General

Privacy Policy for Users Who Apply or Sign Up for a Square Account [effective until 24 May 2018]

Last Updated: 28 March 2017

This Privacy Policy describes the information Squareup Europe Ltd., Squareup International 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.

Sections:

Policy for Users Who Apply or Sign Up for a Square Account (e.g., those who have or apply for a Square Register account)
Policy for Users Who Do Not Apply or Sign Up for a Square Account (e.g., visitors to our website, customers of Sellers who use our Services)
Security
International Data Transfer
Your Rights
Contact

By applying or signing up for a Square account, including through a computer or mobile device (‘device’), 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, including by email at the email address you provide. 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 and to contact us if you have any questions about these changes. Your continued use of our Services constitutes your acceptance of any amendment of this Privacy Policy.

Collection of Information

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 (including information about you) may be uploaded to or sent through our Services.

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

The type of information we collect may vary depending on the country from which you access our Services.

Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information from children under the age of 13.

Information You Provide

We collect information you provide when you apply or sign up for a Square account and when you provide information as part of our identity or account verification process. We collect information about you, including:

Identification information, such as your name, email address, postal address, phone number, photograph, birthdate, passport, driving license, full electoral register information or other government-issued identification number;
Financial information, including bank account and payment card numbers, identity verification and credit reference agency information;
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 sell (including inventory, pricing and other data);
Information you provide about you or your business (including appointment, staffing availability, employee, payroll and contact data); and
Information you provide to a Seller using our Services.

Some of the information we collect is collected to comply with applicable laws and regulations, including anti-money laundering, anti-terrorism and security laws. 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, request or record 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. Through our applications, we collect information about the location of your 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. 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. For more information and to learn how to block or delete cookies used in the Services, please see ‘Your Choices’ below.

Information We Collect from Other Sources

We also collect information about you from third parties, including third-party verification services (e.g. credit reference agencies, identity verification agencies, the electoral register, electricity industry data and corporate verification services), credit bureaus, mailing list providers and publicly available sources. In some circumstances, where lawful, this information may include your government-issued identification numbers. 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 in connection with the processing of any credit investigation, identity or account verification, fraud detection, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or 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 a financial relationship, including without limitation past, present, and future places of employment and personal reporting agencies. Where we engage credit reference agencies to undertake credit checks and reporting, such agencies will place a search footprint on your electronic file and your personal details will be accessed by third parties for the specific purpose of anti-money laundering, credit assessment, identity verification, debt collection, asset reunification, tracing and fraud prevention. Where we engage identity verification agencies, these agencies will access your personal details by using credit files to verify your name, date of birth, and address. Such identity verification is not the same as a credit check. A footprint will be left on your credit file that a search was carried out by the agency for identity verification purposes, which you can see if you check your credit file, but this record will not show up in a credit search and will not affect your ability to obtain credit. The verification agency may also separately retain a record of its search and may share the fact of that past search with other companies that use its services. This search record will show that an unnamed payment processor (or similar industry term) had requested an identity check. We may also carry out a full electoral register search.

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 webpages, 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 analyse 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. 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.

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. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices. To learn about how to manage cookies, please see “Your Choices” section below.

Use of Information

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

Processing or recording payment transactions;
Displaying historical transaction information;
Developing new products and Services;
Delivering the information and support you request, including technical notices, security alerts, and support and administrative messages; and
Sending you information we think you may find useful or which you have requested from us about our Services, provided that you have not objected to being contacted for these reasons.

We may use information about you to improve, personalise and facilitate your use of our Services. For 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 had or currently have with Square, and prior transactions you 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 analyse trends and usage in connection with our Services.

We may use information about you to send you news and information (provided you have not indicated otherwise) 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. You can tell us to not contact you with information about our other products and services at any time, either by contacting us, by following the unsubscribe link in our communications or by changing your notification settings by logging into your Square account. Please note that at all times, even where you choose not to receive promotional content from us, we may still message you about the Services for which you have signed up.

We may use information about you:

To protect our rights or property or the security or integrity of our Services;
To enforce the terms of our Seller Agreement or other applicable agreements or policies;
To verify your identity as required by anti-money laundering, anti-terrorism and security law (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.

We may and we may use third-party service providers to process and store your information in the United States, Japan and other countries. For more information, please see the ‘International Data Transfer’ section below.

We may share information about you as follows:

With our group companies, including our parent company, Square, Inc. and other affiliates, 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 in connection with the payment process;
With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services;
With other users of our Services with whom you interact through your own use of our Services. For example, we may share information when you make or accept a payment using 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, regulation, legal process or governmental request (e.g., from tax authorities), (ii) to enforce the terms of our Seller Agreement 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; or
With your consent.

In connection with the payment process, we engage various third parties. One such party is First Data Europe Limited (‘First Data’) who will also be a data controller of the data we collect from you. First Data processes your information solely for the purpose of facilitating payments which use our Services, including to internally monitor, evaluate and improve any aspect of the First Data services, to fulfil any reporting or compliance obligation to the extent required by applicable law or the card scheme rules and to internally measure trends. First Data may, in accordance with the provision of the First Data services, disclose your information to third parties and regulatory bodies, including First Data’s affiliated companies and applicable card schemes (e.g., Visa and MasterCard). First Data will retain all data in the strictest confidence and in a secure environment. To read more about First Data’s privacy processes, please see https://www.firstdata.com/en_gb/privacy.html. We also engage with card scheme providers (e.g., Visa and MasterCard) that enable payments to be made and may involve the transfer of your information between their subsidiaries, affiliates and employees (for example, from Visa Europe to Visa Inc., and similarly with MasterCard International Incorporated and Maestro International Inc.). Where it may be reasonably necessary to do so, such card scheme providers may disclose your information to other persons such as credit reference agencies, central banks and any other persons as required or permitted by local law and/or regulations.

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.

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. Square generally retains information about you only as long as reasonably necessary to provide you the Services. 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 Seller Agreement or other applicable agreements or policies or to take any other actions consistent with applicable law.

Location Information

In order to provide certain mobile applications, we may require location information, so if you do not consent to collection of this information, then you cannot use our corresponding Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications 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.

When you use our Services, we may collect IP address which will indicate your location to within an area, but not your specific location. This helps us provide you with the correct Service, to deliver content, advertising or other services that are dependent on your location (which may be shared with third parties if applicable, for example to deliver advertisements). This information may also be associated with your device to enable us to recognise your device when you return to our mobile applications.

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 device. 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 and/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 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.

As described above, we also use cookies to gather information about the areas of the Square website you access and your access and use of our applications or other content. This information is used to place interest-based advertisements on the website or application which it is believed will be relevant to you. This may mean you see advertisements for Square on other websites and applications that you visit. For more information about this type of interest-based advertising, including about how to turn this feature off, please visit http://www.youronlinechoices.com/uk/.

Type of Cookies	Description and further information
Essential Cookies	Essential cookies are cookies that enable you to navigate and use all the features in the Services provided by us. For example, without these, you would not be able to navigate between pages on the website
Functionality Cookies	These cookies enable us to remember you have used our Services before, preferences you may have indicated and information you have provided to us to give you a customised experience. For example, this would include ensuring the continuity of your registration process.
Performance and Analytical Cookies	This information is used to make sure our Services can cope with the volume of users, to help us correct errors in the Services and to measure use across our Services. These cookies help us understand if you have used our Services before so we can identify the number of unique users we receive. They also help us understand how long you spend using our Services and from where you have accessed the Services, so that we can improve the Services and learn about the most popular aspects of the Services. We use third parties, for example, Google Analytics, to analyse statistical information from users of the Site. We might be able to associate such information with other information which we collect from you once we receive it from a third party.
Retargeting or advertising Cookies	These cookies collect information about the pages you visit and also other information about other websites you visit. This information is only collected by reference to the cookie identifier that you are using. For more information visit, http://www.youronlinechoices.com/uk/.

Examples of our third-party service providers include:

Google: To understand more about Google Analytics and update your preferences in relation to Google’s analytics tools please see here https://support.google.com/analytics/answer/6004245?hl=en-GB and to opt out of Google Analytics please click here https://tools.google.com/dlpage/gaoptout.
Facebook: To understand more about Facebook advertising please see here https://www.facebook.com/about/ads.

Promotional Communications

You may opt out of receiving promotional messages from Square at the time that you provide your information or by changing your notification settings 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 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 and to contact us if you have any questions about these changes.

Collection of Information

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

The type of information we collect may vary depending on the country from which you access our Services.

Our website and Services are not targeted or directed at children under the age of 13 and do not knowingly collect or store any personal information from children under the age of 13.

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, such as your name, email address and postal address. 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. 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. For more information and to learn how to block or delete cookies used in the Services, please see ‘Your Choices’ below.

Information We Collect from Other Sources

We also 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 analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests and better understand your usage. 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.

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. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices. To learn about how to manage cookies, please see ‘Your Choices’ section below.

Use of Information

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

Processing or recording 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 send you news and information (where you have indicated you are willing to receive such messages) 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. Please note that at all times, even where you choose not to receive promotional content from us, we may still message in relation to our Services which you have interacted with.

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, Japan 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 and to send you promotional messages from Square and / or from Sellers you have visited (subject to our legal obligations and your communication preferences). Digital receipts may contain additional information, for example, you may be able to submit feedback to a Seller, share your experience on social media, view your purchase history or visit websites. 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. and other affiliates 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 in connection with the payment process;
With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services;
With other users of our Services with whom you interact through your own use of our Services. For example, we may share information about you when you make a payment or appointment using 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, regulation, legal process or governmental request (e.g., from 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.

In connection with the payment process, we engage various third parties. One such party is First Data Europe Limited (‘First Data’) who will also be a data controller of the data we collect from you. First Data processes your information solely for the purpose of facilitating payments which use our Services, including to internally monitor, evaluate and improve any aspect of the First Data services, to fulfil any reporting or compliance obligation to the extent required by applicable law or the card scheme rules and to internally measure trends. First Data may in accordance with the provision of services disclose your information to third parties and regulatory bodies for example, First Data’s affiliated companies and the card scheme providers (e.g., Visa and MasterCard). First Data will retain all data in the strictest confidence and in a secure environment. To read more about First Data’s privacy processes, please see https://www.firstdata.com/en_gb/privacy.html. We also engage with card scheme providers (e.g., Visa and MasterCard) that enable payments to be made and may involve the transfer of your information between their subsidiaries, affiliates and employees (for example, from Visa Europe to Visa Inc. and similarly with MasterCard International Incorporated and Maestro International Inc.). Where it may be reasonably necessary to do so, such card scheme providers may disclose your information to other persons such as credit reference agencies, central banks and any other persons as required or permitted by local law and/or regulations.

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

We may retain 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 Seller Agreement or other applicable agreements or policies or to take any other actions consistent with applicable law. 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.

Location Information

When you use our Services, we may collect IP address which will indicate your location to within an area but not your specific location. This is in order to provide you with the correct Service, to deliver content, advertising or other services that are dependent on your location (which may be shared with third parties if applicable, for example to deliver advertisements).

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 and/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.

As described above, we also use cookies to gather information about the areas of the Square website you access and your access and use of our applications or other content. This information is used to place interest-based advertisements on the website or application which it is believed will be relevant to you. This may mean you see advertisements for Square on other websites and applications that you visit and that you see advertisements for companies you have recently browsed on the Square website or applications. For more information about this type of interest based advertising, including about how to turn this feature off, please visit http://www.youronlinechoices.com/uk/.

Type of Cookies	Description and further information
Essential Cookies	Essential cookies are cookies that enable you to navigate and use all the features in the Services provided by us. For example, without these, you would not be able to navigate between pages on the website.
Functionality Cookies	These cookies enable us to remember you have used our Services before, preferences you may have indicated and information you have provided to us to give you a customised experience. For example, this would include ensuring the continuity of your registration process.
Performance and Analytical Cookies	This information is used to make sure our Services can cope with the volume of users, to help us correct errors in the Services and to measure use across our Services. These cookies help us understand if you have used our Services before so we can identify the number of unique users we receive. They also help us understand how long you spend using our Services and from where you have accessed the Services, so that we can improve the Services and learn about the most popular aspects of the Services.
Retargeting or advertising Cookies	We use third parties, for example, Google Analytics, to analyse statistical information from users of the Site. We might be able to associate such information with other information which we collect from you once we receive it from a third party. These cookies collect information about the pages you visit and also other information about other websites you visit. This information is only collected by reference to the cookie identifier that you are using. For more information visit, http://www.youronlinechoices.com/uk/.

Examples of our third party service providers include:

Google: To understand more about Google Analytics and update your preferences in relation to Google’s analytics tools please see here https://support.google.com/analytics/answer/6004245?hl=en-GB and to opt out of Google Analytics please click here https://tools.google.com/dlpage/gaoptout.
Facebook: To understand more about Facebook advertising please see here https://www.facebook.com/about/ads.

Promotional Communications

You may choose to receive promotional messages from Square when you first interact with our Services or by making a request to us using the contact details below. You may opt out of receiving promotional messages from Square by following the instructions in those messages. Even if you do not choose to receive promotional messages, 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. We restrict access to personal information to those Square employees, contractors and agents who need to know that information in order to transmit, store or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with this Policy and other appropriate confidentiality and security measures.

Nevertheless, Square cannot guarantee that unauthorised third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

For more information about our security practices, please visit security.

International Data Transfers

Square participates in international business and is headquartered in the U.S. From time to time, to provide you with Square services and allow you to interact with the Square brand and Services, we may transfer your information globally. We may process and store your information in the United States, Japan and other countries and we may use third-party service providers who also process, store and transfer your information globally, for example, First Data, Visa and MasterCard.

Square is committed to protecting your privacy rights. Further, where we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected under applicable data protection legislation.

By interacting with our Services, you agree to this storing, processing and/or transfer described above.

Your Rights

If you use the Services in Europe you have the legal right under European data protection law to a copy of all the personal information that Square holds about you. If you request this information from us we will provide it to you for a fee not exceeding the amount permitted by law. As mentioned above, you can also ask us to correct any errors in this information. Also as referred above, you have a right to prevent the use of your personal information for direct marketing purposes.

Contact

Please contact our Privacy Department with any questions or concerns regarding this Privacy Policy by emailing privacyuk@squareup.com or by writing to us at:

Squareup Europe Ltd. 6th Floor One London Wall London EC2Y 5EB United Kingdom

Squareup International Ltd. 70 Sir John Rogerson’s Quay Dublin 2 Ireland

If you have any questions or concerns regarding our policy or if you believe our policy or applicable laws relating to the protection of your personal information have not been respected, you may 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 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.

Privacy Policy for Users Who Apply or Sign Up for a Square Account [effective until 24 May 2018]