Deluxe Small Business Sales, Inc. and Hostopia Ireland LTD Privacy Policy

Effective Date: May 16, 2017
Your privacy is important to us. As a result, we’ve developed this Privacy Policy that provides a description of how we collect, use, disclose, transfer, and store your information, as well as your choices regarding use, access and correction of your personal information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

I. Introduction & Notice

    a. Introduction

Deluxe Small Business Sales, Inc. and Hostopia Ireland Limited (“Deluxe”), doing business as (“Aplus”), (“VerticalResponse”), (“Hostopia”),, and, makes reasonable efforts to protect the privacy of your personal information. This Privacy Policy was created to demonstrate our commitment to fair information practices. Our policies and procedures address applicable U.S. and international privacy requirements concerning the collection, use, and cross-border transfer of personal data.

This Privacy Policy covers Deluxe and its subsidiaries’ use of personal information that Deluxe collects when you use its websites, including but not limited to:,,,,, and (collectively, the “Sites”). In the event that personal information is provided to us, whether in electronic, paper, or verbal format, it will be collected, used and disclosed by Deluxe in accordance with this Privacy Policy.

As described more fully below, Deluxe participates in and has certified its compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland, respectively. Deluxe has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Deluxe is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Under certain conditions, more fully described on the Privacy Shield website here, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.Other than as described in this Privacy Policy, we will not disclose personal information about you to others without your express consent.


    b. Definitions

  • The terms "we", "our", and "us" in this Privacy Policy refer to Deluxe delivering the services and products herein.
  • “You” means the individual to whom any given Personal Data covered by this Privacy Policy refers.
  • “Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.

   c. Regulatory Oversight

For this Privacy Policy and its content, Deluxe is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If Deluxe becomes subject to an FTC or court order based on non-compliance with this policy or EU-U.S. and Swiss-U.S. Privacy Shield frameworks, Deluxe shall make public any relevant Privacy Shield related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

II. Collection of Personal Information

Deluxe Sites collect different personal information based upon how you use them.

    a. Personal Information

There are areas on the Sites where you can share information that is unique to an individual; such as your name, company name, postal addresses, e-mail addresses, phone number(s), zip code(s), and billing and payment information such as credit card information (“Personal Information”). All of the foregoing is treated as Personal Information, as described in this policy.

    b. Types of Personal Information Collected

Customer/Visitor Information
Deluxe publishes several digital properties supporting its products and services. Depending on which Sites you visit, Personal Information collected may be different. Below are the types of personal data that may be collected.

  • Personal Information collected via may include name, work email address, phone number, organization, and country.
  • Hostopia & Hostopia Partner Connect Personal Information collected via may include name, email address, and company name.
  • VerticalResponse Personal Information collected via may include name, email address, and company name.
  • Personal Information collected via may include name, address, email address, phone number, organization, country.
  • Personal Information collected via may include name, address, email address, phone number, organization, country.

    c. Information from Children

Deluxe Sites and its related services are directed at adults and businesses. We do not knowingly collect or use information provided from children under the age of 13. If we become aware of any collection of personal information from children, we will delete it immediately.

    d. Cookies

As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, and to improve marketing, analytics, and/or site functionality.

We and our partners use cookies and similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.  A cookie is a small data text file that our server sends to your computer and that your computer sends back to us each time you visit our website.  Most Internet browsers automatically accept cookies.  However, you can disable and/or delete cookies by controlling your browser settings.  If you do disable cookies, our website will not recognize you and you will not be able to place an order or retrieve your order status.

We also partner with third parties to provide you advertising based upon your browsing activities and interests. Our third-party partners may use cookies or similar technologies in order to provide such advertising. If you wish to opt out of interest-based advertising click here, or if located in the European Union click here. Please note you will continue to receive generic ads.

  • Advertising Network Cookies for U.S. Customers

If you are a U.S.-based customer, our business partners may place advertising network cookies in emails we broadcast on your behalf. The cookies contain pseudonymous information about email recipients to provide them with targeted advertising on websites. However, if email recipients wish to not have this information used for the purpose of serving targeted ads, they may opt-out by clicking here.

    e. Analytics

The Sites use analytical data provided by Google Analytics. You can find out more about the types of analytical data and how that data is processed by visiting

III. Purpose & Use of Collected Personal Information

       a. / /

We use the information collected about you to process orders and to provide a more personalized customer experience. We may also use your information to communicate with you about products, services, and future promotions. For the purposes of order verification and fraud prevention, we may exchange information about our customers internally within Deluxe and among our affiliates.

The type of information we collect, use, or share may depend on the product or service you have requested from us. At times, we may request that you voluntarily supply identifying information for purposes such as receiving correspondence, registering on this website, making purchases, or participating in online surveys, forums, blogs, chat sessions, market research or contests/sweepstakes. If you elect to participate, we may require you to provide business information, including your name, mailing address, phone number, financial institution information, credit card information, or e-mail address. In certain areas of our website, you may provide employee information such as when adding authorized users to your business account and updating contact information. When you submit business information to us, you understand and agree that we may access, store, and use your information in accordance with this Privacy Policy.

Using the information you provide us, we will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We may send you strictly service-related announcements when it is necessary to do so. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

If you subscribe to DeluxeRev/Deluxe Marketing Suite, your business information will be de-personalized and aggregated in order to provide subscribers with statistical information to help you make wise marketing decisions as you seek the optimal way to grow your business. For testimonials, we obtain the customer's consent prior to posting the testimonial along with the customer’s name. We are not responsible for the personal information you choose to submit through testimonials.

Deluxe may selectively share customer information, including names and mailing addresses, with reputable third parties and organizations whose products and services we think may interest you.

We may share your email address with third parties for marketing purposes and partner with selected companies to offer products or services we believe may be of interest to you on their behalf.

You may opt out of receiving unsolicited marketing as a result of your transaction with us or request that we refrain from sharing your personal information with third parties and other organizations for marketing purposes. If you no longer wish to receive promotional communications from Deluxe or any third parties, you may edit your Account Profile, follow the unsubscribe instructions included in each communication, or refer to the Contact Us section below.

     b. Hostopia

We act as a service provider or data processor to enable delivery of your requested services. We only collect, receive and use personal information to process these services. Our contractual agreements specify the type of personal information collected based on the subscription level and type of web services implemented by the wholesale customer. Notice of purpose and usage of data is the accountability of each Partner of our customers in its relationships with its end-users, including applicable sharing with third party service providers.We collect this personal information under the direction of our customers, and have no direct relationship with the individuals whose personal information we process.
We only collect and use personal information provided to us for the following purposes:

  • To establish and maintain a responsible commercial relationship to provide ongoing service. For example, with purchased services, we process information that allows us to provide support services so that we can accurately fulfill the delivery of the services
  • We may process your credit card information
  • For authentication purposes to access the products and services

We only collect or process personal information when you specifically and knowingly provide it on our retail websites or to our customer service representatives via telephone, or in delivery of services requested by your communication service provider. For the purposes of fraud prevention, we may exchange information internally and among our affiliates. If you request information or purchase domain name, email web hosting or other services (the “Services”), you will be asked to provide personal information. This information may include the following elements based on your communication service provider’s level of enrolled Services:

  • Account name and account ID
  • Account address
  • Phone/Facsimile number
  • Domain name/email address (ISP account)
  • Domain/ftp or email password
  • Service name (product codes)
  • Billing & Payment information (optional)

If we collect information about you from a co-branded or private label web site, it will be clear at the customer point of collection who is collecting the information and whose privacy statement applies. Our customers maintain responsibility for providing notice to their end-users on the data collected and how it will be used.
In select instances, our wholesale customers may require us to provide this Policy directly to its end-users. The notice would be displayed to you in the terms and conditions and/or End User Licensing Agreement (EULA) that is customized and approved by the communication service provider partner. When providing notice on behalf of our customer, we display the notice whenever personal information is collected and stored, requiring your acceptance before proceeding.

    c. VerticalResponse

VerticalResponse collects information from our users at several different points on our site.No registration is required to view the VerticalResponse site. However, if you choose to register or provide personal information on our newsletter sign-up, free trial, order forms, affiliate, partner and job application pages or other areas of our site, we will ask for information which may include your name, mailing address, email address, billing and payment information (e.g. credit card information), company name, and telephone number. We use this information to create new accounts, fulfill your order, communicate with you regarding our services, and manage our customer relationships. We may send you service-related announcements when it is necessary to do so. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account. For the purposes of order verification and fraud prevention, we may exchange information about our customers internally within VerticalResponse and among our affiliates.

  1. Information You Upload into VerticalRespons VerticalResponse will not sell or rent this data and only the registered account holder can gain access to the uploaded lists.
  2. Customer Testimonial We post customer testimonials on our site which may contain personally identifiable information. We obtain the customer's consent via email prior to posting the testimonial along with the customer’s name. If you wish to update or delete your testimonial, you can contact us at
  3. Public Forum Our site offers publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
  4. Tell-A-Friend If you choose to use our referral/share service to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. VerticalResponse does not store this information and uses this information for the sole purpose of sending this one-time email.
  5. Survey From time-to-time, we may provide you the opportunity to participate in surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you have a choice whether to disclose this information. The requested information typically includes contact information (such as name and shipping address), and demographic information (such as zip code). We use this information to monitor site traffic or personalize the site.

IV. Information Retention & Accuracy

We take reasonable steps to ensure that personal information we receive, process, or maintain is accurate, complete, and reliable for its intended use. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the personal information collected.
In general, we keep personal information only as long as we need it to provide you the services you requested. We may also process data on behalf of third parties who have engaged us.We keep personal information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements. We maintain procedures for the secure disposal or destruction of personal information.

V. Sharing of Personal Information & Accountability for

  Onward Transfer

There are a variety of circumstances where we may need to disclose personal information to:

  • A person who, in the reasonable judgment of Deluxe is seeking the information as your agent. For example, we may provide information about your account to your legal representative if we are satisfied that that individual is requesting the information on your behalf;
  • Our parent company or affiliates to help us serve you better and provide you with requested services;
  • A company or individual employed by us to perform functions on our behalf, such as support services, information technology development and support, customer service or data processing, and are authorized to use your Personal Information only as necessary to provide these services to us; and,
  • A public authority, agent of a public authority or law enforcement agency if required by law.

We will share randomized, aggregated demographic information about our users with third parties. This information is not linked to any personal information and cannot identify any individual person.
Deluxe may also disclose your Personal Information to any other third party with your prior consent.
Additionally, Deluxe may share your Personal Information, without your prior consent, for the limited purposes noted below:

a. Subprocessors/Third Party Service Providers

To provide and market our services, Deluxe uses subprocessors to perform functions such as:

  1. Data Storage
  2. Marketing & Analytics
  3. Support
  4. Credit and payment Card Transactions

We only share Personal Information with third party service providers to the extent necessary to provide the requested services. These companies are prohibited from retaining, sharing, storing or using the personal information for any secondary purposes. By contract, we hold our third-party service providers accountable for the privacy and security of personal information in accordance with our Privacy Policy and applicable laws and regulations. In such cases of onward transfer, we maintain liability for your personal information under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.

You have the choice to limit the use and disclosure of your personal data. If you choose to limit the data to be used, simply do not disclose that information to Deluxe or use the Sites. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Deluxe’s products or services. When Deluxe does share your Personal Information with third party service providers and/or subprocessors, Deluxe will:

  1. transfer such data only for limited and specified purposes;
  2. ascertain that the subprocessor is obligated to provide at least the same level of privacy protection as is required by these Principles;
  3. take reasonable and appropriate steps to ensure that the subprocessor effectively processes the Personal Information transferred in a manner consistent with the organization’s obligations under these Principles;
  4. require the subprocessor to notify Deluxe if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by these Principles;
  5. upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and
  6. provide a summary or a representative copy of the relevant privacy provisions of its contract with that subprocessor to the Department of Commerce upon request.

Deluxe shall remain liable under the Principle of Accountability for Onward Transfer if its subprocessors process your Personal Information in a manner inconsistent with the Privacy Shield Principles, unless Deluxe proves that it is not responsible for the event giving rise to the damage.

b. Legal Obligations

We cooperate with government or law enforcement officials and private parties to enforce and comply with laws applicable to our services. We will disclose information about you to government or law enforcement officials or private parties, as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process, to protect our property, and the property and rights of a third party, to protect national security, the safety of the public or any person, or to prevent or stop activity we consider illegal or unethical. We will also share your information to the extent necessary to comply with ICANN's rules, regulations, and policies regarding your domain services.

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.  In the case of data transfers from the EEA and Switzerland,  the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks apply.

VI. Protection of Personal Information

In order to protect your Personal Information and your right to privacy, Deluxe:

  • Takes steps to protect information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction
  • Maintains physical, electronic, and management procedures to safeguard information based on its sensitivity
  • Uses Secure Socket Layer (SSL) technology to protect sensitive data
  • Uses servers that are protected by firewalls, which are frequently updated to enhance security
  • Protects the confidentiality of personal information when dealing with third parties
  • Strives to keep personal information as accurate and up-to-date as is necessary for the purposes identified above

We cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information.

VII. Limits to Your Privacy

Our Sites contains links to other sites that are not owned or controlled by us. When you leave our website, we encourage you to read the privacy statements of each website that collects personal information. This Privacy Policy applies only to information collected by Deluxe Sites.

VIII. Choice Regarding Collection, Use & Distribution of Personal Information

You can choose to opt-out whether your Personal Information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In such an event, you will be only able to access public areas of the Sites. If you do not wish to receive promotional material from us, you may choose to "opt-out" each time we ask you for Personal Information. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Deluxe products or services.

IX. Access & Correction

a. / /

You have the right to access the Personal Information we hold about you. You may access your information that Deluxe holds by contacting us at the address below. You have the right to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. You may make changes to your account information, access, correct, or delete personal information held by Deluxe by updating your Account Profile or contacting us at:

Deluxe Small Business Sales, Inc. Attn: Privacy Program Office
3680 Victoria Street N.
Shoreview, MN 55126
United States of America

To protect your privacy and security, Deluxe may also take reasonable steps to verify your identity before making corrections to or deleting your account. We will respond to your request for access to modify or delete your information within a reasonable timeframe.

b. Hostopia

We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. Based on the level of services provided by us to your communication service provider, you may make changes to your account information directly, or by working with our Partner Support team. Your communication service provider may notify us to correct, amend or delete inaccurate information, based on your request to them.

Please contact our Information Administrator at to:

•Change or confirm your personal information, or
•Have your information removed from our databases

We act as a service provider and data processor. For individuals who wish to access, correct, or delete personal information managed by your service provider (the data controller), please direct your inquiry to them directly.  For individuals who wish to access, correct, or delete personal information managed by our Partner (the data controller), please direct your inquiry to the Partner directly.

We will respond to your request for access to modify or delete your information within a reasonable timeframe. We may need to contact your communication service provider to validate and coordinate your request.

c. VerticalResponse

We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. You may make changes to your account information, access, correct, or delete personal information held by VerticalResponse using any of the following methods:

  • visiting the MyLounge page on our site
  • calling our toll-free telephone number at 1-866-6VERTICAL
  • emailing Customer Support at or
  • writing to VerticalResponse:

Attn: Account Updates
50 Beale St, 10th Floor
San Francisco, CA 94105
If you would like your account deactivated or deleted, please state this in your communication. We will respond to all requests within a reasonable timeframe.

X. Contacting Deluxe, Dispute Resolution, Arbitration & Cost

Deluxe will address all questions, complaints or requests concerning this Privacy Policy within 45 days of receipt. Please see the applicable details below:

a. EU & Swiss Citizens

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Deluxe commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Deluxe at:

Deluxe Small Business Sales, Inc.
Attn: Privacy Program Office
3680 Victoria Street N.
Shoreview, MN 55126
United States of America

Deluxe has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent 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 (free of charge) at

As noted above, under certain circumstances, more fully described on the Privacy Shield website (, if your complaint remains unresolved, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

If, after exhausting the above remedies your complaint is not satisfactorily addressed, you may, under certain limited conditions, invoke “last resort” binding arbitration before a Privacy Shield Panel.

b. Non-EU/Non-Swiss Citizens

Deluxe commits to resolve complaints about your privacy and our collection or use of your personal information. Non-EU/Non-Switzerland citizens with inquiries or complaints regarding this privacy policy should contact Deluxe at:

Deluxe Small Business Sales, Inc.
Attn: Privacy Program Office
3680 Victoria Street N.
Shoreview, MN 55126
United States of America

c. Arbitration Mandatory Arbitration Agreement, Class-Action Waiver, and Jury Waiver

  1. Applicability of Arbitration Agreement.  You and Deluxe agree that all claims and disputes related in any way to use of this Site, or to products or services sold by Deluxe or distributed by or through Deluxe, will be resolved by individual arbitration before the American Arbitration Association (“AAA”) under the Federal Arbitration Act (“FAA”), except that you and Deluxe are not required to arbitrate small claims court disputes as set forth in subsection (8.) below. To be clear: The phrase “all claims and disputes” also includes claims and disputes that arose between you and Deluxe before the effective date of these Terms.
  2. Waiver of Jury Trial.  You and Deluxe waive any Constitutional and/or statutory rights to a trial in court in front of a judge or a jury.
  3. Class Actions Waiver.  You and Deluxe agree all arbitrations will proceed on an individual basis, and waive any right to bring claims as part of a class action (either as a named-plaintiff or class member), and as part of any other proceeding where someone acts in a representative capacity of any kind.
  4. Authority of the Arbitrator. The arbitrator, and not any federal, state or local court or agency, shall have exclusive authority to resolve all disputes arising out of or relating to the interpretation, applicability, enforceability or formation of this Agreement, including, but not limited to any claim that all or any part of this Agreement is void or voidable. However, an arbitrator can award on an individual basis the same damages and relief as a court (including injunctive and declaratory relief or statutory damages).  The arbitrator’s decision will be final except for a limited right of review under the FAA.
  5. Arbitration Procedure.  Either party may initiate arbitration with the AAA pursuant to its Consumer Arbitration Rules (“AAA Rules”), as modified by this Arbitration Agreement. The AAA Rules are available on the AAA’s website, or by calling the AAA at (800) 778-7879.  You may choose to have the arbitration conducted by telephone, based on written submissions, or in person in the county where you live or at another mutually agreed location. 
  6. Arbitration Fees and Payments.  Payment of all filing, administration and arbitrator fees will be governed by the AAA’s applicable rules, however Deluxe will reimburse those fees to you in an amount up to $25,000 (though, in no event will Deluxe pay any attorneys’ fees and/or costs you may incur).  Deluxe also waives its own right to seek attorneys’ fees and costs in arbitration.
  7. Right to Opt-out. You may opt out of this arbitration agreement by notifying Deluxe in writing no later than 30 days after first becoming subject to this arbitration agreement. Your notice must include your name and address, any additional customer information, and an unequivocal statement that you want to opt out of this arbitration agreement. You must either mail your opt-out notice to this address: Deluxe Small Business Sales, Inc., ATTN: Arbitration Opt-out/Privacy Program Office, 3680 Victoria Street N., Shoreview, MN 55126 United States of America, or email the opt-out notice You also may reject any changes we make to this arbitration agreement in later versions of these Terms by sending Deluxe notice within 30 days of your notice of the change. If you do, the most recent version of the arbitration agreement to which you agreed before the change you rejected will apply.
  8. Small Claims Court. Notwithstanding the foregoing, either you or Deluxe may bring an individual action in small claims court in your county of residence or in Shoreview, Minnesota, if you meet the court’s requirements.
  9. Severability. If the class action waiver is found to be illegal or unenforceable as to all or some parts of a dispute, then those parts will not be arbitrated but will proceed in court, with the rest of the dispute proceeding in arbitration.
  10. Arbitration Agreement Survival. This arbitration agreement will survive the termination of your relationship with Deluxe.

XI. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you by way of an email (sent to the email address associated with your account) or by means of a notice on this site prior to the change becoming effective. We will use information in accordance with the privacy policy under which the information was collected.

We use a self-assessment approach to address compliance with this Privacy Policy, verifying periodically that the policy is accurate, comprehensive, and addresses the privacy requirements applicable to the markets we serve. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information. These reviews are conducted by internal staff who report directly to the Deluxe Board of Directors, external auditing and accounting firms, and government regulators.

We maintain self-assessment procedures to verify our commitment to adhere to Privacy Shield Principles, including ensuring appropriate contract obligations with third parties and service providers acting on our behalf to deliver the requested services.