Data Privacy Framework Policy

This Data Privacy Framework Policy ("Policy") describes how Vesta Corporation ("Company," "we," or "us") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area ("EEA"), Switzerland, and the United Kingdom ("UK"), ("Personal Data"). This Policy applies to the following US entities: Vesta Corporation. This Policy supplements our Privacy Policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.

Vesta Corporation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Vesta Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Vesta Corporation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Vesta adheres to the DPF Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

For purposes of enforcing compliance with the DPF, Vesta is subject to the investigatory and enforcement authority of the US Federal Trade Commission.

Personal Data Collection and Use

Our Privacy Policy located at https://www.vesta.io/privacy-policy describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. We may receive the following categories of Personal Data in the US in connection with the provision of our services and operation of our business: name, mailing address, postal code, email address, telephone number, credit card number, debit card number, card expiration date, CVV number, bank account number, merchant identification, personal identification number, cookies, time zone, language, browser information, javascript settings, type of mobile device, mobile carrier, demographic information and any other information that Vesta may collect in order to process payments. The specific types of information we collect may change from time to time based on the nature of the services we provide to you. We may reach out to third party service providers for more information based on the information you have given. With respect to Vesta job applicants and employees we may collect name, address, telephone number, email address and other contact information, government identification numbers, date of birth, resume information, health or medical information, racial or ethnic origin information and other information related evaluating job candidates and the manner in which employees carry out their job responsibilities.

We process Personal Data for the following purposes: to provide you or your customers with the Vesta services and to help us review, develop, improve the products and services we offer, to facilitate and complete the transactions; to validate customer or card information; to verify and append information to prevent and combat fraud; to comply with government regulations and card association rules; and to perform various research and analytics. Vesta will only process Personal Data in ways that are compatible with the purpose that Vesta collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Vesta maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current. In the case of Vesta job applicants and employees we process Personal Data to consider applicants for employment, to extend job offers, to administer the employment relationship, including payroll and employee benefits, and conduct our business, and to meet our legal obligations.  

We may collect information about medical or health conditions and health or medical information about Vesta job applicants and our employees and use this information for the administration of employee benefits, for legal reporting purposes and other employment-related purposes. When we collect sensitive Personal Data, we will obtain your opt-in consent where the DPF requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for or than you later authorized.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Privacy Policy. Where required by the DPF, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the DPF requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our DPF obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the purposes described in our Privacy Policy. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the DPF requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the DPF requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection the DPF requires.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Vesta maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

Data Subject Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your Personal Data to us at privacy@vesta.io. You may also contact our affiliate Vesta Payment Solutions Ltd.   at Vesta Building, Finnabair Business Park, Dundalk, County Louth, Ireland A91 E934, or by phone at 353 (0)42 939 4600, with any questions or concerns. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate the EU data protection authorities, the UK Information Commissioner, or the Swiss Federal Data Protection and Information Commissioner. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities, the UK Information Commissioner, or the Swiss Federal Data Protection and Information Commissioner for further information and assistance.

Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Vesta and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see  DPF Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: privacy@vesta.io