Privacy Policy for Cemcro PayConnect

This "Privacy Policy" explains how Les Entreprises Cemcro Inc. ("Company" or "we") collects, uses, discloses, and otherwise processes personal data on behalf of our customers – typically, merchants (any, a "Merchant") – in connection with our application, Cemcro PayConnect, which runs on the Clover Point of Sale system ("Clover POS") and is offered to Merchants in Canada and the United States. This Privacy Policy does not apply to Company's privacy practices in any other context.

Company's processing of personal data in connection with our application is governed by this Privacy Policy and our agreements with Merchants. In the event of any conflict between this Privacy Policy and a customer agreement, the customer agreement will control to the extent permitted by applicable law.

This Privacy Policy is not a substitute for any privacy policy that a Merchant may be required to provide to their customers, personnel, or other individuals.

Information Cemcro PayConnect collects

Cemcro PayConnect does not collect, use, retain, or share any personal information. As a payment middleware between a Merchant's Quorion point-of-sale system (running the QMP 2.0 Android application) and the Merchant's Clover payment terminal, its sole function is to (a) send the transaction amount to the Clover payment terminal, and (b) receive the terminal's response (for example, approved or declined) so that the transaction can be completed on the Merchant's Quorion register. This exchange happens in real time.

Cemcro PayConnect keeps a transaction log on the Merchant's own device, so that the Merchant can review past transactions. The log keeps only the 200 most recent entries. For each entry, it contains:

• the date and time;
• the type of operation (sale, refund, reversal or cancellation);
• the amount requested by the register, the amount authorized by the terminal, and the tip amount, if any;
• the result (for example approved, partially approved or failed) and a short status or error message;
• the technical identifiers that Clover assigns to the payment or refund, and the type and reference number of the request sent by the register.

To be able to reverse the most recent sale, the application also keeps, until the next sale, the Clover identifiers, the amount and the tip of that sale.

This log does not contain the payment card number, the cardholder's name, or any contact details. It stays on the Merchant's device and is not sent to the Company or to any third party. It can be erased by clearing the application's data in Android settings or by uninstalling the application.

For technical support only, a "raw" log of the messages exchanged with the Merchant's register and with the Clover payment terminal can be turned on in the application's developer menu. It is turned off by default and is not intended for use by Merchants. When turned on, it keeps the 100 most recent messages on the device, which may include the technical data returned by Clover for a payment, such as the card brand, the last four digits of the card, the authorization code and the card entry mode. It is never sent to the Company or to any third party.

Cemcro PayConnect does not access, transmit, or store the full payment card number, the cardholder's name, or the card's expiry date — that information is captured and processed exclusively between the Clover payment terminal and Clover's own systems. To let the register print the receipts, Cemcro PayConnect builds the receipt text from limited data returned by the Clover payment terminal (card brand, last four digits, authorization code, card entry mode, application identifier, amount and tip) and passes it to the Merchant's register without keeping a copy. Cemcro PayConnect also does not collect customer contact details, marketing preferences, loyalty data, or any information about a Merchant's personnel.

If you contact us directly, for example for support, we will use the contact information you provide (such as your name and email address) solely to respond to your inquiry.

How we share information

Cemcro PayConnect only exchanges information between the Merchant's Quorion point-of-sale system and the Merchant's Clover payment terminal: the transaction amount and tip, sent to the Clover payment terminal in order to complete the transaction; and the terminal's response, the receipt text and, when the register requests an end-of-day report, the batch summary, returned to the Merchant's Quorion point-of-sale system. Cemcro PayConnect does not share, sell, or rent any information with or to any other third party.

You may view Clover's Privacy Notice here for information about how Clover itself handles data on the Clover payment terminal.

Company may nonetheless disclose information as required by law, such as in response to a subpoena, court order, or lawful request from a government authority, or as necessary to enforce the terms and conditions that govern our application, or to protect our rights, privacy, safety, or property, and/or that of others.

Your rights and choices

Data subject rights

Because Cemcro PayConnect does not collect or store personal information, there is generally no data held by Cemcro PayConnect for us to provide, correct, or delete in response to a request. For any concerns about data captured directly on the Clover payment terminal, please refer to Clover's Privacy Notice, https://www.clover.com/privacy-policy, or contact the Merchant.

Complaints

If you have a complaint about our handling of personal data, you may contact us via the contact information provided below.

Updates

We reserve the right to modify this Privacy Policy at any time. We will notify you of updates by updating the date of this Privacy Policy.

Contact us

You may contact us with any questions, comments, or complaints, about this Privacy Policy or our privacy practices via:

Les Entreprises Cemcro Inc.
8034, boul. Henri-Bourassa Est, Anjou, Québec, H1E 1P3, Canada
Phone: 514-321-2526
Email: [email protected]

Your California privacy rights

Because Cemcro PayConnect does not collect, store, or sell personal information, the rights below will generally not apply to any information processed by Cemcro PayConnect. We include this section for completeness, consistent with the CCPA. As a California resident, you have the rights listed below with respect to any personal information a business does hold about you. However, these rights are not absolute, and we may decline your request as permitted by the CCPA.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with whom we share Personal Information.
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient.
• Whether we've sold your Personal Information; and, if so, the categories of Personal Information received by each category of recipient.

Access. You can request a copy of the Personal Information that we maintain about you.

Deletion. You can ask us to delete the Personal Information that we maintain about you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as by denying you goods or services, increasing the price/rate of goods or services, decreasing the service quality, or suggesting that we may penalize you as described above for exercising your rights. However, the CCPA allows us to charge you a different price or provide a different service quality if that difference is reasonably related to the value of the Personal Information we are unable to use.

How to exercise your rights

Because Cemcro PayConnect does not collect personal information, we generally will have no data responsive to an information, access, or deletion request. You may still reach us with any questions in the following ways:

• Call 514-321-2526 or email [email protected]

Identity verification. The CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request. A request must be provided with sufficient detail to allow us to understand, evaluate and respond. The requester must provide sufficient information to allow us to reasonably verify that the individual is the person about whom we collected information. A request may also be made on behalf of your child under 13.

Authorized agents. California residents can empower an "authorized agent" to submit requests on their behalf. We may require the authorized agent to have a written authorization confirming that authority.

Sale of personal information

We do not sell, as defined under the CCPA, your Personal Information to third parties. We do not collect or store personal information, so there is no information for us to sell.

In the preceding twelve (12) months, we have not sold any personal information.

Personal information that we collect, use and share

The chart below summarizes our collection, use and sharing of Personal Information during the last 12 months before the effective date of this Privacy Policy. Because Cemcro PayConnect does not collect any personal information, every category below is "No."

Glossary

Contact information

Les Entreprises Cemcro Inc.
8034, boul. Henri-Bourassa Est, Anjou, Québec, H1E 1P3, Canada
Phone: 514-321-2526
Email: [email protected]