This "Privacy Policy" explains how VNVN Systems LLC ("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, AZCPOS which uses the Clover gateway via the Clover terminal or the in system checkout ("Clover Gate"). This Privacy Policy does not apply to the Company's privacy practices in any other context.

This Privacy Policy and our agreements with Merchants govern the Company's processing of personal data in connection with our application. In case of any conflict between this Privacy Policy and a customer agreement, the customer agreement will control to the extent applicable law permits.

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 We Collect

We may collect personal data from or on behalf of Merchants. Merchants determine the scope of the personal data transferred to us or that we collect, and the information we receive may vary by Merchant. Typically, the information we collect on behalf of Merchants includes:

Information that we collect when a Merchant's customers make a payment

When a customer makes a payment via Clover Gate, we collect information about the transaction, which may include personal data. Information about transactions consists of the payment card used, a name associated with the payment card, the location of the Merchant's store, the transaction amount, and information about the goods or services purchased in the transaction.

Merchants' customers provide additional information through the Clover Clover Gate systems ancillary to a payment.

We may collect additional information ancillary to the payment. This information may include:

Customers' email address or phone number, such as when the customer chooses to receive an electronic receipt

Customers' physical address, where needed for delivery of goods or services

Customers' purchase behavior, such as the specific goods or services rendered

Information that we collect about Merchants' personnel

We may collect information about Merchants' personnel and interactions with the Clover Gate, such as sales, products sold, and tips collected.

Additional information that Merchants provide to us about their customers or personnel

Merchants may provide us with additional information directly, via access they grant to us, or otherwise. Merchants may give us information about their customers, including email addresses, phone numbers, and purchase history. The information merchants may provide us about their personnel includes email addresses, phone numbers, shifts, and sales history.

How We Use the Information We Collect

We use the personal data we collect for or on behalf of Merchants to provide our services and the functionality of our application, such as sending email and SMS text campaigns for order status updates.

We may also use personal data for related internal purposes, including:

To provide information about the application, such as essential updates or changes to the application and security alerts

To measure the performance of and improve the application

To respond to inquiries, complaints, and requests for customer support

In addition, the Company may use personal data as we believe necessary or appropriate to:

1. Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or government authorities' demands.
2. Enforce the terms and conditions that govern our application.
3. Protect our rights, privacy, safety, property, and that of you or others.
4. Protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity.

We do not collect data on minors. If you are under 18 years old and unable to form a binding contract, you must have your guardian's permission to use the Services, and your guardian must provide consent to the terms of this Policy on your behalf. By using such Services, you represent and warrant that you are not a minor and are of legal age to form a binding contract, or, if the Submission is made by a minor child or children under the legal age of majority (under 18 years of age), that you are the legal guardian of the Child or Children making a Submission ("Parents" and each a "Parent"), have read and understand the terms of this Policy, and can legally enter into an agreement behalf of all such minor child/children.

How We Share Information

We may share personal data that we collect with:

The Merchant from whom or on whose behalf we collected the personal data

The platform on which our application runs is the Clover Gate. You may view Clover's Privacy Notice here.

With Company subsidiaries and corporate affiliates for the purposes described in this Privacy Policy or our agreement with a Merchant

Company may disclose personal data to government or law enforcement officials or private parties as required by law and disclose and use such information as we believe necessary or appropriate to:

1. Comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or government authorities' demands.
2. Enforce the terms and conditions that govern our application.
3. Protect our rights, privacy, safety, property, and that of you or others.
4. Protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity.

Company may sell or transfer some or all of its business or assets, including your data, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

We do not sell PII data and have not in the past 12 months, nor do we ever have plans to sell the personal data of our customers or end-users.

Cookies and Third-Party Technologies

User Information

We may collect user information ("user information") from your browser or mobile device each time you access the Site or use the Services. User information may include anonymous information such as your web request, Internet Protocol ("IP") address, browser type, information about your mobile device, referring/exit pages and URLs, domain names, landing pages, pages viewed, and other such information. When you access our Services by or through a mobile device, we may receive or collect and store a unique identification number associated with your device, mobile carrier, device type, manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates or similar information regarding the location of your mobile device.

Cookies

Cookies are small files of letters and numbers downloaded onto your desktop computer, mobile, or other handheld device when you access certain websites.

Cookies allow the Site to recognize a user's device and help your browser navigate through the Site by allowing you to log in automatically by remembering settings you selected during earlier visits, among other functions. Cookies do not harm your computer.

We use cookies on the Site to collect statistical information about how visitors use our website so we can improve the way the Site works and measure our success. By recording statistics such as browser usage, visitor location, operating system, etc., we can measure and improve how we manage and maintain our Site to provide a better visitor experience.

If you would like to manage your use of cookies, you can find out how to do so by visiting www.allaboutcookies.org.

Third-Party Technologies

We do not sell personal information to anyone. We may work with agents, service providers, affiliates, or other third-party providers that store and receive data, reports, and other user information sent by your browser or mobile device, including the pages you visit, your use of our Site, your use of third-party applications, and other information that we may use to analyze and improve the Site or the Services. These third parties may use both temporary and persistent cookies. We do not have control over how third parties use your information. Please check their websites for information about how third parties use your data.

Our Site or Services may contain links to third-party websites. We are not responsible for how third-party websites collect or use your PII or user information. We encourage you to review the privacy policies of third-party websites you visit or use, including those you interact with through our Site or Services.

Your Rights and Choices

Data Subject Rights

To the extent that applicable law provides individuals with rights about their personal information, such as reviewing and requesting changes to their data, individuals should contact the Merchant with any requests about using our application. To the extent that Clover is responsible for responding to data subject rights requests under applicable law, individuals may contact Clover with applicable requests as explained in Clover's Privacy Notice, https://www.clover.com/privacy-policy. Company will assist a Merchant, or Clover, as applicable, in responding to such bids subject to our contract with a Merchant or Clover.

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 Email or Phone: policy@azcpos.net or dial (714) 716-1718

Additional Information for Merchants Located in Europe

Controller

The Company is a data processor acting for and on behalf of the Merchant using our application with their Clover Terminal. Merchant controls personal data that we process on its behalf. Clover is also a controller of personal data in some circumstances. Clover's Privacy Notice is available at https://www.clover.com/privacy-policy.

Legal Bases for Processing

The Company processes personal data as directed or permitted by the Merchant who uses our application. The Merchant is responsible for establishing a legal basis for our processing of personal data for or on behalf of the Merchant.

Cross Border Data Transfer

When we transfer personal data outside of Europe to countries not deemed by the European Commission to provide an adequate level of protection for personal data, we make the transfer under one of the following transfer mechanisms:

A contract approved by the European Commission (sometimes called "Model Clauses" or "Standard Contractual Clauses");

The EU-US Privacy Shield;

The recipient's Binding Corporate Rules;

The consent of the individual to whom the personal data relates; or

Other mechanisms or legal grounds as may be permitted under applicable European law.

You may contact us with questions about our transfer mechanism.

Data Retention

Subject to our agreement with a Merchant, the Company retains personal data for as long as necessary to:

1. Provide our products and services.
2. Comply with legal obligations.
3. Resolve disputes.
4. Enforce the terms of any agreement we may have with a Merchant.

You may contact us for additional information about our data retention practices with the application.

Data Subject Rights

Under certain circumstances, data subjects in Europe have some rights regarding their data, which include the rights to request from the controller:

1. Access to the data subject's data.
2. Correction of incomplete or inaccurate personal data.
3. Erasure of personal data.
4. Restriction of processing concerning the data subject.
5. The controller provides a copy of the data subject's data that the data subject provided to the controller in a structured, commonly used, and machine-readable format.

Data subjects may also object to a controller's processing of personal data under certain circumstances. Where the processing is based on a data subject's consent, the issue has the right to withdraw consent at any time; however, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Data subjects may also file a complaint with a supervisory authority. You may view contact information for supervisory authorities at https://edpb.europa.eu/about-edpb/board/members_en. Data subjects in Europe should direct any rights request to the appropriate controller.