W H I T E PA P E R PRINCETON PAYMENT SOLUTIONS TM How to Eliminate PCIDSS Exposure in SAP® Environments: Goals and Strategies for Using Tokens October 2009 White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 1 Executive Summary The Payment Card Industry goes out of its way to point out that outsourcing payment processing will not make a company PCIcompliant, as outlined in Ten Common Myths of PCI DSS. This document also addresses other common misconceptions that companies should understand. https://www.pcisecuritystandards.org/ pdfs/pciscc_ten_common_myths.pdf Not all companies are responsible for meeting the PCI-DSS requirements, but most that accept payments with SAP solutions are. Companies that do not electronically store, process or transmit any kind of card data need only answer a few short questions on the PCI short form to declare that they have no card data to secure and are thus exempt from the PCI long form assessment. Unfortunately, the simple short form will not suffice for most companies who take credit cards. If your company stores card data onsite or even accepts card data at order entry terminals or within a computer-based system such as an SAP system, you are obligated to address up to 225 detailed security issues in the PCI long forms. The goals of a PCI long-form initiative usually include: nProtect card data by securing the network and encrypting the data. n n n Install encryption in a way that does not change the order process. Reduce the scope of PCI by having as few applications, systems and networks “touch” card data as possible. Implement a “future-proof” solution – be able to use the same system for PII data to comply with upcoming laws in these areas. (PII addresses other personally-identifiable information such as driver’s license number, bank account number, and birth date.) Since the PCI asks for protection of data in storage, processing and transmission, a solution that promises technology for one or two of these requirements will not relieve you of all of your PCI responsibilities. A solution exists now that can take all or part of your SAP system out of PCI scope while still providing data security that meets the requirements, allowing transparent system operation, and accommodating future encryption needs: a token server. The token approach lets you remove all credit card numbers from the SAP database and store them somewhere else, in an external, centralized, secure data vault. In place of the card number or encrypted card number, a representative token value – or “surrogate card number” – is stored in the database. This approach also allows you to keep field sales devices (such as laptops) outside of the PCI scope by tokenizing data before entering it into the device. Before you choose a PCI solution, make sure you fully understand the issues and ramifications related to PCI compliance. This paper outlines some typical goals of a PCI project, sheds light on common PCI misconceptions, and defines successful and costeffective strategies – such as tokens – for complying with PCI requirements. You can read the full PCI-DSS standard at https://www.pcisecuritystandards.org/ Copyright © 2009 Princeton Payment Solutions Introduction: PCI and Data Encryption You’ve certainly heard of identity theft. Possibly you’ve even been a victim of it in one form or another. According to the Identity Theft Resource Center, more than 127 million personal data records were compromised in 2007 in the U.S. As more and more data is accepted, stored, and processed electronically, opportunities proliferate for identity theft on a grand scale. www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments “PCI DSS mostly calls for good, basic security. Even if there was no requirement for PCI compliance, the best practices for security contained in the standard are steps that every business would want to take anyway to protect sensitive data and continuity of operations.” — from Ten Common Myths of PCI DSS, PCI Security Standards Council https://www.pcisecuritystandards.org/ pdfs/pciscc_ten_common_myths.pdf 2 The Payment Card Industry has responded to the fraud increase by creating the Payment Card Industry Data Security Standard, also known as the PCI-DSS, to protect data. The PCI-DSS is a set of 12 general security requirements mandating common-sense best practices that are probably already in place at many companies. According to the Payment Card Industry, “PCI DSS mostly calls for good, basic security. Even if there was no requirement for PCI compliance, the best practices for security contained in the standard are steps that every business would want to take anyway to protect sensitive data and continuity of operations.” If a data breach does occur, it will affect your company significantly, both financially and in terms of reputation. Some of the requirements call for technology solutions to protect the data from unauthorized eyes, corruption from virus, and theft by hackers. Though the card associations have defined a set of penalties for non-compliance with the PCI or breach of data security, the focus of the PCI effort seems to be security over penalty. However, the Payment Card Industry is serious about enforcing the standard, and they are conducting assessments to enforce these rules, with possible fines of hundreds of thousands of dollars levied if data is compromised. One of the mandates of the PCI-DSS strongly affects companies who use SAP solutions: companies must now secure payment data with strong encryption techniques and must use encryption systems that are separate from the payment applications themselves. While the SAP system can provide an encryption capability, its structure does not meet the requirements of the PCI (for example, it is not separate from the payment application). To comply with the PCI, companies who use SAP solutions for payments must: nPurchase an encryption solution from a third-party supplier ~or~ n Move card data off site to a third-party payment provider who can host the system. Princeton Payment Solutions has been successfully building payment solutions for SAP customers for more than eleven years. Our customers have requested – and we have delivered – a variety of encryption technologies for SAP systems, to help our customers meet PCI requirements and provide the most secure and flexible protection for their data. A Quick Approach to the Audit Process 1. If you are a Level 1 or 2 merchant with one million or more transactions per year, you should interview and hire a Qualified Security Assessor (QSA) to lead you through the process and give you the required assessment reports needed by the card brands. Smaller companies may not need a QSA to assist them. 2. Go to the Self Assessment Questionnaire A, or short form. If you can pass all the requirements of no storage, processing or transmission of card data, then you can bypass the rest of the PCI process. 3. If you cannot pass the short form, and almost all SAP installations cannot, you must go to a long form. This process is complex and detailed, so you might want to hire an outside consultant to walk you through the process, explain the questions, and strategize on responses. Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 3 Now let’s talk about the PCI process, what’s needed to meet PCI requirements from a data protection and encryption perspective, the goals of a PCI implementation, and proven strategies to accomplish those goals. What Does the PCI Process Look Like? If you’re an SAP customer that takes orders through your Sales/Distribution or CRM modules, then you will not be able to bypass the requirements in the PCI long For most companies (those processing fewer than a million transactions per year), PCI is a self-assessment process: you fill out some forms describing your environment and the protective measures in place, get them signed by management and send them to your bank card processor or service provider. If your company processes more than a million transactions on an annual basis, you are required to have a formal assessment by a PCI-approved Qualified Security Assessor (QSA). His or her job is to review your application and examine your systems to confirm what you say is what is actually happening in your environment. form. Storing your data offsite won’t help. Part 2c Merchan . 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Signatur e of Mer chant Ex ecutive Officer Merchan t Execut ive Offi Date cer Na me Merchan t Compa ny Repr esente d Title PCI DS S Copyrig SAQ A, v1.2 , At ht 2008 PCI Se testation of Co curity St andard mpliance s Coun cil LLC October 2008 Page 2 Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 4 Entirely Outsourced – the Short Form For most companies, the PCI responsibility involves filling out one of several selfassessment forms. The short form, Self-Assessment Questionnaire A, asks a few questions to determine whether your company does any electronic storage, processing or transmis- Why PCI is Necessary Of course the focus of your business is revenue, not chasing ever-changing nuances of the PCI compliance standards. So it’s understandable that many understaffed IT and security departments look at PCI compliance as a nuisance. PCI isn’t a federal law, it’s a contractual requirement from the card brands for merchants to accept payment cards. There are fines associated with non-compliance but your business most likely won’t come crashing down if it’s not done today. After all, the requirements have been in place for four years… if you haven’t done it by now, why should it be a priority? The simple answer is: the possibility of a breach or other compromise of data. Until the Heartland Payment Systems break-in was discovered in January 2009, many an overworked CIO regarded the PCI as another form to be filled out and fudged as an exercise in line with all pledges to be a good corporate citizen. The Heartland breach revealed that intruders had hacked into the computers used to process 100 million payment card transactions per month for 175,000 merchants (source: USA Today). Heartland announced their intention to notify each victim whose data was stolen to comply with data-loss disclosure laws in more than 30 states; they did not disclose the number of victims, which must have been many millions. The cost to Heartland – and to the victims – was certainly staggering. Companies simply cannot afford to expose themselves to that kind of risk. The practices outlined in the PCI standard have become a necessary protection rather than just a nuisance. In addition, more lawmakers are realizing that data needs to be protected. Individual states such as Massachusetts and Nevada are enacting laws that dictate the protection of personal data such as driver’s license number and birth date. And so the trend continues to move in the direction of strengthening data security, both for card data and personal information. After four years on the books, PCI requirements for data security are gaining acceptance as must-have best practices and are considered part of the cost of doing business. Just like insurance, it is a precaution you hope to never need, but one that’s critical to business continuity should something happen. sion of cardholder data within its environment. If you do not do any of these things – because all of your card processing is completely handled by a third party – then completing the short form is all that’s necessary to comply with the PCI-DSS and you can bypass the longer forms (B, C, or D). You will not need to make any changes to your environment. Everyone Else – The PCI Long Forms Unfortunately, the simple short form will not suffice for most companies who take credit cards. You are obligated to address many or all of the 225 security issues in the 72-page Requirements and Security Assessment Procedures if your company does any of the following activities: nElectronically stores card data onsite. n Processes card data. n Transmits card data, including: n n Accepting card data at order entry terminals. Accepting card data in computer-based systems, such as SAP systems, or any place where card data is typed in. Most SAP customers that have a call center cannot meet the criteria that allow them to bypass the long form requirements. About the only way you won’t trigger responsibility for these security obligations is if your purchase process is completely separate from your ordering process: your customer enters his or her own card number onto your web page provided by a third party who processes the payment, and you never receive or transmit the data. Storing Your Data Somewhere Else: Can You Bypass PCI? Some companies have a misconception that if they simply use a third party solution to store card data offsite, they will be exempt from the cumbersome requirements of the PCI long form. The problem is that all three processes that touch the payment card data – the transmission, processing and storage – must happen offsite in order to exempt your company from the rigors of the long form. The PCI requirements apply not only to the application that accepts payment (in this case the SAP system), they also apply to the database and to your company’s network. Almost all SAP systems that accept card data for orders will subsequently transmit this information from the order entry terminal to the service provider or an internal payment card interface. Even if you take the SAP system out of scope of the PCI for data storage or processing, your detailed PCI responsibility is still triggered by the requirements for data transmission, and thus you must fill out the long form. Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 5 A third-party, offsite data storage solution will exempt you from the PCI requirements that relate to data storage – just not from the requirements for transmission or processing (so you still have to fill out the long form). However, even if you store your data offsite so you no longer need to worry about the PCI data storage requirements, the security of your data is still legally your responsibility. The card processing companies write their agreements to ensure that the merchant (you) is still responsible for the data, unless it is proven that the data is stolen directly from the third party (Heartland Payment as an example). The liability you took on for this data cannot be passed to another facility unless done so in writing, and most thirdparty hosts are unwilling to accept it. If that third party is compromised and your data is stolen, you still have to face the consequences, answer to your angry customers, and clean up a big mess. Rather than storing data offsite, another way you can address your PCI data storage responsibility is by encrypting your data onsite using an encryption solution. This option is less expensive and keeps your data encrypted and under your control, where you can be sure it is properly secured. PCI Goals and Strategies The PCI mandates protection of electronic storage, processing, and transmission of sensitive card data. Most companies define the following goals for their PCI initiatives: nProtect the card data. n n n Install encryption in a way that does not change the order process. Reduce the scope of PCI by having your card data “touch” as few systems and networks as possible. Implement a “future-proof” solution – be able to use the same system for PII data to comply with upcoming laws in these areas. (PII addresses other personally-identifiable data such as driver’s license number, bank account number, and birth date.) Each goal has several considerations and strategies you can use to meet it. Protect the Card Data You need to make sure all parts of your network are secure and can only be accessed by authorized individuals. In addition, data encryption is required by the PCI, and the SAP system’s internal encryption does not meet PCI standards. To adequately protect your card data: nConfirm firewalls, virus protection and access control. n n Copyright © 2009 Princeton Payment Solutions Implement data encryption to conform to the PCI requirement for a segregated key management system and demonstrable key roll-over. Use tokens to move encrypted data to a secure and segregated server. Token values – or “surrogate card numbers” – replace the actual data values within the SAP system, so that the card data can be stored in an external secure data vault and the SAP system never touches it. www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 6 Business Process Transparency: Don’t Complicate Existing Processes The simpler you can make your encryption upgrade, the more smoothly it will go. Try to avoid affecting existing processes as much as possible. nYour staff should be able to use the same order entry screens as before. n n Make sure additional key strokes or fields are not necessary in order for your call center to take an order. Look for systems that allow for continuity of business process and that minimize disruptions. Reduce the Scope of PCI If a system never touches card data (in other words, does not transmit, process, or store it), then the PCI requirements don’t apply to it. Use these tips to keep as many systems out of the PCI scope as you can. nTake your database outside of PCI scope through the use of tokens. n n n Take the SAP system out of scope by conducting tokenization at order entry. Segregate the order entry network from the rest of the systems to keep other networks “clean” of card data, and thus outside of PCI scope. Keep field sales devices (such as laptops) and their networks out of scope by tokenizing data before entry into the system. By reducing the scope of PCI, you can significantly reduce the cost and effort involved in complying with the PCI standard, as well as increase your chance of success in a PCI assessment. Plan for Future Uses of this Technology States are enacting new laws to protect personally identifiable information (PII) – such as driver’s license numbers, birth dates, bank account data, and other sensitive information – using mechanisms similar to the PCI. To both meet future mandates and to protect your customers’ data, make sure that your data protection / encryption solution can be used for personal information such as HR data or vendor data. Using Tokens to Protect Card Data SAP has certified a number of vendors who have developed solutions to assist with SAP payments and protection of data. SAP has not identified a certification process specific to PCI data encryption, however, the payment card interface vendors offer various solutions and strategies that meet the PCI standards. There are currently two approaches to addressing the PCI mandates for handling credit card numbers within the SAP system: 1. Encrypt the data within a proper security infrastructure within the SAP system itself. (Keep in mind that the SAP system’s internal encryption does not meet PCI requirements, so a third-party solution is required.) 2. Remove all credit card numbers from the SAP database and store them in a secure data vault. In place of the card number or encrypted card number, use a token value. Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to eliminate PCI-DSS exposure in SAP® Environments 7 PPS’s traditional encryption within the SAP system solution (option 1 above), with its separate key management and seamless key roll-over, has consistently met PCI requirements and passed assessments. However, while satisfying the PCI mandate, the “encryption within the SAP system” approach kept the SAP environment in scope for PCI. In order to further simplify the PCI process, PPS has now developed a solution for option 2 above: the CardSecure token server. When a Token encryption solution is combined with a “token aware” Payment Card Interface application that can convert the token to the card value (such as PayWare) to process payments, the SAP system can be deemed out of scope by the DSS assessment. The PPS Token Solution By moving all credit card data to another secure database (data vault) and instead storing a token value in the SAP system to represent the actual card number, companies can take their SAP systems outside of the PCI scope. The external data vault can be isolated to its own network segment with access tightly controlled, which considerably shrinks and simplifies the task of PCI compliance. Card data is encrypted in this external data vault, and key management and rollover are invisible to the SAP system. Working together with PPS’s PayWare Payment Card Interface, the CardSecure encryption solution now has the ability to implement a token approach as illustrated in the following diagram. This architecture can take the SAP system out of PCI scope. SAP SAP GUI with Desktop Tokenizer Web Site (WebSphere, IIS, Tomcat) PCI Servers CardSecure PayWare Payment Card Processor Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 8 PPS’s token solution includes a built-in key manager that can integrate with an external hardware security module (HSM). The system allows unlimited use of tokens – we do not charge by the token, and you will not run out of tokens. PPS tokens are also reusable. As an added benefit, our CardSecure token server protects other personal information, such as Driver’s Licenses, generically called PII data. It is designed to adapt to evolving requirements regarding the display of this information. SAP Tokens and Masking A PPS token will show only the first two and last four digits of a card number, so there is no need for a card masking function to obscure the full card number from users who don’t need to see it. The token in the external encryption database consists of eight alphanumeric characters, allowing over 200 trillion values. Wrapping the token with the first two and last four digits of the full card effectively creates a masked value that is human-readable by your call center staff for card number confirmation purposes – without a separate masking function. The wrapped token is not actual cardholder data and thus can be safely seen by anyone – it need not be masked. The token value for a test Visa card is shown in the screen from our CardSecure GUI below. PRINCETON PAYMENT SOLUTIONS CardSecure Server CardSecure Server Login Login Name: Password: PRINCETON PAYMENT SOLUTIONS CardSecure Server CardSecure Status KeyGen CardSecure Token Search Service Manager Key Manager Token Decrypt Token Search Token Rollover You are logged in as admin1 on system rlaptop Token Cleanup 1234123412341234 Log View User Manager Health Check Change Password Logout You are logged in as admin1 on system rlaptop Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 9 With the token approach, access to full card numbers can be provided to users who need it through CardSecure, further removing the SAP system from the PCI scope. SAP Tokens and Data Retention The PCI standard requires cardholder data to be deleted in a timely fashion, yet records of financial transactions must generally be kept for seven years. The token approach facilitates both objectives by allowing the encrypted card data to be securely deleted, while retaining the token indefinitely. Should the card ever return, the system will assign the same token used previously, ensuring the consistency of all transactions. Onsite or Offsite Tokens? You have two options for encrypting your data in a way that will pass the long form: a solution that encrypts your data onsite within your firewall, or a hosted solution with a third party service provider that stores encrypted data offsite. Both solutions use similar methods for securing data and will pass requirements outlined in the long form: nEncryption is used to protect the data, whether it is stored onsite in a secure data vault or offsite in someone else’s secure server. n Both solution types can use a token strategy to replace card data with a token value that represents the encrypted card data, which is securely stored elsewhere. Token strategies reduce the scope of systems that the PCI looks at. Both solutions are secure: the difference lies in cost (hosting offsite is substantially more expensive) and business proposition. In addition, the offsite data is out of your control. That may sound like it’s a good thing. But if there’s a breach, even if your data is offsite, your company is still ultimately responsible for it. Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to eliminate PCI-DSS exposure in SAP® Environments 10 Payment Card Interface Integration The final step to keep card numbers out of the SAP application – and thus reduce the SAP system’s PCI exposure – is to enable the external Payment Card Interface module (such as PayWare) to connect to the token server as a trusted application. This structure eliminates the need for the SAP system to decrypt the card number for authorization and settlement; the detokenized (clear) card number is restricted to the specialized PCI servers. PayWare Payment Card Processor SAP CardSecure NON-PCI ZONE PCI ZONE With CardSecure and PayWare in place, the payment card process now looks like this: nCard information is captured and saved in the sales order. n n n n n Copyright © 2009 Princeton Payment Solutions An SAP conversion exit extracts the card number before it reaches the SAP data table and sends the card data to the CardSecure token server. CardSecure encrypts the card number and stores it, returning a token to be stored in the SAP data table (in the CCNUM field). Individual users can be granted authority to see the full number. To search within the SAP system for transactions using a specific card, the card number is converted to its token (as for order entry) and the search uses the token value. The user sees the correct results but SAP isn’t exposed to the card number. Key rollover happens completely within the CardSecure database. There is no key rollover in the SAP system. Payment card interfaces that are “CardSecure aware,” such as PayWare ERP, receive tokens in the authorization and settlement requests and in turn convert these tokens to clear (actual) card numbers for processing by the Clearinghouse. www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 11 Common Fallacies The PCI requirements are complex, and confusion is fairly common. It’s important to ask the right questions and fully understand the ramifications before you make a decision about the best payment and encryption solutions for your company. Remember that the Payment Card Industry calls for protection of data in storage, processing and transmission. A solution that promises technology for only one or two of these is not giving you a complete solution to your PCI needs. This section addresses common fallacies that you may hear from vendors as you investigate options for securing your data. False How can you expect to meet PCI requirements if you have card data on your facility? We will take it off your facility and put it on ours – otherwise you won’t pass. Where the data vault resides – onsite or offsite – has nothing to do with PCI compliance. As long as your data is properly secured, you can meet PCI requirements regardless of where the data resides. In fact, storing the data onsite is a less expensive option that can accommodate other types of personal data as well (bank account numbers, driver’s license numbers, birth dates, etc.). For sites that only take orders over a web page owned by an outside processor, this approach may help relieve your PCI obligations. But if your business process includes a call center or any employee taking card data for an order or for payment on any outstanding invoice, offsite data storage does not relieve you of the PCI burden. Should you decide to go offsite with storage, the cost could be many times that of keeping it onsite, even factoring in cost of the appropriate controls (encryption, limited access to data, etc.) Also, although card data is likely the first set of data needing security, many states are now passing laws to protect other personal data such as social security, drivers license and bank account numbers. You should plan for this new data and its cost as you make decisions to secure the data in your systems. False If you store the data offsite, you are not responsible for it anymore. Many a CIO would prefer that another company be responsible for protecting sensitive data, rather than his or her company. Offsite facilities can be PCI-compliant but they will not indemnify you should there be a break-in or a breach. The merchant (you) is still responsible for the data even though it is not on your facility. Check your merchant agreement – the liability you took on for this data cannot be passed to another facility unless this indemnification is done so in writing. And of course, regardless of where data is stored, the damage to your reputation is staggering in the event of a breach. Copyright © 2009 Princeton Payment Solutions www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 12 Maybe Our hosted payment approach uses tokens. This method will limit your PCI exposure by taking card numbers out of your systems. Again, taking your company “out of PCI” means no numbers in transmission, processing or storage. If your call center or order entry process takes a card number to initiate the purchase process – even though it later gets tokenized – your SAP application, the call center and the network are still within PCI scope. Offering tokens alone as a PCI solution is like offering a three-legged stool with just one leg on it. Summary The PCI mandates protection of electronic storage, processing, and transmission of sensitive card data. Most companies define the following goals for their PCI initiatives: nProtect the card data. n n n Install encryption in a way that does not change the order process. Reduce the scope of PCI by having your card data “touch” as few applications, systems, and networks as possible. Implement a “future-proof” solution – be able to use the same system for PII data to comply with upcoming laws in these areas. (PII addresses other personally-identifiable data such as driver’s license number, bank account number, and birth date.) PPS’s CardSecure token server meets all of these goals and provides many additional benefits: nSecurely encrypts and stores data on an external, centralized data vault to keep it out of the applications in your environment. Tokens can take the SAP system out of the scope of your next PCI assessment, which considerably shrinks and simplifies the assessment process. n n n n n n Copyright © 2009 Princeton Payment Solutions Allows the encrypted card number to be securely deleted, while retaining the token indefinitely. Negates the need for an additional card masking capability, while still obscuring card details from users who don’t need to see the full number. In the near future, the CardSecure token server will be able to tokenize card data before it is entered into field order entry systems such as laptops, thus keeping those computers and networks out of the PCI scope. PPS does not charge on a per-token basis. Tokens are re-usable, and you won’t run out of them. Key management and rollover are securely conducted and invisible to the SAP system. CardSecure’s security structure can protect personal data (bank ACH numbers, social security numbers, salary details, etc.) that is difficult to protect with the encryption-only approach. www.prinpay.com White Paper: How to Eliminate PCI-DSS Exposure in SAP® Environments 13 PPS can also help you evaluate your needs. We have more than eleven years of experience building payment and encryption solutions for the SAP system. Our PayWare ERP solution became the first implementation available and has since been a leader in complex SAP payment environments. Long-time users of PayWare ERP include The New York Times Company, General Electric, Brother International, Reliant Energy, Johnson & Johnson and SAP itself. In 2004, PPS was the first company to encrypt data within the SAP system and pass a PCI audit with our CardSecure solution. Subsequently, we were the first to create a token infrastructure to take the SAP system completely out of PCI scope in 2008. Companies such as Adobe, Brother, General Electric and Reliant Energy rely on CardSecure to encrypt and protect their credit card information. Please contact us to discuss your environment and to help you determine what type of solution is best for your company. Contact: Alex Chapman Email: [email protected] Phone: +1 (203) 952-5715 www.prinpay.com Copyright © 2009 Princeton Payment Solutions www.prinpay.com
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