Privacy and Cookie Policy

This Privacy and Cookie Policy (this “Policy”) describes the ways in which Juniper Square, Inc., a Delaware corporation and its subsidiaries, affiliates, and related entities (collectively,“Juniper Square”, “us” or “we”) collects, uses, and discloses information about you, including personally identifiable information. This Policy applies to any Juniper Square software platform or application, together with any related managed services, implementation services, professional services, consulting, support, and training we provide (collectively, the “Services”). Throughout this Policy, “you” refers to the individual or entity that is an end user with access and use of the Services as a direct customer of Juniper Square (a “Provider”) or through your relationship with a Provider. Please note that we are not responsible for the privacy or data security practices of Providers, which may differ from those explained in this Policy. For the privacy information related to the Juniper Square Provider you are associated with, please contact that Provider directly. You can also update your contact information and other Personal Information by accessing your account/profile page within the Juniper Square product.

By accessing and using the Services, you consent to the use of your information as set forth in this Policy .

1. This Policy
   1. Scope . In the course of providing the Services Juniper Square may collect Personal Information. “Personal Information” means any information that can personally identify you directly or indirectly, such as your name or contact details, log-in credentials, or online identifiers. Juniper Square processes your Personal Information to perform the Services, or as specifically set forth in this Policy.
   2. Changes to this Policy . Juniper Square reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material Juniper Square may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the System after such changes have been made constitutes acceptance of those changes.
2. Collection of Information.
   1. Information that You Provide . Juniper Square collects any information that you directly provide to us such as when you register or use the Services or when you communicate or interact through the Services to us or a Provider. Personal Information that you provide may include but is not limited to your email address, name, phone number, postal address, location, financial and banking information.
   2. Automatically Collected Information . Juniper Square may automatically collect certain technical information from your computer or mobile device when you use the Services, such as your Internet Protocol (IP) address, your web browser type and version, the name and version of your operating system, the features you view or use in connection with the Services, and the search terms, chat content, or support requests.
   3. Information about Legal and Other Materials . In addition, Juniper Square may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials, approval or execution of contracts, consents or other statements or agreements by means of the Services.
   4. Cookies . Juniper Square may collect this information using “cookies,” which are small text files that the System saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the System. For further information, see the Cookie Policy in Section 3 below.
   5. Tracking Pixels . Juniper Square may also collect information using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help Juniper Square compile information about your interactions with electronic mail sent to you in connection with the Services.
   6. Information We Collect on Behalf of Providers . In providing the Services, we process Personal Information on behalf of and under the instructions of Providers. We process such Personal Information as a service provider or processor (as defined by applicable law), on Providers’ behalf. In addition, Juniper Square may collect Personal Information about you from Providers or other third-party sources. For example, a Provider who invited you to use and/or register an account on the System may facilitate the account registration process by uploading certain information about you.
   7. Cross-Site Tracking . Juniper Square does not utilize technical measures in the Services to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise. The Services do utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
3. Cookie Policy. This section provides Juniper Square’s cookie policy and describes how Juniper Square uses Cookies and similar technologies.
   1. What are Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Juniper Square uses cookies, web beacons and similar technologies (“Cookies”) to enable your user experience and to understand your usage of the Services. Juniper Square uses two types of Cookies: (i ) Session Cookies are temporary Cookies that remain on your device until you exit the Services. (ii) Persistent Cookies may remain on your device for much longer until you manually delete it, or it automatically expires.

   2. How We Use Cookies.
       

      Type of Cookie	Example Uses	Some Services We Use
      Essential Cookies  These cookies are necessary for the product to function and cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.	Keeping you logged in as you move between product features Remembering the items in a form you're filling out Detecting and preventing fraudulent or abusive activity Managing your cookie consent preferences (so we don't ask you every visit)	Datadog Cloudflare
      Performance Cookies These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our product. All information these cookies collect is aggregated and therefore anonymous.	Reviewing heatmaps to see where people click and scroll, to improve user experience layouts Tracking the usage of features and functionality across user types	Mixpanel Amplitude Intercom
      Functional Cookies These cookies enable the product to provide enhanced functionality and personalisation. If you do not allow these cookies then some or all of the Services may not function properly.	Powering the live chat window so you can message our team in real time Pre-filling your name or email if you've submitted a form previously Remembering your language or regional preferences	Forethought Wistia Skilljar Adobe

   3. Third-Party Cookies. An example of the third-party cookies you may see are indicated in the chart above. We carefully select our third-party partners and review their data practices. We do not sell your personal information to third parties.

   4. Your Choices.  Here are the ways you can manage cookies on our site:

      Cookie Settings	Use our Cookie Settings link to review and update your preferences at any time. You can turn off Performance, Functional, and Marketing cookies independently. Essential cookies cannot be switched off.
      Browser Settings	All modern browsers let you block or delete cookies. Visit aboutcookies.org for step-by-step instructions for your browser. Note: blocking all cookies may affect how some parts of our product work.
      Opt Out of Ads	You can opt out of personalized advertising from Google at myadcenter.google.com, and from many other ad networks via the Digital Advertising Alliance at optout.aboutads.info.
      Do Not Track	Our product does not currently respond to Do Not Track browser signals. While some internet browsers offer a “do not track” or DNT option that lets you tell a website that you do not want your online activities tracked, these features are not uniform and the common standard framework has been abandoned by the W3C consortium leading that effort. However, you can use our Cookie Settings and Privacy Request Center to control data associated with your browser or device.
      Do Not Share	If you would like to opt-out of sharing identifiers, turn on a Global Privacy Control in your web browser or browser extension.

4. Use and Disclosure of Information . Juniper Square may collect, use, share, and otherwise process (“Use”) your Personal Information for a number of purposes. We only Use your Personal information to the extent necessary for fulfilling these purposes and where we can rely on a legal basis for such processing. Where legally required we will ask you for your prior consent to processing. The purposes and legal bases are:
   1. Providing the Services. Juniper Square may Use your Personal Information to provide you with the Services; providing you with information about the Services or required notices; customizing your experience when using the Services, such as by providing you with interactive or personalized elements based on your usage and needs. The legal basis for processing this information is the performance of contractual obligations or as necessary to comply with legal requirements.
   2. Analysis. Juniper Square may Use your Personal Information for improving the Services, including by (i) combining or aggregating any of the information collected for generating and analyzing statistics about your use of the Services and user demographics; (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. Juniper Square does not attempt, nor is able, to re-identify individuals based on aggregated and anonymized data. The legal basis for this processing is consent and Juniper Square’s legitimate interest in improving the Services.
   3. Security. Juniper Square may Use your Personal Information for safety and security purposes when it is necessary to pursue Juniper Square’s legitimate interests in ensuring the security of the Services such as detecting, preventing and responding to fraud, intellectual property infringement, violations of law, or other misuse of the Services; or when Juniper Square believes in good faith that disclosure is necessary to protect Juniper Square’s rights; the rights of Providers or other users of the Services; the integrity of the Services; or your safety or the safety of others.
   4. Service Providers. Juniper Square may Use your Personal Information when engaging third-party service providers (such as payment processors, hosting providers, analytics, and security providers) to assist in operating and marketing the Services. Juniper Square’s engagement of third-party service providers is often necessary for Juniper Square to provide the Services to you, particularly where such third-party service providers ensure that the Services are operating and secure. In other cases, Juniper Square has a legitimate interest in third-party service providers that can help improve the Services.
   5. Other Disclosure. Juniper Square may Use Personal Information: (a) if Juniper Square has your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the Juniper Square terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. Juniper Square may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of Juniper Square’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that Juniper Square transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.
   6. Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, and/or telephone, providing support services and complaint handling. The legal basis for this processing is based on fulfilling our contractual obligations in providing the Services. Mobile phone numbers collected for SMS communications, and all SMS opt-in data and consent records will not be shared with third parties or affiliates for marketing or promotional purposes. In addition, text messaging originator opt-in data and consent information will not be shared with any third-parties.
5. International Data Transfers. Your Personal Information may be Used by us in the United States and by our affiliates and third-parties. Therefore, your Personal Information may be transferred outside your country or jurisdiction, including in places that are not subject to an adequacy decision by your local legislature or regulator, and that may not provide for the same level of data protection as your location. For users located in the EEA or the United Kingdom, Juniper Square transfers personal data to the United States on the basis of appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office, as applicable. To obtain more information about these transfer mechanisms or to request a copy, please contact privacy@junipersquare.com. Where required by applicable law, we will obtain your consent before processing, sharing, transferring and/or storing your Personal Information outside of your jurisdiction. See Section 8 for additional information around your rights in the EEA or UK.
6. Storage.
   1. Jurisdiction. Personal Information collected through the Services may be stored in, processed in, and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Services, you consent to such transfer to, storage in, and processing within the United States.
   2. Security. Juniper Square is committed to protecting your information from unauthorized access, use or disclosure. The Services and its operators maintain administrative, technical, and physical safeguards designed to protect the information collected through the Services. For example, all information you transmit to the product is encrypted using Transport Layer Security technology (TLS). However, no information or communication system can be 100% secure, so Juniper Square cannot guarantee the absolute security of your information. In addition, Juniper Square is not responsible for the security of information that you transmit to us over networks that Juniper Square does not control, including the Internet and wireless networks.
   3. Retention. Juniper Square will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Where Juniper Square processes your Personal Information on behalf of a Provider, Juniper Square will retain such information in line with the Provider’s instructions and Juniper Square’s contractual obligations. You may have the right to ask the Provider to delete or correct such Personal Information and Juniper Square will cooperate with the Provider in accommodating such request.
7. Your Rights Related to Your Personal Information.
   1. Your Rights. You may have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
      1. Access your Personal Information held by us;
      2. Know more about how we process your Personal Information;
      3. Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;
      4. Erase or delete your Personal Information;
      5. Restrict our processing of your Personal Information;
      6. Transfer your Personal Information to another controller (data portability), to the extent possible;
      7. Object to any processing of your Personal Information;
      8. Opt out of certain disclosures of your Personal Information to third parties;
      9. Know what categories of Personal Information are shared for delivering advertisements on non-Juniper Square websites, applications, and services and the categories of recipients of such Personal Information;
      10. Not be subject to a decision that produces legal effects based solely on automated processing, including profiling (i.e. Automated Decision-Making);
      11. Withdraw your consent at any time (to the extent we rely on consent as our legal basis for processing), without affecting the lawfulness of the processing based on such consent before its withdrawal;
      12. Complain about the use of your Personal Information;
      13. Not be discriminated against for exercising your rights as described above; and
      14. Appeal our refusal to act upon your request to exercise a right relating to your Personal Information by following the steps provided in our response to your inquiry.
   2. To exercise your rights, please contact the Provider associated with your use of the Services. Because we are processing the information based on their directions they will contact us directly. For Personal Information that is not associated with a specific Provider, you can contact us by using the Privacy Request Center . Your Personal Information may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.
8. Additional Notice to European Residents: General Data Protection Regulation
   1. If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), Juniper Square will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”) and relevant UK laws and regulations.
   2. For certain Personal Information that you provide when you use the Services. For instance, your account information used to access the Services, automatically collected information about your use of the Services and cookie data, Juniper Square, Inc. is the “Controller” as defined under GDPR). In accordance with GDPR, where Juniper Square processes your Personal Information as a Data Controller, in certain circumstances you will have certain rights, which may include the following:
      1. right of confirmation;
      2. right of access;
      3. right to rectification;
      4. right to erasure;
      5. right of restriction of processing;
      6. right to data portability;
      7. right to object;
      8. right to withdraw data protection consent; and
      9. the right to lodge a complaint with a supervisory authority.
   3. To exercise any of these rights, EEA and UK residents may submit a request through Juniper Square’s Privacy Request Center . Juniper Square will respond within 30 days of receipt of a valid request; where a request is complex or numerous, the response period may be extended by up to an additional 60 days, and Juniper Square will notify you of any such extension within the initial 30-day period. If you are an EU/EEA resident and have any questions about this Privacy Notice, how we handle your Personal Information, or would like to file a complaint, and do not see options available to you on the Privacy Request Center please see the Contact Us section below.
   4. For Personal Information that Juniper Square processes on behalf of Providers, Juniper Square is a Data Processor, as defined under GDPR. Juniper Square is not responsible for and has no control over the privacy and data security practices of Providers, which may differ from those explained in this Policy. The data protection rights listed above may apply differently to Juniper Square where Juniper Square processes Personal Information as a Data Processor on behalf of a Provider. If Juniper Square processes your Personal Information at the direction of a Provider, and you wish to exercise any rights you may have under the GDPR or other applicable data protection laws, please inquire with the Provider directly.
9. Notice to California Residents: California Consumer Privacy Act, as amended.
   1. As of January 1, 2023, verified California residents have the right to:
      1. request and receive disclosure of our personal information collection practices during the prior 12 months, including the categories of personal information we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
      2. request and receive a copy of the personal information we have collected about you during the prior 12 months;
      3. request and receive disclosure of our information sharing practices during the prior 12 months, including a list of the categories of personal information sold with the category of third party recipients and a list of the categories of personal information that we disclosed for a business purpose;
      4. request that we not sell personal information about you;
      5. request that we delete (and direct our service providers to delete) your personal information subject to certain exceptions;
      6. request that we correct inaccurate personal information we may have about you; and
      7. request that we limit the use and disclosure of sensitive personal information.
   2. For the purposes of this Section 9, “personal information” has the meaning given in the California Consumer Privacy Act (“CCPA”) as amended, but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA’s scope.
   3. In order to exercise these rights California residents may contact us via the Privacy Request Center . However, If Juniper Square processes your Personal Information at the direction of a Provider, and you wish to exercise any rights you may have under the CCPA or other applicable data protection laws, please first inquire with the Provider directly. Upon receiving your request w e will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be. We will acknowledge receipt of your request within 10 days and will endeavor to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of our need for additional time.We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.
      1. You may make a request for disclosure of our information collection practices, the information we collected about you, or our sharing practices up to twice within a 12-month period. You may make a request that we not sell information or for deletion of your information at any time.
      2. For requests for a copy of the personal information we have collected during the 12 months prior to your request, we will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.
      3. For requests for deletion of your information, please understand that California law permits us to retain certain information and not to delete it under certain circumstances. By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and to comply with legal obligations. If we receive such a request from you, we will notify any service providers we have engaged to delete your information as well.
      4. We will not discriminate against you as a result of your exercise of any of these rights.
   4. Selling Information . We do not sell, share, or disclose your information to third parties for monetary or other valuable consideration. If, in the future, we enter into arrangements that fall within the definition of a “sale” or “share” under the CCPA as amended, we will update this privacy policy and our compliance with the CCPA as amended.
   5. Using an Authorized Agent. You may submit a request through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

   6. During the past 12 months, we have collected the following categories of information from the listed sources, used it for the listed business purposes, and shared it with the listed categories of third parties. The business purposes for which we collect the Personal Information are described in Section 4 a bove.

      Category of Personal Information (PI) collected	Sources of PI	Purposes of collecting PI	Categories of third parties to whom we disclose PI
      Identifiers such as full name, date of birth, nationality, gender, email address, phone number, postal address, or employment related information including office location, and job title.	Information you provide us; information collected from third parties; information we may receive from Providers.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair ; customize user experience ; perform services for you or to Providers;	Third Party service providers (such as payment processors, identity verification providers); government regulators; law enforcement.
      Sensitive Information such as government issued identity document such as passport, driver's license, national identity card, state ID card, tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with legal obligations under applicable financial regulation and law	Information you provide us; information collected or received from Providers or third parties.	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you or to Providers; internal research and development.	Service providers (such as payment processors, identity verification providers); government regulators; law enforcement.
      Commercial information such as bank account information, payment card primary account number (PAN), transaction history, and/or tax identification number	Information you provide us; Information collected or received from third parties or Providers	To maintain legal and regulatory compliance; audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you or to Providers; internal research and development.	Service providers (such as payment processors, employee benefits partners); government regulators; law enforcement.
      Electronic network activity such as browsing or search history, IP address, website interactions and advertisement interactions	Information automatically collected from the Services	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you or to Providers; internal research and development.	Service providers government regulators; law enforcement.
      Audio, video, photographs or similar information such as customer service calls	Information you provide us; information collected from third parties; information we may receive from Providers	Audit transactions; security detection, protection and enforcement; functionality debugging/error repair; customize user experience; perform services for you or to Providers; internal research and development.	Service providers (such as payment processors and marketing partners); government regulators; law enforcement.
      Inferences drawn from the above about your preferences, characteristics, etc.	Internal analytics	To engage in marketing activities; internal research and development.	Service providers (such as marketing partners).

      As described above, where we act as a service provider or data processor to Providers who are users of our Services to process your Personal Information, we are not responsible for and have no control over the privacy and data security practices of such Providers. If your Personal Information has been submitted to us by or on behalf of a Provider and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Provider directly.

10. Third-Party Websites. The Services may contain links to websites operated by third parties, including sites operated by Providers. You acknowledge and agree that Juniper Square is not responsible for the collection and use of your information by such websites that are not under Juniper Square’s control. Juniper Square encourages you to review the privacy policies of each website you visit.
11. Children’s Information.The Services are not directed to, nor does Juniper Square knowingly collect information from, children under the age of 1 6. If you become aware that your child or any child under your care has provided information without your consent, please contact the Provider associated with your use of the Services.
12. Other Agreements. You may from time to time enter into binding legal agreements relating to certain Services available through the System, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.
13. Contact Us. If you have any questions about this Policy or the collection or use of information about you, please write to your Provider or to Juniper Square at privacy@junipersquare.com or 555 Montgomery Street, 14th Floor, San Francisco, CA 94111. If you are an EU/EEA resident and have any questions about this Privacy Notice, how we handle your Personal Information, or would like to file a complaint, please contact the Data Protection Officer at: DPO@junipersquare.com .