Effective Date:1st October 2020
Company: ACE Software Solutions Inc. (“Company”)

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This Product Privacy Policy applies to Company (”Company”, “Us,” or “We”), who owns and controls the Pelican platform (https://pelicanpay.euhttps://pelicanpay.us, https://pelicansanctions.eu, https://pelicansanctions.us) and all of its dependent Group companies, affiliated companies and their employees. Through this Privacy Policy, we wish to inform you how personal information is being processed via our Pelican platform (the “Service”).

Protecting consumer privacy is important to Company. This privacy policy applies only to the Service and outlines how Company's Services process information on behalf of the Company's Client's (for which Company is a data processor), and the choices available to you regarding our use of your personal information and how you can access this information.

Company and its subsidiary company(ies) ACE Software Solutions Limited participate in and have certified its compliance with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Framework.  Company is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List. 
[https://www.privacyshield.gov/list]

Company is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf.  Company complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Company is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Company may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at 
https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

1. Information Collection and Use
Company collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to have your information processed by the Clients that use our Service, please contact the Client that you interact with directly:

We may process the following kinds of personal information on behalf of our Clients:

  • Company information such as name, address.
  • Contact Information such as name and email address, mailing address, phone number.
  • Financial Information such as bank codes, bank name, bank address, bank or brokerage account name and numbers.
  • Unique Identifiers such as user name and password.
  • Your financial transaction information that may contain your company name, address, beneficiary name and address, bank name, bank codes, bank address, bank account numbers, balance information, transaction date, transaction amount, national identification number, salary information.

At the instruction of our Clients, this information can be used to:

  • Facilitate transactions on behalf of our Clients.
  • Send alerts and notifications about account activity.
  • Respond to customer services requests of our Clients.
  • Send payment files to the bank on behalf of our Clients.
  • Provide the financial services you requested on behalf of our Clients.

In order to facilitate faster processing of your transactions and at the instruction of our Clients, our Services may enrich the transaction data with information from third parties to make the transaction go straight through without manual intervention.

2. Information Sharing
We may transfer personal information to companies that help us provide our services. Transfers to subsequent third parties are covered by the agreements with our Clients.

Service Providers

Company may transfer personal information to companies that help us provide our services. 

Legal Disclaimer

In certain situations, Company may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process


3. User Access and Choice
We acknowledge that you have the right to request your personal information. An individual or organisation who is not a direct client of Company and who seeks access or who seeks to correct, amend or delete inaccurate data should direct his or her query to Company’s Client (the data controller). If the Client requests Company to remove the data, we will respond to their request within 30 days.

Requests regarding the personal information we hold or process on our Client's behalf will be forwarded to our respective Clients.

If we hold data about you for which we are a data controller, you can always reach out to us for any requests you have, all as further described in our general Privacy Policy at 
https://www.pelican.ai/privacy.

Retention
We will retain personal data we process on behalf of our Clients in accordance with our Client's instructions and as necessary to comply with our legal obligations. We use aggregated and anonymized data to further develop the Services and for our further business interests. 

Opt-Out Preferences
Receiving emails from the Service is part of the platform functionality. If our Client does not wish to receive any emails, our Clients can inform Company about the same. Company will configure the system to stop sending emails to the Client.

4. Tracking Technologies
Log Files
Through our Services, we gather certain information automatically and store it in log files on behalf of our clients. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click stream data.

Cookies and Other Tracking Technologies 
We and our partners may use cookies or similar technologies to store / retrieve user preferences, analyze trends, administer the platform, track users’ movements around the platform, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our platform or service.

5. Security
We take appropriate physical, technical, and organizational measures to protect personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. We encrypt the transmission of sensitive information using secure socket layer technology (SSL).

We follow generally accepted standards to protect personal information, both during transmission and once we receive it.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however.  Therefore, we cannot guarantee its absolute security
.

6. Changes to This Policy
This Privacy Policy was last revised on 1st October 2020. We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on Product UI page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

7. Contact Us

If you have any questions or concerns about this Privacy Policy, contact us below. We will respond to you within 30 days.

ACE Software Solutions Inc.,
485B, Route 1 South, Suite 310,
Iselin, NJ 08830, USA

Phone: +1 732 603 4990
Fax: +1 732 636 4990
Email: 
privacy@pelican.ai