Privacy Notice for Square Sellers' Employees
Effective Date: June 23, 2020
Last updated: June 23, 2020
When this Privacy Notice mentions “Square,” “we,” “us,” or “our,” it refers to the Square company you contracted with per the Terms of Service. Your contracting entity will generally be determined based on your Country of Residence. Your “Country of Residence” is the jurisdiction associated with your Square Team account as determined by either your express selection or by Square’s assessment of your residence using various data attributes associated with your Square account.
- If your Country of Residence is the United States, your Terms of Service are with Square, Inc., 1455 Market Street, Suite 600, San Francisco, CA 94103, United States.
- If your Country of Residence is Canada, your Terms of Service are with Square Technologies, Inc.
- If your Country of Residence is Japan, your Terms of Service are with Square KK.
- If your Country of Residence is Australia, your Terms of Service are with Square AU PTY, Ltd.
- If your Country of Residence is the United Kingdom, Ireland or anywhere except the United States, Canada, Japan, or Australia, your Terms of Service are with Squareup International Ltd.
This Privacy Notice explains how information about you is collected, used, disclosed, transferred, retained or otherwise processed by Square and its affiliates (collectively, “Square,” “we,” “us” or “our”) when you or your Employer creates a Square Payroll or Square Team account (collectively, the “Services”) through Square’s website or applications (collectively, the “Site”). We receive personal data from our customers (aka your “Employer”, a Square Seller) about their current, prospective and former employees as well as employee dependents and family members, as needed to for employee management and to provide benefits.
This Privacy Notice explains our practices with regard to the personal data we process when providing the Services to your Employer. Please read this Privacy Notice carefully.
This Privacy Notice does NOT describe the purposes for which your Employer uses your information which will be subject to the Employer’s privacy practices and notices. To the extent you have any questions or wish to exercise any of your rights in relation to your information which we process on behalf of your Employer please contact your Employer directly.
Our Privacy Notice explains:
- Information we collect about you
- How we use your information
- How we share your information
- How long we keep your information
- Your rights
- International Data Transfers
- Changes to this Privacy Notice
INFORMATION WE COLLECT ABOUT YOU
In connection with your use of the Site and the Services, we collect and store certain information about you. Some of this information can be used on its own or in combination with other information to identify you individually. We collect this and other information as described below.
Information You and Your Employer Provide
We collect the following information when your Employer and/or you sign up to use the Services, provide information when using the Services and in order to provide the Services to you and your employer.
- Employment information, such as your employee identification number, job title, salary information, hire date, paystub, work schedule, timecard information, and benefits enrollment information.
- Financial information, such as bank account information, and payment card numbers;
- Identification Information, such as:
- Name, date of birth, email address, postal address, signature, and phone number;
- Passport number, driver’s license number, government-issued identification number, or other unique reference number;
- Tax information, such as withholding allowances and tax filing status.
Information We Collect From Your Use of the Services
- Device information: Information about your device, including your hardware model, operating system and version, device name, unique device identifier, country and language settings, mobile network information, and information about the device’s interaction with our Services;
- Use information: Subject to your cookie consent settings, Internet or other electronic network activity information, which includes information about how you use and interact with our Services, including your access time, “log-in” and “log-out” information, browser type and language, the domain name of your internet service provider, other attributes about your browser, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services;
- Online identifiers: Information you use to log in to your account) including, Internet Protocol (“IP”) address, and unique personal identifiers (including device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; unique alias, and other identifiers);
Information We Collect From Other Sources
- Compliance and Fraud. Information about you from third parties for any identity or account verification process, fraud detection process, or as may otherwise be required by applicable law.
We may collect real-time information about the location of your device on behalf of your Employer for time and attendance purposes.
If you do not want us to collect this information, you may decline our request to share your location or disable location services in your mobile device’s settings. However, opting out of the collection of location information will cause certain location-based features to be disabled and the online and/or mobile application may not function fully on your device.
Where your Employer has a lawful basis to do so, we may determine your approximate clock-in location based on an IP address. You may also opt out of this method via the application’s settings, however, opting out will interfere with the application’s functionality.
HOW WE USE YOUR INFORMATION
Square is a service provider acting on behalf of your Employer. We collect and process your personal data as instructed or permitted by your Employer, and will share your personal data with your Employer. In that context, we use information that we collect about you to provide the Services to your Employer and more particularly for the following purposes:
- to administer the Site, manage accounts and provide the Services;
- to monitor, analyze, improve and develop the Site and the Services, and to create and test new Services features;
- to provide a more customized experience on the Site and the Services;
- to validate user information provided to us for fraud and risk detection purposes;
- to determine eligibility for the Services;
- to prevent, identify and address fraudulent or other illegal activity and security issues;
- to (i) solicit feedback, (ii) respond to your or your Employers’ comments, requests or inquiries, (iii) provide customer service and support, or (iv) otherwise contact you in connection with the Site or the Services;
- to generate anonymized, aggregated data containing only de-identified, non-personal information that we may use to publish reports;
- to (i) comply with laws, rules and regulations, including any disclosure or reporting obligations, (ii) resolve disputes with users or third parties, (iii) respond to claims and legal process (including but not limited to subpoenas and court orders) as we deem necessary or appropriate, (iv) protect our property rights, (v) protect the safety of the public or any person, and (vi) prevent or stop any activity that we consider to be (or to pose a risk of being) illegal, unethical or legally actionable; and
- for any other purpose for which you or your Employer expressly authorize us to use your information.
HOW WE SHARE YOUR INFORMATION
We share information about you as follows:
With Your Employer
- With your Employer in using our Services with whom you interact through your own use of our Services. This is necessary to provide our Services to your Employer and in accordance with our Terms of Service. For example, we share information when you interact with a Square Team account.
With our Affiliates
- With our group companies, including our parent company, Square, Inc., and other affiliates, for the purposes outlined above. This is necessary to provide our Services to your Employer.
With Service Providers
- With our group companies, including our parent company, Square, Inc., and other affiliates and third parties to provide, maintain, and improve our Services in accordance with the Terms of Service with your Employer.
- With service providers who access information about you to perform services on our behalf (e.g. identity verification, fee collection services and fraud prevention – including CIFAS, as well as financial institutions, payment networks, payment card associations, credit bureaus, partners providing services on Square’s behalf, and other entities (including First Data) in connection with Services.
- With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services.]
- We may share your information with certain other third parties with whom you or your Employer expressly authorise us to share your information.
Business Transfers and Corporate Changes
We reserve the right to disclose and transfer all information related to the Services, including personal information:
- To a subsequent owner, co-owner, or operator of one or more of the Services in the event of a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets; financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change (including, without limitation, during the negotiation or due diligence process).
Safety and Compliance with Law
If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities, law enforcement agencies, etc.); (ii) to enforce or comply with our General Terms or other applicable agreements or policies; (iii) to protect our or our customers’ 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, fraud or potentially prohibited or illegal activities.
Aggregated and Anonymised Information
- We also may share (within our group of companies or with third parties) aggregated and anonymised information that does not specifically identify you or any individual user of our Services.
HOW LONG WE KEEP YOUR INFORMATION
We generally keep your information for the period of time instructed by your Employer on the basis of your Employer’s privacy practices. However, even after you deactivate your account, we can retain copies of information about you and the Services for a period of time as we believe is reasonably necessary to comply with applicable law, applicable statute of limitations, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with the Services, to assist with investigations, to enforce applicable agreements or policies, or to take any other actions consistent with applicable law.
COOKIES AND OTHER SIMILAR TECHNOLOGIES
We use various technologies to collect information when you access or use our Services, including placing a piece of data, commonly referred to as a “cookie,” or similar technology on your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your 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 below.
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.
- Remember that you have visited us or used the Services before. This allows us to identify the number of unique visitors we receive, so that we can provide enough capacity to accommodate all of our users.
- Customise elements of the promotional layout and/or content of our Services.
- Collect data about the way you interact with our Services (e.g., when you use certain features or upload attachments).
- 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.
We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the Third-Party Analytics section below), which use automated technologies to help us evaluate how customers use our websites.
Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without certain necessary or functionality cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device.
You also can learn more about cookies by visiting http://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.
THIRD-PARTY ANALYTICS SERVICES
We may use third-party service providers to analyze and track usage of our Services, determine the popularity of certain content, and better understand how you use our Services ultimately to improve the Services for your Employer. We may disclose your device and use 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 webpages and, links clicked with these service providers for these purposes. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.
Examples of our third-party service providers to help deliver our Services or to connect to our Services include:
- Google Analytics: We use Google Analytics to understand how our Services perform and how you use them. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout.
- Facebook: We use Facebook to advertise and market our services, and to enable our customers to market their services. To learn more about how Facebook uses your data please visit https://en-gb.facebook.com/help/325807937506242 or log on to you Facebook account and access your settings. To understand more about Facebook advertising please see https://www.facebook.com/about/ads.
- BugSnag and Crashlytics: We use Bugsnag and Crashlytics monitoring apps to monitor errors that impact customers and report diagnostic data to us so we can improve our Service and help to make sure they work when you need to use them. Please visit https://docs.bugsnag.com/legal/privacy-policy/ to learn more about how Bugsnag processes your data and https://fabric.io/terms to learn more about how Crashlytics processes your data.
You have certain rights in relation to your information (right to access, amend, erase, or restrict access to your information, object to processing, or withdraw your consent, in certain circumstances). To exercise any of these rights, please contact your Employer’s human resources department.
Location sharing. You can access certain controls directly within the application or website settings such as turning off location sharing.
Deactivating Your Account
If you wish to deactivate your account, you can do so by logging into your account or by emailing us using the contact details provided below.
RIGHTS OF CALIFORNIA RESIDENTS
If you live in California, California law gives you the right to ask if we disclose your personal information to third parties for their direct marketing purposes (we do not disclose your personal information for others’ direct marketing purposes). It also gives you the right to ask if we sell your personal information to third parties (we do not sell your personal information and have not done so in the past), and if we did (which we don’t), you’d have the right to opt out of such sales.
INTERNATIONAL DATA TRANSFERS
We may use third-party service providers to process and store your information in the United States, Canada, Japan, the European Union, and other countries.
For EU residents:
Square operates internationally and many of our systems are based in the United States which has different data protection standards to the European Union. When we transfer your personal data to our affiliates outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. For a list of the countries in which we operate, please see https://squareup.com/gb/about.
We also use standard contractual clauses when we transfer your personal data to third parties outside the EEA or we adopt other means to ensure that adequate safeguards are applied to your personal data, such as a relevant third party’s Privacy Shield certification or binding corporate rules (approved by EU data protection authorities and put in place to protect your personal data).
CHANGES TO THIS PRIVACY NOTICE
We change this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. If you disagree with these changes, you may cancel your account at any time.
As we process your information as a service provider on behalf of your Employer, we suggest you first contract your Employer with any questions on the use of your information.
Otherwise, you may contact our privacy team at firstname.lastname@example.org.
In the EU, please contact:
FAO: Data Protection Officer.
Squareup International Ltd. Fumbally Square Fumbally Lane Dublin 8, Ireland
In Australia, please contact:
Phone: 1800 760 137
In Canada, please contact:
Square, Inc. 1455 Market Street, Suite 600 San Francisco, CA 94103, U.S.A.
In Japan, please contact:
Square, K.K. c/o Square, Inc.
1455 Market Street San Francisco, CA 94103, USA
If you have any questions or concerns regarding our notice or if you believe our notice or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with our Privacy Department listed above and we will respond to let you know who will be handling your matter and when you can expect a further response. We can 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 your request or concern is not satisfactorily resolved by us, you can approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).