Last Revised: November 25, 2019
PayEM, Inc. ("us", "we" or "Company") respect the privacy of our users (each, "you" or "User") and are committed to protect the privacy of Users who access, engage, use, download, install or register to our mobile or web application (the "Application"), or any other online services we provide (collectively: the "Services").
- What type of information we collect
- Cookies and Google Analytics
- How we use the information
- With whom we share the information and for what purpose
- International transfer
- For how long we retain the information
- Your privacy rights
- How we protect your information
- Advertising ID and Advertising Identifier
- How to contact us
What type of information we collect
We may collect the following types of data and information from or about you:
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services ("Non-personal Information"). We are not aware of the identity of the user from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time, the website's domain name from which you linked to the Services, etc.). We may use this information in order to administer the Services and analyze this information to improve and enhance the Services by expanding their features and functionality. Such information may also be used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, online browsing, etc.).
For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual ("Personal Information"). Such information may include:
- Registration Information: When signing-up or registering to our Services, we may collect certain information that can be used to identify you. You may register to the Services directly through the Application or through third party services.
- Registering through the Application: When you register to the Services through the Application, we may collect from you the following information: full name, email address, company name, address, phone number, business and DBA names, incorporation type, date of establishment, Tax ID number, bank name, bank account number, bank routing number, name of the account, bank account type, as well as other relevant details that you agreed to share with us.
- Registering through third party services: When you register or sign-in to the Services via third party services (e.g., Google), we may have access to basic information from your account, such as your full name, home address, email address, birthdate, profile picture, personal description, as well as any other information you made publicly available on such account or agreed to share with us. At all times, we will abide by the terms, conditions and restrictions of the third party platform.
- Voluntary Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, ask our support, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports that you send to us.
- Device Information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you. Such information may include: geolocation data and IP address.
Cookies and Google Analytics
A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother.
We may use the following types of cookies:
- Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
- Persistent Cookies which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next sign-in).
- Third-Party Cookies which are set by other online services that run content on the page you view on your browser (for example, by third-party companies that monitor and analyze our marketing campaigns).
You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited.
How we use the information
- To set up Users' accounts;
- To identify and authenticate Users' access to certain features of our Services;
- To provide the Services to our Users;
- To send you relevant push notifications, which are based on different features offered by the Services;
- To support and troubleshoot our Services and to respond to your queries;
- To communicate with you and to keep you informed of our latest updates;
- To obtain Users’ feedback with regards to the Services;
- To perform a research or to conduct analytics in order to improve and customize the Services to Users' needs and interests;
- To investigate and resolve disputes in connection with your use of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information and for what purpose
We do not rent or sell any Personal Information. We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) trusted subcontractors and third-party service providers (e.g., Firebase, Amazon Web Services, Marqeta, Sutton Bank); (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations (e.g., issuing credit cards and processing transactions); and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third-party collection of information
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. In these instances, we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
For how long we retain the information
We retain the information that we collect from our Users for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we may keep records containing Users' Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
Without derogating from the foregoing, in any other case we will retain the information for a maximum period of five years (unless we are required by applicable laws and regulations to keep the information for longer periods of time).
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Your privacy rights
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:
- Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
- Right to see what Personal Information about you we have;
- Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
- Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
- Right to export Personal Information in a portable format.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.
How we protect your information
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the confidentiality, integrity, and availability of your information, the safety of your Personal Information and prevent unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to information despite our efforts. You should note that by using our Services, your information would be transferred through third-party infrastructures that are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security, and we make no warranty, express, implied or otherwise, that we will prevent unauthorized access to our Services.
The Services are not designated to individuals under the age of 16. If you are under 16 years old, you should not download the Application, use the Services, or provide any Personal Information to us.
Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for user analytics purposes. We may also use Apple's Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for user analytics purposes.
By downloading the Application or using the Services, you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.
How to contact us
Information about us
The details of the Company are as follows:
50 New Burton Rd., Suite 201, Dover, Delaware 19904, United States
PayEm Card Ltd.
35 Shenkin Street #2 Tel Aviv, Israel
Telephone Number: 1-888-301-0773