Pipe Technologies Inc. Global Privacy Policy

1. Scope

This Privacy Policy applies to Personal Information processed by Pipe Technologies Inc. and all of its subsidiaries such as Pipe Technologies UK Limited (“us”; “our”; “Pipe”), including on our websites, our services, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, services, and other offerings are collectively called "Services." Personal Information is generally defined as any data which is related to an identified or identifiable natural person.

2. Information We Collect

The categories of Personal Information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

2.1 – Information you provide to us directly

We may collect the following personal information that you provide to us:

• Business Account Information. We may collect Personal Information when you create an account, such as names, email addresses, telephone numbers, company registration numbers, other professional details, and other profile information you choose to provide, including information you provide by “linking” other data sources, integrations, or similar services to Pipe. We may also collect financial data including your percentage of ownership in the company (if relevant) and information which we collect for purposes of fraud prevention.

  In addition, we may require that you provide us with a written authorization from yourself and other company personnel to obtain consumer credit reports, details about the business, acquirer Merchant ID(s), information about the purpose for which the company is requesting funding, the company’s current and historical card takings, chargeback and refund data, as well as its Merchant Category Code(s) and/or industry type, other reports such as credit, fraud and Office of Foreign Asset Control (“OFAC”) reports on each member of the company, and confirmation that the company is continuing to take payments through the card terminal(s) provided to us.

• Underwriting Information. We may collect the following Personal Information to help us with underwriting. This can include information such as the currency used; payouts amounts, transaction counts, chargeback amounts, and days of transaction activities.

• Your communications with Us. We may collect Personal Information, such as email addresses, phone numbers, or mailing addresses when you request information about our Services, register for our product, attend or request customer or technical support, or otherwise communicate with us.

• Research. We may collect Personal Information, such as names, email addresses, phone numbers, or mailing addresses, if you opt to participate in one of our research studies. We may also collect any video or voice recordings taken during this research. Pipe will ask for your explicit consent to collect and process this sensitive information. 

• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain data which may include Personal Information.

• Interactive Features. We and others who use our Services may collect Personal Information that you submit or make available through our interactive features (e.g., profile pages which are available to other Pipe users, messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. 

• Sweepstakes or Contests. We may collect Personal Information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Conferences, Trade Shows, and Other Events. We may collect Personal Information from individuals when we attend conferences, trade shows, and other events. 

• Business Development and Strategic Partnerships. We may collect Personal Information from individuals and third parties to assess and pursue potential business opportunities.

• Job Applications. We may post job openings and opportunities on our Services. You may reply to one of these postings by submitting your application, CV, cover letter, and/or other information to us.

2.2 - Information Collected Automatically

We may collect personal information automatically when you use our Services:

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you.

• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 

• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

  Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

• Advertising or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

  See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:

  • Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

  • LinkedIn Analytics. For more information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

2.3 - Information Collected from Other Sources

We may, and often do, obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect Personal Information about you from that third-party application that you have made available via your privacy settings, or if, as part of signing up for our services, you link, integrate, or otherwise grant us access to other platforms. In addition, we may also collect Personal Information contained in a credit report from a consumer reporting agency or from other public information databases.

Pipe users may, at times, provide us with Personal Information about other individuals, in particular customers of such users. For example, a Pipe user may upload transactional records which contain Personal Information about the individuals involved with such transactions.

3. How We Use Your Information

We use your Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

3.1 - Provide Our Services

We use your Personal Information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;

• Rating, evaluation, and risk management purposes;

• Deciding whether to offer you a Pipe product or service;

• Enhancing the accuracy of the information that we hold about you;

• Monitoring your account and linked data for eligibility for future Pipe products or services; 

• Enabling you to access our Services through Third-Party Services, such as our referral or embedded partners;

• Carrying out activities that we determine are necessary or appropriate as it relates to our Services;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing applications and assessing qualifications if you apply for a job we post on our Services; and

• Allowing you to register for events.

3.2 - Administrative Purposes

We use your Personal Information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services; 

• Improving, upgrading or enhancing our Services; 

• Developing new products and Services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this policy and for reviewing credit standing;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions and other compliance activities;

• Enforcing our agreements and policies; and

• Complying with our legal obligations.
  

3.3 - Marketing and Advertising our Products and Services

We may use Personal Information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

3.4 - Other Purposes

We also use your Personal Information for other purposes as requested by you and/or as permitted by applicable law.

• Consent. We may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your Consent. Consent is defined as “freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to you.”

• De-identified and Aggregated Information. We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

• Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).
  

4. How We Disclose Your Information

We disclose your Personal Information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

4.1 - Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below. 

• Other Pipe Users In Your Organization. The Services may allow you to share Personal Information or interact with other Pipe users in your organization. For example, parts of your Pipe profile may be accessible by other Pipe users in your organization.

• Third-Party Services You Share or Interact With. The Services may allow you to share Personal Information or interact with Third-Party Services (defined below). For example, we may share personal information with referral or embedded partners who have referred our Services or integrated our Services into their platform and/or product.

• “Buyside” and “Sellside” Participants. We may share personal information with our “buyside” and “sellside” Participants in limited circumstances that we determine are necessary or appropriate.

• Service Providers. We may share your Personal Information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

• Business Partners. We may share your Personal Information with business partners to provide you with a product or service you have requested. We may also share your Personal Information to business partners with whom we jointly offer products or services.

• Affiliates. We may share your Personal Information with our company affiliates. 

• Advertising Partners. We may share your Personal Information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” 

• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

For customers in the United Kingdom (Bacs), we use GoCardless to securely process your payments.  GoCardless Ltd (company registration number company registration number 07495895) is authorized by the Financial Conduct Authority under the Payment Services Regulations 2017, registration number 597190, for the provision of payment services.GoCardless uses personal data as described in their Privacy Notice. More information on how GoCardless processes your payments, personal data and your data protection rights, including your right to object, is available at http://gocardless.com/legal/privacy/

4.2 - Disclosures to Protect Us or Others

We may access, preserve, and disclose any Personal Information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us or any “Buyside” participants; or assist with an investigation or prosecution of suspected or actual illegal activity.

4.3 - Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Our Lawful Basis for Processing

Pipe’s processing of your Personal Information may be supported by the following lawful bases under the United Kingdom General Data Protection Regulation:

• Performance of a Contract: Pipe needs to process your Personal Information to perform our contract with you or in order to take steps at your request prior to you entering into a contract.

• Legitimate Interest: Pipe may process your Personal Information to further its legitimate interests but only where our interests are not overridden by your interests or fundamental rights and freedoms. 

• Consent:  In some cases, Pipe also relies on your Consent to process your Personal Information. 

• Compliance with our Legal Obligations: Pipe may process your Personal Information to comply with our legal obligations.
  

6. Your Privacy Choices and Rights

6.1 - Your Privacy Choices

The privacy choices you may have about your Personal Information are determined by applicable law and are described below. 

• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy). 

• Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Interest-Based Advertising.

  You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting theNetwork Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  

  Please note you must separately opt out in each browser and on each device.
  

6.2 - Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Access Personal Information about you,  including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”);

• Request Correction  of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;

• Request Deletion of your personal information;

• Request Restriction of or object to our processing of your personal information; and

• Withdraw your Consent to our processing of your personal information.

Pipe does not “sell” Personal Information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws, including taking steps to verify your identity. 

7. Security of Your Personal Information

We take steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

8. International Data Transfers

All Personal Information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer Personal Information outside the United Kingdom, we will use commercially reasonable efforts to ensure that: (i) there are appropriate safeguards in place such as binding corporate rules or the approved EU standard contractual clauses between Pipe and the recipient; (ii) the transfer is to a country that provides an adequate level of protection under applicable laws; (iii) one of the derogations for specific situations found in applicable law applies to the transfer including explicit consent, where such transfer is necessary for the performance of a contract or exercise, or the defense of legal claims; or (iv) the transfer is otherwise consistent with the requirements of applicable laws.

9. Retention of Personal Information

We store the Personal Information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

10. Children's Information

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children.

If you are a parent or guardian and believe your child has uploaded Personal Information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with Personal Information in violation of applicable law, we will delete any Personal Information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

11. Other Provisions

• Third-Party Services. The Services may contain links to or be compatible with third-party websites, applications, platforms, products, or services (each a “Third-Party Service”) and other Third-Party Services may reference, link to, or interface with our Services. These Third-Party Services are not controlled by us. We encourage our users to read the privacy policies of each Third-Party Service with which they interact. We do not endorse, screen or approve, and are not responsible for, the practices or content of such other Third-Party Services. Providing Personal Information to Third-Party Services is at your own risk.

• Supervisory Authority. If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your Personal Information violates applicable law.

• Updates. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

12. Contact Us

Pipe is the controller of the Personal Information we process under this Privacy Policy.

This Privacy Statement is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate.

If you have any questions about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to the following address, legal@pipe.com, with the subject “PRIVACY REQUEST”. 

If you are a UK resident, you have the right to make a complaint at any time to the UK Information Commissioner’s Office (ICO), at any time. The ICO can be contacted as follows:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire