Privacy Policy

Last updated:

Introduction

Welcome to Squad Ltd.

Squad Ltd ("us", "we", or "our") operates https://paysquad.co and https://paysquad.co.nz (hereinafter referred to as "Service" or "Our Service").

Our Privacy Policy governs your visit to our service, and explains how we collect, safeguard and disclose information that results from your use of our service.

We use your data to provide and improve Service. By using our service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions ("Terms") govern all use of our service and together with the Privacy Policy constitutes your agreement with us ("agreement").

Definitions

SERVICE means the Squad platform, including the websites https://paysquad.co and https://paysquad.co.nz, our checkout and payment integrations, any Squad mobile or web application, and any related payment flows, operated by Squad Ltd.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • Phone number
  • First name and last name
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data
  • Identity verification data (KYC Data), such as date of birth, government-issued identification number, and verification documents, where required for AML/CFT compliance or fraud prevention

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at support@paysquad.co.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies: We use Session Cookies to operate our Service.
  • Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies: We use Security Cookies for security purposes.
  • Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Squad Ltd uses the collected data for various purposes:

  • to provide and maintain our Service;
  • to notify you about changes to our Service;
  • to allow you to participate in interactive features of our Service when you choose to do so;
  • to provide customer support;
  • to gather analysis or valuable information so that we can improve our Service;
  • to monitor the usage of our Service;
  • to detect, prevent and address technical issues;
  • to fulfill any other purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  • to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  • in any other way we may describe when you provide the information;
  • for any other purpose with your consent;
  • to verify your identity and comply with our Anti-Money Laundering and Countering Financing of Terrorism Act 2009 obligations;
  • to screen for sanctions, fraud and prohibited use; and
  • to detect, investigate and prevent fraudulent, unauthorised or illegal activity.

Where you consent to receive marketing from us through our opt-in feature (for example, as a Squad Leader or contributing Squad member), we collect and use that consent, and the associated Personal Data, in our own right and for our own purposes. This applies independently of, and survives the termination of, any agreement we have with the merchant through whose checkout you transacted.

Retention of Data

We retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy, including:

  • transaction and payment records, retained for 7 years to meet our financial reporting, tax and AML/CFT record-keeping obligations;
  • identity verification (KYC) records, retained for 7 years or as required by the Anti-Money Laundering and Countering Financing of Terrorism Act 2009;
  • fraud and dispute records, retained for 7 years to meet card scheme evidentiary requirements;
  • Usage Data, retained for a shorter period unless needed for security or functionality purposes, or we are legally required to retain it for longer; and
  • as otherwise required by law.

Where our legal, contractual or scheme obligations require us to keep information, we will retain that information notwithstanding a deletion request and will inform you accordingly.

Transfer of Data

Your Personal Data may be stored and processed outside New Zealand, including in Australia, the United States and other jurisdictions where we or our service providers operate.

Where we transfer your Personal Data outside New Zealand, we take reasonable steps to ensure the overseas recipient is either subject to the New Zealand Privacy Act 2020 in respect of that data, or is subject to privacy obligations comparable to that Act, or you have expressly authorised the transfer after being informed that the recipient may not be so bound, in each case as permitted under the Privacy Act 2020.

If you are located in the European Union or European Economic Area, we rely on the safeguards described in this section, and on Standard Contractual Clauses or an equivalent lawful transfer mechanism where required by the UK GDPR or EU GDPR.

Disclosure of Data

We may disclose personal information that we collect, or you provide:

Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Other cases. We may disclose your information also:

  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties we use to support our business;
  • to fulfill the purpose for which you provide it;
  • To merchants, where you have contributed to a purchase through their checkout via our Platform. We share only the information the merchant reasonably requires to process and fulfil that purchase, being your name, contact details, delivery address (where applicable), and confirmation of your payment contribution. For this purpose, the merchant acts as an independent controller of that information, and its use of your Personal Data is governed by its own privacy policy. Where you have indicated consent to a merchant contacting you for marketing purposes, we disclose your details to that merchant for that purpose only;
  • with your consent in any other cases;

Disclosure to Squad Holdings Group

By using our Service, you agree that we may share your Personal Data with other entities within the Squad Holdings group of companies, namely Squad Limited, for purposes consistent with this Privacy Policy, including providing and improving our Service, payment processing and settlement, customer support, fraud prevention, and group-wide reporting and administration.

Where settlement of a transaction requires it, we may share limited payment method details (such as card type, last four digits, and payment status) with these group entities. We do not share full card numbers, which are held only by our payment processors.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. - See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@paysquad.co.

In certain circumstances, you have the following data protection rights:

  • the right to access, update or to delete the information we have on you;
  • the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
  • the right to object. You have the right to object to our processing of your Personal Data;
  • the right of restriction. You have the right to request that we restrict the processing of your personal information;
  • the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  • the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. - See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

According to CalOPPA we agree to the following:

  • users can visit our site anonymously;
  • our Privacy Policy link includes the word "Privacy", and can easily be found on the page specified above on the home page of our website;
  • users will be notified of any privacy policy changes on our Privacy Policy Page;
  • users are able to change their personal information by emailing us at support@paysquad.co.

Your Data Protection Rights under the New Zealand Privacy Act 2020

If you are located in New Zealand, the Privacy Act 2020 grants you specific rights regarding your personal information. You have the right to:

  • ask for a copy of any personal information we hold about you;
  • request correction of your personal information (and if we do not agree to the correction, you may ask us to attach a statement of the correction sought to your information); and
  • be informed-whether we collect your information directly from you or indirectly from a third party-of the fact of collection, the purpose for which it is collected, the intended recipients, the name and address of the agency collecting and holding the information, whether providing it is mandatory or voluntary, and the consequences if it is not provided.

To exercise your rights, or to request details about the specific agencies collecting and holding your data, please contact us at support@paysquad.co.

If you are not satisfied with our response, you have the right to make a complaint to the Office of the Privacy Commissioner (www.privacy.org.nz).

Our Policy on "Do Not Track" Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

What personal information we have about you. If you make this request, we will return to you:

  • The categories of personal information we have collected about you.
  • The categories of sources from which we collect your personal information.
  • The business or commercial purpose for collecting or selling your personal information.
  • The categories of third parties with whom we share personal information.
  • The specific pieces of personal information we have collected about you.
  • A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
  • A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

To delete your personal information. If you make this request, we will delete or de-identify the personal information we hold about you, except to the extent we are required or permitted to retain it - including for tax, financial reporting, AML/CFT, fraud prevention or dispute-resolution purposes, or to comply with a legal obligation (see Retention of Data above

Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by one of the following means:

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website and app usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement."

Behavioral Remarketing

Squad Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Requesting Data Deletion

If you ask us to delete your personal information, we will delete or de-identify it except to the extent we are required or permitted to retain it - including for tax, financial reporting, AML/CFT, fraud prevention or dispute-resolution purposes, or to comply with a legal obligation. We will tell you if any of your information is being retained on this basis and why. If you delete your personal information, you may not be able to use functions that require it to operate.

Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe:

Their Privacy Policy can be viewed at: https://stripe.com/us/privacy

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service is not intended for use by anyone under the age of 18 ("Minors"), consistent with our age eligibility requirement under the Terms. We do not knowingly collect personal information from Minors. If you become aware that a Minor has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a Minor, we take steps to remove that information from our servers and, where applicable, to address the transaction under applicable laws.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us: