Link to ASI GDPR Data Processor Policy Statement


At Appropriate Solutions, Inc. (“ASI”), we take your privacy seriously. We developed this privacy policy to explain our information collection and use practices. We respect the confidentiality of personal information that identifies you and treat that information responsibly.

By using our web site (the “Web Site”), you accept the practices that are described in this Privacy Statement, which is effective as of June 15, 2017 and is part of the Web Site General Terms and Conditions governing use of this site. We may change or add to this statement from time to time. When that happens, we will post the revised statement here. Your use of our site after changes to this Privacy Statement have been made constitutes acceptance of those changes going forward.

ASI is a Business-to-Business (B2B) service provider of a data storage service that associates tokens with secure encrypted data. The service uses encryption and tokenization of actual cardholder data associated with an electronic payment transaction that can be used by merchants in the same way that actual cardholder data is used. Cardholder payment data is replaced with a unique identifier, enabling merchants to process an encrypted and tokenized electronic payment. ASI provides on-line encryption and tokenization services for replacing financial information, personally identifiable information, and health data with a unique identifier for data storage, data transmission and recall, for increased data security. ASI also offers payment processing applications and web services that enable merchants to easily route payment information from their business environment to leading payment processing gateways.

ASI does not conduct or fulfill consumer transactions, and, except as otherwise disclosed, ASI does not collect or receive personal information directly from consumers. Rather, ASI encrypts and tokenizes data that consumers have provided to merchant clients. As described below, we do not authorize the selling or renting of your personal information to third parties for their business purposes.

ASI is not responsible for the privacy policies or practices of the web sites from which you access our site, sites to which we link, or any sites that are linked to our site.

This Privacy Statement tells you the types of customer information we collect, how we use that information and with whom we may share it, and how you can access or change information about you (such as your email address). If you have questions about ASI’s privacy policy or practices, or if you would like more information, please contact us at

1. What personal information do we collect about our customers?

We collect the personal information that you, our customer, tell us when you contact us via the Internet, or use our site, license from us, or order a product or service, or to process an order, to register for a service, to provide you with a subscription, or to do business with us if you are a supplier or a business partner. When you request information from ASI, we may ask you to provide your name, address, telephone number, and email address. If you place an order, we will ask you for financial information, such as a credit card number, and a billing and shipping address.

From time to time we may offer a contest, promotion, or survey, and you may complete an entry form. We may collect additional information about you, including your social security number.

2. What other kinds of customer information do we collect?

Our system may also identify which browser, language, and Internet Provider you use to access our site. In addition, to help us understand the use of our site by our visitors and improve your browsing and shopping experiences, we automatically collect information as to how you were directed to the site, how you navigate around it, what products you browse, as well as your purchasing activities. We may log certain information that your browser sends us, such as your IP address, access time, and referring web site addresses, and we may collect information about the pages you view within our sites and other actions you take while visiting us. To help us understand our interactions with you, we may permit web analytics providers and other providers to collect, process and track information on our Web Site using the technologies described below.

Our Web Site includes social media features such as the Twitter button and LinkedIn link that may include widgets such as the “share this button” or other interactive programs. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Web Site. Your interactions with these features are governed by the privacy policy of the company providing it.

3. How do we collect this information?

When you register with ASI, we compile the personal information you give us about yourself into an individual profile. We add other personal information about you to that profile as you give it to us. We also collect information about your purchases and other uses of our site as they are made. We gather other information through the use of scripts, tags, Local Shared Objects (Flash cookies), and “cookies”.

4. What are “cookies” and how do we use them? What are “web beacons”?

Cookies are small text files that allow a web site to store on a computer an identification code associated with you which can later be retrieved and associated with your visit to the site. There are two types. Session cookies terminate shortly after you close your Internet browser. Persistent cookies are stored on your hard drive until they expire or are deleted. Both types of cookies enhance our ability to serve you by recalling information about you such as your password, shopping preferences and shopping cart information.

Cookies can be placed on a user’s device by the owner of the site that is visited, or by a third party. For example, if the web site’s owner uses a third party to allow the visitor to purchase goods or services via the site, the e-commerce provider may place a cookie on that individual’s computer.

We may also use “web beacons” or “pixel tags” in conjunction with cookies. A web beacon is typically a small transparent graphic that is placed on a web site or email. We track how visitors arrive at our site and your browsing activities at our web site. We use this information to compile sales and statistical data.

We understand that not everyone wants to permit the use of cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting cookies and how to disable cookies.

5. Must a visitor provide personal information to use the site? What about use by children?

Personal information is not required to access the site or navigate from web page to web page. However, you will be asked to provide personal information if you request assistance or want to use our services. Personal information is also required to request information or assistance from us or to take advantage of certain optional features of our site such as a contest. The Web Site is not targeted to children and is not intended to collect personal data from children under the age of 13.

6. What if a visitor does not want to provide information over the internet?

You may contact ASI by telephone at 1-603-924-6079. We respect the confidentiality of your personal information as described in this Privacy Statement whether you provide it over the internet or by telephone.

7. How do we protect personal information?

All of your personal information is encrypted by Transport Layer Security (TLS) software when it is transmitted to us via the web. We maintain the servers that store this information in a secured cloud. We also truncate your credit card number to the last four digits when we communicate with you about your order. We use encryption and tokenization. No method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

8. How do we use information about our customers?

We use your personal information to process your orders. This includes contacting you to confirm your order and fill the order via download or shipment to you. We may also contact you if we want to communicate with you about your order.

We will use your contact information to respond to requests for information. We may send you E-newsletters or other promotional notices. If you choose to participate in a contest or sweepstakes, we will use your personal information to administer and manage those features.

We may also use your personal information to improve our service to you and for other business purposes. For example, we periodically review customer information as part of servicing our accounts. We may also contact you from time to time to inform you of the services that we offer and to gather information about how we can improve them.

Finally, we analyze information we obtain from cookies and web beacons concerning our customers’ access and navigation of our site and their browsing and purchasing activities to improve our services and enhance our customers’ shopping experiences.

9. How do we share customers’ personal information with third parties?

In order to process your orders and requests, we make your name, address, and sometimes your e-mail address or telephone number available to other entities such as credit card companies and package delivery services.

We may use third party agents, consultants and contractors to perform business functions on our behalf, including customer service, account servicing, customer research, marketing, provision of IT services and records maintenance. We give these entities access to our customers’ personal information to perform these functions for us and do not authorize them to use that information for any other purpose.

Additionally, we share personal information about you when you voluntarily use certain optional features of our site. If you participate in a contest or sweepstakes, we may share the information you submit with others assisting us in the administration of that feature.

It is possible that ASI or part of its business or one of its affiliates could merge with, acquire or be acquired by another business entity and your personal information could be among the assets transferred. If this occurs, you will be notified of the change by e-mail or notice on this site.

We reserve the right to share personal information about you with our affiliates in the course of our business operations. We also reserve the right to share personal information about you as required by law or in cooperation with legal authorities and to enforce the Web Site General Terms and Conditions governing use of this site or to protect the rights, property, or safety of ASI and its customers. We reserve the right to use non-confidential information in any manner we feel appropriate.

ASI may be required or compelled to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

ASI’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, in the context of an onward transfer, ASI remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless ASI proves that it is not responsible for the event giving rise to the damage.

10. How do we share other customer information with third parties?

We may share non-personal non-individually identifiable information about our customers with the group of people with whom we share personal information, as well as with other third parties such as vendors, advertisers and marketing firms.

11. How can visitors to our web site access or change the information we collect about them? Do I have a right to choose? Is there an option to “opt out?”

You have the right to access your personal information in order to correct, amend, update or delete information that is inaccurate or to request that we no longer use your personal information. You can opt out of ASI’s use of cookies to recall information about you by setting your browser not to accept cookies or to disable cookies.

You have the right to choose (opt out) whether your personal data 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 you. If you wish to opt out, simply contact us using the information provided here and in the section called “How do I contact ASI?”

For Sensitive Personal Data, we will give you the opportunity to affirmatively and explicitly consent (opt in) to permit ASI to (1) disclose Sensitive Personal Data to a third party that is not an agent or (2) use Sensitive Personal Data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. “Sensitive information” under the EU-U.S. Privacy Shield means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or health or sex life. “Sensitive information” under the Swiss-U.S. Privacy Shield program means personal information specifying medical or health conditions, personal sexuality, racial or ethnic origin, political opinions, religious, ideological or trade union-related views or activities, or information on social security measures or administrative or criminal proceedings and sanctions, which are treated outside pending proceedings. These definitions may change from time to time.

ASI is a service provider and our customers are mostly merchants that sell goods and services via the Internet. ASI may have an individual’s personal data because the individual patronized a merchant that is an ASI client. We only process and disclose the personal information specified in our agreements with our customers. Our direct customer controls how personal information is disclosed to us and processed, and how it can be modified. Accordingly, if you are a customer of one of our customers and you want to request access to, or to limit use or disclosure of, your personal information, please contact the company to which you submitted your personal information. If you contact us with the name of our customer to which you provided your personal information, we will refer your request to that company.

You may send us updated information via email to or by mail to Appropriate Solutions, Inc., PO Box 458, Peterborough, New Hampshire 03458-0458 USA. You can also change personal information such as your shipping address or payment method when ordering. You can subscribe to or unsubscribe from E-newsletters and other promotional notices by sending us an email with your instructions. Our Customer Service Representatives are also ready to assist you in checking or changing your personal profile or removing your name from our contact lists. We will use reasonable efforts to respond to your requests as soon as practicable. When updating your personal information, we may ask you to verify your identity before we can act on your request.

Applicable law allows certain exceptions to your ability to opt out, such as where we are parties to a contract that is still being performed, where law requires us to maintain information on warranty claims, or otherwise. Where applicable law permits us to retain and continue to use such information and we do so, we will do so only to the extent permitted or required by law.

If you contact us to opt out, we will explain the options available and comply with your request as required by the Privacy Shield Privacy Principles and applicable law.

If you have any questions or concerns regarding ASI’s collection, use or disclosure of your personal information, or if you wish to change, amend, delete or review your personal information, please send a letter or email with your request and current contact information to ASI. Our contact information is provided below.

12. What Regulatory Authorities do we follow?

Appropriate Solutions, Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States. ASI has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit

13. What if I have a question or an issue or dispute arises?

If you have an inquiry regarding our privacy practices in relation to our Privacy Shield certification, we encourage you to contact us.

In compliance with the Privacy Shield Principles, ASI commits to resolve complaints about our collection or use of your personal information. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. European Union, United Kingdom, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ASI via email to or by mail to Appropriate Solutions, Inc., PO Box 458, Peterborough, New Hampshire 03458-0458 USA.

ASI has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, administered by the BBB National Programs, Inc. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information or to file a complaint.

If your complaint is not resolved through the above channels, under limited circumstances a binding arbitration option may be available before a Privacy Shield Panel, as described in Annex I to the Privacy Shield Principles.

ASI is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

14. How do I contact ASI?

Please send a letter with your request and current contact information to ASI to:

Appropriate Solutions, Inc.

85 Grove Street / PO Box 458

Peterborough, New Hampshire 03458-0458 USA

Email to:

You may contact ASI by telephone at 1-603-924-6079.

Effective Date: June 15, 2017
Revised: April 4, 2020; May 26, 2020; March 1, 2022

* * *