Privacy Policy

1. APPLICATION

Global e-Trading, LLC doing business as ResolveLab and its affiliated brands have adopted this Privacy Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that ResolveLab obtains from Customers located in the European Economic Area.

All ResolveLab Employees who handle Personal Data from Europe are required to comply with the principles stated in this Policy.

2. SCOPE

This Policy applies to the processing of Customer Personal Data and/or HR data that ResolveLab receives in the United States concerning either Customers and/or Chargeback911 human resource data. This Policy applies to all of our US legal entities, subsidiaries and/or affiliates.

3. RESPONSIBILITIES AND MANAGEMENT

ResolveLab has designated its Legal Department to oversee its information security program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to legal@resolvelab.com.

ResolveLab will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. ResolveLab personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 6 for a discussion of the steps that ResolveLab has undertaken to protect Personal Data.

4. COLLECTION AND USE OF PERSONAL DATA

ResolveLab provides various solutions to its Customers, which are predominantly business Customers, and collects some Personal Data from Customers when they purchase our services, log in to their account, request information from ResolveLab, or otherwise communicate with ResolveLab. For example, ResolveLab’s Customers may choose to seek live support or request transactional data concerning a chargeback or the associated 

customer to a transaction where a chargeback has occurred.

The Personal Data that ResolveLab collects may vary based on the Customers and their specific request for services. As a general matter, ResolveLab may collect the following types of Personal Data from its Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Customers have the option to log in to their accounts online and ResolveLab will collect information that Customers choose to provide to ResolveLab through these portals.

ResolveLab serves as a service provider to its Customers. In our capacity as a service provider, ResolveLab will receive, store, and/or process Personal Data owned and/or controlled by our Customers, including information about their employees, clients, customers, agents, or other individuals. In such cases, ResolveLab is acting as a data processor and will process the personal information on behalf of and under the direction of each Customer. The information collected from ResolveLab’s Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Customer, and as otherwise requested by the Customer.

5. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA

Except as otherwise provided herein, ResolveLab discloses Personal Data only to a Third Party who reasonably need to know such data. Such recipients must agree to abide by confidentiality obligations. ResolveLab provides, upon request, Mutual Non-Disclosure Agreements for its Customers, which may be tailored based upon Customer’s individual business needs, as a means to control and limit the disclosure of Customer Personal Data.

ResolveLab may provide Personal Data to a Third Party that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, ResolveLab may store such Personal Data in the facilities operated by a Third Party. Such Third Party must agree to use such Personal Data only for the purposes for which they have been engaged by ResolveLab and they must agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy. ResolveLab also may disclose Personal Data for other purposes or to another Third Party when a Data Subject has consented to or requested such disclosure. 

6. DATA INTEGRITY AND SECURITY

ResolveLab uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. ResolveLab has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically-stored Personal Data is stored on a secure network with firewall protection, and access to ResolveLab's electronic information systems requires user authentication via password or similar means. ResolveLab also employs access restrictions, limiting the scope of Employees who have access to Customer Personal Data. Further, ResolveLab uses secure encryption technology to protect certain categories of Personal Data. Despite these precautions, no data security safeguards can guarantee absolute security all of the time, and as such ResolveLab does not make any such guarantee.

7. NOTIFICATION

ResolveLab notifies Customers about its adherence to the Privacy Policy principles through its publicly posted website privacy policy, available at https://resolvelab.com/privacy-policy/

8. ACCESSING PERSONAL DATA

ResolveLab personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

9. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA

9.1 Right to Access. Data Subjects have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which ResolveLab collected the Personal Data. Data Subjects may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law. Upon reasonable request, ResolveLab allows Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Customers may edit their Personal Data by contacting ResolveLab by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Customers should submit a written request of the same. Persons that have submitted their Personal Data to a ResolveLab Customer should contact the Customer in the first instance to update their data.

9.2 Requests for Personal Data. ResolveLab will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If ResolveLab receives a request for access to his/her Personal Data from a Customer's customer, then, unless otherwise required under law or by contract with such Customer, ResolveLab will refer such Data Subject to Customer.

9.3 Satisfying Requests for Access, Modifications, and Corrections. ResolveLab will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

10. CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with applicable data protection and privacy laws and principles. ResolveLab will make Employees aware of changes to this policy, and will notify Customers if any changes are made that materially affect the way that Personal Data is handled and previously collected, and ResolveLab will allow Customers to choose whether their Personal Data may be used in any materially different manner.

11. QUESTIONS OR COMPLAINTS

Customers may contact ResolveLab with questions or complaints concerning this Policy at the following address: legal@resolvelab.com

12. ENFORCEMENT AND DISPUTE RESOLUTION

ResolveLab commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Policy should first contact ResolveLab at:

Legal Department

ResolveLab 
18167 US Highway 19 North Suite 600
Clearwater, Florida 33764
Email: legal@resolvelab.com 
Phone: (813) 421-0734

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 inquiry or complaint. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit your country’s data protection authorities (“DPAs”) for more information or to file a complaint.

ResolveLab has further committed to refer unresolved complaints to the appropriate DPA. The services of the DPAs are provided at no cost to you.

Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

13. Definitions

Capitalized terms in this Policy have the following meanings:

"Customer" means a prospective, current, or former partner (distributor or reseller), vendor, supplier, customer, or client of ResolveLab. The term also shall include any individual agent, employee, representative, customer, or client of a ResolveLab Customer where ResolveLab has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.

"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of ResolveLab or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

"Europe" or "European" refers to a country in the European Economic Area.

"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not
include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.

"Third Party" means any individual or entity that is neither ResolveLab nor a ResolveLab employee, agent, contractor, or representative.