1.Personal Data Processed and Sources of Data
We collect two types of information from Users: User Data and Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data may also be considered to be Personal Data under applicable laws and we will treat the combined data as Personal Data if required by applicable laws.
We may collect and process, for example, the following User Data from Users: (i) name and contact details; (ii) e-mail address; (iii) phone number; (iv) invoicing and billing information; (v) transaction and other payment data; and (vi) other Personal Data Users provide themselves. The specific kind of User Data collected may depend on the Services used by the User. Some of the User Data is received directly from Users at the point of opening an account, onboarding, or otherwise at the beginning of and during the customer relationship, and the rest is based on the data they provide to us that is processed.
Technical Data we gather in connection with the use of our Services may include, for example: (i) User's IP address; (ii) browser type and version; (iii) preferred language; (iv) geographic location using IP address or the GPS, wireless, or Bluetooth technology on your device; (v) operating system and computer platform; (vi) the full Uniform Resource Locator (URL) clickstream to, through, and from our Services, including date and time; (vii) products or services a User viewed or searched for while using our Services; (viii) areas of our Services a User has visited; and (ix) historical data regarding the use of our Services.
1.1Web analytics services
Our Services use several web analytics services to compile Technical Data and reports on visitor usage and to help us improve our Services.
1.2Cookies
We use various technologies to collect and store Technical Data and other information when Users utilize our Services, including cookies. Cookies allow us to calculate the aggregate number of people visiting our Services and monitor their use. This helps us to improve our Services and better serve our Users. We may also use cookies that make use of the Services easier, for example by remembering usernames, passwords, and preferences. We may use tracking and analytics cookies to see how well our Services are being received by our Users.
Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. This can usually be done through Internet browser settings. Information about how to manage cookies can be found online. Please note that some parts of our Services may not function properly if use of cookies is refused.
2.Legitimate Grounds for Processing
We process Personal Data to perform our contractual obligations to certain Users and to comply with legal obligations. Furthermore, we process Personal Data to pursue our legitimate interest to run, maintain, and develop our business. In some parts of the Services, Users may be requested to grant their consent for the processing of Personal Data. In this event, Users may withdraw their consent at any time. More information regarding the transfers of Personal Data may be obtained by contacting us via the contact information set forth in this Privacy Policy.
3.Consent
By signing up for, accessing, or using our Services, you accept this Privacy Policy and consent to our collection, use, and disclosure of Personal Data as described in this Privacy Policy.
4.Purposes and Legitimate Grounds for Processing of Personal Data
There are several purposes for the processing of Personal Data by us. Personal Data is processed by us for managing the relationships with Users, facilitating transactions and payments, and for managing, developing, and analyzing our Services and customer service. Personal Data is also used to direct marketing at special customer groups, and other business activities related to any of these activities. User Data and Technical Data are also used or processed by us for some or all of the following purposes:
4.1For quality improvement and trend analysis
We may process information regarding the use of the Services to improve the quality of our Services, e.g. by analyzing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.
4.2To provide our Services and carry out our contractual obligations
We process Personal Data to be able to offer the Services to Users and to run, maintain, and develop our business. In some cases, Personal Data may be processed in order to carry out our contractual obligations in relation to the User. We may use the data, for example, to offer essential functionalities of the Services and to provide access to the Services. If a User contacts our customer service, we will use the provided information for answering questions and solving possible issues.
4.3For customer communication
We may process Personal Data for the purpose of contacting Users regarding our Services and to inform Users of changes in our Services. Data may also be used for research and analysis purposes in order to improve our Services.
4.4For adding Value-Added Functionality to our Services
In all instances, we use data solely to the extent permitted by applicable laws, rules, and regulations. Provided the following are done in full compliance with this Privacy Policy, applicable laws, rules, and regulations, we may (a) process, analyze, and manage data to provide services to our customers; (b) use data to mitigate fraud, financial loss, or other harm to our Users and ourselves; and (c) use data to analyze, develop, and improve our products, systems, and tools.
4.5For other purposes
We may share Personal Data with affiliated third parties for business purposes, but never in a manner prohibited by applicable laws, rules, and regulations. Our sharing or use of Personal Data will, at all times, be compliant with applicable law. We may use or share Personal Data in conjunction with providing Services to Users and with companies we include in ancillary products or services offered in conjunction with the Services. We will not sell your Personal Data.
5.Storage Period
We do not store Personal Data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. Typically, we will store a User's Personal Data for as long as the User has an active account or for as long as we have a legitimate purpose to do so and, thereafter, for no longer than is required or permitted by law or reasonably necessary for internal reporting and reconciliation purposes. In general, Personal Data of a User is deleted within reasonable time after the User no longer uses any part of the Services or when the User makes a request regarding deletion of the User's Personal Data.
6.User Rights
6.1Right to withdraw consent
In case the processing is based on a consent granted by User, User may withdraw the consent at any time. Withdrawing consent may lead to fewer possibilities to use, or the complete termination of, our Services.
6.2Right to correct
Users have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary Personal Data we have stored about the User corrected or completed.
6.3Right to object
Users may object to certain use of Personal Data if such data are processed for purposes other than those necessary for the performance of our Services to the User or for compliance with a legal obligation. Users may also object to any further processing of Personal Data after prior given consent. If User objects to the further processing of Personal Data, this may lead to fewer possibilities to use our Services or for termination of the Services. In the event, and at our sole discretion, we determine that the Services can no longer be provided without User's acceptance and consent of use of Personal Data, the Services will be terminated by us.
6.4Right to access
We offer access for the Users to the Personal Data processed by us. This means that a User may contact us and we will inform what Personal Data we have collected and processed regarding such User and the purposes such data are used for.
6.5Right to data portability
Users have the right to receive their Personal Data from us in a structured and commonly used format and to independently transmit that data to a third party.
6.6Right to deletion
Users may request us to delete User's Personal Data from our systems. We will comply with such request unless we have a legitimate ground to not delete the Personal Data. We may not immediately be able to delete all residual copies from our servers and backup systems after the active Personal Data has been deleted. Such copies shall be deleted as soon as reasonably possible and legally permissible.
6.7Right to restriction of processing
Users may request us to restrict certain processing of Personal Data; this may however lead to fewer possibilities to use our Services, or termination of the Services.
6.8How to use the rights
The above-mentioned rights may be exercised by sending a letter or an e-mail to us at the addresses set out in Section 10 below, including the following information: the User's full name, company name (if applicable), address, and e-mail address. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded. As a User you have the right to access, correct, and delete your Personal Data. Contact us for any requests to exercise your rights.
6.9Lodging a complaint
In case a User considers our processing of Personal Data to be inconsistent with the applicable data protection laws, a complaint may be lodged by email at support@sbstexas.com, online through our website, or by mail to Silverado Business Services, 1155 Dildy Drive, Elgin, Texas 78621.
7.Information Security
We will take all reasonable and appropriate security measures to protect the Personal Data we store and process from unauthorized access or unauthorized alteration, disclosure, or destruction. Measures include, for example, where appropriate, encryption, firewalls, secure facilities, and access right systems. We maintain all Personal Data collected through industry standard safe mechanisms including, but not necessarily limited to, encryption of password data as well as API keys, SSL encryption, passing of credit card information directly to processor, and encryption of any collected credit card information.
We use administrative, organizational, technical, and physical safeguards to protect the Personal Data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our websites, data centers, systems, and other assets for security vulnerabilities. If a security breach occurs despite our security measures that is likely to have negative effects on the privacy of Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible.
8.Recipients
We share Personal Data internally and with third parties only upon your permission or as reasonably necessary to perform and develop our Services as further set forth herein. We do not share Personal Data with third parties outside of us unless one of the following circumstances applies:
8.1With explicit consent
We may share Personal Data with third parties outside of us when we have the User's explicit consent to do so. The User has the right to withdraw this consent at all times. We do not share your Personal Data with third parties unless necessary to provide you with our Services or for legal reasons.
8.2It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to Personal Data to perform the Services, we have taken appropriate contractual and organizational measures to ensure that Personal Data is processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.
8.3To authorized third party service providers
We may share Personal Data with authorized third party service providers who perform services for us or in conjunction with our Services (including without limitation merchant services processing, data storage, sales, marketing, software and product features, and customer support services). Our agreements with our third party service providers include commitments that the third party service providers agree to limit their use of Personal Data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide Personal Data directly to a third party, such as through a link on our website, any such Personal Data and the use thereof will be in accordance with such third party's privacy policies and standards.
8.4For legal reasons
We may share Personal Data with third parties outside of us if we have a good-faith belief that access to and use of the Personal Data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security, or technical issues; and/or (iii) protect the interests, properties, or safety of our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.
8.5For other legitimate reasons
If we are involved in a merger, acquisition, or asset sale, we may transfer Personal Data to the third party involved. However, we will continue to ensure the confidentiality of all Personal Data. We will give notice to all Users concerned when their Personal Data is transferred or becomes subject to a different privacy policy as soon as reasonably possible.
8.6For other purposes
We may share Personal Data with affiliated third parties for business purposes, but never in a manner prohibited by applicable laws, rules, and regulations. Our sharing or use of Personal Data will, at all times, be compliant with applicable law. We may use or share Personal Data in conjunction with providing Services to Users and with companies we include in ancillary products or services offered in conjunction with the Services. We will not sell your Personal Data.
9.Changes to This Privacy Policy
We reserve the right to modify or amend this Privacy Policy at any time and for any reason. If we make any changes, we will notify you by posting it on our website and revising the "Last Updated" date at the top of this Privacy Policy and, in some cases, provide you with additional notice (such as adding a statement to the platform or sending you an email notification). If there are material changes to this Privacy Policy, we will notify you more directly by email or means of a notice in the platform prior to the change becoming effective. We encourage you to review our Privacy Policy periodically to stay informed about our information practices and the ways you can help protect your privacy. Your continued access or use of our Services following a change means you consent to the collection, use, and disclosure of Personal Data as set out in this Privacy Policy.
10.Contact Us
If you have additional questions about this Privacy Policy, wish to object to certain use of your Personal Data, or wish to access your Personal Data, please contact us by email at support@sbstexas.com, online through our website, or by mail to:
11.Notice to California Residents
This section applies only to California residents.
11.1 This Notice applies to personal information we collect in connection with your interactions with us, including when you visit our website, communicate with us, create an account, or apply for a job. Certain personal information is exempt from the CCPA, including information subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and related laws. This exemption applies only to the extent such information is collected, processed, or disclosed pursuant to those laws.
11.2 As set forth in this Privacy Policy, we do not sell your Personal Data for monetary consideration. However, we may “share” Personal Data (as defined under California law) as set forth further in this Privacy Policy. You may opt out of such sharing as described below.
11.3 Subject to certain limitations, California residents have the right to:
- Request access to the categories and specific pieces of Personal Data we have collected about you;
- Request deletion of Personal Data;
- Request correction of inaccurate Personal Data;
- Opt-out of the sale or sharing of Personal Data;
- Limit the use and disclosure of sensitive Personal Data (i.e. your social security number, financial account information, your precise geolocation data, or your genetic data), if applicable; and
- Not receive discriminatory treatment for exercising these rights.
11.4 To exercise your rights, please contact us at support@sbstexas.com. We will verify your request and respond in accordance with applicable law. You may designate an authorized agent to make a request on your behalf, subject to verification requirements.
11.5 We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or as required by law. We will not and cannot deny you the Services, charge you a different price, or provide a different level or quality of the Services just because you exercised your rights under the CCPA. However, if you refuse to provide your Personal Data to us or ask us to limit, delete, or stop sharing your Personal Data, and that Personal Data or the sharing of the Personal Data is necessary for us to provide you with the Services, we may not be able to complete that portion of the Services or the Services in its entirety.
12.Residents of Virginia, Colorado, Connecticut, & Utah
In addition to your rights set forth in this Privacy Policy, residents of Virginia, Colorado, Connecticut, and Utah have the right to opt-out of the sharing of Personal Data and the right to appeal any decision made by us concerning the use of your Personal Data. While you retain the right to opt-out of the sharing of Personal Data, if you refuse to provide your Personal Data to us or ask us to delete or stop sharing your Personal Data, and that Personal Data or the sharing of the Personal Data is necessary for us to provide you with the Services, we may not be able to complete that portion of the Services or the Services in its entirety.
13.Persons Under the Age of 18
Our Site is not directed at persons under the age of 18. Further, we do not knowingly collect or maintain personal information of persons under 18 years of age. If we learn we have collected such information, we will delete such information. To notify us that we might have any information from or about a person under the age of 18, please contact us at support@sbstexas.com.
14.Legal Disclaimer
All logos, brands, proprietary services and product information and materials qualified as trademarks of Silverado Business Services should not be shared or disseminated without our express written permission.