and analytics, and to create new Services.
• Professional Information you submit when you apply for a job opening, such as your work history and other information provided on your resume. We use this to evaluate your eligibility for employment.
• Other Information that you provide to us online, via email, Slack, text, SMS, phone or in person. We use this information to respond to your request or provide you the requested Services.
In addition to the above, we may use the information we collect from you:
• To provide you with Services that you request or in which you express interest;
• To communicate with you, including via email, text message, Slack, social media, direct mail and/or phone calls;
• To customize the advertising and content you see;
• For marketing and advertising purposes, including to market to you or offer you through email, information and updates on products or services we think you may be interested in;
• To process payment for our Services;
• To respond to your emails, comments, questions, or requests for Services;
• To improve, customize, and augment our Services, and to develop new Services to address the needs and interests of our user base;
• To test, enhance, update and monitor the Services, or diagnose or fix technology issues;
• To enforce our Terms of Use, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• To prevent, investigate or provide notice of fraud or unlawful or criminal activity;
• For any other purpose we may describe when you provide the information; and
• For any other lawful purpose, or other purposes that you consent to.
2. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use the Services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:
• Information the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behavior and actions you take on the Sites.
• Information about how you use the Service, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Service and may record your mouse movements, scrolling, clicks and keystroke activity on the Service and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Service or engage in chat features through our Service.
• Information about your location, such as general geographic location that we or our third-party providers may derive from your IP address.
All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Service, offers, advertising, communications and customer service. We may also use this information the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
3. SHARING OF YOUR PERSONAL INFORMATION
We may share your personal information with:
• Other companies owned or controlled by Pagos, or under common ownership and control as Pagos. These companies will use your personal information in the same way as we can under this Privacy Policy.
• Service providers or contractors that Pagos uses to support the operations of our business and that perform services on our behalf, which may include sending emails, processing payments, providing customer service, or providing web hosting and analytical services.
• We may display targeted advertising to you through social media platforms, such as LinkedIn, and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements of our products and services to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
• Other parties in connection with a corporate business transaction or potential transaction where Pagos merges with another organization, files for bankruptcy, or sells some or all its assets or capital stock. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Third parties, such as legal advisors and law enforcement, as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or other agreements or to protect the security or integrity of the Pagos services, including to prevent harm or financial loss, or in connection with preventing fraud or illegal activity; (c) to exercise or protect the rights and property of Pagos, our customers, visitors, or others; (d) to protect the health and safety of us or others; or (e) as otherwise required by applicable law.
• With third parties or publicly with your consent or direction.
5. CONTROL OVER YOUR INFORMATION
You may control your information in the following ways:
• Email Communications Preferences. From time to time, we may send you emails regarding updates to our Service, products or services, or notices about our organization. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly using the information provided in the Contact Us section, below. We will review your request and may require you to provide additional information to identify yourself. We may not be able to modify or delete your information in all circumstances.
6. DATA RETENTION
We will usually store the personal information we collect about you for as long as necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator, or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.
Once retention of the personal data is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if this is not possible (for example, because personal data has been stored in backup archives), then we will securely store the personal data and isolate it from further processing until deletion or deidentification is possible.
If Pagos receives any personal information that is not necessary for providing Services that you request, Pagos will anonymize or de-identify such information and delete the original information. You are solely responsible for providing only information that is necessary to perform the requested Services, subject to our Terms of Use.
7. CHILDREN'S PERSONAL INFORMATION
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we have collected has been provided by a child under the age of 16, we will promptly delete that personal information.
8. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
Our Service may include links to third-party websites, plug-ins and applications that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any site or service before providing any personal information.
9. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to change this Privacy Policy from time to time at our sole discretion. We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Pagos account and/or by placing a prominent notice on our website. It is your responsibility to review this Privacy Policy periodically. When we do change the Privacy Policy, we will also revise the “effective” date.
10. CONTACT US
If you have any questions regarding this Privacy Policy, or any of our services, please send an email to privacy@pagos.ai.
11. ADDITIONAL U.S. STATE PRIVACY DISCLOSURES
For residents of the States of California, Colorado, Connecticut, Nevada, Utah, and Virginia: These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individual residents of these States. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you. Additionally, the Additional Disclosures set out in this Section do not describe our practices when we process Customer Data as a service provider on behalf of our customers in accordance with our Terms of Use.
Sensitive Personal Information
The following personal data elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”): account log-in in combination with any required security or access code, password, or credentials allowing access to an account, or PAN. We use this sensitive information for the purposes set forth in the How We Collect and Use Personal Information section of our Privacy Policy.
We do not sell sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising. However, depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive information (as described in the Your Privacy Choices section below).
Your Privacy Choices
Depending on your state of residency, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
• The Right to Know. The right to confirm whether we are processing personal data about you, including:
- The categories of personal data collected;
- The categories of sources of the personal data;
- The purposes for which the personal data were collected;
- The categories of personal data disclosed to third parties (if any), and the categories of recipients to whom the personal data were disclosed;
- The categories of personal data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for those purposes; and
- The categories of personal data sold (if any), and the categories of third parties to whom the personal data were sold.
• The Right to Access and Portability. The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• The Right to Request Deletion. You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
• The Right to Correction. You have the right to request that any inaccuracies in your personal information be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Privacy Rights
To submit a request to exercise one of the privacy rights identified above, please submit a request by emailing privacy@pagos.ai with the subject line “Data Subject Rights Request.”
We may need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these U.S. Disclosures where we can verify the authorized agent’s authority to act on your behalf.
For requests to know, delete, or correct personal information, we require the following for verification purposes:
(a) a power of attorney valid under the laws of California from you or your authorized agent; or
(b) sufficient evidence to show that you have:
1. provided the authorized agent signed permission to act on your behalf; and
2. verified your own identity directly with us pursuant to the instructions set forth in these U.S. Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
Appealing Privacy Rights Decisions
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted at privacy@pagos.ai.
California-Specific Disclosures
The following disclosures only apply to residents of the State of California.
• Personal Information Collection. In the last 12 months, we may have collected the following categories of personal information: identifiers, commercial information, internet/network information, geolocation data, professional/employment information and inferences generated from your use of our sites. For more information about our collection of personal information, the sources of personal information, and how we use this information, please see How We Collect and Use Personal Information section of our Privacy Policy.
• Disclosure of Personal Information. In the last 12 months, we may have disclosed all of the categories of information we collect from you, with:
- Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, fraud prevention, web hosting, or similar services;
- Social networks for advertising or personalization purposes, or to engage with you;
- Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service; and
- We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in our Privacy Policy.
• Sales of Personal Information and Sharing for Targeted Advertising. In the previous 12 months, we have not sold or shared any personal information for targeted advertising.