Introduction and Summary

We want to make it easy for you to understand what information we collect from you, what we do with it, and how you can request access to this information. 

We believe this is a best practice to maintain transparency and trust with our website visitors and clients, and it just so happens that this complies with the laws of many countries around the world, too. If you have questions about this policy, you can contact us at [email protected]. 

We collect as little information from you as possible for a specific and identifiable purpose, and then we commit to using this information only in the way we have specified. When you visit this site, you are agreeing to this Privacy Policy, the collection of information identified in this policy, and you always have the ability to opt out. 

What Personal Information We Collect and When

We collect information so that we can make our products and services better tailored to the people who visit our site and do business with us. We collect this information to (i) deliver products and services you have purchased from us, (ii) to notify you about our product or service offerings that you may be interested in, so long as you have given us consent to do so, (iii) to keep track of visitor information to our site and/or or create retargeted and “lookalike” audiences for advertising purposes.

We collect information from you directly and indirectly through third-party services, as follows:

When you contact us...

With questions or comments in the contact form.

When you comment on a post directly on the website.

To request more information, schedule a telephone call, or sign up to the newsletter.

To place an order for products or services. 

To receive your product or services. 

When we contact you...

To provide the goods and services you requested. 

To request occasional feedback.

To provide news, updates, and offers through the newsletter, usually by email, with an opt in consent. 

When we contact others...

We may see certain personal information from third party apps and services that allow us to complete your order.

We may see certain personal information from third party installations that allow us to remarket our services and products to you on other websites. 

We may see certain personal information from third party apps and services that allow us to monitor website traffic, email conversion, and other analytics data. 

We may see your personal information when we work with third party processors, like our email provider and web host. For EU residents, please note that this means we may transmit your data across international borders. 

 

Your Privacy Controls

We use third-party services on our websites to assist in communicating or interacting with the public, including social media services, widgets, apps, pixels, and plugins, as further identified below. These services may distinguish or trace your identity, through, for example, persistent, multi-session cookies. 

 

You can configure your system to delete cookies or disable them. In general, we do not collect or disseminate information collected by these services. When interacting with these third parties, their privacy policies apply. As of the time of this writing, we use: 

Google Analytics: Specifically, Google Analytics collects data about visitors to the Site via Google advertising cookies and anonymous identifiers, in addition to other data which may be collected through a standard Google Analytics implementation. We do not merge personally-identifiable information with non-personally identifiable information collected through any Google advertising product or feature. Should you wish to opt out of any Google Analytics Advertising features, you are encouraged to change your Ad Settings and Ad Setting for mobile apps, through the NAI’s consumer opt-out, or by using any of the other opt-out options currently available: currently available opt-outs.

Facebook pixels:Facebook Business Tools Terms

When you use the Facebook Business Tools to send us or otherwise enable the collection of Business Tool Data (as defined in Section 1 below), these terms govern the use of that data.

Background: Ad Products and other Business Tools

We may receive Business Tool Data as a result of your use of Facebook ad products, in connection with advertising, matching, measurement and analytics. Those ad products include, but are not limited to, Facebook Pixel, Conversions API (formerly known as Server-Side API), Facebook SDK for App Events, Offline Conversions, App Events API and Offline Events API. We also receive Business Tools Data in the form of impression data sent by Facebook Social Plugins (for example the Like and Share buttons) and Facebook Login, and data from certain APIs such as Messenger Customer Match via the Send API. Facebook may also offer pilot, test, alpha, or beta programs from time to time through which you may provide Business Tool Data. Uses of Business Tools Data are described below.

By clicking "Accept" or using any of the Facebook Business Tools, you agree to the following:

Sharing Business Tool Data with Facebook

You may use the Facebook Business Tools to send us one or both of the following types of personal information (“Business Tool Data”) for the purposes described in Section 2:

“Contact Information” is information that personally identifies individuals, such as names, email addresses, and phone numbers, that we use for matching purposes only. We will hash Contact Information that you send to us via a Facebook JavaScript pixel for matching purposes prior to transmission. When using a Facebook image pixel or other Facebook Business Tools, you or your service provider must hash Contact Information in a manner specified by us before transmission.

“Event Data” is other information that you share about people and the actions that they take on your websites and apps or in your shops, such as visits to your sites, installations of your apps, and purchases of your products. While Event Data does include information collected and transferred when people access a website or app with Facebook Login or Social Plugins (e.g. the Like button), it does not include information created when an individual interacts with our platform via Facebook Login, Social Plugins, or otherwise (e.g. by logging in, or liking or sharing an article or song). Information created when an individual interacts with our platform via Facebook Login, Social Plugins, or otherwise is governed by the Platform Terms.

Note: for purposes of these Business Tool Terms, references in existing terms or agreements to “Customer Data” will now mean “Business Tool Data.”

Subject to Section 1.d, we will not share Business Tool Data that you provide to us with third parties (including advertisers) unless you advise us that we are permitted to do so or we are required to do so by law.

We will implement processes and procedures to protect the confidentiality and security of the Business Tool Data, including by maintaining appropriate organizational, technical and physical safeguards that are designed to (a) protect the security and integrity of the Business Tool Data while they are within our systems and (b) guard against the accidental or unauthorized access, use, alteration, or disclosure of Business Tool Data within our systems. These processes and procedures include the measures listed in Facebook’s Data Security Terms (as updated from time to time, for example, to reflect technological developments) which are expressly incorporated into these Business Tools Terms.

You agree that Facebook may provide access to and/or a copy of Event Data about a particular individual to that individual upon their request.

You represent and warrant that you (and any data provider that you may use) have all of the necessary rights and permissions and a lawful basis (in compliance with all applicable laws, regulations and industry guidelines) for the disclosure and use of Business Tool Data.

You will notify us promptly in writing of any actual or threatened complaint or challenge related to the use of any Business Tool Data under these Business Tools Terms and will cooperate with us in responding to such a complaint or challenge.

If you are using or sharing the Business Tool Data on behalf of or together with a third party, you also represent and warrant that you have the authority as agent to such third party to use, share, and process such data on its behalf and bind such third party to these Business Tools Terms. You will only use or share the Business Tool Data or any audience or reports generated through use of the Business Tool Data with or on behalf of such third party.

You will not share Business Tool Data with us that you know or reasonably should know is from or about children under the age of 13 or that includes health, financial information or other categories of sensitive information (including any information defined as sensitive under applicable laws, regulations and applicable industry guidelines).

Use of Business Tool Data

We will use Business Tool Data for the following purposes depending on which Facebook Business Tools you choose to use:

Contact Information for Matching

You instruct us to process the Contact Information solely to match the Contact Information against user IDs (“Matched User IDs”), as well as to combine those user IDs with corresponding Event Data. We will delete Contact Information following the match process.

Event Data for Measurement and Analytics Services

You may instruct us to process Event Data (a) to prepare reports on your behalf on the impact of your advertising campaigns and other online content (“Campaign Reports”) and (b) to generate analytics and insights about people and their use of your apps, websites, products and services (“Analytics”).

We grant to you a non-exclusive and non-transferable license to use the Campaign Reports and Analytics for your internal business purposes only and solely on an aggregated and anonymous basis for measurement purposes. You will not disclose the Campaign Reports or Analytics, or any portion thereof, to any third party, unless otherwise agreed to in writing by us. We will not disclose the Campaign Reports or Analytics, or any portion thereof, to any third party without your permission, unless (i) they have been combined with Campaigns Reports and Analytics from numerous other third parties and (ii) your identifying information is removed from the combined Campaign Reports and Analytics.

Event Data for Targeting Your Ads

You may provide Event Data to target your ad campaigns to people who interact with your business. You may direct us to create custom audiences, which are groups of Facebook users based on Event Data, to target ad campaigns (including Website Custom Audiences, Mobile App Custom Audiences, and Offline Custom Audiences). Facebook will process Event Data to create such audiences for you. You may not sell or transfer these audiences, or authorize any third party to sell or transfer these audiences. Facebook will not provide such audiences to other advertisers unless you or your service providers share audiences with other advertisers through tools we make available for that purpose, subject to the restrictions and requirements of those tools and our terms.

These terms apply to the use of Website Custom Audiences, Mobile App Custom Audiences, and Offline Custom Audiences created through Facebook's Business Tools. Customer List Custom Audiences provided through our separate custom audience feature are subject to the Customer List Custom Audience Terms.

Event Data To Deliver Commercial and Transactional Messages

We may use the Matched User IDs and associated Event Data to help you reach people with transactional and other commercial messages on Messenger and other Facebook Company Products.

Event Data to Improve Ad Delivery, Personalize Features and Content and to Improve and Secure the Facebook Products

You may provide Event Data to improve ad targeting and delivery optimization of your ad campaigns. We may correlate that Event Data to people who use Facebook Company Products to support the objectives of your ad campaign, improve the effectiveness of ad delivery models, and determine the relevance of ads to people. We may use Event Data to personalize the features and content (including ads and recommendations) that we show people on and off our Facebook Company Products. In connection with ad targeting and delivery optimization, we will: (i) use your Event Data for delivery optimization only after aggregating such Event Data with other data collected from other advertisers or otherwise collected on Facebook Products; and (ii) not allow other advertisers or third parties to target advertising solely on the basis of your Event Data.

To improve the experience for people who use Facebook Company Products, we may also use Event Data to promote safety and security on and off the Facebook Company Products, for research and development purposes and to maintain the integrity of and to improve the Facebook Company Products.

Special Provisions Concerning the Use of Certain Business Tools

This section applies to your use of Business Tools to enable Facebook to store and access cookies or other information on an end user's device.

You (or partners acting on your behalf) may not place pixels associated with your Business Manager or ad account on websites that you do not own without our written permission.

You represent and warrant that you have provided robust and sufficiently prominent notice to users regarding the Business Tool Data collection, sharing and usage that includes, at a minimum:

For websites, a clear and prominent notice on each web page where our pixels are used that links to a clear explanation (a) that third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the Internet and use that information to provide measurement services and target ads, (b) how users can opt-out of the collection and use of information for ad targeting, and (c) where a user can access a mechanism for exercising such choice (e.g., providing links to: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/).

For apps, a clear and prominent link that is easily accessible inside your app settings or any privacy policy and from within any store or website where your app is distributed that links to a clear explanation (a) that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads, and (b) how and where users can opt-out of the collection and use of information for ad targeting.

In jurisdictions that require informed consent for storing and accessing cookies or other information on an end user’s device (such as but not limited to the European Union), you must ensure, in a verifiable manner, that an end user provides all necessary consents before you use Facebook Business Tools to enable the storage of and access to Facebook cookies or other information on the end user’s device. (For suggestions on implementing consent mechanisms, visit Facebook’s Cookie Consent Guide for Sites and Apps.)

Modification, Termination, and Retention:

We may modify, suspend, or terminate your access to, or discontinue the availability of the Facebook Business Tools at any time. You may discontinue your use of the Facebook Business Tools at any time.

Subject to these Business Tools Terms, we may retain the Event Data for a maximum of two years. We will retain any audiences you create using the Event Data until you delete them via your account tools. These Business Tools Terms do not replace any terms applicable to your purchase of advertising inventory from us (including but not limited to the Self-Serve Ad Terms and the Facebook Advertising Policies) and such terms will continue to apply to your ad campaigns. Facebook's Custom Audience Terms will not apply to audiences generated through the processing of Business Tools Data under these Business Tools Terms.

We reserve the right to monitor or audit your compliance with these Business Tools Terms.

These terms supplement and amend the Facebook Commercial Terms of Service. Facebook may update these Business Tools Terms from time to time. By continuing to access or use the Business Tools after any update, you agree to be bound by it. The parties acknowledge and agree that the US State-Specific Terms may apply to the provision and use of the Facebook Business Tools and are incorporated into these Business Tools Terms by reference.

Nothing in these Business Tools Terms will prevent us from making disclosures to our users in relation to Facebook Business Tools as we may be advised or as we may determine are appropriate or required under applicable law.

In the event of any express conflict between these Business Tools Terms and the Commercial Terms, these Business Tools Terms will govern solely with respect to your use of the Facebook Business Tools, and solely to the extent of the conflict.

Additional Terms for Processing of Personal Information

To the extent the Business Tool Data contain Personal Information which you Process subject to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), the following terms apply:

The parties acknowledge and agree that you are the Controller in respect of the Processing of Personal Information in Business Tool Data for purposes of providing matching, measurement and analytics services described in Sections 2.a.i and 2.a.ii above (e.g. to provide you with Analytics and Campaign Reports), and that you instruct Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (“Facebook Ireland”) to Process such Personal Information for those purposes on your behalf as your Processor pursuant to these Business Tools Terms and Facebook’s Data Processing Terms. The Data Processing Terms are expressly incorporated herein by reference and apply between you and Facebook Ireland together with these Business Tools Terms.

Regarding Personal Information in Event Data referring to people’s actions on your websites and apps which integrate Facebook Business Tools for whose Processing you and Facebook Ireland jointly determine the means and purposes, you and Facebook Ireland acknowledge and agree to be Joint Controllers in accordance with Article 26 GDPR. The joint controllership extends to the collection of such Personal Information via the Facebook Business Tools and its subsequent transmission to Facebook Ireland in order to be used for the purposes set out above under Sections 2.a.iii to 2.a.v.1 (“Joint Processing”). For further information, click here. The Joint Processing is subject to the Controller Addendum, which is expressly incorporated herein by reference and applies between you and Facebook Ireland together with these Business Tools Terms. Facebook Ireland remains an independent Controller in accordance with Article 4(7) GDPR for any Processing of such data that takes place after it has been transmitted to Facebook Ireland.

You, as the case may be, and Facebook Ireland remain independent Controllers in accordance with Article 4(7) GDPR for any Processing of Personal Information in Business Tool Data under GDPR not subject to Sections 5.a.i and 5.a.ii.

Section 5.a.i also applies when you are in Andorra, Azores, Canary Islands, Channel Islands, French Guiana, Guadeloupe, Isle of Man, Madeira, Martinique, Mayotte, Monaco, Réunion, San Marino, Saint Barthélemy, Saint-Martin, Switzerland, United Kingdom sovereign bases in Cyprus (Akrotiri and Dhekelia), and Vatican City.

To the extent the Business Tool Data contain Personal Information which you Process not subject to GDPR and you are not in any of the territories listed in Section 5.b, you acknowledge and agree that you are the Controller in respect of the Processing of such Personal Information for purposes of providing matching, measurement and analytics services described in Sections 2.a.i and 2.a.ii above (e.g. to provide you with Analytics and Campaign Reports), and you instruct Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA to Process such Personal Information for those purposes on your behalf as your Processor pursuant to these Business Tools Terms and Facebook’s Data Processing Terms. The Data Processing Terms are expressly incorporated herein by reference and apply in addition to these Business Tools Terms.

"Personal Information", "Controller", “Processor” and “Processing” in this Section have the meanings set out in the Data Processing Terms. References to GDPR and its provisions in this Section 5 include the GDPR as amended and incorporated into UK law after the GDPR ceases to apply in the UK.

Note:

We have updated the Terms For Conversion Tracking, Custom Audiences From Your Website, and Custom Audiences From Your Mobile App, including changing its name to the Facebook Business Tools Terms. For purposes of the Facebook Business Tools Terms, references in existing terms or agreements to the “Facebook Tools” will now mean Facebook Business Tools.

We have updated the Offline Conversion Terms, including changing its name to the Facebook Business Tools Terms. For the purposes of the Facebook Business Tools Terms, references in existing terms or agreements to (i) “Sales Data” will now mean Business Tool Data; (ii) “User Information” will now mean Contact Information; (iii) “Sales Transaction Data” will now mean Event Data; (iv) “Matched Data” will now mean Event Data that is combined with Matched User IDs; (v) “Unmatched Data” will now mean Event Data that is not combined with Matched User IDs; (vi) “Reports” will now mean Campaign Reports; and (vii) “OC” will now mean our Offline Conversions feature.

Effective date: August 31, 2020

PayPal

This Privacy Statement applies to PayPal and aims to provide you with sufficient information regarding our use of your Personal Information when you visit our website, apply for, or use our services (collectively, the “Services”). We encourage you to read this Privacy Statement and to use it to help you make informed decisions.Certain capitalized terms that are not otherwise defined in the Statement are explained in Section 11 (“Definitions”).We revise this Privacy Statement from time to time to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the "Policy Updates" or "Privacy Statement" page of our website, otherwise the revised Privacy Statement will be effective as of the published effective date.

2. Non-Account Holders

Our Services may be accessed by individuals without a PayPal account or profile. We will collect Personal Information from you even if you are a non-account holder when you use our Services, such as when you use our Services without a PayPal account, use Unbranded Payment Services (e.g., Braintree and Zettle), or when you receive a payment through our Services from account holders (“Recipient”). We may connect this information with your account, if you have one at the time you use the Service without logging in, or if you create an account later. With your consent, we may also save your credit card information for future use.

When you shop on Partner and Merchant sites, the partner or merchant may disclose Personal Information with PayPal that will be used in accordance with this Privacy Statement and the relevant PayPal user agreement.

3. Categories of Personal Information We Collect

Categories of Personal Data collected from you, including from your interactions with us and use of the Services:

Personal Identifiers: Such as name, Business Name, Address, Phone Number, Email, IP address, Device Information, Information collected from cookies or other tracking technologies, other information necessary to establish an account

Records and Financial Information: Such as, bank account and routing numbers, credit and debit card information, amount you send or request, other financial information

Commercial Information: Such as online shopping cart information, shopping activity on merchant sites, purchase history, and order tracking and product information

Geolocation: We may collect IP-based geolocation data and Global Positioning System (GPS) with your consent during your user experience or based on your mobile application settings.

Internet or network activity: interactions with our Services, Information about response time for web pages, download errors, date and time when you used the service, Location Information, such as your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies (“Technical Usage Data”)

Biometric: When you consent in the user experience, we collect voice identification or face scans to authenticate your account

Audio, electronic, visual, or similar information: Call recordings when you talk to customer service

Professional or employment information: including business information, contact emails, phone numbers and taxpayer ID numbers

Imported Contact Information: including name, address, phone number, images, email address or usernames associated with the contacts

Account Profile Information: username, profile picture, gender, or personal description which you add that may include sensitive Personal Information. You can set your profile to “Private” at any time

Information you provide when you contact us: Your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account status, repayment history, voice identification, Information about others if you choose to share it with us

Inferred data: We may infer information about you such as your preferences and shopping behavior, based on your transactions and interactions with our Services

Characteristics of Protected Classifications: including age or date of birth, national origin, disability, citizenship, military status

Sensitive Personal Information: Social Security number, government-issued identification, bank account and routing numbers, credit and debit card information, voice identification and Photo IDs or Precise Geolocation

Information from your device: including, language settings, browser ID, cookie preferences, time zone, operating system, platform, screen resolution and similar information about your device settings, data collected from cookies or other tracking technologies

We may also obtain the above categories of Personal Information from the following categories of sources:

PayPal or PayPal Companies

Third parties: including Service Providers, Partners and Merchants, Payment Partners, such as card networks and payment processors, Credit Reporting Agencies, Government Entities, Data Brokers, and Financial Institutions

Connected Accounts: Non-financial or financial accounts you agree to link to PayPal, such as social network accounts, mail accounts or for open banking. You may change your mind about use of this feature and unlink your connected accounts at any time. If you choose to link these accounts or share such information with us, we will periodically collect and process it until you disconnect the account

Third Party Applications: Applications that you choose to use for example, the Apple App Store, Google Play Store, or social networking sites

 

4. How is Personal Information used?

We may process your Personal Information for a variety of reasons, including to provide our Services, for security and fraud prevention and to comply with law. We may also use personal data with your consent to participate in certain features that while not necessary for use of the Services may be of interest to you, such as syncing your contact list to your account, targeted advertising, or connecting to a third-party platform.\

We may collect Personal Information to:

Provide our Services: such as to help you send or request money, initiate a payment, add monetary value to an account, pay a bill, administer your purchases, show you your account information, to assess your creditworthiness in connection with our Services, confirm your identity and your contact information, to authenticate your access to your account and to confirm your Account and financial information is accurate and up to date.

Provide receipts in connection with Zettle services: For buyers using our Zettle services, you may choose to provice us your contact details so that we can send you digital receipts.

Manage and improve our Services: for example, to develop new products and features, for customer analysis, to administer our Services, and for internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.

Manage fraud and risk: We conduct risk analysis, fraud prevention and risk management to protect our customers and business, including fraud that involves our Partners and Merchants and strategic ventures.

Associate information about you: if you use our Services without a PayPal account (e.g., Pay without a PayPal account) or Unbranded Payment Services (e.g., such as Braintree) we may associate such transactions with your account, if you have one or later establish an account.

Market our Services: We may use Personal Information to market our Services including where we partner with others to offer similar services to market about our Partners and Merchants. We use Personal Information to better understand and cater to your interests.

Communicate with you: We may contact you when you need us, such as answering a question you sent to our customer service team.

Comply with Laws: to comply with applicable laws and rules and enforce our agreements with you and other people who use our Services.

Process information about your contacts: to make it easy for you to find and connect them, improve payment accuracy and suggest connections with people you may know. By providing us with information about your contacts you certify that you have permission to provide that information to PayPal for the purposes described in this Privacy Statement.

Create an account connection between your Account and a third-party account or platform: such as with a social media account or a financial institution in connection with your participation in Open Banking.

Send you locally relevant options: If you agree to let us track your location, we can enhance your security of our Services and customize our Services by using the right language and personalizing content such as providing location-specific options, functionality or offers, ads and search results.

Remember your preferences: We may remember your preferences for the next time you use the Services, such as whether you choose to receive digital receipts via email or text when you checkout.

Personalize your experience: When you use Services, as well as other third-party sites and services we might use tracking technologies like cookies. See our Cookie Statement for more details.

5. Do We Disclose Personal Information, and why?

We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any Sensitive Personal Information.

However, we will disclose your Personal Information with third parties to help us provide Services, protect our customers from risk and fraud, market our products, and comply with legal obligations.

In addition, we may disclose Personal Information with:

PayPal and PayPal Companies, including our brands such as Venmo to provide you with the Services and to manage our business or with PayPal Honey to manage our Rewards program.

Authorities, when accompanied by a subpoena or other legal documentation that requires PayPal or PayPal Companies to respond. Such authorities include courts, governments, law enforcement, and regulators. We may also be required to provide other third parties information about your use of our Services, for example to comply with card association rules, to investigate or enforce violations of our user agreement or to prevent physical harm or illegal activity.

Other financial institutions, to jointly offer a product, such as PayPal Credit, PayPal Savings, PayPal Cashback Mastercard and PayPal Extra Mastercard.

Card networks and payment processors, to facilitate payment processing or to add cards to your electronic wallet.

Fraud prevention and identity verification agencies, for example to assist us in detecting activities suggestive of fraud.

Credit reporting and debt collection agencies, for example to collect unpaid overdue debts through a third party such as a debt collection agency.

Service providers that operate at our direction and on our behalf to perform services we outsource to them, such as processing payments, marketing, research, compliance, audits, corporate governance, communications, IT development, maintenance, hosting and support and customer service operations.

Other Users in accordance with your Account Settings. You may choose to display or make certain information available to other Users, such as your profile photo, first and last name, username, or city in accordance with your Account Settings.

Connected accounts, for example any social media accounts you asked us to connect or when you initiate an Account connection with another bank or financial institutions, card account, or aggregator in connection with your participation in Open Banking, so we can check if you have sufficient funds or confirm your ownership of the account.

Partners and Merchants, their service providers and others involved in a transaction, for example when you use the Services to initiate online purchases, pay other Users, or return goods we may disclose information about you and your Account with the other parties (or their service providers) involved in processing your transactions. Please note that Personal Information shared with Partners and Merchants (or their service providers) involved in a transaction is subject to the Partners and Merchants own privacy policy and procedures.

Other third parties, for example we disclose Personal Information to advertising platforms at your direction, or security service providers to help prevent unauthorized access to our Services. Please be aware that these parties’ privacy notice applies to the Personal Information that you share directly with them. For example, we use Google’s reCAPTCHA to prevent misuse of our Services, when you access our mobile application. We may also use Google Address Autofill to ensure accuracy of your address. Google’s Privacy Policy and Terms of Use apply to the Personal Information you share with them.

Buyers or in connection with business transfer, for example if we are involved in a merger, a purchase or sale of all or part of our business or assets, we may disclose your Personal Information to a buyer of those business or assets. If PayPal or a significant portion of PayPal’s assets are acquired by a third party, Personal Information may also be disclosed.

We may disclose your sensitive personal information as appropriate to carry out legitimate business activities allowed by law.

 

6. How long does PayPal store your Personal Information?

We retain Personal Information for as long as needed or permitted in context of the purpose for which it was collected and consistent with applicable law.

The criteria used to determine our retention period is as follows:

Personal Information used for the ongoing relationship between you and PayPal is stored for the duration of the relationship plus a period of 10 years, unless we need to keep it longer, such as:

a legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under applicable bankruptcy laws and AML obligations

litigation, investigations, audit and compliance practices, or to protect against legal claims.

 7. How Do We Use Cookies and Tracking Technologies?

When you interact with our Services, open email we send you, or visit a third-party website for which we provide Services, we and our partners use cookies and other tracking technologies such as pixel tags, web beacons, and widgets (collectively, “Cookies”) to recognize you as a user, customize your online experiences and online content, including to serve you interest-based advertising, perform analytics; mitigate risk and prevent potential fraud, and promote trust and safety across our Services.

We use Cookies to collect your device information, internet activity information, and inferences as described above.

You can disable or decline some cookies for our Services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.

Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.

If you want to know more about how we use cookies, please review our Statement on Cookies and Tracking Technologies to learn more about our use of Cookies. To learn how to opt-out of this kind of tracking technology, visit About Ads.

 

8. Your Data Protection Rights

Your rights to access, correction, deletion, and restriction to use or share your information.

Under applicable data protection law, you have certain rights to how your Personal Information is collected, stored, used and shared.

We recognize the importance of your ability to control the use of your Personal Information and provide several ways for you to exercise your rights to access (right to know), correction, deletion (erasure), and to restrict certain information (right to opt out of sharing and right to limit use and disclosure of sensitive personal information).

We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights. If you are a California resident, learn more about how we have handled your Privacy Rights.

How do you exercise your rights?

If you, or an authorized agent, want to exercise any of your rights relating to your Personal Information, contact us or submit your request from your Account Settings. If you have an account, you can exercise your privacy rights by accessing “Data and Privacy” from Account Settings in the PayPal app.

Even if you do not have an account (for example, where you use Payment without a PayPal account), you can submit a request for access, correction, or deletion of your information for your Payment without a PayPal account by contacting us at the number provided in the Contact Us section.

If you or an authorized agent submit a request, we’ll first need to verify who you are before we can respond to your request. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will compare the information you submit against our internal business records to verify your identity. If we can’t verify your identity, we will not be able to fulfill your request. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.

Your right to request a copy of the Personal Information. If you want to make a request to know about the data we’ve collected about you in the past 12 months, you have choices:

Log in to your account and submit a request

Call or contact us and request that we provide you with the data we’ve collected.

Your right to correct your Personal Information:

Log in to your account and correct information you previously added. For example, you can edit your addresses in your settings

Call or contact us and request that we correct specific information

Your right to delete your Personal Information:

Log in to your account and delete information you previously added. For example, you can delete your profile picture and non-primary addresses in your settings

Call us or contact us and request that we delete specific information

Close your account

If you close your account or request that we delete Personal Information, we still need to keep some Personal Information as explained in How long does PayPal store your Personal Information section so we can:

Complete a transaction, provide goods or services you requested, or comply with our promises to you in the user agreement or other contract you have with us

Detect and prevent malicious, fraudulent, or illegal activity

Protect your (or another person’s) legal rights, including the right to free speech

Manage our internal business processes that are reasonably related to your expectations when using our Services

Comply with laws and other legal or governmental processes

California also offers a right to opt out of “Selling” and “Sharing” Personal Information. Global Privacy Control setting is a browser setting that notifies website owners of users' privacy preferences regarding selling or sharing their personal information. PayPal does not respond to these settings because we do not sell or share data. Some Personal Information collected, processed, or disclosed by a financial institution are subject to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice for more information about their rights under US federal law.

Understanding your choices

You can control how Personal Information is collected or disclosed, as well as how we communicate with you. Here are some of the ways you can customize your choices.

Choose how we collect Personal Information

You may choose to limit the Personal Information you provide when our apps or Services request it. To help make choices that are right for you, it’s important to understand that Personal Information helps us provide a richer, more personalized experience for you. Also, some Personal Information is required for our Services to function at all.

For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if shared your contacts. Another example is creating an account with us. If you choose not to provide information that is required for an account to function, like your name and email address, we will not be able to create an account for you.

Choose how connected accounts collect and use Personal Information

If you connect your account to a third-party service, you may be able to manage how your Personal Information is collected, used, and shared by them. Read the third parties’ privacy policies to see the choices they offer you.

You can control which third-party services you connect to your account and what Personal Information they can collect about you. For example, to manage the permissions, go to the Security settings in your PayPal account.

Choose how we communicate with you

Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional, and some are necessary for you to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even phone or paper mail depending on the situation and your preferences.

You can click the unsubscribe link in a PayPal marketing email, opt out of a text message by replying “STOP,” or turn off notifications on your device. You can also change your account’s notification settings or the notification preferences on your device.

You won’t be able to opt out of messages that are considered necessary for the Services, such as digital receipts and emails that alert you to changes in your account’s status. You may be able to decide how we send those messages, such as by email, phone, text message, or a notification on your mobile device.

 

9. How Do We Protect Your Personal Information?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Information against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Information we maintain about you is accurate and current. We are not responsible for protecting any Personal Information that we share with a third-party based on an account connection that you have authorized.

10. Can Children Use Our Services?

We do not knowingly collect information, including Personal Information, from children under the age of 13 or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Information from someone not allowed to use our Services, we will promptly delete it, unless we are legally obligated to retain such data.

Please contact us if you believe that we have mistakenly or unintentionally collected information from someone not allowed to use our Services.

We do not sell to third parties for money or share Personal Information of anyone under 16 years of age for cross context behavioral advertising.

11. Definitions

Device Information means data that can be automatically collected from any device used to access the Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Services; Geolocation Information; information about apps downloaded to your device; and biometric data.

Geolocation Information means information that identifies, with precise specificity, your location by using, for instance, longitude and latitude coordinates obtained through your GPS, or your device settings.

Location Information means information that identifies, with reasonable specificity, your approximate location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.

Partners and Merchants means our partners and the merchants, partners or businesses that our Users transact with for the purpose of obtaining goods or services.

Pay without a PayPal account means our Services may be accessed by individuals without a PayPal account or profile.

PayPal means PayPal, Inc. which includes Braintree, Xoom and Zettle.

PayPal Companies means companies or separate brands, affiliates or subsidiaries of PayPal, and who process Personal Information in accordance with their terms of service and privacy statements. PayPal Companies include Honey Science LLC, Chargehound LLC, Happy Returns, LLC, Hyperwallet, Simility, Swift Financial LLC, Bill Me Later, Inc., and Venmo.

Personal Information in this Privacy Statement means information about you, including your identity, finances and online behavior.

Sell under California law is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration.

Services means any PayPal branded or Unbranded Payment Services, Pay without a PayPal account, Xoom services, bill pay, Rewards, sending or receiving money, credit products and services, content, features, technologies, or functions, and all related websites, applications and services offered to you by PayPal. Your use of the Services includes use of our Sites.

Sharing under California law is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites.

Sites means the websites, mobile apps, official social media platforms, or other online properties through which PayPal offers the Services and which has posted or linked to this Privacy Statement.

Unbranded Payment Services means when you are interacting with and making payments to Partners and Merchants using our card processing services that do not carry the PayPal brand or when you use our Zettle services.

User is any person who uses the Services as a consumer for personal or household use. For the purposes of this Notice, “User” includes “you” and “your.”

 

12. Our Contact Information

If you have questions about this Privacy Statement or your Personal Information, contact us so we can help.

To talk about your PayPal account or Unbranded Payment Services:

Call PayPal Customer Service at 1-888-221-1161

or visit our Customer Service web portal

To talk about your Xoom account:

Call Xoom Customer Service at 1-877-815-1531

or visit our Help Center web portal

13. California Privacy Notice of Collection

Under the laws of California and certain other US states (i.e., Virginia), we are required to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information.

Under California law, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We do not sell or share your Personal Information, including any Sensitive Personal Information. We also do not sell or share and have no actual knowledge that we have sold or shared any Personal Information of anyone under 16 years of age.

Cookies are small text files placed on your computer to collect information about the pages you view and your activities on the site. They enable the site to recognize you by, for example, remembering your user name, offering a shopping cart, or keeping track of your preferences if you visit the site again. The cookie transmits this information back to the website's computer (or server) which generally is the only computer that can read it. You can set your Web browser to warn you about attempts to place cookies on your computer, or to limit the type of cookies you allow. See also more information on how to change cookies settings in popular desktop browsers. 

This site uses single and multi-session cookies to enhance the visitor experience. Use the link above to opt out. 

This site does not sell or share its email list for use by third parties. 

If you choose to opt out of some or all of our data collection, you may not be able to access all features of this website or our services. 

 

Keeping Your Information Secure

 

We store personal information with third parties that use industry standard practices for data security. 

 

Your Rights to Your Information

 

You own your personal information and have rights to it. For example, you have the rights to: 

- Withdraw your consent for us to market our products and services to you and otherwise use the personal information you have provided to us. Withdrawing consent is easy. Simply click “unsubscribe” in the footer of our emails, or email [email protected] to:. 

- Request a copy of the information we have about you; 

- Be forgotten (that is, have your data deleted and/or ask us to stop using your information for any purpose); 

- Correct inaccurate information we have about you (and that means we will notify other service providers we use, and who hold your personal information for us, of those changes as well);

- Object to direct marketing and profiling (for example, we will remove you from our email list and from any list we have uploaded for the purposes of creating custom or retargeted audiences). We also encourage you to disable data collection services on your browser; 

- Make complaints about the use of your data to regulatory authorities. 

We will comply with these requests within 30 days. 

Compliance

We make commercially reasonable efforts to work with data controllers (like our email provider) who guarantee compliance with privacy laws like the European Union’s General Data Protection Regulation. 

 

We store your personal information only for as long as it is needed to use it for the reasons you have consented to. 

 

Occasionally we will revise this policy and will use your contact information to notify you of these changes if they reduce your privacy rights in any way. 

 

Our data protection officer is Tracy Grant, [email protected].

 

Updated 2/19/2023..