EU CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to EU customers, and can be found at Appendix below.
HOW, WHEN AND WHAT WE COLLECT?
How do we collect your information?
We collect information directly from you, about you from third parties (with consent for EU users), and automatically as you use our Website and the Invoice Billing..
When do we collect you information?
- When you apply for and use the Invoice Billing, you contact us with questions, and you otherwise choose to provide information to us.
- We receive information about you from banking references, credit reporting agencies, affiliates, and other third parties (e.g., entities that assist us in validating your identity, among others). We may combine this with other information that we collect about you.
What information do we collect?
The types of information we collect about you depends on your particular interaction with our Website and the Invoice Billing, and might include, where permitted by applicable law:
- Your contact information (e.g., name, email address, phone number, billing or mailing address)
- Bank and credit account information
- IP address.
- Identity validation (e.g., photograph, other information requested to verify your information)
- Credit history
- National identification numbers
- Date of birth
- Details of any transactions carried out using any the services
- Any other information that you choose to provide to us (e.g., if you send us an email/otherwise contact us)
- Calls/emails/other correspondence
You are responsible for providing accurate and up-to-date information. If you choose to participate in our Refer a Friend program, you acknowledge that you have your friend’s consent to provide your friend’s information to us.
HOW WE USE YOUR INFORMATION
- To validate your identity.
- To provide the Invoice Billing to you, to communicate with you about your use of the Invoice Billing and related services or any changes in our Terms and Conditions that apply to you.
- For the purpose for which you specifically provide the information to us, including, to respond to your inquiries, to provide any information that you request, and to provide customer support.
- To tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), personalized help and instructions, and to otherwise personalize your experiences while using our Website.
- For marketing and promotional purposes, for example, where permitted by law (other than if (where applicable) you opted out), and as noted in the table below, we may use your information, such as your email address, phone number, or mailing address to send you newsletters, special offers and promotions, or to otherwise contact you about services or information we think may interest you, or to conduct draws for campaigns and the like and deliver prizes and rewards.
- As permitted by applicable law (other than if (where applicable) you opted out), to assist us in advertising our products and services in various mediums including, without limitation, sending you promotional emails, advertising our services on third party sites and social media platforms, sending you direct mail, and by telemarketing.
- To better understand how users access and use our Website and the Invoice Billing, both on an aggregated and individualized basis, to administer, monitor, and improve the Website and Invoice Billing, for our internal purposes, and for other research and analytical purposes. Please see our discussion below regarding Third Party Analytics.
- To protect our customers, employees or property — for instance, to investigate fraud, harassment or other types of unlawful activities involving us or other companies that we do business with, to enforce this Policy, as well as our Terms and Conditions.
WHEN DO WE SHARE YOUR INFORMATION?
We will only share your information with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and partners as set out in the table below. In the section below, we list the reasons under which we may choose to share information.
|How and Why We Share Your Information||>Do We Share?|
|With our service providers and affiliates – to assist us with our everyday business purposes, such as to process your transactions and maintain your account(s).||Yes|
|For marketing purposes:
|With other customers of ours or third parties using the Invoice Billing – to assist in carrying out your transactions with such customers or third >parties or for purposes of our refer-a-friend program(s).||Yes|
|In response to legal process – to comply with the law, a judicial proceeding, subpoena, court order, or other legal process.||Yes|
|In connection with business transfers – to another entity if we are acquired by or merged with such other entity, if substantially all of our assets are transferred to such other entity, or as part of a bankruptcy proceeding.||Yes|
|To protect us and others – we may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which we are involved.||Yes|
|Aggregate and de-identified information – we may disclose aggregate or de-identified information about users for marketing, advertising, research, or similar purposes.||Yes|
If you do not want us to use your details for us to market to you, and/or to pass your details on to third parties for marketing purposes, please contact us through the phone number or email address listed in the Section Contact Us, Questions, Updating Your Info, Opting Out below. You will also be able to unsubscribe from any marketing emails sent to you by us using a link provided in the email.
WHERE WE STORE YOUR DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent un-authorized access.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website and Invoice Billing, while others are used to enable a faster log-in process or to allow us to track your activities at our Website and Service. There are four types of cookie:
- Strictly necessary cookies These are cookies that are required for the operation of our Website. They include, for example, cookies that enable users to log into secure areas of our Website.
- Analytical/performance cookies. These types of cookies allow us to recognize, count the number of visitors, and see how visitors move around our Website when they are using it. This assists us to improve the way in which our Website works, for example, by ensuring that you can find what you are looking for easily.
- Functionality cookies These cookies are used to recognize you when you return to our Website. They enable the personalization of content, recognition of users, and also remember your user preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Website, the individual pages visited and the links followed. If the cookie is set by a third party (for example, an advertising network) which also monitors traffic on other websites, this type of cookie may also be used to track your movements across different websites and to create profiles of your general online behaviour. Information collected by tracking cookies is commonly used to target online advertising.
The four types of cookies above will be either session cookies or persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website or Invoice Billing. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website or Invoice Billing.
- Persistent Cookies Persistent cookies remain on your computer after you have closed your browser or turned off your computer.We use persistent cookies to remember your user information, preferences and activity, to enable us to provide the Invoice Billing to you when you next return to our Website or Invoice Billing.We also use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Website preferences and to personalize your visit. Flash LSOs are different from browser cookie because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Storage HTML5 Storage. We may also store your user information and Website preferences locally within your web browser via HTML5.
Clear GIFs, pixel tags and other technologies Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website or the Invoice Billing to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website and the Invoice Billing usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Changing or Disabling your Cookie Settings Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in the future.The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.Visitors to our Website who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, most site features will not function if you disable cookies and you will not be able to login to use the Invoice Billing.
Do Not Track. Currently, our systems do not honor browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies); you also may opt-out of Third Party Analytics or targeted advertising by following the instructions in the Third Party Ad Networks section below.
THIRD PARTY ANALYTICS
We use automated devices and applications, such as Google Analytics, Mixpanel, VWO and Trendemon, to evaluate use of our Website and the Invoice Billing. To opt-out of Google Analytics, please go to:https://tools.google.com/dlpage/gaoptout/.You may opt-out of Mixpanel’s analytics athttps://mixpanel.com/optout/.. To track opt-outs, Mixpanel will use a persistent cookie on your device. Please note that if you use a new or different computer, install a new browser, or clear your cookies, you may clear the Mixpanel opt-out cookie; in that case, you will need to re-opt-out through the link above.
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THIRD-PARTY AD NETWORKS
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”).For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA)
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Website or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or mobile device or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
This Policy may change from time to time. Any changes in the future will be posted on our Website and, where appropriate, notified to you by email.Please check back frequently to see any updates or changes to our Policy. Continued use of the Invoice Billing will constitute acceptance of the Policy in place from time to time. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention and obtain your consent to the same.
CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT
If you have provided us with information, and would like to update your information, you may contact us through the email address listed below. From time to time, we may email you with special offers; you may opt-out of those offers through the email or by contacting us as noted below. If you otherwise would like to contact us for a privacy-related matter, please use the following contact information:
GOVERNING LAW & JURISDICTION
Save in relation to EU customers, this Policy shall be governed by and interpreted in accordance with the laws of the State of Delaware, and any dispute hereunder shall be brought exclusively in the courts of the State of Delaware except where prohibited by US law.
For our EU customers, this Policy shall be governed by and interpreted in accordance with the laws of Gibraltar, and any dispute hereunder shall be brought exclusively in the courts of Gibraltar.
Any and all content provided on this Website or the Services, including links to other websites is provided for information purposes only and does not constitute advice, recommendation or support of such content or website. We make every effort to provide true and accurate content on its Website. However, we provide no warranty, express or implied, of the accuracy, completeness, timeliness, or applicability of such content. We accept no responsibility for and excludes all liability in connection with information provided on the our website, including but not limited to any liability for errors, inaccuracies or omissions.
APPENDIX 1: ADDITIONAL TERMS FOR EU CUSTOMERS
The information below is required pursuant to EU law regarding privacy and data protection. The terms below apply to EU customers in addition to the terms in the rest of the Policy.
For the purposes of the Data Protection Act 2004 (Gibraltar) (the “Act”), the data controller is Payoneer EU Limited of 57/63 Line Wall Road, Gibraltar, a company established in Gibraltar and regulated for data protection purposes in Gibraltar by the Gibraltar Regulatory Authority (“Payoneer EU”).
WHEN DO WE SHARE YOUR INFORMATION
The table headed “How and Why We Share Your Information” in the main part of the policy under the heading “WHEN DO WE SHARE YOUR INFORMATION&rdquolists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with the Invoice Billing.
You should be aware that when sharing your information it may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. Wwill take various measures to ensure that your data is treated securely, which may include, but not be limited to:
- assessing the security measures taken at any place your data is transferred to;
- having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions; and
- having monitoring, reporting and resolution procedures in place with regard to ongoing security.
EU CUSTOMERS ONLY: YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your at any time by contacting us at firstname.lastname@example.org.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
EU CUSTOMERS ONLY: ACCESS TO INFORMATION
The Act gives you the right to access information held about you and the right to rectify that data. Your rights of access and rectification can be exercised in accordance with the Act. Any access request may be subject to a fee of GIP£10 to meet our costs in providing you with details of the information we hold about you. We may reject requests for disclosure or rectification of data that are unreasonable or extremely impractical (e.g. because they require disproportionate human or technical effort or require significant changes to our processes and technology and impact our ability to provide the Invoice Billing). You can also exercise the right at any time by contacting us at email@example.com.