Accrualify Privacy Policy

Last updated January 11, 2019

Accrualify Privacy Policy

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INTRODUCTION

This Privacy Policy (“Privacy Policy”) sets forth the privacy practices of Accrualify, Inc. and its current and future Accrualify Affiliates (collectively, “Accrualify”) for all Accrualify software and applications (including, without limitation, mobile software and applications) (collectively, the “Software”); the Accrualify websites located at www.accrualify.com, app.accrualify.com, swisscard.accrualify.com and any other Accrualify websites or services that link to this Privacy Policy, (collectively, the “Websites”); and all other Accrualify products or services provided or otherwise made accessible on or through the Software or the Websites or that otherwise link to or reference this Privacy Policy. The Software, the Websites, and any other Accrualify products or services that link or refer to this Privacy Policy are collectively referred to as the “Service.” This Privacy Policy describes how Accrualify collects, discloses, stores, transfers, and uses information that could individually identify our users (“Personal Data”) in connection with our Service.

This Privacy Policy does not apply to the practices of third parties, as explained in more detail below. In this Privacy Policy, “we,” “us,” “our,” and other similar references mean Accrualify, “you” and “your” and other similar references mean any user of the Service, and “Accrualify Affiliates” means any parent, subsidiary, member, officer, director, employee, agent, or contractor of Accrualify or any entity under common control with Accrualify.

This policy applies (i) immediately to new users who use or access the Service on or after the Effective Date and (ii) on the Effective Date to users who use or access the Service before the Effective Date.

Please contact us if you have any questions or comments about our privacy practices. You can reach us online at privacy@accrualify.com.

TRANSFERS OF PERSONAL DATA

The Service is hosted and operated in the United States (“U.S.”), with development, support and maintenance operations in other countries (and hosting soon to come in the European Union (“EU”), through Accrualify and its service providers. If you do not reside in the U.S., laws in the U.S. (and other countries) may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Accrualify in the U.S. and will be hosted on U.S. servers, and you authorize Accrualify to transfer, store, host and process your information to and in the U.S., and possibly other countries. You hereby consent to transfer of your data to the U.S. pursuant to, at Accrualify’s discretion, the details of which are further set forth below, or the standard data protection clauses promulgated by the EC, a copy of which can be obtained at
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.

EU PERSONAL DATA

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. Accrualify will be the controller of your Personal Data processed in connection with the Service, unless you access the Service through an enterprise account, or other Accrualify account that is controlled by a third party (e.g. your employer).

ACCRUALIFY GDPR COMPLIANCE

Accrualify is committed to compliance with the General Data Protection Regulation (GDPR), a new EU data privacy regulation that will go into effect May 25, 2018. The regulation is designed to give EU citizens more control over their data and to unify a number of existing privacy and security laws under one comprehensive law.

Our legal and security experts have closely analyzed the requirements of the GDPR and continue to monitor new guidance on best practices for implementing the requirements of the GDPR. We are updating our products, contracts, and policies to ensure that we are in compliance with the GDPR before May 25, 2018. We are also dedicated to helping our customers succeed in complying with the GDPR.

WHAT ACCRUALIFY IS DOING

Accrualify is currently implementing its company-wide GDPR compliance strategy ahead of the May 2018 due date. Below are a few examples of initiatives Accrualify has committed to in order to satisfy GDPR requirements that apply to both Accrualify and our customers:

  • Accrualify maintains strict security and compliance protocols which are affirmed through our annual SOC 1 & 2 audit.
  • When processing personal data regulated under GDPR, we commit to follow any additional security and privacy measures required under GDPR.
  • Where we are transferring personal data outside of the EU, we are committing to appropriate data transfer mechanisms as required by GDPR.
  • We are ensuring that applicable users have the ability to access and update their personal data.
  • We are notifying regulators, customers, and users of breaches, if applicable, promptly as required by the GDPR.
  • We are holding vendors that handle personal data to required data management, security, and privacy practices and standards.
  • We are ensuring that Accrualify staff that process Accrualify customer personal data have been trained in handling that data and are bound to maintain the confidentiality and security of that data.

GENERAL DATA PROTECTION REGULATION FAQS

DOES ACCRUALIFY PROCESS THE PERSONAL DATA OF ITS CUSTOMERS?

Yes, Accrualify processes customer personal data to provide the products and services as set forth in our customer agreements and as listed in our Privacy Policy.

WHAT PERSONAL DATA DO WE PROCESS?

For most users, we process data needed to provide our Service which includes their names, e-mail addresses, IP address, financial account information, phone number and physical address.

WHERE DOES ACCRUALIFY STORE AND PROCESS MY DATA?

Our goal is to provide our customers with secure, fast, and reliable services. Today, Accrualify stores data in its AWS data center located in the U.S. In order to bring you world class products, and to provide support and maintenance (e.g. 24×7 support coverage), Accrualify may also allow employees and contractors located outside the U.S. (e.g. in the EU, India, Australia, and Canada) to access to certain data for product development, and customer and technical support purposes. We ensure that all such disclosures are compliant with the law and that all use will be for the limited purpose described.

HOW CAN I MANAGE MY PERSONAL DATA THAT IS STORED BY ACCRUALIFY?
You can contact us directly at privacy@Accrualify.com if you desire to have any of your personal data removed. Please note this may impact your ability to use the Accrualify Service.

DOES ACCRUALIFY ENTER INTO GDPR-COMPLIANT DATA PROCESSING AGREEMENTS (DPA)?

For our customers:
Accrualify will enter into DPAs with our customers who are data controllers and have purchased a subscription to our design collaboration platform via a written agreement.

MORE RESOURCES

Accrualify is committed to our customers’ success and the protection of customer data, which is why our customers can count on our commitment to GDPR compliance.

Privacy: You own your data, and we’re committed to protecting your privacy.

Security: Accrualify maintains customer security as our highest priority.

Compliance: We maintain strict standards for achieving legal, regulatory and industry compliance frameworks such as SOC and PCI.

EU-U.S. and Swiss-U.S Privacy Shield Participation

Accrualify complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and Switzerland to the United States, respectively. Accrualify has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Accrualify adheres to the Privacy Shield Principles of (1) Notice; (2) Choice; (3) Accountability for Onward Transfer; (4) Security; (5) Data Integrity and Purpose Limitation; (6) Access and (7) Recourse, Enforcement and Liability (collectively, the “Privacy Shield Principles”).

As further set forth in the Privacy Shield Principles, we remain potentially liable if a third party processing Personal Data received from the EU or Switzerland on our behalf processes that Personal Data in a manner that is inconsistent with the Privacy Shield Principles (unless we can prove that we are not responsible for the event giving rise to the damage). Accrualify is subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to any failure to comply with the Privacy Shield Principles. EU or Swiss individuals with inquiries or complaints regarding U.S. privacy practices should contact us at privacy@accrualify.com.

Accrualify commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship, as well as the rights of Swiss individuals.

NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT

Types of Personal Data We Collect
Accrualify collects Personal Data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our Service), or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:

Contact Information: information we collect to identify or contact you, such as your first and last name, email address, phone number, and occasionally, physical address. For example, this is the basic information that we collect when you register to be a user in our administrative procure to pay Service.

Financial Account Information: If you are receiving or sending payments through the Service in any capacity, we will collect financial information in order to provide the Service. This information may include the following: bank account number, bank account title, bank name, branch location, routing number, Iban number, Swift code and/or any other data needed to facilitate payment.

Transaction Information: information related to transactions you conduct on the Service, including any payments made or received, and your interactions with the Service.

User Account Information: information that identifies you to the Service, such as your user name, email address, password, and IP address. For example, we use this information to authenticate you when you log in to the Service, and use the IP address to help maintain your web session security while using the Service.

Log Data: information automatically recorded by the Service about how a person uses our Service, such as IP addresses, device and browser type, operating system, the pages or features of our Website or Service to which a user browsed, the time spent on those pages or features, the frequency with which the Service is used by a user, the links on the Service that a user clicked on or used, and other statistics.

We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.

We collect Personal Data when a user (i) creates an account (a “User Account”); (ii) logs into the Service; (iii) interacts with the Service; (iv) communicates with us; and (v) responds to a communication or interaction from us. Some of the methods and tools we use to collect Personal Data are:

Unique Identifiers: We use unique identifiers such as cookies, e-mail or your pseudonymized customer ID to track individual usage behavior on our Service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our Service on an individual basis.

Cookies: Like many websites, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service.

Use of Personal Data
Accrualify uses Personal Data to: (i) make and/or receive payments, (ii) provide and administer our Service; (iii) fulfill requests you make; (iv) protect, investigate, and deter against fraudulent, harmful, unauthorized, or illegal activity and (v) comply with legal obligations.

For example, we use Personal Data to:

  • Make and receive payments
  • Operate the Service
  • Learn more about our users and their behaviors
  • Facilitate communications among and between users
  • Provide user support
  • Communicate with users regarding support, security, technical issues, commerce, marketing, and transactions
  • Facilitate marketing, advertising, surveys, contests, sweepstakes, and promotions
  • Administer the Service, User Accounts, and transactions with respect to User Accounts
  • Enforce our contracts, administering and carrying out our obligations under contracts, and complying with the law
  • Complete corporate transactions such as mergers, sales of assets, or bankruptcies

PROCESSING GROUNDS

We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our Service:
  • Contact Information
  • User Account Information
  • Financial Account Information
  • Transaction Information
  • Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:
  • Contact Information
  • Financial Account Information
  • User Account Information
  • Transaction Information
  • Log Data

Examples of these legitimate interests include:

  • Operation and improvement of our business, products, and services
  • Marketing of our products and services
  • Provision of customer support
  • Protection from fraud or security threats
  • Compliance with legal obligations
  • Completion of corporate transactions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

HOW AND WITH WHOM DOES ACCRUALIFY SHARE PERSONAL DATA?

We share Personal Data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to the Service. These parties include:

  • Third parties who act for us or provide services for us, such as payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting, and database management services
  • Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance, and corporate governance
  • Accrualify Affiliates, including persons or entities that acquire some or all of Accrualify or our assets
  • Co-sponsors and presenters of webinars and events that you attend

We also share Personal Data with third party service providers and agents when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested.

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • Protect us, our business or our users, or third parties, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
  • Maintain the security of our products and services

We also share information with third parties when you have given us consent to do so.

Use of Third-Party E-mail Address
If you register for the Service using an e-mail address that we recognize to be either a part of a third-party enterprise account for the Service (an “Enterprise Account”) or a potential enterprise Service purchaser (for example, your employer’s) (each, an “E-Mail Holder”), we may provide your name and email address to the E-Mail Holder and their administrator. In some cases, we will also consolidate your account(s) with the accounts of the E-Mail Holder and we provide your E-Mail Holder and their administrator with access to your User Account information. This may happen when the E-Mail Holder’s account is established after you register for your individual User Account. We make these transfers to allow users who are part of a larger organization to take advantage of the special features and security enjoyed by our enterprise Account holders, and in order to help you and your organization comply with its internal security and email usage obligations. Please note that all accounts for the Service, and all applicable subaccounts (which may include your User Account), are controlled by the account administrator.

Business Transfers
Accrualify may sell, transfer, or otherwise share some or all of its business or assets, including your Personal Data, in connection with a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of Accrualify or its assets may continue to use your Personal Data as set forth in this Privacy Policy. You will be notified via email and/or a prominent notice on our Website or Service of any change in ownership or resulting change in uses of your Personal Data, as well as any choices you may have regarding your Personal Data. Similarly, if you access the Service as part of a third party Enterprise Account, the individual or entity controlling the Enterprise Account may transfer or otherwise share the account (including your User Account, User Content, and Personal Data) to an acquirer of some or all of its assets in connection with the migration to an E-Mail Holder’s account, or a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets, or in the event of bankruptcy.

YOUR PRIVACY CHOICES (Opt Out)

To opt out of having your personal information stored please email privacy@accrualify.com. Please keep in mind to use the Service certain information is required and you will be notified if you are unable to continue using the services upon your request.

Our Cookie Management Tool: We also allow you the ability to opt out of certain types of Cookies by clicking on the cookie banner when you first enter the applicable website (for EU and Swiss users).

Emails: We will give you the ability to opt-out of marketing-related emails by specifically emailing privacy@accrualify.com, or clicking on a link at the bottom of each such email. You cannot opt-out of receiving certain non-marketing emails regarding the Service.

Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at privacy@accrualify.com. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service.

When we transfer your information to third party companies (e.g. analytics or web hosting vendors), we will ensure they maintain the same level of security as us.

SECURITY

We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse, and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit, data encryption at rest, and enforcement of least privilege and need-to-know principles.

DATA RETENTION

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service. In some cases we retain Personal Data, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Data. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

WHAT RIGHTS AND CHOICES DO YOU HAVE REGARDING YOUR PERSONAL DATA?

Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights
You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up-to-date. We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

If you are an Accrualify account holder, you can accomplish most of the following by logging into your User Account or, for those using enterprise accounts, by contacting your account administrator. You can also contact us directly at privacy@accrualify.com if you have any additional requests or questions:

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.

Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. For the following, please email us at privacy@accrualify.com:

Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.

Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.

Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

You also have the right to lodge a complaint about Accrualify’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, you can also submit your complaint to Privacy Trust, an independent third party. Visit https://www.privacytrust.com/drs/accrualify to file a complaint.

Finally, as a last resort and in limited situations, EU or Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

Closing Your Account
You may close an account, and upon termination of your User Account, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, Accrualify may nevertheless retain your Personal Data to protect the business interests of Accrualify, Accrualify Affiliates, vendors, and other users, and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.

California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Data that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Data that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Accrualify pursuant to Section 1798.83 of the California Civil Code, please contact as set forth above.

ENFORCEMENT AND RECOURSE

We take our privacy commitments very seriously. We will conduct internal audits of our compliance with this Privacy Policy, and work to ensure that our employees and service providers also adhere to the Privacy Policy. If you have any questions or concerns regarding privacy related to the Service, please send us a detailed message to privacy@accrualify.com, and we will try to resolve your concerns.

If you are unhappy with how we deal with your complaint, or the outcome, you may invoke binding arbitration or refer your complaint to a data panel.

In compliance with the Privacy Shield Principles, Accrualify commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Accrualify at privacy@accrualify.com.

Accrualify has further committed to refer unresolved Privacy Shield complaints to PrivacyTrust, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.privacytrust.com/drs/accrualify for more information or to file a complaint. The services of PrivacyTrust are provided at no cost to you.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via email (if you have an account where we have your contact information) or otherwise in some manner through the Service that we deem reasonably likely to reach you (which may include posting a new privacy policy on our Website—or a specific announcement on this page or on our blog). Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting) or on the Effective Date set forth in the modified Privacy Policy. In all cases, your continued use of the Service or Website after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

CHILDREN

Our Service is not intended for children under the age of 18 (16 in the EU), and therefore, Accrualify does not knowingly acquire or receive Personal Data from children under the age of 18 (16 in the EU). If we later learn that any user of our Service is under the age of 18 (16 in the EU), we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.

WHAT IF YOU HAVE QUESTIONS REGARDING YOUR PERSONAL DATA?

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at privacy@accrualify.com.

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