Square
Square is a commerce and payments platform from Block, Inc. offering card payments, point-of-sale systems, online stores and invoicing. On a website, the Square Online store or the Web Payments SDK loads scripts from Square to display checkout and process cards. These scripts set cookies needed for payment security and fraud prevention, and the store may also add analytics cookies.
What does Square do?
Square, the payments brand of Block, Inc., was founded in 2009 by Jack Dorsey and Jim McKelvey. Originally famous for its card reader dongle, Square is now a full commerce platform covering point of sale, online checkout, invoicing, payroll and lending. European merchants are contractually engaged with Square Up Europe Ltd in Dublin and Square UK Ltd in London, with payment processing performed on US infrastructure.
What Square does
Square offers in person card readers, the Square Terminal, the Square Register, the Web Payments SDK (tokenised card collection for any website), the Checkout API (hosted payment pages), Square Online (e commerce builder) and recurring billing. It also includes anti fraud, 3D Secure, Strong Customer Authentication under PSD2, dispute management and tax reporting.
Data and cookies set
The Square Web Payments SDK loads JavaScript from web.squarecdn.com and may set cookies including __cf_bm (Cloudflare bot management) and a fraud risk fingerprint cookie. Square Online sites set additional analytics and marketing cookies such as _ga and _fbp. Square collects card BIN, last four digits, billing address, IP, user agent and device fingerprint for risk scoring.
GDPR and ePrivacy implications
Payment processing is performed on the legal basis of contract (Art. 6(1)(b) GDPR) and legal obligations (AML, tax). The fraud detection cookie may be considered strictly necessary for the security exemption of Art. 5(3) ePrivacy. Marketing and analytics cookies set by Square Online require ePrivacy consent. SCA under PSD2 requires the customer to authenticate with two factors for most online card payments above 30 EUR.
Data transfers to the United States
Although Square Up Europe Ltd is contractually established in Dublin, the underlying systems (authorisation, fraud, settlement, support) run on Block, Inc. infrastructure in the United States. Block, Inc. is self certified under the EU US Data Privacy Framework. Document the transfer mechanism and the Transfer Impact Assessment for the payment processing and the supporting systems.
Practical compliance steps
Use the Square Web Payments SDK rather than collecting card data on your own servers to keep PCI DSS scope minimal. Enable 3D Secure 2 for SCA compliance. Sign the Square DPA. Block marketing and analytics cookies behind a CMP category. Mention Block Inc. and Square Up Europe Ltd in your privacy notice with the EU US DPF transfer mechanism. Configure retention of payment records (typically 10 years for tax).
Square and the GDPR
Square is classified as “Preferences”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.
- Legal basis
- Performance of a contract (Art. 6(1)(b) GDPR) for the payment itself. Legal obligation (Art. 6(1)(c)) for anti money laundering and tax recordkeeping. Consent (Art. 6(1)(a) GDPR and Art. 5(3) ePrivacy Directive) for the marketing and analytics cookies set by the Square Web SDK or by Square Online sites.
- Risk level
- medium
- Applicable regulations
- GDPR, PSD2, ePrivacy Directive, TDDDG, LSSI CE, CCPA/CPRA, EU US Data Privacy Framework, PCI DSS Level 1, AML Directive, EBA RTS on SCA
What Square sets and contacts
- Tracking method
- Payment processing platform. Square Web Payments SDK and Checkout API are loaded via JavaScript and iframe to handle card collection on the merchant website. Square also operates Square Online (e commerce site builder) and embedded buy buttons that set tracking cookies.
- Server location
- Block, Inc. (parent of Square), San Francisco, California, United States. Payment data is processed on PCI DSS Level 1 certified US infrastructure with regional acquiring partners in the United Kingdom (Square UK Ltd) and Ireland (Square Up Europe Ltd) for European merchants.
- Data transferred outside the EU
- European merchants are contractually engaged with Square Up Europe Ltd (Dublin, Ireland) but payment authorisation, fraud detection and back office systems run on Block Inc. infrastructure in the United States. Transfers from the EU rely on the EU US Data Privacy Framework or on Standard Contractual Clauses with supplementary measures.
Cookies set (4)
| Name | Type | Duration | Purpose |
|---|---|---|---|
| __cf_bm | third_party | 30 minutes | Cloudflare bot management cookie used by Square to distinguish humans from automated traffic on web.squarecdn.com. |
| sq_fid | third_party | Session | Device fingerprint cookie used by Square for fraud detection on online payments. |
| _ga | third_party | 2 years | Google Analytics identifier set by Square Online stores for visitor analytics. |
| _fbp | third_party | 3 months | Meta Pixel identifier set by Square Online when the merchant has enabled Facebook advertising. |
Third-party domains contacted (6)
squareup.comweb.squarecdn.compci-connect.squareup.comsquare.sitecash.appblock.xyz
Frequently asked questions about Square
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Which cookies does Square set?
The Square Web Payments SDK sets a Cloudflare bot management cookie (__cf_bm, 30 minutes), a fraud fingerprint cookie and a session cookie on web.squarecdn.com. Square Online sites set additional cookies including _ga and _fbp. Strictly necessary cookies do not require consent; analytics and marketing ones do.
Is consent required to use Square?
Consent is not required for the strictly necessary payment cookies and the security cookie. Consent is required for the marketing and analytics cookies set by Square Online and for any newsletter subscription or remarketing flow.
What is the legal basis for processing payment data?
Contract (Art. 6(1)(b) GDPR) for processing the payment itself. Legal obligation (Art. 6(1)(c)) for anti money laundering and tax recordkeeping. Legitimate interest (Art. 6(1)(f)) for fraud detection. Consent (Art. 6(1)(a)) for marketing and analytics.
Is data transferred to the United States?
Yes. Although the EU contracting entity is Square Up Europe Ltd in Dublin, the back end systems are operated by Block, Inc. in the US. Transfers rely on the EU US Data Privacy Framework (Block is certified) or on Standard Contractual Clauses with supplementary measures.
Do I need a DPIA for Square?
A DPIA is recommended when handling card data at scale, recurring payments, card on file, or sensitive verticals (health, gambling). The DPIA covers the lawful basis, PCI DSS scope, SCA flow, fraud detection, US transfers and retention.
How do I implement Square correctly?
Use the Web Payments SDK with tokenisation to minimise PCI DSS scope. Enable 3D Secure 2 for SCA compliance. Sign the Square DPA. Block analytics and marketing cookies behind a CMP category. Document Block Inc. and Square Up Europe Ltd as sub processors and the EU US transfer mechanism in your records of processing.
Which alternatives to Square should I consider?
EU based payment processors: Adyen (Netherlands), Mollie (Netherlands), Stripe Ireland (with US back end), Worldline (France), Lyra (France), GoCardless (UK). For SMB: SumUp (UK/Germany), Klarna Checkout (Sweden), Viva Wallet (Greece).
How do I update the cookie policy when Square changes?
Subscribe to the Square trust centre. When sub processors, certifications, payment flows or cookies change, update your cookie table, privacy notice and records of processing, and bump the consent banner version. Re run your PCI DSS self assessment annually.
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