Privacy Policy

Overview

SDD Creations (“we,” “our,” “us,” “SDD Creations”) provide this Privacy Policy to describe our use of your Personal Information when you visit or use our website.

We encourage you to read this Privacy Policy and to use it to help you make informed decisions.

Certain capitalized terms that are not otherwise defined in the Policy are explained in the Definitions section below.

We revise this Privacy Policy from time to time to reflect changes to our business, Services, or applicable laws. If the revised version requires notice in accordance with applicable law, we will provide you with 30 days prior notice by posting notice of the change on the "Policy Updates" or "Privacy Policy" page of our website, otherwise the revised Privacy Policy will be effective as of the published effective date. If you are a new User or are receiving this Privacy Policy for the first time and there is an upcoming change described on the Policy Updates or Privacy Policy page at the time you receive this Privacy Policy, such upcoming change will apply to you on the indicated effective date.

For most of our Services, we act as a “data controller” or “business”, however there are some products and features where PayPal may also act as a “data processor” or “service provider” when providing services to our Partners and Merchants. The “data controller” or “business” (each as defined under applicable data protection laws) is the entity that has the control over the purposes and means by which the data processing is performed. The “data processor” or “service provider” (each as defined under applicable data protection laws) is the entity that processes the Personal Information for the data controller, for the data controller’s specific purposes, and as otherwise permitted under applicable data protection laws.

Non-Account Holders and Fastlane Profile Users

Our Services may be accessed by individuals without a user account. We will collect Personal Information from you even if you are a non-account holder when you use our Services, such as when you use our Pay Without a PayPal account, use Unbranded Payment Services (e.g., Braintree and Zettle), use a Fastlane profile, or when a non-accountholder receives a payment through the Visa+ service from a PayPal account holder (“Recipient”). If you Pay Without a PayPal account, we may link your transaction information with your PayPal account, if you have one at the time you use the Service without logging in, or if you create a PayPal account later.

With a Fastlane profile, individuals can store their payment methods and Personal Information with PayPal so that they can complete the checkout process faster at participating Partners and Merchants without having to manually input payment method details and Personal Information each time they checkout ("Fastlane").

The Visa+ Service enables eligible customers with a PayPal account to send and receive money to and from Venmo and third-party Visa+-enabled digital wallets (“Visa+”).

When you shop on Partner and Merchant sites, the Partner or Merchant may disclose Personal Information with PayPal that we will use in accordance with this Privacy Statement and the relevant PayPal user agreement.

Categories of Personal Information We Collect

Categories of Personal Information collected from you, including from your interactions with us and use of the Services:

Personal Identifiers: Such as Name, Business Name, Address, Phone Number, Email, IP address, Device Information, Information collected from cookies or other tracking technologies, other information necessary to establish an account or profile.

Records and Financial Information: Such as, bank account and routing numbers, credit and debit card information, amount you send or request, other financial information.

Commercial Information: Such as online shopping cart information, shopping activity and goods or services considered on Partners and Merchants sites, purchase history, and order tracking and product information.

Geolocation: We may collect IP-based geolocation data and Global Positioning System (GPS) with your consent during your user experience or based on your mobile application settings.

Internet or network activity: interactions with our Services, Information about response time for web pages, download errors, date and time when you used the service, Location Information, such as your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies (“Technical Usage Data”).

Biometric: When you consent in the user experience, we collect voice identification, photo identification, or face scans to verify your identity and authenticate you for certain actions related to your account, including, for example, verify your identity and authenticate you to meet regulatory requirements or before you access accounts and Services, recover passwords, update profile info, manage payments and payment methods, lift account limitations, and initiate cryptocurrency transfers.

Audio, electronic, visual, or similar information: Call recordings when you talk to customer service.

Professional or employment information: including business information, job title, contact emails, phone numbers and taxpayer ID numbers.

Imported Contact Information: including name, address, phone number, images, email address or usernames associated with the contacts.

SDD Creations Account Profile Information: username, profile picture, gender, or personal description which you add that may include sensitive personal information. You can set your profile to “Private” at any time.

Information you provide when you contact us: Your response to surveys, recorded conversations, chat conversations with us, email correspondence with us, account or profile status, repayment history, voice identification, Information about others if you choose to share it with us.

Inferred data: We may infer information about you such as your preferences and shopping behavior, based on your transactions and interactions with our Services or with our Partners and Merchants.

Characteristics of Protected Classifications: including age or date of birth, national origin, disability, citizenship, military status.

Sensitive Personal Information: Social Security number, government-issued identification, bank account and routing numbers, credit and debit card information, voice identification and Photo IDs or Precise Geolocation.

Information from your device: including, language settings, browser ID, cookie preferences, time zone, operating system, platform, screen resolution and similar information about your device settings, data collected from cookies or other tracking technologies.

We may also obtain the above categories of Personal Information from the following categories of sources:

Excluded Services including Venmo and PayPal Honey.

Third parties: Service Providers, Partners and Merchants, Payment Partners, such as card networks and payment processors, Credit Reporting Agencies, Government Entities, Data Brokers, and Financial Institutions.

Linked Accounts: Non-financial or financial accounts you agree to link to PayPal, such as social network accounts, mail accounts or for open banking. You may change your mind about use of this feature and unlink your linked accounts at any time. If you choose to link these accounts or share such information with us, we will periodically collect and process it until you unlink the account.

Third Party Applications: Applications that you choose to use for example, the Apple App Store, Google Play Store, or social networking sites.

How is Personal Information used?

We may process your Personal Information for a variety of reasons, including to provide our Services, for security and fraud prevention and to comply with law. We may also use personal data to participate in certain features, that while not necessary for use of the Services, may be of interest to you, such as syncing your contact list to your account, personalizing content and offers, targeted advertising, or connecting to a third-party platform. Some of these features may be offered with an opt-out or require your consent to enable.

We may collect Personal Information to:

Provide our Services: such as to help you send, receive or request money, initiate a payment, add monetary value to an account, pay a bill, administer your purchases, show you your Fastlane profile, account and payment information, send and receive Visa+ transactions, to assess your creditworthiness in connection with our Services, confirm your identity and your contact information, to authenticate your access to your account or Fastlane profile and to confirm your account or profile and financial information is accurate and up to date. For Visa+, we will receive the recipient's name and payment information from Visa and third-party Visa+ participating digital wallets for the purpose of processing and matching Visa+ payment transactions between participating digital wallets and PayPal. If you are using Fastlane, we will also use your Personal Information and payment method details to determine whether the payment you are making with a participating Partner or Merchant is authorized by you and likely to be successfully authorized by the payment method you choose to use when you make a purchase using details from your Fastlane profile.

Provide receipts in connection with SDD Creations services: If you provide your e-mail address or mobile number to a Partner or Merchant who uses Zettle, we may remember your details for the next time you buy something from a Merchant who uses Zettle in its physical store, if you use the same payment card. This is regardless of whether you have previously bought something from this Merchant or not. This means that your e-mail address or mobile number will be pre-filled in the receipt view for your convenience the next time you buy something from a Merchant who uses Zettle in its physical store.

Manage and improve our Services: for example, to develop new products and features, for customer analysis, to administer our Services, and for internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.

Manage fraud and risk: We conduct risk analysis, fraud prevention and risk management to protect our customers and business, including fraud that involves our Partners and Merchants and strategic ventures.

Associate information about you: if you use our Services Without a PayPal Account (e.g., Pay without a PayPal account), we may associate such transactions with your PayPal account if you have one or later establish an account. If you use one of the following Services: Fastlane, Venmo, and PayPal Honey; we may associate information about your transactions and experiences using these Services to personalize content and offers and improve your use of the PayPal services.

Market our Services: We may use Personal Information to market our Services including where we partner with others to offer similar services to market about our Partners and Merchants. We use Personal Information, including when we associate information about you, to better understand and cater to your interests.

Communicate with you: We may contact you when you need us, such as answering a question you sent to our customer service team.

Comply with Laws: to comply with applicable laws and rules and enforce our agreements with you and other people who use our Services.

Process information about your contacts: to make it easy for you to find and connect them, improve payment accuracy and suggest connections with people you may know. By providing us with information about your contacts you certify that you have permission to provide that information to PayPal for the purposes described in this Privacy Statement.

Create an account connection between your account and a third-party account or platform: such as with a social media account or a financial institution in connection with your participation in Open Banking.

Send you locally relevant options: If you agree to let us track your precise location, we can customize our Services by using the right language and personalizing content such as providing location-based options, functionality or offers, ads and search results. Even if you don’t allow us to track your location, we may still use your address to send you location-based options recommended by businesses that are near to your address.

Develop product recommendations: We may use insights from purchases and other behaviors on our and our Partner or Merchant websites or apps to develop product recommendations about products, brands, sizes, preferences and styles that we provide to our Partners and Merchants so that they can recommend relevant products to you.

Remember your preferences: We may remember your preferences for the next time you use the Services, such as whether you choose to receive digital receipts via email or text when you checkout.

Personalize your experience: When you use Services, as well as other third-party sites and services, we might use tracking technologies like cookies. See our Cookie Statement for more details.

Do We Disclose Personal Information?

We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any sensitive personal information. However, we may disclose customer insights, product recommendations, sizes, and preferences to Partners and Merchants to help them and us improve your shopping experience to make it more convenient and personalized for you.

How long does SDD Creations store your Personal Information?

We retain Personal Information for as long as needed or is permitted in context of the purpose for which it was collected and consistent with applicable law.

The criteria used to determine our retention period is as follows:

Personal Information used for the ongoing relationship between you and SDD Creations is stored for the duration of the relationship plus a period of 1year, unless we need to keep it longer, such as:

A legal obligation or compliance with laws to which we are subject is retained consistent with the applicable law, such as under applicable bankruptcy laws and AML obligations, litigation, investigations, audit and compliance practices, or to protect against legal claims.

We retain biometric data for as long as needed or permitted given the purpose for which it was collected and no more than 1 year after your account closes, unless otherwise required by applicable law.

How Do We Use Cookies and Tracking Technologies?

When you interact with our Services, open email we send you, or visit a third-party website for which we provide Services, we and our partners use cookies and other tracking technologies such as pixel tags, web beacons, and widgets (collectively, “Cookies”) to recognize you as a user, customize your online experiences and online content, including to serve you interest-based advertising, perform analytics; mitigate risk and prevent potential fraud, and promote trust and safety across our Services.

We use Cookies to collect your device information, internet activity information, and generate inferences as described above.

You can disable or decline some Cookies for our Services. But, since some parts of our service rely on Cookies to work, those services could become difficult or impossible to use.

Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Because many of our services won’t function without tracking data, we do not respond to DNT settings.

If you want to know more about how we use cookies, please review our Statement on Cookies and Tracking Technologies. To learn how to opt-out of this kind of tracking technology, visit About Ads.

Your Data Protection Rights

Your rights to access, correction, deletion, and restriction to use or share your Personal Information.

Under applicable data protection law, depending upon the jurisdiction in which you reside and subject to applicable exceptions and definitional differences among various state laws, you may have certain rights about how your Personal Information is collected, stored, used and shared.

We recognize the importance of your ability to control the use of your Personal Information and provide several ways for you to exercise your rights to access (right to know your information), right to know third parties to which we have disclosed Personal Information, correction, deletion (erasure), and to restrict certain information (right to opt-out of sharing and right to limit use and disclosure of sensitive personal information).

Certain state laws also provide residents of those states with the right to opt out of the “sale” (disclosing Personal Information in exchange for money or other consideration) or “sharing” (disclosing Personal Information for cross-context behavioral advertising) of your Personal Information or use of your Personal Information for certain types of targeted advertising. Global Privacy Control settings is a browser setting that notifies website owners of users' privacy preferences regarding selling or sharing their Personal Information for cross-context behavioral advertising. PayPal does not respond to the Global Privacy Control signal because we do not sell or share your data.

We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights; although, certain personalized services for PayPal customers may not provide the same level of personalization with limited data sharing. If you are a California resident, learn more about how we handle your Privacy Rights.

How do you exercise your rights?

If you, or an authorized agent where permitted, want to exercise any of your rights relating to your Personal Information, contact us or submit your request from your account settings. If you have a PayPal account, you can exercise your privacy rights by accessing “Data and Privacy” from account settings in the PayPal app.

If you, or an authorized agent where permitted, want to exercise any of your rights relating to your Personal Information in your Fastlane profile, contact us or submit your request from your Fastlane profile management portal.

Even if you do not have a SDD Creations account (for example, where you use Pay without a PayPal account), you can submit a request for access, correction, or deletion of your Personal Information by contacting us at the number provided in our Contact Information section.

We’ll first need to verify who you are before we can respond to your request. We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will compare the information you submit against our internal business records to verify your identity. If we can’t verify your identity, we will not be able to fulfill your request. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process.

Your right to request a copy of the Personal Information. If you want to request the data we’ve collected about you in the past 12 months, you have choices:

Log in to your SDD Creations account, or Fastlane profile management portal, and submit a request.

Call or contact us and request that we provide you with the data we’ve collected.

Your right to correct your Personal Information:

Log in to your SDD Creations account, or Fastlane profile management portal, and correct any information that you've previously added. For example, you can edit your addresses in your settings.

Call or contact us and request that we correct specific information.

Your right to delete your Personal Information:

Log in to your SDD Creations account, or Fastlane profile management portal, and delete any information that you've previously added. For example, you may delete your non-primary addresses in your settings.

Call us or contact us and request that we delete specific information.

Close your SDD Creations account or Fastlane profile.

If you close your SDD Creations account, or Fastlane profile, or request that we delete Personal Information, we still need to keep some Personal Information as explained in How long does PayPal store your Personal Information section so we can:

Complete a transaction, provide goods or services you requested, or comply with our promises to you in the user agreement or other contract you have with us

Detect and prevent malicious, fraudulent, or illegal activity

Protect your (or another person’s) legal rights, including the right to free speech

 Manage our internal business processes that are reasonably related to your expectations when using our Services

Comply with laws and other legal or governmental processes

California also offers a right to opt out of “Selling” and “Sharing” Personal Information. The Global Privacy Control setting is a browser setting that notifies website owners of users' privacy preferences regarding selling or sharing their personal information. PayPal does not respond to these settings because we do not sell or share data. Some personal information collected, processed, or disclosed by a financial institution are subject to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice for more information about their rights under US federal law.

Understanding your choices

You can control how Personal Information is collected or disclosed, as well as how we communicate with you. Here are some of the ways you can customize your choices.

Choose how we collect Personal Information

You may choose to limit the Personal Information you provide when our apps or Services request it. To help make choices that are right for you, it’s important to understand that Personal Information helps us provide a richer, more personalized experience for you. Also, some Personal Information is required for our Services to function.

For example, sharing your contacts helps make it easier for you to find the people you want to send money to. If you choose not to share your contacts with us, you can still use our mobile apps, but some actions may not be as fast or easy as it would be if you shared your contacts. Another example is creating an account or Fastlane profile with us. If you choose not to provide information that is required for an account or Fastlane profile to function, like your name and email address, we will not be able to create an account or Fastlane profile for you.

Choose how linked accounts collect and use Personal Information

If you link your account to a third-party service, you may be able to manage how your Personal Information is collected, used, and shared by them. Read the third party’s privacy policies to see the choices they offer you.

You can control which third-party services you link to your account and what Personal Information they can collect about you. For example, to manage the permissions, go to the Security settings in your PayPal account.

Choose what we disclose with other Users

Some Personal Information may be seen by other Users. You may be able to adjust or turn off this setting in the Data and Privacy section in your account settings.

Choose what we share with Partners and Merchants for Personalized Shopping

Unless we are required by law to obtain your consent, we share Personal Information collected after November 27, 2024 (or from earlier if you consent) for personalized shopping experiences. Personal Information we disclose includes, for example, products, preferences, sizes, and styles we think you’ll like. To opt out of Personal Information sharing with Partners and Merchants for personalized shopping experiences, log into your PayPal account and edit your preferences in the Data and Privacy setting. If you opt-out, we will continue to disclose your Personal Information as necessary to complete transactions you initiate but will not disclose Personal Information to Partners and Merchants for personalized shopping experiences.

Choose how we communicate with you

Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional, and some are necessary for you to manage your accounts or Fastlane profile with us. We use email, text messages, push notifications on your mobile device, and even phone calls or paper mail depending on the situation and your preferences.

You can click the unsubscribe link in a PayPal or Fastlane marketing email, opt-out of a text message by replying “STOP,” or turn off notifications on your device. You can also change your account’s notification settings or the notification preferences on your device.

You won’t be able to opt-out of messages that are considered necessary for the Services, such as digital receipts and emails that alert you to changes in your account or Fastlane profile's status. You may be able to decide how we send those messages, such as by email, phone, text message, or a notification on your mobile device.

How Do We Protect Your Personal Information?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Information against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and account/Fastlane profile registration information and verifying that the Personal Information we maintain about you is accurate and current. We are not responsible for protecting any Personal Information that we share with a third-party based on a linked account connection that you have authorized.

Can Children Use Our Services?

We do not knowingly collect information, including Personal Information, from children under the age of 13 or other individuals who are not legally allowed to use our Services. If we obtain actual knowledge that we have collected Personal Information from someone not allowed to use our Services, we will promptly delete it, unless we are legally obligated to retain such data.

Please contact us if you believe that we have mistakenly or unintentionally collected information from someone not allowed to use our Services.

We do not sell to third parties for money or share Personal Information of anyone under 16 years of age, for the purpose of cross-context behavioral advertising.

Definitions

• Device Information means data that can be automatically collected from any device used to access the Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and internet connection you use to access the Services; Geolocation Information; information about apps downloaded to your device.
• Excluded Services means companies or separate brands, affiliates, or subsidiaries of PayPal, who process Personal Information in accordance with their own terms of service and separate privacy statements. Examples include Venmo, Honey Science LLC, Chargehound LLC, Hyperwallet, Simility, Swift Financial LLC, and Bill Me Later, Inc

• Geolocation Information means information that identifies, with precise specificity, your location by using, for instance, longitude and latitude coordinates obtained through your GPS, or your device settings.

• Location Information means information that identifies, with reasonable specificity, your approximate location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.

• Partners and Merchants means our partners and the merchants, partners or businesses that our Users transact with for the purpose of obtaining goods or services.

• Pay Without a PayPal account means our Services may be accessed by individuals without using a PayPal account, a Fastlane profile, or the Unbranded Payment Services. Pay Without a PayPal account does not include Venmo, which is subject to its own terms of service and separate privacy statement.

• PayPal means PayPal, Inc., which offers PayPal, Unbranded Payment Services, and Fastlane profile services.
• Personal Information in this Privacy Statement means information about you, including your identity, finances and online behavior.

• Sell under California law is defined as the disclosure of Personal Information to third parties in exchange for monetary or other valuable consideration.

• Services means any PayPal, Unbranded Payment Services, Pay Without a PayPal account, Fastlane, Xoom, Zettle (including Tap to Pay), bill pay, Rewards, sending or receiving money, credit products and services, including those offered with our Partners and Merchants, content, features, technologies, or functions, and all related websites, applications and services offered to you by PayPal, with the exception of the Excluded Services. Your use of the Services includes use of our Sites.

• Sharing under California law is defined as the targeting of advertising to a consumer based on that consumer’s Personal Information obtained from the consumer’s activity across websites.

• Sites means the websites, mobile apps, official social media platforms, or other online properties through which PayPal offers the Services and which has posted or linked to this Privacy Statement.

• Unbranded Payment Services means when you are interacting with and making payments to Partners and Merchants using our card processing and/or ACH origination services that do not carry the PayPal brand or when you use our Braintree or Zettle services.

 Our Contact Information

If you have questions about this Privacy Statement or your Personal Information, contact us so we can help.

To talk about your SDD Creations account or Unbranded Payment Services:

• Call Customer Service at 240-890-3305
• or visit our Contact Us page

CCPA California Notice at Collection

Most of the Personal Information we collect is subject to federal and state privacy laws that apply to financial institutions. To the extent the Personal Information is not subject to these federal and state financial privacy laws and to the extent it is collected in California about California residents, the California Consumer Privacy Act (“CCPA”) may apply. The following section pertains only to Personal Information that is subject to the CCPA (“CCPA personal information”) and makes statements that reference unique definitions and requirements of law.

This CCPA California Notice at Collection describes: (1) the purpose for which we use each category of “CCPA personal information” we collect; and (2) the categories of third parties to which we (a) disclose CCPA personal information for a business purpose, (b) “share” CCPA personal information for “cross-context behavioral advertising,” and/or (c) “sell” such CCPA personal information.

Under California law, “sharing” is defined as the sharing or disclosure of CCPA personal information by a business to a third party, for the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s CCPA activity across businesses, websites, applications, or services, other than those with which a consumer uses or directs a business to internally disclose CCPA personal information or intentionally interact with one or more third parties. “Selling” is defined as the disclosure of CCPA personal information to third parties in exchange for monetary or other valuable consideration but does not apply to such disclosures when a consumer uses or directs a business to intentionally disclose CCPA personal information or interact with one or more third parties. We do not sell or share your CCPA personal information, including any Sensitive CCPA personal information, outside the exceptions. We also do not sell or share and have no actual knowledge that we have sold or shared any CCPA personal information of anyone under 16 years of age.

For more information about each category, purpose of use, and the third parties to which we disclose CCPA personal information, please see the “Categories of Personal Information We Collect”, “How is Personal Information used,” and “Do We Disclose Personal Information” sections.