Privacy Policy

This Privacy Policy was last changed on July 23, 2014.

Bluefin (dba “Bluefin”) and its subsidiaries (“Bluefin”, “us”, “we” or “our”) operate this website (the “Site”). The Site may include, without limitation, tools, applications, email services, bulletin and message boards, chat areas, news groups, forums, communities, calendars, and downloadable mobile applications related to the Site (collectively the “Services”).

We provide you this Privacy Policy (the “Policy”) to help you understand the kinds of information we may gather about you when you visit the Site or use any of the Services, how we may use and disclose the information, and how you can control, correct and/or update the information.

To be clear about the terminology we are using, when we use the phrase “Personal Information” in this Policy, we mean information that can be used to identify or contact a person, like a person’s full name, address, e-mail address, or phone number. For the purposes of this definition, Personal Information shall also encompass information about your place of work. When we use the phrase “Anonymous Information” in this Policy, we mean information that cannot reasonably be used to identify individual persons.

By visiting the Site or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit the Site or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.

In addition to this Policy, each Service may have additional privacy provisions that are specific to the particular Service. These supplemental disclosures are made adjacent to the particular Service at the time we collect the information. These supplemental disclosures also govern the use of your information.

1. The information we gather.

We collect information about you and your establishment in the following ways:

A. Information you voluntarily provide us.

We collect and maintain information that you voluntarily submit to us during your use of the Site and the Services. For example:

·         when you register for the Site, you may provide us certain information including your name, email address, demographic information and contact information and the PCI related topics that interest you and your establishment;

·         if you sign up to receive a newsletter or to receive other services, you may provide us contact information (e.g., email or physical address);

·         you may provide us with Personal Information in the course of email, participating in a survey or taking our Assessment Tools.

You can choose not to provide us with certain information, but this may stop you from gaining access to a Service or limit the features that you can use.

B. Information we collect through your use of the Site.

As you use the Site and the Services, certain information may also be passively collected. Through cookies, pixels, beacons, log files and other technologies, we may collect information about how you use the Site and the Services. For example we may determine through an IP address that a particular computer or device is located in New York City and we may use this information to deliver advertisements promoting New York City-based businesses. This information allows us to deliver more helpful information, programs, tools and advertisements. Please see the Cookies and Targeted Advertising section below for more information.

C. Information we receive from third parties.

We may also combine online and/or offline information received from third parties with the information we have already collected from you via the Site and the Services. The third party information is used for a variety of purposes including to verify other information about you and your place of work (e.g., verify your mailing address to send you requested products or services) and to enhance the content and advertising we provide to you.

2. How we use your information.

We will use your Personal Information in the ways described below or described at the time that the information is collected.

A. Advertising.

We believe that advertising is more interesting to you and your place of business when it is relevant. Accordingly, we customize the advertisements that you see based upon: (i) the information that you provide us; (ii) geographic location information, which we may determine through your IP address, from your mobile device, or other ways; (iii) data we receive from third parties or; (iv) your visits on the Site or use of the Services (commonly referred to as “Behavioral Advertising”). Please see the Cookies and Targeted Advertising section below for more information on the use of cookies and the information collected for Behavioral Advertising.

You can delete the cookies that we have placed on your browser. Please see the section below on Cookies, Web Beacons and IP Address Information for more information.

B. To provide the Site and the Services.

In general, we use your Personal Information as necessary or appropriate for purposes including to:

·         administer your account;

·         register you and provide you access to the Site and/or the Services;

·         respond to inquiries or requests that you direct to us;

·         connect you with vendors that provide products or services which we feel may be of benefit to you;

·         send communications and administrative emails about the Site and/or the Services;

·         personalize and better tailor the features, performance and support of the Site and the Services for your use;

·         send you promotional/marketing information, newsletters, offers or other information regarding opportunities and functionality that we think would be of particular interest to you;

·         improve the quality of the Site and the Services; and

·         analyze, benchmark and conduct research on user data and user interactions with the Site and the Services.

3. Cookies and targeted advertising.

A. Cookies, web beacons and IP Address information.

·         “Cookies” are small pieces of information that a website places on your browser when you visit that website. We may use cookies to provide you with a more personal and interactive experience with the Site and the Services. For example, we may use cookies to manage what advertisements you see, the sequence of advertisements and to make sure you don’t see the same advertisement too many times. Cookies can be removed by following your Internet browser’s directions within the help tab. In order to use certain Services offered through the Site, your web browser must accept cookies. If you choose to disable cookies, some aspects of the Site may not work properly, and you may not be able to access our Services.

·         We may also use cookies, pixels, web beacons (which are usually small, transparent graphic images), operating system and device information and navigational data like Uniform Resource Locators (“URL”) to gather information regarding the date and time of your visit, the features and information for which you searched and viewed, the email you opened, or on which advertisements you clicked. This type of information is collected to make the Site and the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

·         An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. We, or our service providers, may use your IP Address when you access the Site and the Services or use other means to assist with delivering geographically targeted advertisements.

B. Targeted advertising.

Companies that we work with may use cookies for purposes including understanding Web usage patterns of users who see advertisements on the Site, managing the sequence of advertisements you see, making sure you don’t see the same advertisement too many times, determining your interests and tailoring advertisements and promotions based on those interests. For example, if you read an article about a particular product or service on the Site, we may use cookies from a vendor to later serve you an advertisement for a product related to the viewed article. These third party vendors may connect information about pages you visit on the Site with information about pages you visit on other websites and show you advertising based on this combined information. The advertisement may appear when you are visiting a different section of the Site, another site or any other website on the Internet if the website also has a relationship with our vendor.

C. Information collected by third party advertisers.

Advertisers or other third parties on the Site may also engage in Behavioral Advertising and use cookies and web beacons in the manner described above. We do not control these advertisers or other parties’ use of cookies or web beacons or what they do with the information they collect.

4. How we disclose information to third parties.

We may share your Personal Information with third parties as specifically approved by you or under the circumstances described below. If you do not want us to use or disclose Personal Information collected about you and the place you work in the ways identified in this Policy, you should not use the Site or the Services. However, should you utilize the Site or the Services, but have any questions or concerns about how the Personal Information is being used, we would invite you to contact us as we wish to understand and address any such questions or concerns.

A. Disclosure for legal reasons.

We may disclose and release your Personal Information to third parties: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or in any cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this Policy or other agreement we may have with you.

B. Agents and Contractors.

We may provide your Personal Information to service providers who work on our behalf or help us to operate our business, the Site and the Services. Examples of such service providers include vendors and suppliers that provide us with technology, services, and/or content for sending email, analyzing data, research, providing advertising and marketing assistance, and providing customer service. Access to your Personal Information by these service providers is limited to the information reasonably necessary to perform its limited function.

C. Aggregated Anonymous Information.

We may share aggregated Anonymous Information about you with third parties. Aggregated Anonymous Information is your Anonymous Information that is combined with the Anonymous Information of other users.

D. Promotions and Polls.

Some or all of the information collected during promotions (“Promotions”) or polls may be disclosed publicly. It may also be shared with other third parties as disclosed at the time of collection or in the Promotion rules. These third parties may include providers or a co-sponsor who may use your Personal Information to administer the Promotion or for their marketing purposes, but only in conformance with their privacy policy as made available to you at the time of collection. We are not responsible for their privacy policy or practices.

When you participate in a Promotion, you are subject to any official rules for that Promotion, which may contain additional information about the specific privacy practices associated with the Promotion.

E. Disclosure to our licensors.

We may share some or all of your Personal Information with our licensors. This Policy does not cover the use of your Personal Information by our licensors. The privacy practices of our licensors may differ from this Policy and we encourage you to contact those third parties directly if you have questions regarding their use of your Personal Information.

F. Sponsors, merchants and other ways that you approve at the time of collection.

If you use our PCI Assessment tool, we will provide your information to merchants in the following manner:

·         should you request to hear from or be connected to a vendor to offer you products or services;

·         even if you do not request to be connected to a vendor, we may provide your information to a select number of vendors who are prepared to offer products and services which they feel will be useful to you;

·         your current service provider or merchant of choice may receive information so as to better service your account; and

·         we may also gather Personal Information on behalf of a sponsor in association with a promotion of goods or services that are intended to be of benefit to you.

G. Within our company; changes to our company.

We may share your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.

5. Message boards and chats.

We may make message boards, chat rooms, and other interactive forums available as part of the Services. You should be aware that any information which you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to that portion of the Site or the Services. By using these interactive forums, you agree that we are not responsible for any information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.

6. Updating and control of your Personal Information.

We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail or newsletter you receive or by editing your preference to receive these communications within the “Manage My Email” or similar feature on the individual Sites when you are logged in as a registered user.

7. Co-branded sections of the Site.

Certain portions of the Site may be co-branded with a business partner and subject to a different privacy policy that is either the partner’s privacy policy or a privacy policy developed jointly by us and our partner (collectively the “Co-branded Policy”). The partner’s collection, use and dissemination practices regarding any data or Personal Information provided by, or obtained from users of these Co-branded portions of the Site will be governed by the Co-branded Policy. Please read the Co-branded Policy for each Co-branded Site before providing any Personal Information.

8. Third party links.

The Site may link to websites operated by third parties that we do not control. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through the Site or the Services and does not apply to these third party websites. The ability to access information of third parties from the Site or the Services, or links to other websites or locations, is for your convenience only and does not signify our endorsement of such third parties, their products, services, websites, locations or their content.

9. Security.

We place a priority on the security of Personal Information, and we undertake reasonable security measures to help protect the data that resides on our servers. However, no security system is impenetrable. We do not warrant the security of our servers, nor do we warrant that your information, including Personal Information, will be completely secure or not be intercepted while being transmitted over the Internet.

10. How to contact us.

If you have any questions regarding privacy or this Policy, you may contact us as follows:


11. Policy changes.

We reserve the right to change, modify, add or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. Your continued use of the Site and the Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.

Copyright © 2014 Bluefin, LLC
The material on this web site is provided for educational or informational purposes only, and is not to be considered under any circumstances as legal or professional consulting advice. You are to independently select your own trusted advisers and qualified specialists to assist you in determining what actions to take to comply with the PCI Data Security Standard (the “PCI DSS”) and to better protect you from a data breach. Use of this site is subject to Bluefin’s
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