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Privacy Policy

EFFECTIVE DATE: 18 June 2024

Privacy Policy

Network Merchants, LLC and all its subsidiaries and Affiliates (herewith referred to as NMI, we, our or us) are committed to protecting and respecting your privacy.

When collecting the data specified in this Privacy Policy (Policy), we, NMI, are both the Data Controllers and Data Processors.

This Policy has been produced in line with the UK General Data Protection Regulation and the Data Protection Act 2018 (UK Privacy Laws), consumer privacy laws of California, Colorado, Connecticut, Utah, Virginia and any applicable laws depending on your jurisdiction (US Privacy Laws).

This Policy covers all aspects of NMI’s business, including and not limited to:

the use of our website including any related blogs, domains, mobile applications, mobile sites, online services and applications that we maintain (collectively, the “Website”).
the Services NMI provides and the linked Affiliates:

TABLE 1:

Affiliate: (of any party means any person or entity that controls, is controlled by, or is under common control with, such party)	Service: (means the services provided by NMI under a contractual agreement between you and NMI)
Network Merchants, LLC	Omni
Network Merchants, Ltd.	CardEase (or any gateway offered in the UK)
GOR Corporation	USAePay
Agreement Express Inc.	Merchant Relationship Management (Agreement Express)
Anovia Payments, LLC	NMI Payments
Integrated Reporting Is Simple, LLC	Merchant Relationship Management (IRIS CRM)

This Policy sets out the basis on how we process any personal data we collect from you, or that you provide to us. Please read the following Policy carefully to understand our views and practices regarding your personal data and how we will treat it.

This Website is not intended for children, and NMI does not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions, when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Depending on the context, “you” will mean either the merchant, partner, end user, or a visitor to this website or our services – whichever is applicable:

Merchant: as defined within your agreement with NMI
Partner: as defined within your agreement with NMI
Other end users: When you directly use an end user service for your personal or business use
Visitor: When you visit the Website without being logged into a NMI account or otherwise communicating with NMI (e.g. you send NMI a message asking for more information because you are considering being a user of our products).

Third party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy notice of every website you visit.

1. Information We May Collect From You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows

TABLE 2:

Category	Description of category, including but not limited to:
Identity Data	a) first name b) last name c) username or similar identifier d) marital status e) title f) date of birth g) social security number or similar government issued identification number h) gender
Contact Data	a) address (billing, shipping, etc.) b) email address c) telephone numbers
Financial Data	a) bank account details b) tax ID FEIN or equivalent c) payment card details d) credit check information
Transaction Data	a) details about payments to and from you b) other details of products and services you have purchased
Technical Data	a) includes Internet Protocol (IP) address b) your login data c) browser type and version d) time zone setting and location e) browser plug-in types and versions f) operating system and platform g) other technology on the devices you use to access the Website.
Profile Data	a) your username and password b) purchases or orders made by you c) your interests d) Preferences e) Feedback f) any provided images, and survey responses
Usage Data	a) information about how you use the Website b) How you use products c) How you use services
Marketing and Communications Data	a) your preferences in receiving marketing notifications from us b) Your preference in receiving marketing information from our third parties c) your overall communication preferences

We also collect, use, and share aggregated data, such as statistical or demographic data, for any NMI business purposes. Aggregated data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing specific features of the Website. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not knowingly collect any special categories of Personal Data about you, including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic or biometric data. Nor do we collect any information about criminal convictions and offenses.

How is your personal data collected?

We may use different methods to collect and process data from and about you, this includes as is not limited to:

Direct interactions
- Information that you provide us. This includes information provided when filling in forms on our Website, placing an order for Services, applying for a vacancy to work at NMI, and, if applicable, at the time of registering to use the Website, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with the Website. “Services” means the goods and services provided by or through the Website and broken down in Table 1 above.
- If you contact us, we may keep a record of that correspondence.
- If you phone us, we may record the phone call and keep a record of the recording.
- We may also ask you to complete surveys that we use for research purposes, although you are not required to respond to them.
Merchant physical device integrations or online integrated payment systems
- As part of NMI’s Service – we integrate with Merchant physical devices, or integrate with online applications to receive payments. All information provided to enable the payment is thus processed by NMI accordingly.
Automated technologies or interactions
- As you interact with the Website, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server and network security device logs, and other similar technologies.
- Utilization of the Website, including NMI’s payment gateway service and its other Services, will retain details regarding specific transactions.
Business partners and Affiliates
- At times, we may receive information on your behalf from an authorized NMI partner or Affiliate who provides goods or services to you.
Third parties or publicly available sources
- We may receive personal data about you from various third parties [and public sources] as set out below:
  - Technical data from the following parties:
    - Analytics providers (i.e., Google)
    - Managed security service providers
  - Identity and contact data from the following parties:
    - Sales/marketing insight providers (i.e., Salesforce)
    - Marketing/sales/product convention providers
    - Publicly available data identified through search engines
  - Background checks for potential Partners/ Merchants:
    - Credit reference agencies (Experian)
    - Verification agencies (LexisNexis, LSEG, Giact)

Do Not Track

We may not recognize all web browser based “Do Not Track” signals. However, you may be able to modify your internet-enabled device’s web browser settings to block all cookies or third-party cookies.

2. Data Security

We have put in place appropriate security measures designed to protect your personal data from being accidentally lost, misused, accessed, altered, or disclosed in an unauthorized way. As a portion of this security, we limit access to your personal data by only those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

3. Cookies

The Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse the Website, facilitate interactions with customer portals, and allows us to improve our site. For more information on the cookies we use and their purpose, please refer to our Cookie Policy.

4. Where We Store Your Personal Data

The data that we collect from you is stored as per below:

TABLE 3:

Affiliate:	Location
Network Merchants, LLC	USA
Network Merchants, Ltd.	USA, UK, Netherlands
GOR Corporation	USA
Agreement Express Inc.	Canada and USA
Anovia Payments, LLC	USA
Integrated Reporting Is Simple, LLC	USA

Your data may be transferred to, processed, and stored at a destination outside these destinations, by staff operating outside of these locations who work for us or for one of our partners. Such staff may be engaged in, among other things, in the fulfillment of an agreement, the processing of your payment details, or the provision of support services.

Whenever we transfer your personal data out to a remote staff or partner, we contractually require, or we ensure a similar degree of protection of your personal data be implemented to protect it from unauthorized use or access.

5. Purpose of Processing Personal Information

In general, we use the information we collect primarily to provide, maintain, protect, and improve our current products and services, including the development of new offerings. We use personal information collected through our Sites and Application(s) as described below and described elsewhere in this Policy.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us (dpo@nmi.com) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the “Lawful Basis” section of the table below:

TABLE 4:

CATEGORY OF PERSONAL INFORMATION (categories are defined in Section 1 above)

PURPOSE/ACTIVITY

LAWFUL BASIS/ LEGAL BASES

(a) Identity

(b) Contact

To facilitate the creation and security of your account

Performance of a contract with you

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing & Communications

To process and deliver your services, including:

(a) Manage payments, fees, and charges

(b) Collect and recover money owed to us

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(a) Identity

(b) Contact

(d) Transaction

(e) Technical

(f) Usage

(g) Marketing & Communications

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or our Policy

(b) Asking you to leave comments

(d) Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(a) Identity

(b) Contact

To maintain a marketing database and send electronic marketing to you where we consider such marketing relevant to you and where we are satisfied that we have a legitimate interest in doing so

Necessary for our legitimate interests (to allow us to maintain current contact details and to market our products to individuals who have expressed or are likely to have an interest in those products)

(a) Identity

(b) Contact

(d) Usage

(e) Marketing & Communications

To enable you to partake in a survey

(a) Consent as survey are optional

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business)

(a) Identity

(b) Contact

(d) Transaction

To administer and protect our business, services, and this Website, including:

(a) Troubleshooting

(b) Data Analysis

(d) System Maintenance

(e) Support

(f) Reporting

(g) Hosting of Data

(h) Identification of you as a user on our system(s)

(a) Necessary for our legitimate interests (for running our business, execution of administration and IT services, network security, to prevent fraud, unauthorized, or illegal activity, and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

(a) Identity

(b) Contact

(d) Usage

(e) Marketing & Communications

(f) Technical

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(a) Technical

(b) Usage

To use data analytics to improve the Website, products/services, marketing, customer relationships, and experiences

Necessary for our legitimate interests (to keep the Website updated and relevant, to develop our business, and to inform our marketing strategy)

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Consent

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)

When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.

Marketing usage

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your personal data to assist in improving, developing and marketing NMI’s services and products. We may also use your personal data to assist in developing new products and services. We may use your personal data to assist in improving and developing our IT platform, network, product and service security, support capabilities, and the organization as a whole. We will contract with and provide third-party sources’ Identity, Contact, Usage, Profile, and Marketing and Communications data types.

In a business-to-business market, this profile helps us improve our marketing and sales efforts to be more relevant to you and to create a more personalized, improved experience.

Personal information in relation to marketing will not be shared with any third parties.

User feedback

We often request and receive feedback and comments from you who have had positive experiences with our services and may post user feedback on our website from time to time. If we choose to post your feedback, we will obtain your consent prior to posting your information (corporate or personal) with your feedback.

Data Retention

There are certain reasons why we keep some of your data. How long we keep your personal data depends upon the type of data we hold and the purpose(s) for which it was collected and processed. We may hold some of your data with third parties, but where we do, we ensure these third parties also only keep the data only for as long as necessary and adhere to our retention policies.

We will store your personal data for no longer than necessary to support the purposes explained above. We keep the personal data we hold about you for up to a maximum of 6 years from the date of collection unless related correspondence or legal claims are on-going.

International data transfers

We may transfer your Personal Information to countries other than your own country, including to the United States. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Information in response to lawful requests from officials (such as law enforcement or security authorities, as discussed above).

Where applicable law requires a data transfer mechanism, we use one or more of the following:

Transfers to certain countries or recipients that are recognised as having an adequate level of protection for Personal Data under applicable law.
EU Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office. You can obtain a copy of the relevant Standard Contractual Clauses.
or other legal methods available to us under applicable law.

NMI complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), and the UK Extension to the EU-U.S. DPF. Data Privacy Framework as set forth by the U.S. Department of Commerce (as applicable).

6. Disclosure of Your Personal Information (who we share your data with)

As a course of business and for reasons stated in this Policy, we may disclose your personal information to any member of our group, which means our subsidiaries, business partners, service providers, sub-processors, shareholders, investors, and Affiliates. As a necessity, we may disclose your personal information to third parties:

In the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
If NMI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or other agreements; or to protect the rights, property, or safety of NMI, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Where necessary for the purposes of preventing or detecting crime, we may share your personal data about you to the following third parties, including and not limited to:
- Court
- Police
- Federal agents

Excluding Google & Microsoft data, NMI may use aggregated and/or anonymized data to compile statistics and may distribute those anonymized statistics to third parties. NMI may also use data to offer you additional features within the services or services of third parties that NMI believes are compatible with your interests.

Third parties that we may disclose data to both inside and outside the United States and the EU include:

Acquiring Banks
Payment Processors
Fraud Detection Providers
Additional Authentication Providers (i.e., Visa 3DSecure, MasterCard Securecode Providers, etc…)
Project Management and Productivity Providers
Sales, Marketing, and Marketing Analytics

We use the services of data processes acting on our behalf, some may store your personal information outside the European Economic Area, where we have appropriate safeguards in p;ace that are required by data protection laws.

7. YOUR LEGAL RIGHTS

Your Privacy Rights Related to Marketing

Your privacy rights include, but are not limited to, having the right to request NMI to not process your personal data for marketing purposes. We will usually inform you (prior to collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise this right at any time by contacting us at support@nmi.com.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Your Data Protection Rights

Depending on your location, and subject to applicable law, you may have the following rights with regards to the Personal Information we process about you

Right to be Informed: You have the right to be provided with clear and concise information about what we do with your personal data.
Right to Access: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to Request Correction of Your Personal Information: Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to Request Deletion of Your Personal Information: Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to Opt-out of Processing: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to Impose Restrictions on the Processing of Your Personal Data: Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful, but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Right to Data Portability: Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdrawal of Consent: Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to Opt-out of Sharing for Cross-Context Behavioral Advertising: You may request to opt out of the sharing of your personal data for purposes of cross-context behavioral advertising.
Right to Appeal: You have the right to appeal our denial of your request(s).
Right to Export your Personal Data that we hold to another company, where technically feasible.
The right not to be discriminated against for exercising these rights.

You may have additional rights regarding your Personal Data under applicable law. For example, see Section 8 below.

If you wish to exercise any of the rights set out above, please contact us as outlined in section “10. Contact”.

Cross-Border Data Transfer

Personal data voluntarily submitted to us online, via electronic communication, or otherwise, may be maintained or accessed in servers or files in the United States, which the European Union and UK have not deemed to provide “adequate” privacy protection. If you do not consent to having your personal data processed and stored in the United States, please do not provide it to us on the Website or through any other means.

How do the SCCs and UK Addendum impact my organization?

SCCs are legal contracts entered into between parties that are transferring EEA Personal Data outside of the EEA. NMI may rely on the SCCs for transfers of EEA data in our services. We have updated our Data Processing Addendum and agreements to incorporate the SCCs (where applicable).

How to get a copy of the SCCs or UK Addendum?

You can review our Data Processing Addendum which includes the latest data transfer mechanisms, including the SCCs and the UK addendum.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you are concerned about our processing of your data or if you have a privacy related query not answered by this Policy, please contact our Privacy Team using the contact details below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). For further information, please refer to the ICO website, www.ico.org.uk.

Specific rights related to Jurisdiction

Australia: If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Policy, you may wish to contact the Office of the Australian Information Commissioner.
South Africa: As used in this Policy, “applicable law” includes the Protection of Personal Information Act (POPIA).
Canada: As used in this Policy, “applicable law” includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and “Personal Data” includes “personal information” as defined under PIPEDA.
EEA and UK: To exercise your rights, you may contact our DPO. If you are a resident of the EEA and you believe our processing of your information is not in line with the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office.

EU: European Data Protection Board members page.

UK: Ico. contacts page

United States – California: If you are a consumer located in California, we process your personal information in accordance with California law (e.g. the “CCPA”). NMI uses cookies, including advertising cookies, as described in our Cookie Policy.
- Your Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information (learn more about data subject rights metrics). In addition to the above rights (see here), please note these other California-specific rights:
  - Exercising the right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
  - Exercising the right to opt-out from a sale: We do not sell “Personal Information” as defined by the CCPA and have not done so in the past 12 months. Learn more.
  - Exercising the right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months. Learn more about our collection and use of Sensitive Personal Information here.
  - Right to opt-out of sharing of cross-context behavioral advertising. Learn more here and here.

What sensitive personal information under the California Consumer Privacy Act (CCPA) NMI does collect and for what purposes does NMI use that data?

NMI only processes sensitive personal information for the purposes specified in section 7027(m) of the California Consumer Privacy Act Regulations, or without the purpose of inferring characteristics about a consumer.

TABLE 5:

Sensitive Personal Information Categories	Purpose
Identification documents, including driver’s license, passport, and social security (including any underlying sensitive information in the identity card, such as racial or ethnic origin)	Identity verification, fraud prevention and security, to provide our services, and to comply with legal obligations.
Biometric information	Identity verification, fraud prevention and security, and for other purposes consistent with your consent and applicable law, such as to improve our verification systems.
Location Data	Fraud detection and security, to comply with law, and to provide our services
Account log-in, financial account in combination with any required security access code, password, or credentials allowing access to an account	To provide our services, comply with law, enforce our terms of services, and for other purposes consistent with your consent and applicable law.

Does NMI”sell” or “share” my personal information under the CCPA?

We do not transfer your personal data to third parties in exchange for payment. However, as noted above, we may provide your personal data to third party partners.

If you wish to exercise any of the rights set out above, please contact us as outlined in Section “10. Contact”. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your identity, including name, address, transaction history, photo identification, and other information associated with your account.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Your agent may submit a request on your behalf by contacting us using the methods described in the Contact section below. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.

No fee typically required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, excessive, or not provided for within your legal rights. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

When exercising your rights or when exercising rights on behalf of someone-else related to personal data, we may need to request specific information from you to help us confirm your identity and validate your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated on the progress of your request(s).

9. Changes to Our Policy and Your Duty to Inform Us of Changes

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, by notification email sent to you.

It is important that the personal data we hold about you is accurate and current for the appropriate delivery of goods and services from NMI. Please keep us informed if your personal data changes during your relationship with us.

10. Contact

General communications

Questions, comments, and requests regarding this Policy are welcomed and should be addressed to:

Network Merchants, LLC
Email: support@nmi.com

Data protection office

NMI has a Data Protection Office (DPO) responsible for matters relating to privacy and data protection. Please use this contact for any requests to exercise your rights under this Policy. Our DPO can be reached at the following contact information:

Network Merchants, LLC
Email: dpo@nmi.com

We have appointed IT Governance Europe Limited to act as our EU Representative. They can be reached out to at eurep@itgovernance.eu or post your request or query to: EU Representative, IT Governance Europe, The Mill Enterprise Hub, Stagreenan, Drogheda, Co. Louth, A92 CD3D, Ireland.

When contacting our Representative please ensure you include our company name in any correspondence.

Escalation

All residents of the United States and any other country, province, state, municipality, or other location with specific privacy regulations have the right to make a complaint at any time to their local/federal supervisory authority for data protection issues.

If you are a European Union or United Kingdom resident, you may make a complaint regarding the use of your personal information to your local data protection regulator. You can find your data protection regulator here:

EU: European Data Protection Board members page.
UK: Ico. contacts page

We would, however, appreciate the chance to address your concerns before you approach these authorities, so please contact us in the first instance.

*Please note that in the event of any inconsistencies regarding how we process your data, the following order of precedence will apply:

1. Any signed Data Processing Agreement (DPA) between the parties. 2. Any signed data transfer agreement between the parties. 3. This Privacy Policy. 4. Any other declarations of how we process your information.

This hierarchy ensures that your data is managed according to the most current and binding agreements in place.