Privacy Policy
Effective Date: January 31, 2022
Sesami Cash Management Technologies Corporation, (hereafter “Sesami,” “we,” or
“us”), respects individual privacy and values the confidence of its customers,
employees, consumers, business partners, and others. Sesami strives to
collect, use, and disclose personal and other information in a manner
consistent with applicable laws, and prides itself on upholding the highest
ethical standards in its business practices. Sesami complies with the General
Data Protection Regulation (“GDPR”) and for the purposes of this Policy, the
Accountability principle under Article 5 [2] of GDPR, which establishes
responsibility for, and demonstrating compliance with, the GDPR primarily for
Data Controllers. However, Sesami undertakes to adopt this principle as a Data
Processor for our Clients (the Data Controller) as well as a Data Controller
for our employees.
Your privacy is important to us. This Privacy Policy describes how Sesami
collects, uses, and shares information in connection with our website at
Sesami.io and including but not limited to services listed on our website and
any listed mobile applications (the “Apps”); and the emails that we send to
our customers (collectively, the “Services”). It also describes users’ choices
regarding use, access and correction of personal information.
What Information is Collected
Sesami Commercial Services
Sesami collects both Personal Information and Other Information when you
register for or use the Services. Sesami does not collect any Sensitive
Personal Information, known as Special Categories under GDPR, unless expressly
directed to do so by your employer, whereby your employer would need to secure
a lawful processing ground for such data. “Personal Information” is any
information or set of information relating to an identified person or an
identifiable person who can be identified, directly or indirectly, by
reference to an identifier such as an identification number, location data, an
online identifier or one or more factors specific to physical, physiological,
genetic, mental, economic, cultural, or social identity. For example, Personal
Information includes name, address, email address, employer’s company name,
job title, phone or fax number, employee ID, travel itineraries, including
emergency contact information and, if requested by a client, passport numbers.
“Sensitive Personal Information” means Personal Information that reveals race,
ethnic origin, sexual orientation, political opinions, religious or
philosophical beliefs, or trade union membership, that concerns an
individual’s health or sex life, criminal proceedings, or that is designated
in writing by a third party as Sensitive Personal Information.
“Other Information” is any information that is not Personal Information or
Sensitive Personal Information. For purposes of this Privacy Policy, Personal
Information does not include information that is anonymized, or publicly
available information that has not been combined with Personal Information or
Sensitive Personal Information.
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For individuals residing in the European Union or in the United Kingdom,
where Sesami collects Personal Information directly from you, we will inform
you about the type of Personal Information collected, the purposes for which
we collect and use the Personal Information, and the types of non-agent
third parties to which Sesami discloses or may disclose that information,
and the choices and means, if any, Sesami offer individuals for limiting the
use and disclosure of their Personal Information. Under these circumstances,
notice will be provided in clear and conspicuous language when you are first
asked to provide Personal Information to Sesami, or as soon as practicable
thereafter, and in any event before Sesami uses or discloses the information
for a purpose other than that for which it was originally collected or
discloses it for the first time to a third party.
We collect Personal Information for the Sesami Commercial Services in the
following circumstances:
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You provide certain Personal Information to us when you: (a) register to use
the Services, (b) order products and services from us, and (c) send email
messages, submit forms, or send other information to us.
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When you complete a profile form to obtain personalized Sesami reports, you
are required to give your contact information (such as name and email
address). This information is used to contact you about Sesami services
about which you have expressed interest. It is optional for you to provide
additional Personal Information (such as health and activity information)
and unique identifiers (in the case of employees), but doing so permits
Sesami to provide a more report.
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If you use our Apps, Sesami may request to collect information about the
precise location of your device using GPS, WiFi, or cellular network signals
from your device. Keep in mind precise location data cannot be collected
unless you allow the app to use your terminal equipment location. If you
would like Sesami to stop collecting precise location from your device,
please follow the instructions in the section below titled “The Choices
Available to Users Regarding Collection, Use, Sharing, and Correction of
Personal Information” and in our
Cookie Policy.
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In the event of a complaint, we may receive Personal Information about you
from other users or third parties who may communicate information to us
about you in relation to that complaint.
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We may collect Personal Information from you at other points on our Services
that state that Personal Information is being collected.
We and our service providers may also collect Personal Information and Other
Information when you use our website or the Services. This may include your
computer or device operating system and browser type, your IP address, your
Internet service provider, your domain name, your general geographic location,
the website that you visited before the Site and referring URLs, the webpage
visited, the content accessed, the date and time spent on the webpage and the
link you used to leave the Sites.
Sesami and its partners collect this Personal Information and Other
Information automatically through the use of cookies or similar technologies,
such as Javascript, for many purposes, including to analyze trends, administer
the website, track users’ movements around the Site, and to gather demographic
information about our user base as a whole.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data 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 a specific
feature of the Sesami platform or our websites. 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 Policy.
You can find more information about the usage of cookies and similar
technologies in our
Cookie Policy.
Sesami Marketing
Sesami collects both Personal Information and Other Information for Marketing
purposes when you register for access to content in any form or you contact
us. Personal Information collected for Marketing purposes includes name,
address, email address, employer's company name, job title, phone or fax
number. We do not request any "Sensitive Personal Information" for Marketing
purposes.
We collect Personal Information for Marketing purposes in a variety of ways
including:
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Offline: When you attend one of our events, during phone calls with sales
representatives, or when you contact customer service.
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Through You: Information that you voluntarily provide through forms or
access requests. Note that there is no legal obligation for you to provide
us with Personal Information and any information collected by us will be
provided by you at your own will and with your consent. We may also collect
Personal Information from you at other points on our Services that state
that Personal Information is being collected. You always have the ability to
modify or remove information you provide Sesami either in the form or
through an email to marketing@sesami.io.
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Information From Other Sources: In order to enhance our ability to provide
relevant marketing, offers and services to you, to the extent permitted by
law, we may obtain information about you from other sources, such as search
information providers, analytics providers, advertising platforms public
databases, joint marketing partners, social media platforms, as well as from
other third parties.
We and our service providers may collect Other Information for Marketing
purposes in the following ways, including:
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Through Your Browser or Device: Certain information is collected by most
browsers or through your device by automated means, such as computer type
(Windows or Mac), screen resolution, operating system name and version,
device manufacturer and model, language, Internet browser type and version,
and the name and version of the Sites (such as the Apps) you are using, IP
address, referring URLs, information on actions taken on our website, and
dates and times of website visits.
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Through Cookies and Similar Technologies: Sesami and its business partners
use cookies and similar technologies to analyze trends, administer the
Sites, track users' movement around the Sites, and to gather demographic
information about our user base as a whole. In particular, cookies and other
technologies are used by our web analytics services which currently include
Google Analytics, Microsoft Clarity and similar technologies to analyze how
users use the Sites.
Employee Information
Sesami collects both Personal Information and Other Information when you apply
through our careers portal or some other method and when you are employed by
Sesami. Personal Information collected may include name, address, bank
information for payroll purposes, email address, job title, phone or fax
number, emergency contact information, and where appropriate, passport numbers
and/or national registration numbers. "Sensitive Personal Information" means
Personal Information that reveals race, criminal proceedings as part of
routing background checks, and work performance information.
On our career portal, we use Google Analytics in the manner described above.
Who Collects the Information
The entities listed below are the companies that make up Sesami and which
collect Personal Information and Other Information through our Services.
Sesami Cash Management Technologies Corporation
Canada
1250 René-Lévesque Blvd West
20th Floor
Montréal QC H3B 4W8
U.S.
2025 W Belt Line Rd #114
Carrollton TX 75006
And our customer service email address is
marketing@sesami.io.
In some cases, as part of our Commercial Services, we may collect information
from or through a third party, such as itinerary aggregators to provide you
risk management services. In those circumstances, the collection, use, and
disclosure of your information is subject to the privacy policy of the
third-party website or service, and not this Privacy Policy.
How the Information Is Used
For individuals residing in the European Union and in the United Kingdom,
Sesami will use Personal Information only in ways that are compatible with the
purposes for which it was collected or subsequently authorized by the
individual or directed by an employer that has purchased Sesami products or
services on behalf of its employees. Sesami will take reasonable steps to
ensure that Personal Information is reliable for its intended use, accurate,
complete and current.
Commercial Services
We use Personal Information and Other Information as part of our Commercial
Services to:
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Provide you with content, products, and services that you request, fulfil
the terms of any agreement you have with us, and operate our business.
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Register you for the Services and tailor the Services specifically to the
profile you provide.
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Send administrative communications about the Services, respond to your
requests, request feedback or handle customer service questions or issues,
or to notify you of important changes or updates to the Services.
- Operate our Services, enhance our Services, and deliver messages.
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Maintain the essential functionality of our Sites and analyze the Sites'
performance so that we can make them work more efficiently and securely.
Marketing
We use Personal Information and Other Information collected for Marketing
purposes to:
- Respond to any requests for information you submit.
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If you elect to use our referral service for informing a friend about our
Services, we ask you for the friend’s name and email address. Where
permitted by law, Sesami will automatically send the friend a one-time email
inviting them to visit the Services. Sesami stores this information for the
sole purpose of sending this one-time email. The friend may contact Sesami
at dataprotection@sesami.io to request the removal of this information from
our database.
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Send newsletters and promotional communications (which we send on an opt-in
basis where required by law) regarding our current products, Services, and
features; our new or improved products, services, or features; and other
information that we believe may interest you. Although we hope that you will
find our promotional communications useful, you may opt out of receiving
them by following the “unsubscribe” instructions included at the bottom of
each email message.
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Where you have given your consent (where legally required), we use cookies,
log files and other technologies to collect personal information from the
computer hardware and software you use to access our Sites, or from your
mobile. As described above, this may include for example:
- an IP address to monitor traffic and volume on our Sites;
- a session ID to track usage statistics on our Sites; and
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information regarding your personal or professional interests, demographics,
experiences with our products and contact preferences.
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We use your information in order to perform insight and analysis activities
for our Services and our Sites, including to understand and analyze how the
Services are being used, measure the effectiveness of our content and how
visitors use our Sites, learn what pages of our Sites are most attractive to
our visitors, which parts of our Sites are the most interesting, create new
products and services, and deliver messages. Please see our Cookie Policy
for further information.
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We may provide lists of prospects from tradeshows with partners (on an
opt-in basis where required by law).
Employee
We use Personal Information and Other Information collected for Employment
Purposes to:
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Fulfil our legal obligations as your employer including performance
evaluation, tax reporting, payroll data and employee benefit services.
Information We Collect on Behalf of Our Clients
The use of information collected through our service shall be limited to the
purpose of providing the service for which the Client has engaged Sesami.
Sesami collects information under the direction of its Clients and has no
direct relationship with the individuals whose personal data it processes. If
you are a customer of one of our Clients and would no longer like to be
contacted by one of our Clients that use our service, please contact the
Client that you interact with directly. We may transfer personal information
to companies that help us provide our service. Transfers to subsequent third
parties are covered by the service agreements with our Clients.
If your employer (our Clients) has purchased Sesami products or services on
your behalf, Sesami may receive Personal Information about you directly from
your employer. For individuals residing in the European Union, if your
employer has given Sesami any Personal Information about you in connection
with its purchase of a Sesami product or service for your benefit, your
employer and not Sesami will be responsible for determining the method and
means by which you will receive notice and the ability to consent to Sesami’s
receipt and use of such information.
An individual who seeks access, or who seeks to correct, amend, restrict,
port, or delete data should in most cases direct his query to the Sesami’s
Client (the data controller). If requested to remove data, we will respond
within a reasonable timeframe and inform you thereof.
We will retain personal data we process on behalf of our Clients for as long
as needed to provide services to our Client. Sesami will retain this personal
information as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
With Whom the Information May Be Shared
We share information within Sesami organization. This will involve
transferring your data inside and outside of the European Economic Area
(“EEA”)
We also share the disclose information to third parties in the following
circumstances:
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Sesami may share Personal Information and Other Information we collect with
our contractors and third-party service providers, including companies that
send email and other messages on our behalf to you, to companies that store
such information for these uses, and companies that perform analytics
services for us, on a need-to-know basis in order to provide and maintain
our Services. These companies are authorized to use your personal
information only as necessary to provide these services to us. For consumers
residing in the European Union, Sesami will obligate such service providers
to safeguard such information in a manner consistent with this Policy and
the consent provided by you and to provide the same level of protection as
the GDPR requires. Sesami will remain liable if the service provider
processes information in a manner inconsistent with GDPR, unless Sesami
proves that it is not responsible for the event giving rise to the damage,
if any.
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Our Sites and Apps may allow third parties (such as Google) to collect
information through cookies, pixel tags, and mobile advertising identifiers,
such as Apple’s IDFA or Android’s Advertising ID, for use in online
interest-based advertising. For more information about behavioral
advertising practices, please see our Cookie Policyor visit the Network
Advertising Initiative, the Digital Advertising Alliance or the European
Digital Advertising Alliance. You may opt out of our third-party service
providers’ interest-based advertising practices by visiting our preference
management centre for cookies in web browsers and mobile apps or by clicking
http://preferences-mgr.truste.com or if located in the European Union click
http://www.youronlinechoices.eu. Please note you will continue to receive
generic ads.
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For California residents, although our Sites currently do not respond to "do
not track" browser headers, you can limit tracking by taking the steps
discussed above. Please note that the use of online tracking mechanisms by
third parties is subject to those third parties' own privacy policies and
not this Policy.
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You can find more information on cookies and tracking mechanisms used by
third parties on our Sites and Apps, as well as how to opt out of these in
our Cookie Policy.
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When you contribute to a public area or feature of our Site, the information
that you submit will be made available to other users, and sometimes to the
general public. For this reason, we recommend that you do not submit any
Personal Information, including your full name, home address, phone number,
other information that would enable other users to locate you, or financial
or medical information on these areas of our Site. If you are a California
resident under the age of 18 and a registered user of our Services, you may
request that we remove content that information that you post on our
Services that personally identifies you. To obtain removal of such content
or information, please send an email with a detailed description of the
specific content or information you would like removed to
dataprotection@sesami.io. Please be aware that such a request does not ensure complete or
comprehensive removal of the content or information you have posted, since
the content or information may remain in our database, may remain visible in
a manner that does not identify you, or may have been re-posted by another
user. There may be other circumstances in which applicable laws do not
require or allow removal even if requested.
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In addition, Sesami may use and disclose Personal Information and Other
Information as it believes reasonably necessary: to comply with applicable
law or respond to legal process (for example, a court order, search warrant
or subpoena); in response to lawful requests by public authorities (such as
to meet national security or law enforcement requirements); to investigate,
prevent, or take action regarding illegal activities, suspected fraud,
violations of our Terms and Conditions, or in other circumstances in which
Sesami has a good faith belief that its products or Services are being used
in the commission of a crime or that there is an emergency that poses a
threat to the safety of you or another person; or to protect our rights and
property.
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Sesami may disclose Personal Information and Other Information to facilitate
the financing, securitization, insuring, merger, sale, assignment,
bankruptcy, or other disposal of all or part of our business or assets.
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We may also disclose aggregated, de-identified information about users of
the Services for any purpose, such as by publishing a report on trends in
the usage of the Sesami Services.
Privacy Protections for Children
This Site and the Sesami Services are provided for adults only. The Site and
the Services are not directed to children under the age of 13, and we do not
knowingly collect personal information from children under the age of 13
through the Site or Services.
The Choices Available to Users Regarding Collection, Use and Distribution
of Personal Information and Other Information
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You can control the collection, use, and sharing of your information by
following the instructions stated below. Please note that if you provide any
information to parties who provide services to our Site or Apps or to any
other sites or apps you encounter on the Internet or otherwise (even if
these sites are branded with our branding), different rules may apply to
their use or disclosure of the Personal Information you disclose to them. We
encourage you to investigate and ask questions before disclosing Personal
Information to third parties.
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You have the right to access, amend or delete Personal Information we hold
about you, and in some cases to object to the processing of your Personal
Information or request your Personal Information to be provided to you in a
portable form. For example, if your Personal Information changes, you would
like to review or correct your Personal Information, or if you no longer
desire our Services, you may correct, update, or remove your Personal
Information at the member information page or by emailing our Customer
Support at marketing@Sesami.io. Upon request Sesami will provide you with
information about whether we hold any of your personal information. We will
respond to your request within a reasonable timeframe.
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You are given the opportunity to ‘opt in’ to having your Personal
Information used for purposes not directly related to our Services at the
point where we ask for the information. For example, Sesami might want to
use your information as part of future marketing campaigns.
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You may also ‘opt out’ of receiving non-essential or promotional
communications directly from Sesami. If you no longer wish to receive our
non-service-related mailings, you may opt out of receiving these
communications by following unsubscribe instructions at the bottom of each
communication, replying to the email and placing “unsubscribe” in the
subject line of the email, or emailing us at
dataprotection@sesami.io
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Sesami may collect location information if you use a Sesami application on
your mobile device. The iOS and Android (OS 6.0+) platforms will alert you
the first time a Sesami app wants permission to access certain types of data
and will let you consent (or not consent) to that request. You may
subsequently manage your location sharing preferences at any time with the
iOS and Android (OS 6.0+) platforms by changing the Location Services
settings on the device. Android (OS 5.1.1 and earlier) devices will notify
you of the permissions that a Sesami app seeks before you first use the app,
and your use of the app constitutes your consent.
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For more information on how to opt out of the use of cookies and other
tracking mechanisms from our Sites please see our
Cookie Policy.
What Kind of Security Procedures We Use to Protect the Loss, Misuse, or
Alteration of the Information Under Our Control
Sesami takes commercially reasonable administrative, technical, and physical
precautions to protect our users’ information against loss, misuse and
unauthorized access, disclosure, alteration, and destruction. However, no
system is 100% secure, and therefore we cannot guarantee the absolute security
of the information that we collect.
How long do we retain your Personal Information for?
We may retain your information for as long as your account is active or as
needed to provide you services, comply with our legal obligations, resolve
disputes and enforce our agreements, consistently with applicable law.
How Information for European Users
Sesami is GDPR compliant and committed to subjecting all personal data
received from European Union (EU) member countries and Switzerland,
respectively.
Sesami is responsible for the processing of personal data it receives, under
GDPR, and subsequently transfers to a third party acting as an agent on its
behalf. Sesami complies with GDPR for all onward transfers of personal data
from the EU and Switzerland, including the onward transfer liability
provisions.
In certain situations, Sesami may be required to disclose personal data in
response to lawful requests by public authorities, including to meet national
security or law enforcement requirements.
International Transfer
Sesami provides services globally so it may be necessary to transfer your
Personal Information internationally. In particular, your Personal Information
will be transferred to and processed in the United States and/or the United
Kingdom and wherever you access Sesami provided services while you travel. You
acknowledge that the data protection and other laws of other countries may
provide a less comprehensive or protective standard of protection than those
in your country or the country you are in while using our services. Where
European or UK data protection laws apply, we use Standard Data Protection
Clauses in line with the guidance from the Court of Justice of the EU.
Complaints and Dispute Resolution
In compliance with the GDPR, Sesami commits to resolve complaints about our
collection or use of your personal information. All individuals with inquiries
or complaints should first contact Sesami at:
Privacy Office
Sesami Cash Management Technologies Corporation
Canada
1250 René-Lévesque Blvd West
20th Floor
Montréal QC H3B 4W8
U.S.
2025 W Belt Line Rd #114
Carrollton TX 75006
And our customer service email address is
marketing@sesami.io.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy
with our response to any requests you have made to us regarding the use of
your personal data, you have the right to lodge a complaint in the UK with the
Information Commissioner’s Office.
You can contact them by calling +44 (0) 303 123 1113 or go online to
www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content
of external websites).
If you are based outside the UK, you have the right to lodge your complaint
with the relevant data protection regulator in your country of residence.
Changes to this Privacy Policy
This Privacy Policy may be amended from time to time, consistent with changing
legal, regulatory, or client requirements. We will post any changes to this
Privacy Policy on our website. If we make a material change to this Privacy
Policy, we will provide you with appropriate notice on our website prior to
the change becoming effective. We encourage you to periodically review this
page for the latest information on our privacy practices.