General

Privacy Notice for Users Who Apply or Sign Up for a Square Account or Other Services

Last updated: 7 November 2018

This Privacy Policy describes the information Square, Inc., Square AU Pty Ltd and our affiliates (collectively, ‘Square’, ‘we’ and ‘us) collect when a person or business (‘you’, ‘your’):

applies or signs up for a Square account;
accesses or uses in any manner any Square application, product, service, feature, technology, content or website (collectively, ‘Services’); or
otherwise contacts or interacts with us.

By applying or signing up for a Square account, including through mobile devices, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you) and for all other purposes permitted under applicable personal information privacy statutes, credit bureau reporting rules, anti-spam legislation and consumer protection laws.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the ‘Last Updated’ date above. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information. Where these changes would cause material detriment to you, you may of course cancel your account at any time. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you. Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Collection of Information

Without information about you, we may not be able to provide you with the Services or the support you request.

Our Services can be used by a broad range of industries in connection with their products, services, activities and administrative functions, whether they are involved in government, retail, health, politics, human resources, technology or anything else. Accordingly, a broad range of information may be uploaded to or sent through our Services.

Information You Provide.

We collect information you provide when you apply or sign up for a Square account and when you provide information about yourself and individuals associated with your business as part of our identity verification process. We may collect, without limitation, the following information about you and individuals associated with your business:

Identification information, such as your name, email address, mailing address, phone number, photograph, birthdate and passport, driver’s licence, Medicare or other government-issued identification number];
Financial information, including bank account and payment card numbers;
Tax information, including withholding allowances and tax filing status; and
Other historical, contact and demographic information.

We also collect information you upload to or send through our Services, including:

Information about products and services you may sell (including inventory, pricing and other data);
Information you may provide about you or your business (including appointment, staffing, employee, payroll and third party contact data); and
Information you may provide to a Seller using our Services (including hours worked and other timecard data).

Some of the information we collect is collected pursuant to applicable laws and regulations, including anti-money laundering laws (e.g., the Anti-Money Laundering and Counter-Terrorism Financing Act).

We collect information you provide when you participate in contests or promotions offered by Square or our partners, respond to our surveys or otherwise communicate with us.

Information We Collect from Your Use of our Services.

We collect information about you when you use our Services, including the following:

Transaction Information. When you use our Services to make, accept or request payments, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment amounts, billing and shipping information and the devices and payment methods used to complete the transactions.
Location Information. When one of our applications is open on your mobile device, we periodically collect information about the location of the device. For more information and to learn how to disable collection of location information, please see ‘Your Choices’ below.
Device Information. We collect specific information about your device when you access our Services, including your hardware model, operating system and version, unique device identifier, mobile network information and information about the device’s interaction with our Services. We may also identify other software running on the device for anti-fraud and malware-prevention purposes (but will not collect any content from such software).
Use Information. We collect information about how you use our Services, including your access time, browser type and language and Internet Protocol (‘IP’) address.
Information Collected by Cookies and Web Beacons. We use various technologies to collect information when you use our Services, including sending cookies to your computer or mobile device and using web beacons. Cookies are small data files that are stored on your hard drive or in device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings and help evaluate and compile aggregated statistics about user activity. For more information and to learn how to block or delete cookies used in the Services, please see ‘Your Choices’ below. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Information We Collect from Other Sources.

As authorised under the Australian Anti-Money Laundering and Counter-Terrorism Financing Act, we also may collect information about you and individuals associated with your business from third parties, including third-party verification services (e.g., the government Document Verification Service in Australia), credit bureaus, mailing list providers and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification number. By applying or signing up for a Square account, you authorise and consent to our obtaining from and disclosing to, third parties, from time to time, any information about you and individuals associated with your business as necessary in connection with the processing of any credit investigation, identity verification, fraud detection or collection procedure or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of credit-related information with any credit reporting agency or credit bureau, where lawful and any person or corporation with whom you have had, currently have or may have financial relations, including without limitation past, present and future places of employment and personal reporting agencies.

Third-Party Advertising and Analytics

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on web pages, links clicked and conversion information (e.g., transactions entered into). This information may be used by Square and third-party service providers on behalf of Square to analyze and track usage of our Services, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand how you use our Services. We do not permit any third-party service providers to collect information through our Services for their own purposes, and all third-party service providers that we do engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third parties’ privacy policies. We encourage you to check the privacy policies of these third parties to learn more about their privacy practices.

Use of Information

We may use information about you to provide, maintain and improve our Services, such as:

Processing payment transactions;
Displaying historical transaction or appointment information;
Developing new products and Services; and
Delivering the information and support you request, including technical notices, security alerts and support and administrative messages.

We may use information about you to improve, personalise and facilitate your use of our Services. To take just one example, when you sign up for a Square account, we may associate certain information with your new account, such as information about other accounts you have had or currently have with Square, and prior transactions you have made using our Services. We also may use information about you to measure, customise and enhance our Services, including the design, content and functionality of our applications and websites, or to track and analyze trends and usage in connection with our Services.

We may use information about you to send news and information, or to conduct surveys and collect feedback, about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives and rewards offered by us and select partners, based on your communication preferences and applicable law. We also may contact you to resolve disputes, collect fees and provide assistance for problems with our Services or your Square account.

We may use information about you:

To protect our rights or property, or the security or integrity of our Services;
To enforce the our Terms of Service or other applicable agreements or policies;
To verify your identity as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (e.g., some of the government-issued identification numbers we collect are used for this purpose);
To investigate, detect and prevent fraud, security breaches and other potentially prohibited or illegal activities;
To comply with any applicable law, regulation, legal process or governmental request;
For any other purpose disclosed to you in connection with our Services.

If you so choose, we may verify your identity by disclosing your name, residential address and date of birth to a credit reporting body. The credit reporting body will match this information against your credit information file and will provide us with an assessment of the matching process. We use this assessment only for the purpose of verifying your identity in compliance with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. Alternatively, you may choose not to have your identity verified against your credit information file. In that case, the credit reporting body will access other government sources to verify your identity, although your likelihood of successful identity verification may decrease as a result.

We may and we may use third-party service providers to, process and store your information in the United States, Japan and other countries.

We may share information about you as follows:

With our group companies, including our parent company, Square, Inc., for the purposes outlined above;
With third parties to provide, maintain and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations and other entities that are part of the payment process;
With users of our Services who have signed up for Square accounts. For example, we may share information when you make or accept a payment using our Services;
With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services;
In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business;
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law (e.g., transaction reporting under the Tax and Superannuation Laws Amendment (2015 Measures No.5) Bill 2015), regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce our Terms of Service or other applicable agreements or policies, (iii) to protect our rights or property, or the security or integrity of our Services, or (iv) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities;
With your consent; or
With Cuscal Limited, an Authorised Deposit-Taking Institution (ADI) supervised by the Australian Prudential Regulation Authority (APRA). Cuscal supports our provision of the Services through its banking and payments services and may not be able to provide its services without information about you. Cuscal’s privacy policy is available via www.cuscal.com.au/privacy-policy and sets out details about Cuscal’s collection, use and disclosure of information about you, as well as information about your rights to access your personal information.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

Your Choices

Personal Information

You may access, change or correct information about you by logging into your Square account at any time or by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information. We will provide you with our reasons if we are unable to grant any such request for access to or change or correction of your information.

Deactivating Your Account

If you wish to deactivate your Square account, you may do so by logging into your Square account or by emailing us using the contact details provided below. However, even after you deactivate your Square account, we may retain archived copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.

Location Information

When you first launch any of our mobile applications, you will be asked to consent to the application’s collection of location information. We currently require this location information in order to provide our mobile applications, so if you do not consent to collection of this information, then you cannot use our corresponding Services. If you initially consent to our collection of location information through a mobile application, you can subsequently stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, our mobile application will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all Square mobile applications from your device.

Cookies

We try to make your experience with Square simple and meaningful. When you access or use the Services, our web server may send a cookie to your computer or mobile device (as the case may be). Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We may use cookies to:

Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.
Customise elements of the promotional layout any/or content of our website or application.
Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set. You also can learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

Promotional Communications

You may opt out of receiving promotional messages from Square by following the instructions in those messages, or by changing your notification setting by logging into your Square account. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

By using our Services, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation and consumer protection laws.

This Privacy Policy applies to information we collect if you make a payment, request a digital receipt, schedule an appointment or otherwise interact with our Services, even if you have not applied for a Square account or downloaded one of our applications. However, this Privacy Policy does not describe the practices of other users of our Services, including Sellers, that may collect information from you when you interact with them through our Services, and we encourage you to ask them about their privacy practices before providing any information to them.

Amendment

We may amend this Privacy Policy from time to time by posting a revised version and updating the ‘Last Updated’ date above. The revised version will be effective at the time we post it. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you.

Collection of Information

Without information about you, we may not be able to provide you with the Services or the digital receipts described below.

Information You Provide.

We collect information you upload or send to or through our Services, including information you provide when you request delivery of a digital receipt or schedule an appointment. We also collect information you provide when you participate in contests or promotions offered by Square or our partners, respond to our surveys or otherwise communicate with us.

Information We Collect from Your Use of our Services.

We collect information about you when you use our Services, including the following:

Transaction Information. When you use our Services to make payments or to request delivery of digital receipts, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment amounts and the devices and payment methods used to complete the transactions.
Use Information. We collect information about how you use our Services, including your access time, browser type and language and Internet Protocol (‘IP’) address.
Information Collected by Cookies and Web Beacons. We use various technologies to collect information when you use our Services, including sending cookies to your computer or mobile device and using web beacons. Cookies are small data files that are stored on your hard drive or in device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. For more information and to learn how to block or delete cookies used in the Services, please see ‘Your Choices’ below. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Information We Collect from Other Sources.

We also may collect information about you from third parties, including mailing list providers and publicly available sources. By using our Services, you authorise and consent to our obtaining from, and disclosing to, third parties, from time to time, any information about you as necessary in connection with the processing of any fraud detection procedure, or as may otherwise be required by applicable law.

Third-Party Advertising and Analytics

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with or applications on your device, the browsers you use to access our Services, pages viewed, time spent on pages, links clicked and conversion information (e.g., transactions entered into). This information may be used by Square and third-party services providers on behalf of Square to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your usage. We do not permit any third-party service providers to collect information through our Services for their own purposes, and all third-party service providers that we do engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

Use of Information

We may use information about you to provide, maintain and improve our Services, such as:

Processing payment transactions;
Displaying historical transaction or appointment information to our Sellers; and
Delivering the information and support you request, including digital receipts and scheduling information.

We may use information about you:

To protect our rights or property, or the security or integrity of our Services;
To investigate, detect and prevent fraud, security breaches, and other potentially prohibited or illegal activities;
To comply with any applicable law, regulation, legal process or governmental request;
For any other purpose disclosed to you in connection with our Services.

We may, and we may use third-party service providers to, process and store your information in the United States and other countries.

Digital Receipts

If you choose to receive receipts via email or text message, we store the email address or phone number you provide. We use your email address or phone number to send you a receipt for your purchase, to send you promotional messages from Sellers you have visited (subject to our legal obligations and your communication preferences) and to automatically send you digital receipts for future purchases you make from other Sellers. Digital receipts may contain additional messages, offers, or links that may be of interest to you. For example, you may be able to submit feedback to a Seller, share your experience on social media, view your purchase history, join programs, visit websites or take advantage of promotions. When you submit or share information through a receipt (such as submitting feedback), we may share that information with Sellers and you may receive responses. As mentioned above, this policy does not describe the practices of Sellers that may receive or collect information from you. We encourage you to ask them about their privacy practices before providing any information to them. If at any time you wish to opt out of receiving automatic digital receipts or change your preferences, you may do so by following the instructions in the ‘Your Choices’ section below.

We may share information about you as follows:

With our group companies, including our parent company, Square, Inc., for the purposes outlined above;
With third parties to provide, maintain and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations and other entities that are part of the payment process;
With users of our Services who have signed up for Square accounts. For example, we may share information about you when you make a payment or appointment using our Services;
With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services;
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., with tax authorities), (ii) to protect our rights or property, or the security or integrity of our Services, or (iii) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities; or
With your consent.

For customers of our Australian Sellers, we may share information about you with Cuscal Limited, an Authorised Deposit-Taking Institution (ADI) supervised by the Australian Prudential Regulation Authority (APRA). Cuscal supports our provision of the Services through its banking and payments services and may not be able to provide its services without information about you. Cuscal’s privacy policy is available via www.cuscal.com.au/privacy-policy and sets out details about Cuscal’s collection, use and disclosure of information about you, as well as information about your rights to access your personal information.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

Your Choices

Personal Information

You may access, change or correct information about you by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information. We will provide you with our reasons if we are unable to grant any such request for access to or change or correction of your information.

Cookies

We may use cookies to:

Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.
Customise elements of the promotional layout any/or content of our website or application.
Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Promotional Communications

You may opt out of receiving promotional messages by following the instructions in those messages or by making a request to us using the contact details below. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts you request.

Security

We take reasonable measures, including administrative, technical and physical safeguards, to protect your information from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction. We hold information about you at our own premises and with the assistance of third-party service providers.

Contact

Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy.

privacy-au@squareup.com
Phone: 1800 760 137

If you raise any concerns, we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

If you are dissatisfied with the results of our investigation or any resulting corrective measures, you may be entitled to make a written submission to the Office of the Australian Information Commissioner, whose contact details are as follows:

Office of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Address: GPO Box 5218 Sydney NSW 2001