Updated: Dec. 1, 2021
I. WHAT PERSONAL INFORMATION WE COLLECT
"Personal Information" is data that relates to you that can identify you as an individual, either on its own or in combination with other information. Personal Information does not include data that has been aggregated or de-identified such that you can no longer be identified using means reasonably available to us. The Personal Information we actually collect depends on the nature and type of Squire Services you use or interact with. The types of Personal Information we may collect will fall in the following general categories:
- Profile Information: We collect certain information when you create or modify your account with us. This information may include name, birth date, email, phone number, postal address, profile picture, payment method, and other information you choose to provide.
- Location Information: If you permit the Squire Services to access geolocation information, such as through your mobile device's GPS signal or WIFI signal, we may collect the precise location of your device when the Squire Flagship or Commander mobile application is running in the foreground or background. We may also derive your approximate location through other device identifiers such as your IP address or WIFI MAC address.
- Transaction Information: We collect transaction details related to your use of the Squire Services, including but not limited to payment method, purchase amount, date of purchase, description of the goods or services purchased and other related transaction details.
- Enterprise Account Information: If you are an Enterprise Customer, we may collect financial and other sensitive personal information about you as part of your business relationship with us, including but not limited to your date of birth, social security number, tax number, Employer Identification Number, and bank account information.
- Device Information: We may collect information about your mobile device, including but not limited to, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
- SMS Data and Emails: Some Squire Services facilitate communications between Enterprise Customers and Consumer Users. In connection with facilitating this service, we may receive and collect communication data, including, but not limited to, the date and time of the SMS message or email, the parties' phone numbers or email addresses, and the content of the SMS message or emails.
- Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with the Squire Services.
- Other Information You Choose to Provide: We may collect information about your mobile device, including but not limited to, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.We collect any other information that you provide directly to us, such as when you contact customer support, or otherwise communicate with us.
We may also receive information from other sources and combine that with information we collect through our Services. For example:
- If you choose to link, create, or log in to your Squire account with a payment provider (e.g., Apple Pay) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
- Enterprise Customers may provide us with a rating after providing services to you.
- If you also interact with our Services in another capacity, for instance as an Enterprise Customer, we may combine or associate that information with information we have collected from you in your capacity as a Consumer User.
II. WHERE/HOW DO WE COLLECT PERSONAL INFORMATION
We collect Personal Information about you from:
- You. When you provide such information directly to us, and when Personal Information about you is automatically collected in connection with your use of Squire Services as described in our Cookies Policy.
- Enterprise Customers. When Enterprise Customers upload your Personal Information to our platforms in connection with their use of the Squire Services.
- Third Party Applications. We collect transaction details related to your use of the Squire Services, including but not limited to payment method, purchase amount, date of purchase, description of the goods or services purchased and other related transaction details.
- Advertising Partners. We work with companies that help us deliver, measure and analyze the effectiveness of our ads. These companies collect information about you when you interact with our ads on our platforms and on the websites where our ads are displayed.
- Data Brokers and Information Providers. We may collect information from data brokers and other information providers who may make your Personal Information available to us, as permitted by law.
III. HOW WE USE YOUR PERSONAL INFORMATION
- Provide, maintain, and improve the Squire Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Enterprise Customers and Consumer Users, develop safety features, authenticate users, and send product updates and administrative messages;
- Perform internal operations, including, for example, to prevent fraud and abuse of the Squire Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
- Send or facilitate communications either between you and Squire or you and an Enterprise Customer, such as appointment cancellation confirmations or other appointment status updates;
- Contact you about Squire Services, news, and events, offers, contests, sweepstakes or other promotions of Squire; or an Enterprise Customer may, using the Squire Services, contact you for similar marketing purposes, which may include SMS messages, email or push notifications to your mobile device, in accordance with applicable law, including any consent requirements;
- Personalize and improve the Squire Services, by providing appointment reminders, appointment date and time suggestions, recommend features, content, social connections, referrals, and advertisements; and
- Comply with any legal obligations and enforce our legal rights, such as, among other things, to exercise contractual rights, to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.
IV. SHARING OF PERSONAL INFORMATION
In limited circumstances, we may share your Personal Information in order to provide and improve the Squire Services or as required by applicable law. Where required by applicable law, we will only share your Personal Information with third parties with your consent. We may share your Personal Information as follows:
- Among Squire. We may share your Personal Information across Squire businesses and affiliated entities to provide the Squire Services to you, for administrative purposes within Squire or for data centralization and/or logistics purposes.
- Between Consumer-Users and Enterprise Customers. As a Consumer-User using the Squire Services to interact with an Enterprise Customer, we share your Personal Information with the relevant Enterprise Customer to enable them to perform the services you request. Please note, we are not responsible for the privacy practices of our Enterprise Customers, or their third-party service providers. Please contact the Enterprise Customer you interact with directly for more information on that Enterprise Customer's privacy practices.
- Integrated Partners and Service Providers. We may share your Personal Information with our integrated partners and service providers who provide services for us and our Enterprise Customers as part of delivering or enhancing the Squire Services, such as payment processing services, order fulfillment, website hosting, customer relationship management services, email services, SMS services, auditing, financial services promotions or offerings such as debit card and/or loan services, and other similar partnerships and services.
- Third Party Applications You may choose to share your Personal Information with other third party applications or websites that integrate with our API (e.g. Google, Facebook, Instagram, etc.) to access certain Squire Services. We may share your Personal Information received from such third party applications with relevant Enterprise Customers from which services you requests as well as back to the third party applications from where your Personal Information originated.
- Other Third Parties in Connection with a Corporate Transaction We may disclose or share your Personal Information in the event that we are involved with a purchase, sale, financing, transfer, or acquisition of all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganization or liquidation.
- Other Parties As Necessary or as Required by Law We may collect information about your mobile device, including but not limited to, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
V. ANALYTICS AND ADVERTISING SERVICES PROVIDED BY OTHERS
VI. LEGAL BASES FOR PROCESSING
We process your Personal Information as follows:
- With your consent (for example, we process data from cookies when you consent to that use and we collect your precise Location Information when you provide consent through your mobile platform);
- When necessary to perform our agreements with you (for example, we use your Transaction Information to confirm and manage your appointments with Enterprise Customers);
- When necessary to ensure compliance with a legal obligation to which we are subject; and
- In the pursuit of our legitimate interests (for example, we use your Account Information to provide our Services)
VII. DATA PROTECTION RIGHTS
Squire values your rights with respect to your Personal Information. In accordance with applicable law, you may be entitled to some or all of the following:
- The right to information: You have the right to request confirmation of whether we store, use, or share any of your Personal Information and be informed about with whom your Personal Information has been shared.
- The right to access: You have the right to request copies of your Personal Information.
- The right to rectification: You have the right to change or modify your Personal Information that you believe is out-of-date or incorrect.
- The right to erasure: You have the right to request erasure of your Personal Information held by Squire, subject to certain exceptions as prescribed by applicable law.
- The right to restrict processing: You have the right to restrict our uses of your Personal Information under certain circumstances as prescribed by applicable law.
- The right to data portability: You have the right to request copies of your Personal Information in an electronic format and request that we send that information to you or another third party under certain circumstances as prescribed by applicable law.
- The right to object to processing or withdraw consent: You have the right to object to our use of your Personal Information or withdraw consent where you have given it.
- The right to avoid automated decision-making. You have the right not to be subject to a decision based solely on automated processing, including profiling, if this has a legal or other significant effect on you as an individual, subject to certain exceptions as prescribed by applicable law.
VIII. HOW TO EXERCISE YOUR RIGHTS
Squire will comply with individual's requests, including access, correction, and/or deletion of the Personal Information it stores in accordance with applicable law.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us.
You can also designate an authorized agent to make a request on your behalf. If you use an authorized agent, please include written permission that you have designated that agent to make the request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request.
You may exercise the above rights by emailing us at email@example.com.
In addition, if you are in the European Economic Area or the United Kingdom, you have the right to complain to a data protection authority about our collection and use of your Personal Information. The data protection authority for the UK is the Information Commission's Office - whose website is https://ico.org.uk. Contact information for data protection authorities based in the European Economic Area, Switzerland and certain non-European countries are available on the EU Commission's website via the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
IX. OTHER CHOICES YOU HAVE
You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at firstname.lastname@example.org. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated the policies governing the Squire Services, we may seek to resolve the issue before deleting your information.
Information About Platform Permissions
Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Squire app wants permission to access certain types of data and will let you consent (or not consent) to that request.
- Location Information. We request permission for our app's collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of the Squire Services. Additionally, disabling our app's collection of precise location from your device will not limit our ability to derive approximate location from your IP address.
- Contact Information. We may also seek permission for our app's collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, users can later disable it by changing the contacts settings on your mobile device.
At times, we or our Enterprise Customers via the Squire Services may send you marketing and promotional information about products and services that may be of interest to you. With respect to marketing communications, you have many choices regarding the use of your Personal Information, as described below:
- Opting Out of SMS Text Messages. Within each marketing related SMS communication, we will provide a means to unsubscribe. You may also opt-out of receiving marketing-related SMS text messages by sending us an email at email@example.com with a note requesting to opt-out. Note, Squire will continue to send transaction-related SMS text messages regarding any products or services purchased while utilizing the Squire Services even after you unsubscribed from marketing-related SMS text messages. Receipt of transactional messages is a condition to using the Squire Services. If you no longer desire to receive transaction-related messages, you must cease using the Squire Services and terminate all accounts with us.
FOR CALIFORNIA RESIDENTS - "Do Not Sell My Personal Information"
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time. We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out you (or your authorized representative) may submit a request to us by sending us an email at firstname.lastname@example.org. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to Personal Information sales at any time by sending us an email. We will only use Personal Information provided in an opt-out request to review and comply with the request.
X. SOCIAL SHARING FEATURES
The Squire Services may integrate with social sharing features and other related tools which let you share actions you while using the Squire Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please note, we are not responsible for the privacy practices of those social sharing services. Please contact the relevant social sharing service for more information on how they handle your Personal Information and their privacy practices.
XI. CALIFORNIA SHINE THE LIGHT DISCLOSURE
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Squire does not share your Personal Information with third parties for direct marketing purposes unless you provide us with consent to do so.
XIII. INTERNATIONAL TRANSFERS OF INFORMATION
We have put in place safeguards to provide adequate protection for transfers of certain information, in accordance with applicable legal requirements. For more information on the appropriate safeguards in place, or to request a copy of these safeguards, please contact us using the contact details listed in the How to Contact Us section below.
XIV. SECURITY, RETENTION, AND STORAGE OF PERSONAL INFORMATION
We use commercially reasonable procedures to protect the information that we collect. However, we cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. Squire will keep your Personal Information for seven years. Once this time period has expired, we will delete your data.
XV. CHILDREN UNDER 16
The Squire Services are not intended for children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If we learn that we have collected any Personal Information from a child under the age of 16 without verifiable parental consent, we will delete that information from our database as quickly as possible. If you believe that we may have collected information from a child under 16, please contact us at email@example.com.
We will not discriminate against you for exercising any of your rights with respect to your Personal Information as granted under applicable law. Unless permitted by applicable law, we will not:
- Deny you any goods or services.
- Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
XXVIII. HOW TO CONTACT US