Privacy Policy for 360WINERY APP

Effective Date: JANUARY 2, 2020

This “Privacy Policy” explains how 360 GROWERS 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, 360WINERY APP, which is using the Remote-pay-cloud of Clover Flex semi-integration. This Privacy Policy does not apply to Company’s privacy practices in any other context.
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 that we collect when a Merchant’s customers make a payment

When a customer makes a payment via a Clover Flex, using the credit card for payment at Clover Flex, we are passing only the payment amount to the Remote-Cloud-SDK and we get the information about the transaction which includes the payment card used, name associated with the payment card, the location of the merchant’s store, date and time of the transaction, transaction amount, and authorization code. But we save in 360Winery app only the Auth code, transaction Id and payment ID.

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. The types of information that merchants may provide to us about their customers include email addresses, phone numbers, and purchase history. All these data Customer uploads to our application 360winery and not related to clover

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: Customer uses 360winery application to enter their data which is in no way connected to clover. 360winery have an End User License Agreement (EULA) for those data.

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

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

· To measure performance of and improve the application

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

In addition, Company may use personal data as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our application; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

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 360Winery app and not connected with clover.

· With third parties as a Merchant may direct

· With third party service providers that help us manage and improve the application

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

Your Rights and Choices

Data Subject Rights

To the extent that applicable law provides individuals with rights pertaining to their personal information, such as to review and request changes to their personal information, individuals should contact the Merchant with any requests pertaining to the Merchant’s use of 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 requests 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: info@360growers.com