Introduction

Effective May 1^st 2017

This Privacy Policy explains how OCTPOS Limited and its related entities (collectively, “OCTPOS”, “us”, “we” or “our”) collect, use, disclose, transfer, protect and store your information. It also explains your options around our use of your personal information and how you can access and update this information. If you don’t agree with the terms of this Privacy Policy that’s totally fine, but unfortunately you will not be able to access or use any of OCTPOS’s Services or applications.

Scope

OCTPOS is committed to protecting the privacy of the individuals on OCTPOS’s websites, mobile applications, products and services, (collectively, "Services") that include a link to this Privacy Policy. For the purposes of this Policy, “Subscriber”, as the term is used here, refers to an individual or an entity that registers to use our Services.

In this Privacy Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.

Subscribers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services - for instance if you’re an employee or customer of a retail store - then you will be directed to contact the Subscriber - the owner or manager of the retail store - for assistance with any requests or questions relating to your personal information.

We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with the use of our Services. If you are a Subscriber providing information (including personal information) about someone else, you must have the authority to act for them and to consent to the collection and use of their personal information as described in this Privacy Policy. If you are an individual who interacts with a Subscriber using our Services and would no longer like to be contacted by this Subscriber, please contact the Subscriber directly to arrange this.

By registering for or using Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

Your Information

In using our Services, you provide us with the following information which we store securely:

ACCOUNT AND PROFILE INFORMATION

· Contact information such as name, email address, mailing address, phone number and country

· Profile information such as usernames, profiles photos, and job roles

· Preferences information such as notification and marketing preferences

OPERATIONAL DATA

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

· Information about products and services the Subscriber sells, manufacture or buy (including inventory, pricing, sale, transaction, tax, and other data)

· Information about the Subscriber or Subscriber’s business (employee, customer, and contact data)

OTHER SUBMISSIONS

We ask for and collect personal information from you when you submit web forms on our websites or when you participate in any interactive features of our Services, participate in a survey, competition, promotion, activity or event, apply for a job, request customer support, download content, communicate with us via third party social media sites, or otherwise communicate with us.

What other information do we collect?

ACCESS LOGS

Like with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our websites and Services. This information includes Internet protocol (IP) addresses as well as browser type, URLs of referring/exit pages, operating system, language and location preferences, time/date stamp, search history, device identification numbers and system configuration information. Occasionally, we connect personal information to information gathered in our log files as is necessary to improve our Services. If we do this, we would treat the combined information in accordance with this Privacy Policy.

ANALYTICS INFORMATION

We collect analytics information when you use our Services to help us improve our products and services. We are always aiming to make OCTPOS a better experience for our customers, and your information really helps us to do this! This analytics information consists of the function and feature of the OCTPOS Service being used, and domain name, the username and IP address of the individual who is using the function or feature (which will include any personal information incorporated into the username), and other information needed to detail the operation of the function and the parts of the Services are being affected.

We use Google Analytics as one of our analytics providers. Refer to Google's Policies and Principles to find out more about the privacy policy of Google Analytics. To prevent analytics information from being sent to Google Analytics, use the Google Analytics Opt-out Browser Add-on.

ANALYTICS INFORMATION DERIVED FROM OPERATIONAL DATA

Analytics information also consists of data we collect as a result of running queries against Operational Data across our user base for the purposes of generating Usage Data. "Usage Data" is aggregated data about a category or group of features, services, or users that is not of itself personal information. It is also data about our Subscribers and their business.

We may incidentally come across sensitive or personal information when we compile Usage Data.

COOKIES, WEB BEACONS AND OTHER TRACKING TECHNOLOGIES

Cookies, web beacons and other technologies are used by OCTPOS and our third party partners (for example, our advertising and analytics partners) to collect information. A cookie is a small text file that is stored on your hard drive or in device memory for record keeping purposes. We use cookies to give you a better and more personalized use of the Services, to save you logging in every time and to count the number of visits. OCTPOS and our third party partners also collect information using web beacons. Web beacons are objects embedded in our Services or in emails that assist us to check that Content has been accessed for web analytics.

INFORMATION FROM THIRD PARTY SERVICES

We may also receive personal information from third parties such as social media, data enrichment or authentication services when, for example, you sign up to our Services, fill in forms on our Services through such services. Any access we may have to such information is governed by the authorization procedures of that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), locale, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Privacy Policy. Check your privacy settings on these third party services to learn and modify the information these services send to us. For example, you could authorize the third party service ecommerce to retrieve your products information from within our Services.

How OCTPOS uses your information

We are continually striving to improve OCTPOS. Being able to identify how our customers are using our product plays a big part in helping us to make our software better. We may use information about you for purposes such as:

· Enabling you to access and use our Services

· Displaying historical business transactions information

· Sending you marketing, advertising, educational content and promotional messages and other information that may be of interest to you, including information about us, our Services, or general promotions for business partner campaigns and services. You can unsubscribe or opt-out from receiving these communications described below under “How You Can Protect Your Information”

· To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners

· Measuring, customizing and improving the Services and developing new products

· Sending to you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you

· Investigating and preventing fraudulent transactions, unauthorized access to Services, and other illegal activities

· For other purposes about which we obtain your consent

Sharing & disclosure of your information

When you use the Services, we may share your information only as described below:

OCTPOS BLOGS, FORUMS AND WIKIS

Our websites may offer publicly accessible community services such as blogs, forums, and wikis. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. To request removal of your personal information from a OCTPOS community service, please contact us using the information listed below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to and why.

SERVICE PROVIDERS, BUSINESS PARTNERS AND OTHERS

We use and work with third party service providers to provide application development, hosting, website, infrastructure, maintenance, backup, payment processing, customer relationship management, marketing, accounting, human resources, business intelligence, customer support and other services for us. These service providers may have access to or process your information for the purpose of providing those services for us. Some of our pages use white-labeling techniques to serve content from our service providers while providing the look and feel of our site. Please note that you are providing your information to these third parties acting on behalf of OCTPOS. These third parties are located in countries which may be outside of your location.

THIRD PARTIES YOU AUTHORIZE

You can give third parties access to your information and your end users’ information on the Services. For example, you may wish to integrate OCTPOS with a third party appointment scheduling service that requires access to the email addresses you collect from your end users, in order for that appointment service to send reminder emails on your behalf and at your direction. Just be aware that such third party’s use of this information will be governed by the terms and privacy policies of the third party.

LINKS TO THIRD PARTY SITES

Our Services may contain links to other sites. We have no control over, and take no responsibility for, the privacy practices or content on other sites. You are responsible for checking the privacy policy of any such sites so that you can be informed of how they handle personal information.

SOCIAL MEDIA WIDGETS

Our Services may include social media features, such as the Facebook “Like” button and widgets, and the “Share” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

COMPLIANCE WITH LAWS AND PROTECTION OF RIGHTS

In certain situations, we may be required to use and disclose your information (including personal information) to a third party if we believe the disclosure is reasonably necessary:

· To comply with any applicable law, legal process (for example, subpoenas and warrants) or governmental request

· To enforce and administer our agreements, policies and terms of use

· To protect the property, rights, and safety of OCTPOS or its related organizations, our Subscribers or the public from harm or illegal activities

· For fraud prevention, risk assessment, investigation, customer support, product development or debugging purposes

· To protect the rights, property or personal safety of OCTPOS. its users or members of the public

· To establish or exercise our legal rights or defend ourselves against any third-party claims or allegations

BUSINESS TRANSFERS

If OCTPOS undertakes or is involved in any merger, acquisition, reorganization, sale of assets or bankruptcy or insolvency event, then we may transfer or share some or all of our assets, including your personal information. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

NON-IDENTIFYING OR AGGREGATED DATA

We may share aggregate or other non-personal information that does not directly identify you with third parties in order to improve our Services.

TRANSFERS WITH YOUR EXPRESS CONSENT

We will share your personal information with third parties when we have your consent to do so.

How you can protect your information

PERSONAL INFORMATION

You may access, change, or correct information about you by logging into your OCTPOS 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.

ACCOUNT INFORMATION AND DEACTIVATING YOUR ACCOUNT

We will retain your account information for as long as reasonably necessary to provide you Services, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you wish to deactivate your OCTPOS account, you may do so by logging into your OCTPOS account and click the deactivate or unsubscribe link/button or by emailing us using the contact details provided below.

OPTING OUT OF PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional communications from OCTPOS by using the unsubscribe link within each email or contacting us via our home page or sales team. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding Services (e.g., account verification, purchase and billing confirmations and reminders, technical and security notices).

YOUR CALIFORNIA PRIVACY RIGHTS

California law permits residents of California to request certain details about information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at the address listed below.

COOKIES AND ADVERTISING

You may opt out of receiving cookies by instructing your browser to stop accepting cookies or to prompt you before accepting a cookie from websites you visit, by changing your browser options.

You also can learn more about cookies by visiting www.allaboutcookies.org, which includes 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 Services, you may not be able to use all aspects of our Services.

Children’s use of the services

Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at the address listed below.

Data storage, transfer & security policies

OCTPOS hosts data with Amazon Web Services in the United States. If you are a non-US resident, this means that your personal information will be transferred to the US. The servers on which personal information is stored are kept in a controlled environment. We have adopted technical, administrative and physical procedures to collect, manage, maintain and store information in a manner designed to help protect your information from loss, misuse, unauthorized access, and alteration. Unfortunately, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any incidentally-collected personal information you choose to store in our Services are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

Where data is transferred over the Internet as part of the Services, the data may be encrypted using industry standard TLS (HTTPS).

Our global operations

To bring you Services, we operate globally. If you are from the European Union or other regions with laws governing data collection and use, you hereby consent to the transfer of your personal information to outside of the European Union (or from your country, as applicable), including to the United States. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

If you are from Australia, you hereby consent to the transfer of your personal information to outside of Australia and you acknowledge that as a result of your consent to such disclosure, clause 8.1 of the APPs does not apply. The Privacy Act 1988(Cth) requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act 1988(Cth). By providing your consent, under the Privacy Act 1988(Cth), we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

Updates to our privacy policy

OCTPOS reserves the right to change this Privacy Policy from time to time, and if we do we will post any changes on this page. OCTPOS will make every effort to communicate any significant changes to you directly. Your continued use of the Services will be deemed acceptance of any updated policy.

Do You Have Questions?

Thanks for reading! If you have any questions about this Privacy Policy or OCTPOS’s privacy practices, please contact us at privacy@octpos.com

Contact:

privacy@octpos.com