This Privacy Statement was last updated May 5th 2020

As a leading provider of payment management services to hundreds of thousands of online businesses around the world, privacy and data protection are of the utmost importance to 911 Software dba C9PG (“C9PG”)

This Privacy Statement details C9PG’s policies with respect to the handling of personally identifiable information (“Personal Information”) submitted to or otherwise collected by C9PG via C9PG’s website(s), mobile application(s), and/or in the course of providing its payment processing, payment security and fraud management solutions and services (collectively the “Services”). C9PG will use and disclose Personal Information in accordance with the terms of this Privacy Statement.

Personal information we collect:

Personal Information is information which can be used to identify an individual. We collect Personal Information any time the Services are used. The Personal Information collected includes information provided to us directly by individuals and that is provided to us by merchants or financial institutions. The collection of Personal Information described herein is necessary for use of the Services. This information includes but is not limited to:

Consumer Name

Contact information (such as email address, phone number, and mailing address)

Order and payment information

We collect other information, such as:

IP address and information about the device used to access the Services

How and which Services are used

Merchant and merchant account information, including account information we may gather from third party sources

Information provided to us through means such as social media or when you contact us through our website

We also collect or compile other information about you (such as enrollment numbers or demographic group information) which does not identify you. We may use or share any other information with third parties for any lawful purpose.

Use of cookies

C9PG and its third party service providers use certain tools to collect information about users browsing our website. These tools use cookies which are small text files that are stored on a user’s computer hard drive. The cookies are used, among other things, to improve website performance, to provide customized viewing options, to compile statistical reports on website activity, for fraud reduction or for security purposes. We also use cookies to recognize customers or a previous visitor of our website, or to pre-populate website forms. Such information may be disclosed to third parties to provide any of the activities mentioned above on behalf of C9PG.

To find out more about cookies, including browser-specific instructions on how to restrict or block cookies, go to http://www.allaboutcookies.org. Remember, though, without cookies, users may not be able to take full advantage of all of our website features.

We may also use locally stored objects (sometimes referred to as “Flash cookies”) for security and fraud detection purposes. Flash cookies are not managed through web browser settings. Please visit Adobe’s Flash Player Help website for help with managing Flash cookies.

How we use personal information

Usage and disclosure of Personal Information varies based on a party’s relationship with C9PG. C9PG primarily uses this information to provide the Services and related features and to

Facilitate the processing of payment transactions

Respond to requests and inquiries

Provide support services

Send administrative information, such as changes to our terms, conditions, and policies

Administer promotions or contests

Facilitate social sharing functionality

Analyze and monitor Services usage and to make improvements

Help secure the Services, prevent fraud and enforce our policies

Help personalize our Services

Communicate about other C9PG services or those of our affiliates or other third parties

To make contact, directly or through a third party vendor, to complete a survey or questionnaire

To communicate, directly or through a third party vendor, about C9PG offerings, about general company news and industry trends, and to address responses to a survey or questionnaire

Compile information for use on an aggregated and de-identified basis

Conduct data analysis and research, audits, develop new products, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities

Perform other activities with consent

How we share personal information

We will only share Personal Information as described in this policy. Specifically, we may share Personal Information:

As necessary to perform the Services and to complete payment transactions

With companies and vendors that help us to operate our business by providing services such as website hosting, fraud screening, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services

With third parties that have contracted with C9PG to perform certain functions on our behalf

With third parties sponsors of promotions or contests where consent has been given

To comply with law or other legal obligations such as responding to subpoenas, or other requests from public and government agencies, including laws and other legal obligations outside a party’s country of residence

To protect our rights, operations or property, or that of our users

To investigate, prevent, or take action regarding potential or suspected illegal activities, fraud, threats to the personal safety of any person, or violations of the Service’s terms and conditions

With other companies that control, are controlled by, or are under common control with C9PG that support the provision of Transaction Services or relationship with a party. This includes its subsidiaries and parent companies.

With a purchaser of all or a unit of C9PG (or the majority of C9PG’s or its unit’s assets), a merger, acquisition, or internal reorganization of C9PG or a unit of C9PG

With consent

Please note that any information posted to public areas such as on our social media pages may be seen by other visitors.

Choices

Users can choose not to provide us Personal Information when you use our website(s) or mobile application(s). However if the information request is not identified as optional and a user chooses to not provide required Personal information, then the user may not be able to use the features of the website or mobile application.

Users can opt out of receiving promotional email from C9PG by following the unsubscribe link in those email messages. Users can opt out of receiving SMS text messages from C9PG by replying STOP to any message.

Users can learn more about C9PG’s use of online behavioral advertising and how it can manage its choices for online behavioral advertising by clicking here.

Users can configure its browser to reject cookies, or to notify it when a cookie is set. However, if you reject cookies, the Services may not operate properly.

Accessing or editing personal information

C9PG may be contacted at the email address at the bottom of this policy to request access to or that we update, or correct the Personal Information collected by our Services. Please note, that consistent with local law, C9PG may retain Personal Information for auditing purposes, to troubleshoot problems, assist with investigations, enforce our policies or comply with legal requirements. Please note that we are not responsible for permitting the review, or the updating or deleting Personal Information provided to a third party, including any mobile application, social media platform, or wireless service provider.

Third parties and linked services

C9PG is not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, including any Personal Information disclosed to other organizations through or in connection with the Services.

The inclusion of a link on the C9PG website does not imply endorsement of the linked site or service by C9PG.

Changes to this privacy policy

We may change this privacy policy at any time by posting an updated privacy policy.

Retention period

We will retain Personal Information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by applicable law or regulation.

Use of the services by minors

The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services.

The Data Protection Act does not generally apply to data about limited companies or partnerships, but it does cover personal data relating to sole traders and partnerships. When we receive an application from a business, we may perform a search with a credit reference agency and fraud prevention agency on the individual company directors or partners.

Personal Information may be processed and stored by C9PG or its affiliates, service providers or agents located in the United States, Singapore and other countries. By providing Personal Information directly to C9PG or to its customers, you consent to the transfer of such information outside of the European Union and to its storage and use as described herein.=

How to contact C9PG regarding your privacy concerns and questions

If you have questions or comments about our privacy practices, or if you want C9PG to correct your Information that is stored on C9PG systems, please submit your request in writing to:

C9PG Inc

265 S Federal HWY 353

Deerfield Beach, FL 33441

ATTN: Data Use and Privacy Office

Subject to our ability to verify your request, C9PG will correct the information within thirty (30) days of receipt of your request.