- Clip: Payclip, Inc and its subsidiaries.
- Personal Data: any information concerning an identified or identifiable individual.
- Sensitive Personal Data: personal data that affect the most intimate expectation of its owner or whose improper use may give rise to discrimination or entails a serious risk to the owner. In particular, are considered sensitive those that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, trade union, political opinions, sexual preference.
- Privacy Notice: document in physical, electronic or any other format, generated by the data controller, that is made available to the data owner prior to the processing of their personal data or legal person of a private nature who decides on the processing of personal data.
- Processing: retrieval, use, disclosure, or storage of personal data by any means. Use covers any action of access, management, exploitation, transfer, or disposal of personal data.
The purpose of PayClip, Inc. and its subsidiaries (hereinafter, Clip) is to respect and guarantee the privacy and confidence of our clients, employees, associates, suppliers, among others with whom we do business. Accordingly, Clip strives to process Personal Data consistent with the laws of the countries we have a commercial relationship with.
All of Clip’s employees, department leaders, and associates who are involved in the processing of personal data must comply with this Policy.
The Policy applies worldwide, either physically or electronically, as well as the regulatory particularities of each jurisdiction.
- Data Protection Principles
In the course of Clip's activities and services, Personal Data of various data owners will be subject to processing. Therefore, all Clip employees must act in accordance with the following principles:
- Lawfulness, Fairness, Honesty and Transparency.
Clip’s employees must ensure all Personal Data is not used inappropriately and for different purposes other than the rendering and development of our products and services always in accordance with the legal provisions that apply to the case.
- Purpose limitation or specification.
All personal data collected by Clip must have a determined, specific, and legitimate purpose. Any further processing must not be incompatible with the purposes specified at the outset.
Thus, all of Clip’s employees must guarantee that the Personal Data collected is only used for the purposes described in its Privacy Notices.
Employees should review and guarantee that only the Personal Data that is necessary and relevant for the purposes stated in Clip’s Privacy Notices is the one processed. Any exceptions to this must be very limited and clearly defined.
Personal Data must be accurate throughout processing. That is why all employees must take every reasonable step to ensure this. This includes the following elements:
- Accuracy: all Personal Data processed must be accurate throughout the data lifecycle.
- Complete: any category of Personal Data must be complete to the extent possible that the omission of relevant data may not lead to the inference of different information.
- Up to date: any Personal Data stored by Clip must be kept up to date.
- Limited: Personal Data should only be processed for the period it is required for the purpose for which it was collected.
- Storage Limitation.
Personal Data should only be retained for the period required for the purpose for which it was originally collected and stored.
Thus, all of Clip’s employees must delete Personal Data at the end of its processing. This means that Personal Data should not be kept longer than necessary, according to the purpose for which it was originally obtained.
In addition to the above, if Clip comes across another use of the Personal Data, this will not justify its indefinite retention. Consequently, the period it is necessary to store personal data will be context-specific, however, this should be guided by the corresponding legislative obligations.
Last, Clip will establish retention schedules, specifying the retention periods for all the Personal Data it holds. And all its employees have the obligation of keeping such schedule under regular review.
- Integrity and Confidentiality.
Personal Data should be protected by security measures against risks, such as, unlawful or unauthorized access, use and disclosure, as well as loss, destruction, or damage.
These security measures include:
- Physical measures, such as locked doors and identification cards.
- Organizational measures, such as access controls.
- Technical measures, such as encryption, pseudonymization, and anonymization.
Nonetheless, other organizational measures include the periodic testing of the adequacy of these measures, implementation of data protection and information security policies, and training.
The foregoing without prejudice that the Personal Data Protection Department may implement additional measures.
In Clip we must comply with data protection standards, laws, and regulations. Therefore, Clip will implement policies, standards and controls to prove or demonstrate how we comply with data protection legislation, including its principles and obligations, guaranteeing the rights of personal data owners.
- Personal Data Security
Any unauthorized processing of Personal Data by employees is prohibited. That is why every employee must make sure that he or she only processes Personal Data as part of his or her legitimate duties.
Additionally, employees may have access to Personal Data only as appropriate for the tasks they must execute, which requires the definition and implementation of roles and responsibilities.
Employees are prohibited from disclosing Personal Data to unauthorized persons or to make it available in any other way outside the permitted business use. Therefore, every employee must be informed at the start of their employment relationship about the obligation to protect Personal Data, which shall remain in force even after their employment relationship with Clip has ended.
All of Clip’s employees are responsible for reading and complying with this Policy and related policies, as well as for reporting violations of this Policy.
Additionally, the leaders of Clip’s departments are responsible for ensuring all their employees understand the requirements of this Policy, as well as for ensuring appropriate safeguards are in place to protect Personal Data, and for providing all necessary training and guidance.
- Review and Modification
This Policy will be reviewed periodically, and its modifications will be informed in a timely manner.
For further information specific to applicable legislation were we have operations, please review:
Privacy Notice: [*]
Privacy Notice: [*]