US-EU Safe Harbor | Client Data

Introduction

At Fraudpointer we recognize that privacy is important. This Fraudpointer policy applies to the collection of data by Fraudpointer its subsidiaries, and affiliates (collectively, “Fraudpointer”).
Fraudpointer provides fraud prevention services and application hosting on behalf of our clients. As a hosting provider, we receive a variety of data from our clients in regards to online transactions. We respect consumers’ online privacy and are committed to following industry privacy standards and directives. This privacy policy describes the nature of how this data is stored and secured while at Fraudpointer. Consumers should also review the privacy policy of their direct merchant or financial provider in addition to this policy.
Compliance with U.S – EU Safe Harbor Principles

As a ‘processor’ of data on behalf of e-commerce merchants, travel providers, and financial institutions we do not get data directly from the consumer, but we are committed to complying with the principles of Safe Harbor as it applies to processors. This privacy policy outlines our general policy and practices for implementing the Principles of Safe Harbor, including the types of information we gather, and how we use it.
Fraudpointer is committed to abide by the Safe Harbor framework as defined by EU Data Protection Directive regarding the collection, use and retention of personal information collected from the European Union or the US (the “Safe Harbor Principles”).
Enforcement

Fraudpointer uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.
Purpose of Data Received

In the course of providing fraud prevention and application hosting services on behalf of our clients, Fraudpointer may receive consumer data that would be relevant in our clients online processing. This data may include, but not be limited to, items such as consumer name, billing address, email address, and payment instrument (“Personal Information”). This data is used for analysis to prevent online financial fraud and only retained for a limited amount of time.
Fraudpointer never discloses client data or consumer personal information outside of our company or business partners without knowledge and consent, except when obligated by law.


Nature of data collected

Fraudpointer employs device identification technology to assist our subscribers in detecting and preventing fraud. Fraudpointer’s device identification technology collects system (PC and Network) information about devices (such as computers and smart phones) that enables us to develop a “digital identifier” of the device. Fraudpointer may also receive other information regarding the user’s device from its subscribers and other third parties, including but not limited to IP address, account identifier, and geo-location. Fraudpointer may combine this information with information from other Fraudpointer services, third parties, or Fraudpointer subscribers in order to provide our subscribers a better and more secure online environment and to improve the quality of our services.


Information stored on user’s device

In the delivery of Fraudpointer services, at the completion of the device identification process, Fraudpointer stores a device identifier on the user’s computer. Device identifiers are small amounts of information that are stored on the user’s device to accurately identify a re-visiting device. In order for Fraudpointer to be able to provide and improve its services, Fraudpointer may send one or more device identifiers to user’s computer.
Notice

Fraudpointer informs individuals of the purpose for which it collects and uses the Personal Information and the uses of the data via our privacy policy on this website. Fraudpointer also works with its clients to identify the types, format, and security of the data sent to Fraudpointer.
Choice

Fraudpointer receives data directly from our clients; never is data received directly from an individual. In doing so, Fraudpointer clients with direct contact with the consumer would be encouraged to provide the necessary notice and opt-in choices on Personal Information. Again, it is important to note that Fraudpointer never discloses client data or consumer personal information outside of our company or business partners without knowledge and consent, except when obligated by law.
Onward Transfers

Fraudpointer will not transfer data it receives to any outside party. If in any event this became a requirement, Fraudpointer would notify the client and the consumer prior to disclosing Personal Information to a third party. Fraudpointer would also ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Data Security

Fraudpointer takes reasonable steps to protect the Personal Information it stores and has put in place appropriate physical, electronic and managerial procedures to safeguard and secure it from loss, misuse, unauthorized access or disclosure, alteration or destruction. We cannot guarantee the security of Personal Information on or transmitted via the Internet. All employees of Fraudpointer who have access to the data are subject to Company policies that prohibit unauthorized transmission of data to third parties.
Data Integrity

Fraudpointer only processes Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by our client. To the extent necessary for those purposes, we take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.


Access

Fraudpointer will allow an individual access to their Personal Information to the extent it is available and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Amendments

This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.
Fraudpointer is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of Fraudpointer that may differ in some respects from the general policies set forth in this privacy policy.


Contact Information

Questions, comments or complaints regarding the Company’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:

Fraudpointer Ltd

Attn: Data Security

61-63 Evelpidon Av.

Athens

GR-113 62