Parlevel Systems Inc. (collectively, “Parlevel,” “we,” “us,” or “our”) respect your privacy and are committed to protecting your personal information.
By visiting our websites or using any of our products or services, you agree that your personal information will be handled as described in this policy.
Table of Contents
Personal Data We Collect
How We Use the Personal Data We Collect
How We Disclose and Transfer Your Personal Data
How We Secure Your Personal Data
Choices You Have Regarding Your Personal Data
Retention of Your Personal Data
Cookies, Web Beacons, and Other Technologies
International Privacy Laws
Terms of Service
Your Local Privacy Rights
1. Personal Data We Collect
1.1 Personal Data You Provide Us
Personal Data is information that can be used to specifically or explicitly identify or contact a single person. When providing you Services, there is some Personal Data that You voluntarily provide to Us. This may include your name, telephone number, address, email address and contact preferences when you create an account, register for special services, download updated software or participate in a survey, or contact customer support. When using the Parlevel koin web portal, parlevel koin mobile app, or the Parlevel Micro Market solution you may also choose to voluntarily disclose Personal Data such as a month and year of birth, preferred gender, and provide a picture or avatar for your account profile.
In order to easily access your Micro Market wallets at a Parlevel Micro Market kiosk, you may also voluntarily provide certain biometric data such as a fingerprint. You are not required to provide such biometric information and you may access your wallet by alternative means, like a) email and PIN number, b) scanning a previously assigned wallet tag (barcode), or c) scanning the QR code that your Parlevel koin mobile app is able to display in your smartphone’s screen.
1.2 Personal Data We Collect Automatically
When you visit our website or use our services, we collect information sent to us by the means with which you contacted us, such as your computer, mobile phone or other device used to access us or the services. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit the Parlevel website or use the Parlevel Services, we may also collect information about your transactions and your activities.
In the case you take advantage of our gifting services, sending information, gift certificates or products, or invite others to join the services, Parlevel may collect the information you provide about those people such as name, address, email address, and telephone number.
Parlevel micro market kiosks are also equipped with a user-facing camera which collects photographs at various times during a user’s interaction with the kiosk. Such pictures are taken for security and quality assurance purposes and are not used as biometric data. If a user is logged into its Parlevel wallet, pictures taken are linked to transactions and therefore can be linked to a specific user.
2. How We Use The Personal Data We Collect
We use your personal information to provide you services, and to complete transactions by using the services. We may also use your personal information for communications; from time to time, we may use your personal information to send updates and important notifications, such as changes to our documentation (terms conditions policies and procedures) and because this communication pertains to the provision of your services, you may not opt out of receiving these updates. We may also use your personal information to improve our products, content and services. In the case of promotions of any kind, Parlevel and/or the Micro Market operator owning and operating the Micro Market to which your Parlevel Wallet or Parlevel koin account pertains may use your given personal information to administer such promotions and to send you targeted marketing and promotional offers based on your preferences. Images captured by micro market kiosk cameras is used only for security, quality assurance, and auditing purposes.
Any biometric data you have voluntarily provided to Parlevel, such registering a fingerprint at a Parlevel Micro Market kiosk, is used by Parlevel to provide you with a quick and easy way to log into your Parlevel Wallet by identifying you without having to rely on other means, like an email + PIN combination.
3. How We Disclose and Transfer Your Personal Data
3.1 Not Selling Your Personal Data
We consider your trust in us regarding your Personal Data to be an important part of our relationship with you. Therefore, we will not sell your Personal Data to third parties, including third party advertisers. There are some circumstances, however, where we may disclose, transfer, or share your Personal Data with a third party without notice to you, as described below.
3.2 Business Transfers
3.3 Parent Companies, Subsidiaries, and Affiliates
3.4 Contractors, Consultants, and Service Providers
3.5 Parlevel Customers - Your Vending or Micro Market Operator
3.6 Legal Requirements
We may disclose your Personal Data if required to do so by law in order to respond to a subpoena or request from law enforcement, a court, or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend our rights, interests, or property, or that of third parties, (iii) prevent or investigate possible wrongdoing in connection with our Services, (iv) act in urgent circumstances to protect the personal safety of users of our Services or the public, or (v) protect against legal liability.
4. How We Secure Your Personal Data
We take your security seriously and strive to take reasonable steps to protect your information. No data transmission over the internet or information storage technology can be guaranteed to be 100% secure. The following is a summary of the measures we take to protect the Personal Data you provide us and an explanation of ways we implement these measures. We continue to evaluate and implement enhancements in security technology and practices, however we can only take steps to help reduce the risks of unauthorized access. You can also take steps to protect your information and further minimize the likelihood that a security incident may occur.
4.1 Secure Socket Layer
We use Secure Socket Layer (“SSL”) encryption when transmitting certain kinds of information, such as payment information or Personal Data. An icon resembling a padlock is displayed in most browsers’ window or address bar during SSL transactions. For example, any time we ask for a credit card number for payment or for verification purposes, it will be SSL encrypted in its transmission to our third party payment gateways, like Braintree, Conekta, RedSys, among others. The information you provide will be stored securely on those gateways’ services. Once you choose to store or enter your credit card number in our Services, it will not be displayed back in entirety for any users. Instead of the entire number, you will only see asterisks and either the first four digits or the last four digits of your number.
This is also the means used to encrypt and transmit any biometric data such as fingerprints, both when you register it the first time as well as when anyone uses its fingerprint to log in.
4.2 Secure Storage
We maintain reasonable physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you, this includes your biometric data.
4.3 Vendors and Partners
We work with vendors and partners to protect the security and privacy of user information. We host our Services on Google Cloud, who maintains its own procedures and controls to ensure data security. Details can be found at https://cloud.google.com/security/
4.4 Employee and Contractor Access to Personal Data
We limit access to personal information about you only to those trained employees who we reasonably believe need to come into contact with that information to provide products and services to you in order to do their jobs.
5. Choices You Have Regarding Your Personal Data
5.1 Accessing, Updating, Correcting, or Deleting Your Personal Data
Upon request, we will provide you with information about whether we maintain, or process on behalf of a third party, any of your Personal Data. If your personal information changes, the Personal Data we collected about you is inaccurate, or if you wish to no longer use our services, you may also request that your Personal Data be corrected, amended, or deleted. Requests for access to your Personal Data and to have it corrected, amended, or deleted should be sent to firstname.lastname@example.org or writing to us at Parlevel Systems Inc., 114 E. Cevallos St., San Antonio, TX 78204.
We will try to meet all requests regarding Personal Data, however, you may not be able to remove your personal information from archived web pages we no longer maintain. If we are unable to complete your access request, we will let you know we are unable to do so and why. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
If your information has been shared with a third party, as described above, then that third party has received their own copy of your data. If you have been contacted by one of these third parties and wish to correct or request they delete your information, please contact them directly.
5.2 Limiting the Personal Data You Provide
You can browse our Services without providing any Personal Data (other than data automatically collected to the extent it is considered Personal Data under applicable laws) or by limiting the Personal Data you provide. If you choose not to provide any Personal Data or limit the Personal Data you provide, you may not be able to use certain functionality of the Services.
5.3 Opting Out of Electronic Communications
Parlevel may send you electronic communications marketing or advertising through the Services themselves or events on the Services. When you use our Services, you have the option of signing up for Newsletters or to request further information. If at any time you would like to stop receiving the information that you have requested to receive from us, you may follow the opt-out instructions contained in any such electronic communication. In the case of the Parlevel koin and Micro Market solutions, you may also manage your email preferences at any time through your account.
If you opt-out of receiving emails or promotions from us, we may still send you emails about your account or any Services you have requested or received from us, or for other customer services purposes. In addition, you may still receive emails sent by third parties through means other than our Services.
Please be aware that you cannot unsubscribe from update communications about our Services unless you deactivate your account.
6. Retention of Your Personal Data
7. Cookies, Web Beacons, Etc.
7.1 What Cookies and Web Beacons Are
7.3 Controlling Cookies
8. Children and Minors
The Children’s Online Privacy Protection Act of 1998 and its rules (“COPPA”) requires us to inform parents and legal guardians about our practices for collecting, using, and disclosing personal information from children under the age of thirteen (13). In some countries or jurisdictions, even higher age limits may apply. Parlevel does not intend to collect Personal Data from children under the age of thirteen (13), or the otherwise applicable age limit if different in your country or jurisdiction of location, and expressly hereby prohibits Children under such age to create Wallets. If you are aware of a user under the age of thirteen (13) who has provided Personal Data through our Services, please contact us at email@example.com
If your state laws and regulations on Biometric Information specifically require Minors (younger than 18 years of age) to have a Parent or Guardian’s provide written consent in order for Parlevel to capture their Biometric Information, Parlevel expressly prohibits such Minors from disclosing Biometric Information without having a parent or guardian provide written consent.
9. International Privacy Laws
B. Data Controller
Parlevel is the data controller for processing of your Personal Data, but we act as a data processor for Personal Data that we process on behalf of our Customers. Please see the “Contacting Us” section below to find out how to contact us.
C. Your Rights
Subject to applicable EU law, you have the following rights in relation to your Personal Data:
-Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
-Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
-Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
-Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our agreement with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
-Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
--If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or
--If we are processing your Personal Data for direct marketing.
-Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
-Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
For purposes of the California Consumer Privacy Act, we do not “sell” your Personal Data.
If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by the California Consumer Privacy Act.
You may exercise your rights by contacting us as indicated under “Contacting Us” section below.
D. Legitimate Interest
E. Data Transfers
We rely on the EU-U.S. and Swiss-U.S. Privacy Shield certification to transfer Personal Data and other information that we receive from the EU and the United Kingdom and Switzerland to Parlevel in the U.S. (for more information, please read the “Privacy Shield” section below).
F. Contacting Us
If you have a privacy or data use concern please contact Parlevel at firstname.lastname@example.org
10. Privacy Shield
We rely on our Privacy Shield certification to transfer Personal Data and other information that we receive from the EU and the United Kingdom and Switzerland to Parlevel in the U.S. and we process such in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (“Privacy Shield Principles”), as described below.
B. Notice And Choice
This Policy provides notice of the Personal Data collected and transferred under the Privacy Shield and the choice that you have with respect to such data. It also provides information about other Privacy Shield Principles that are set forth below.
C. Accountability for Onward Transfers
We may be accountable for the Personal Data we receive under the Privacy Shield that we may transfer to third-party service providers (as described in Section 3 above) if they process Personal Data in a manner inconsistent with the Privacy Shield Principles and we are responsible if they do so and for the harm caused.
We maintain security measures to protect Personal Data as described in Section 4 of this Policy.
E. Data Integrity and Purpose Limitation
You have certain rights to access, correct, amend, or delete Personal Data where it is inaccurate, or has been processed in violation of the Privacy Shield Principles. Please see the Section 9 above for more information on rights of EU data subjects (and, to the extent applicable, data subjects in Switzerland). When we process Personal Data on behalf of our Users, we will process such requests pursuant to our contract with that User.
G. Recourse, Enforcement, Liability
In compliance with the Privacy Shield Principles, Parlevel commits to resolve complaints about our processing of your Personal Data. European Union and Swiss individuals with inquiries or complaints regarding this Private Shield Policy should first contact Parlevel as follows:
Postal Mail: 114 E. Cevallos St. San Antonio TX 78204 USA
We have further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider. 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 JAMS (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Parlevel will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at https://www.jamsadr.com/international-mediation-rules.
If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Privacy Shield Panel. For additional information, please visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to Personal Data received or transferred pursuant to the Frameworks.
12.1 Third Party Sites And Services
12.2 Aggregated Personal Data
In an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests, and behavior based on Personal Data and other information that we have collected. This research may be compiled and analyzed on an aggregate basis and this aggregate information does not identify you personally and we therefore consider and treat this data as Non-Personal Data.
14. Contacting Us
Who To Talk To About Your Privacy Questions
15. Your Local Privacy Rights
15.1 Do Not Track
Our Services are not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.
15.2 Other US State Regulations
15.2.1 California Residents
184.108.40.206 California Consumer Privacy Act
The California Consumer Privacy Act provides California residents with the right to know what categories of personal information Parlevel has collected about them acting in its capacity as a “business”:
Category of Personal Information
Collected by Parlevel?
Personal information categories listed in Cal. Civ. Code § 1798.80(e)
Protected classification characteristics under California or federal law.
Internet activity or electronic network activity information
Professional or employment-related information
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Inferences drawn from other personal information to create a profile
220.127.116.11 “Shine Your Light”
California residents may request a list of all third parties to which Parlevel has disclosed certain personally identifiable information about you for marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information by contacting us at: email@example.com or writing to us at Parlevel Systems Inc., 114 E. Cevallos St., San Antonio, TX 78204
15.3 Your Privacy Rights in Mexico
Parlevel Systems Inc, located at 114 E. Cevallos St., San Antonio, Texas, 78204 United States of America, is responsible for the use and protection of your personal data, and in this regard we inform you that the personal information we collect from you, will be used for the following primary purposes: for identification purposes, contact and technical support, related to the use of the Parlevel system, its kiosks, web portals and mobile apps.
For more information about the terms and conditions under which your personal data will be processed, such as the third parties with whom we share your personal information and how you can exercise your rights of Access, Rectification, Cancellation or Opposition, you can request our privacy notice by sending an email to the following address: firstname.lastname@example.org
I consent to the processing of my personal data in accordance with the terms and conditions stated in this privacy notice .
Residents of Spain are protected by the “Reglamento General de Protección de Datos” (RGPD) and European Norms. Parlevel complies as described in Section 9, especially with the transfer and processing of such information in the USA as it is an adequate level recipient (“destinatario declarado de nivel adecuado”) according to the RGPD by being certified by Privacy Shield.
Parlevel Systems Inc., Last Updated: January 31st, 2020