Effective Date: February 14, 2020

If you are a merchant Copper works with, please click here.

Copper Inc. (“Copper,” “we,” “us,” or the “Company”) provides our clients with plug and play hardware that unlocks item-level transaction data in any Point of Sale (POS) environment and makes it available via a single API. API stands for "Application Programming Interface", which is a software intermediary that enables two or more applications to communicate with one another. APIs enable organizations to extract and share data in an accessible manner.

This Privacy Policy (“Policy”) describes how we collect, use, disclose, transfer, store, retain, or otherwise process your information when you access Copper services (including, but not limited to the Copper Checkout mobile web application, a digital receipt, or any Copper API products) through Copper’s website or applications (collectively, the “Services”); or otherwise contact or interact with us.

Please read this Policy carefully. By continuing to interact with our Services, you are consenting to the practices described in this Policy.

INFORMATION WE COLLECT ABOUT YOU

We need to collect information about you to provide you with our Services or the support you request. Additionally, you can choose to voluntarily provide information to us.

Information You Provide

We collect information you provide when you visit Copper’s public website, usecopper.com, upload or send to or through our Services, communicate with us, answer our surveys, make a payment at a Merchant using our Services, or otherwise use or access our Services.

We call this information “Customer Data.”

Specifically, we collect the following categories of information:

· Identification Information. Name, email address, mailing address, phone number.

· Financial Information. Bank account and payment card numbers.

· Transaction Information. When you use our Services to make a payment or request delivery of a receipt from a Merchant using our Services, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions which may include item-level data, the payment amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.

· Other Information You Provide. Information that you voluntarily provide to us, including your survey responses; participation in contests, promotions, or other forms or devices; suggestions for improvements; referrals; or any other actions performed on our Services.

Information We Collect from Your Use of Our Services

We collect information about you and the devices you use to access our Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

· Location information. The location of your device if you pay with Apple Pay or Google Pay. You can disable collection of location information by changing the preferences on your mobile device or by choosing to pay with a payment instrument other than Apple or Google Pay.

· Device information. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services.

· Internet or other electronic network activity information. Information about how you use and interact with our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your internet service provider, other attributes about your browser, mobile device, and operating system, features you use, and the date and time of your visit to or use of our Services.

· Customer Information. Information you provide to a Merchant using our Services, for example if you are a customer who provides a Merchant with your email address, phone number, payment information, or other information.

SOURCES OF INFORMATION WE COLLECT ABOUT YOU

Besides collecting information directly from you and from how you use our services, we also collect information about you from other sources, including:

· Information Entered by Merchants. Any information a Merchant enters into our systems about you.

· Identity Verification. Information from third parties and publicly available sources.

· Credit, Compliance, and Fraud. Information about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

HOW WE USE YOUR INFORMATION

We may collect, use, and share information about you for the following reasons:

Providing, Improving, and Developing our Services

· Processing or recording payment transactions;

· Displaying your historical transaction information;

· Providing, maintaining, and improving our Services;

· Developing new products and Services;

· Delivering the information and support you request;

· Improving, personalizing, and facilitating your use of our Services;

· Measuring, tracking, and analyzing trends and usage in connection with your use or the performance of our Services; and

· Otherwise providing you with the products and features you choose to use.

Communicating with You About our Services

· Sending you surveys and getting your feedback about our Services;

· Providing information about and promoting our Services to you; and

· Sending you information we think you may find useful or which you have requested from us about our products and services.

Protecting our Services and Maintaining a Trusted Environment

· Conducting investigations, complying with and enforcing any applicable laws, regulations, legal requirements, and industry standards, and responding to lawful requests for information from the government or to valid legal process;

· Contacting you to resolve disputes and help you with our Services;

· Debugging to identify and fix errors that impair how our Services function;

· Enforcing our General Terms or other applicable agreements or policies;

· Investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, or other potentially prohibited, malicious, or illegal activities;

· Protecting our, our Merchants’, or your rights or property, or the security or integrity of our Services;

· Verifying or maintaining the quality and safety of our Services; and

· Verifying your identity.

Advertising and Marketing

· Marketing our Services to you; and

· Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys, and rewards offered by us and select partners.

If we send you marketing emails, each email will have instructions on how you can “opt out” of getting future marketing from us.

To learn about what choices you have about interest-based advertising and cross-device tracking, please see the “Cookies and Other Similar Technologies” section below;

Other Uses

· For any other reason we may tell you about from time to time.

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We may share the information described in the “Information We Collect About You” section with the following categories of service providers and third parties:

With Other Users of our Services with Whom You Interact

· With other users of our Services (e.g., Merchants) with whom you interact through your own use of our Services. For example, we may share information when you make a payment with a Merchant.

With Our Service Providers

· With service providers who help us provide, maintain, and improve our Services (e.g., vendors who help us with fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, partners, and other entities that help us provide our Services;

· With service providers that help us run our advertising campaigns, contests, special offers, or other events or activities.

Business Transfers and Corporate Changes

· To a subsequent owner, co-owner, or operator of one or more of our Services; or

· If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

· If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise, or defend our legal rights; (iii) to enforce or comply with our General Terms or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

· With your consent. For example:

o At your direction or as described at the time you agree to share; or

o When you authorize a third-party application or website to access your information.

With Others

· With other companies who deliver services on our behalf, including via the use of cookies and similar automated technologies and third-party analytics.

Aggregated and Anonymized Information

· We also may share (with service providers or other third parties) aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

When you interact with our online services, or open emails we send you, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.

We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to:

· Remember your information so you do not have to re-enter it;

· Track and understand how you use and interact with our online services and emails;

· Tailor our online services to your preferences;

· Measure how useful and effective our services and communications are to you; and

· Otherwise manage and enhance our products and services.

We set some of these automated technologies ourselves, but others are set by third parties who deliver services on our behalf. For example, we may use other companies’ web analytics services (described in the “Third-Party Analytics Services” section), which use automated technologies to help us evaluate how customers use our websites.

Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.

THIRD-PARTY ANALYTICS SERVICES

We may use third-party analytics service providers to help us with our online services, such as Google Analytics and Facebook. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.

· To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=en.

· To learn more about how Facebook uses your data please visit https://www.facebook.com/help/325807937506242/ or log on to your Facebook account and access your settings. To understand more about Facebook advertising, please visit https://www.facebook.com/about/ads.

HOW LONG WE KEEP YOUR INFORMATION

We generally keep your information as long as reasonably necessary to provide you our Services or to comply with applicable law. However, we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.

YOUR CHOICES

Personal Information

You may access, change, or correct information that you have provided by making a request to us using the contact details below. We may need to verify your identity before granting access or otherwise changing or correcting your information.

Location Information

In order to provide certain Services (like let you use Apple Pay or Google Pay), we may request access to location information, including precise geolocation information collected from your device. If you do not consent to the collection of this information, certain Services will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, mobile payments may no longer function.

Do Not Track

Certain web browsers allow you to instruct your browser to respond to Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites are not designed to respond to DNT signals or similar mechanisms from browsers.

Promotional Communications

You may opt out of receiving promotional messages from Copper or Merchants using our Services, if those messages, are powered by Copper, by following the instructions in those messages. Opting out of receiving communications may impact your use of our Services. If you decide to opt out, we may still send you non-promotional communications, such as digital receipts.

RIGHTS OF CALIFORNIA RESIDENTS

If you live in California, you also have rights under the California Consumer Privacy Act (“CCPA”) to request certain information from certain businesses that collect that information from you. We are generally a service provider of the Merchants using our Services (for example, we’re a service provider for a restaurant that accepts your payment using Copper). Where we are a service provider, the Merchant is the “business” under CCPA and you can exercise your CCPA rights directly with the Merchant.

Here are the rights that CCPA gives to California residents that you may be able to exercise with a Merchant using our Services:

Right to Know

You may have the right to request, up to twice in a 12-month period, to see the following information about the personal information a Merchant has collected about you during the past 12 months:

· The categories and specific pieces of personal information the business has collected about you;

· The categories of sources from which the business collected the personal information;

· The business or commercial purpose for which the business collected the personal information;

· The categories of third parties with whom the business shared the personal information; and

· The categories of personal information about you that the business disclosed for a business purpose, and the categories of third parties to whom the business disclosed that information for a business purpose.

California law gives you the right to ask if the business discloses your personal information to third parties for their direct marketing purposes. You also have the right to know if the business sells your personal information, and if they do, to opt out of such sale.

Right of Deletion

You can ask the business to delete the personal information they have collected from you (subject to exceptions the law provides).

Right of Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. The business cannot discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

How to Exercise Your Rights

To the extent we act as the Merchant’s service provider (for example, when we process your payments on their behalf), you can exercise your CCPA rights directly with the Merchant(s) you use.

CHILDREN’S PERSONAL INFORMATION

Our services are general audience services not directed at children under the age of 13. If we learn that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.

HOW WE SECURE INFORMATION

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

For more information about our security practices, please contact us privacy@usecopper.com.

STORAGE AND PROCESSING

We may, and we may use third-party service providers to, process and store your information in the United States, Canada, Japan, the European Union, and other countries.

CHANGES TO THIS PRIVACY NOTICE

We may amend this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, including by email, if you have provided one. If you disagree with these changes, you may stop using our services at any time. Your continued use of our services constitutes your consent to any amendment of this Privacy Notice.

HOW TO CONTACT US

Please contact our Privacy Department with any questions or concerns regarding this Privacy Notice.

Copper, Inc.
10753 Harbottle Dr.

Reno, NV 89511

privacy@usecopper.com