Effective date: 15 March 2024
Last Reviewed: 15 March 2024
Here at Mashgin, Inc. (hereafter simply “Mashgin” or the “Company”), we know that you care about how your personal data and information is used and shared, and we take our obligation seriously to be good stewards of the privacy of your data. By using or accessing any of Mashgin’s websites, products, services, or applications, which for the avoidance of doubt includes any use or access via devices hosted by any affiliated third-party partners, and otherwise in any manner and without limitation, hereafter collectively referred to as the “Services”, you hereby acknowledge that you accept the practices and policies outlined in our Privacy Policy, and you hereby consent that Mashgin may collect, use, transmit, process, and share your information as described in the following Policy.
This Privacy Policy covers Mashgin’s treatment of Personally Identifiable Information (hereafter “Personal Information”, “Personal Data”, or simply “PII”) that we gather when you access or use our Services, but does not cover the practices of other companies over whom we have no ownership or control (including, without limitation, our affiliated third-party partners), or people whom Mashgin does not manage or oversee. Mashgin gathers various types of Personal Information from our users, as explained in more detail below, and we use this PII internally in connection with our Services, such as by offering personalization, providing and improving our products and services, enabling you to set up a user account and profile, contacting you when required, fulfilling your requests for certain products and services, and analyzing how you use the Services. In certain cases, we may also share some Personal Information with third parties, but only as described below.
We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact our Privacy team by writing an email to privacy@mashgin.com.
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on the Services, by sending you an email, or by other appropriate means. Please kindly note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will nonetheless still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, you thereby agree to all of the changes.
Information You Provide to Us: We receive and store any information you knowingly provide to us. For example, through the check-out or registration process or through your account settings, we may collect Personal Information such as your name, email address, phone number, or credit card information. Certain information may be required to register with us or to take advantage of some of our features.
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. If you do not want to receive communications from us, please indicate your preference by contacting us at privacy@mashgin.com.
Information Collected Automatically: Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, cookie information, the type of browser or device you’re using to access our Services, and the page or feature you requested. Cookies are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people.
You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. Also, if you click on a link to a third-party website or service, such third-parties may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third-parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third-parties may continue to track your activities online even after you have left our Services, and those third-parties may not honor “Do Not Track” requests you have set using your browser or device.
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services. For example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
Information Collected From Other Websites and Do Not Track Policy: Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support “Do Not Track” requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
We may share your Personal Information with third-parties as described in this below:
Affiliated Businesses: In certain situations, businesses or third-party websites we’re affiliated with may sell or provide products or services to you through, or in connection with, the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to scan or purchase certain items from our third-party partners via kiosks or scanning devices. Such services may automatically transmit certain data collected during such transactions to us and our third-party partners affiliated with such services. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else so if you choose to take part in any transaction or service relating to an affiliated website or business, we ask that you please review all such businesses’ or websites’ policies.
De-Identified Information: We may de-identify or pseudonymize your Personal Information so that you are not identified as an individual and then provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.
Advertisers: We allow advertisers and merchant partners (“Advertisers”) to choose the demographic information of users who will see their advertisements or promotional offers, and you hereby agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements or offers. For example, we might use the fact you are located in San Francisco to show you ads or offers for San Francisco businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage information to Advertisers except in aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. For example, we may use a payment processing company to receive and process your credit card transactions for us. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
Business Transfers: We may choose to buy or sell assets, and may share or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third-party.
Protection of Mashgin and Others: We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; or enforce or apply other agreements; or protect the rights, property, or safety of Mashgin, our employees, our users, or others.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Mashgin seeks to comply with the E.U. and U.K.’s General Data Protection Regulation, or simply the “GDPR.” Under the GDPR, Data Subjects are granted the following data privacy rights, among many others, and we provide a brief overview of those core rights for your reference and to reaffirm Mashgin’s commitment to complying with the GDPR:
Mashgin, as Data Processor, maintains its lawful basis for data processing in the E.U., E.E.A., and the U.K. under the scope of the GDPR by merit of providing point-of-sale and self-checkout services strictly in the fulfillment of its contractual obligations to its clients, the locally based Data Controllers. Because Mashgin limits the data processed solely to that data, which is strictly required to provide the Company’s products and services, Mashgin holds that it maintains adequate grounds for necessity and proportionality with regards to its processing activities.
Mashgin processes Personal Information from E.U. and U.K. citizens solely on the legal basis of fulfilling its contractual obligations, and by obtaining consent from the Data Subject. Mashgin websites display an opt-in or opt-out cookie banner for visitors from relevant regions as is appropriate per site to collect user consent, as well as for Mashgin web-based applications like Mashgin Cloud, which require registration for user account creation.
Your data will be stored only for as long as it is necessary to provide our services, to meet our obligations to you and meet our legal obligations. For more information, please contact us about our Data Retention Policy by sending a message to privacy@mashgin.com. Mashgin maintains current information on the retention policies of its cookies via its publicly accessible Cookie Table. For Personal Data associated with Mashgin Cloud accounts, accounts are retained until client off-boarding or upon request. Mashgin maintains a GDPR-compliant and publicly accessible Data Map you may reference for the types of Personal Data we process as well as their retention periods.
In the normal course of its business, Mashgin acts as Data Processor to fulfill its contractual obligations to the Data Controller within the E.U., E.E.A., and the U.K. to provide point-of-sale and self-checkout products and services. Mashgin processes basic transaction data to enable sales, enable basic reporting for clients, and issue refunds and receipts. Mashgin processes limited Personal Data to enable basic functionality and navigation on its web-dashboard Mashgin Cloud, which enables managerial functions and reportings for our clients per contract. Mashgin does not benefit from the processing of this Personal Data in other ways, such as marketing outreach.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@mashgin.com.
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@mashgin.com, and we will try to resolve your concerns.
To exercise any of your rights under the GDPR in regards to Data Processing at Mashgin, such as those rights previously enumerated in this Policy, please send our Privacy team a message at privacy@mashgin.com. You have the right to request access to your Personal Information at no cost. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or otherwise excessive. We will respond to your request within one month of receipt. In cases of complex or numerous requests, this period may be extended by two months at our discretion.
Should you have specific questions relating to Mashgin’s services in the E.U. or U.K., such as regarding the General Data Protection Regulation or “GDPR”, please refer to the following contact details should you have any specific questions to be routed to Mashgin’s E.U. or U.K. Representatives:
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our Data Protection Agent:
Instant EU GDPR Representative Ltd.
INSTANT EU GDPR REPRESENTATIVE LTD
Office 2, 12A Lower Main Street, Lucan Co. Dublin
Ireland, K78 X5P8
Adam Brogden: contact@gdprlocal.com
Tel +35315549700
Under Article 27 of the U.K. Data Privacy Act, we have appointed a U.K. Representative to act as our Data Protection Agent:
GDPR Local Ltd
1st Floor Front Suite, 27-29 North Street,
Brighton, England
Adam Brogden: contact@gdprlocal.com
Tel. +44.1772.217800
For other data privacy or GDPR-related inquiries, please send a message to Mashgin’s Data Protection Officer “DPO” via the following contact details:
Cody Dales
Vice President, Special Projects and Compliance
Tel. +1.276.312.9295
