privacy policy

This Privacy Policy will help you better understand how we collect, use, and share your personal information. If we change our privacy practices, we may update this privacy policy. If any changes are significant, we will let you know (for example, through the PANACHE admin or by email).

Our values

Trust is the foundation of the PANACHE platform and includes trusting us to do the right thing with your information. Three main values guide us as we develop our products and services. These values should help you better understand how we think about your information and privacy.

Your information belongs to you

We carefully analyze what types of information we need to provide our services, and we try to limit the information we collect to only what we really need. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our products, our engineers work closely with our privacy and security teams to build with privacy in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.

We protect your information from others

If a third party requests your personal information, we will refuse to share it unless you give us permission or we are legally required. When we are legally required to share your personal information, we will tell you in advance, unless we are legally forbidden.

We help merchants and partners meet their privacy obligations

Many of the merchants and partners using PANACHE do not have the benefit of a dedicated privacy team, and it is important to us to help them meet their privacy obligations. To do this, we try to build our products and services so they can easily be used in a privacy-friendly way. We also provide detailed FAQs and documentation covering the most important privacy topics, and respond to privacy-related questions we receive.

Why we process your information

We generally process your information when we need to do so to fulfill a contractual obligation (for example, to process your subscription payments to use the PANACHE platform), or where we or someone we work with needs to use your personal information for a reason related to their business (for example, to provide you with a service). European law calls these reasons “legitimate interests.” These “legitimate interests” include:

  • preventing risk and fraud

  • answering questions or providing other types of support

  • helping merchants find and use apps through our app store

  • providing and improving our products and services

  • providing reporting and analytics

  • testing out features or additional services

  • assisting with marketing, advertising, or other communications

We only process personal information for these “legitimate interests” after considering the potential risks to your privacy—for example, by providing clear transparency into our privacy practices, offering you control over your personal information where appropriate, limiting the information we keep, limiting what we do with your information, who we send your information to, how long we keep your information, or the technical measures we use to protect your information.

One of the ways in which we are able to help merchants using PANACHE is by using techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications (for example, reordering how apps might appear when you visit the app store).

We may process your personal information where you have provided your consent. In particular, where we cannot rely on an alternative legal basis for processing, where your data is sourced and it already comes with consent or where we are required by law to ask for your consent in the context of some of our sales and marketing activities. At any time, you have a right to withdraw your consent by changing your communication choices, opting out from our communications or by contacting us.

Your rights over your information

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use PANACHE, you may have the right to request access to, correct, amend, delete, port to another service provider, restrict, or object to certain uses of your personal information (for example, direct marketing). We will not charge you more or provide you with a different level of service if you exercise any of these rights.

If you buy something from a PANACHE-powered store and wish to exercise these rights over information about your purchase, you need to directly contact the merchant you interacted with. We are only a processor on their behalf, and cannot decide how to process their information. We will of course help our merchants to fulfill these requests by giving them the tools to do so and by answering their questions.

If you are a merchant, partner, Shop user, PANACHE employee, or other individual that PANACHE has a direct relationship with, please submit your data subject request through our online portal. Please note that if you send us a request relating to your personal information, we have to make sure that it is you before we can respond. In order to do so, we may use a third party to collect and verify identification documents.

If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.

Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.

Where we send your information

To operate our business, we may send your personal information outside of your state, province, or country, including to the United States. This data may be subject to the laws of the countries where we send it. When we send your information across borders, we take steps to protect your information, and we try to only send your information to countries that have strong data protection laws.

How we protect your information

Our teams work tirelessly to protect your information, and to ensure the security and integrity of our platform. We also have independent auditors assess the security of our data storage and systems that process financial information. However, we all know that no method of transmission over the Internet, and method of electronic storage, can be 100% secure. This means we cannot guarantee the absolute security of your personal information.

How we use “cookies” and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies that we place when we power a merchant’s store, and an explanation of how you can opt out of certain types of cookies, please see our Cookie Policy.

The CCPA provides California residents with the following additional rights:

  • Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.

  • Right to Opt Out of the "Sale" of Personal Information: PANACHE does not "sell" personal information as that term is traditionally understood; however, our use of third-party tracking technologies for interest-based advertising may be considered a “sale” of personal data under California law. You can opt out of being tracked by these third parties by clicking the “Privacy / Do not sell my personal info” link at the footer of our homepage or through your account privacy settings. You can also opt out by broadcasting the Global Privacy Control signal from a supported browser. We do not knowingly “sell” the personal information of consumers under 16 years of age.

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Last updated on October 20, 2022