Last Revised: July 2019
Decentralized Mobile Applications Ltd., an Israeli private limited company, having its principal place of business at 121 Derech Menachem Begin St., Tel-Aviv, 6701203, Israel (“PayKey“, “We“, “us” or “our“), welcomes you to our owned and operated website, at: https://paykey.com/ (“Website“).
PayKey are fully committed to protect the privacy of the visitors and/or users of our Marketing Platforms (collectively, the “Visitors” or “Customers“, referred as “you” or “your“), in compliance with applicable privacy and personal data laws and regulations.
2. YOUR CONSENT
3. INFORMATION WE COLLECT
We may collect several types of data and information from and about our Customers. In this section, we describe the categories of information which we may collect, and the applicable circumstances under which such collection is performed.
3.1. First – What is Personal Information?
Personal information refers to individually identifiable information, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature information, relating to an identified or identifiable natural person. Identification of an individual includes association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person.
3.2. We collect personal information from you when you use or interact with our Marketing Platforms
We collect personal information from you and any devices (including mobile devices) you use when you: use, interact or access our Marketing Platforms, register for an account with us, provide us information on a web form or other text field within our Website, update or add information to your account, or through correspondence you and we conduct with each other.
More specifically we collect and use the following categories and types of information in the following respective circumstances:
Personal information Visitors and Customers provide us actively and voluntarily when they use or interacts with our Marketing Platform:
● Contact information such as Customers and/or Visitors name, company number, signing person name and position, email and physical addresses, and telephone number, all when such Customers and/or Visitors fill our online form or register for an account with us or when they update their account details.
● When you voluntarily share Information with us. For example, when you register to one of our events, request that we contact you through our online forms, submit your CV, or when you request to receive certain content that we may make available (e.g. research and white papers).
● The contents of Customers and/or Visitors interaction with our customer support which may include text/video/audio recording and transcripts of such communications.
● Information we are required or authorized by applicable national laws to require Customers and/or Visitors to provide us in order to authenticate or identify them or to verify the information we have collected or otherwise provide them with our Marketing Platforms.
Personal information we automatically obtain when Customers and/or Visitors use or interact with our Marketing Platforms:
● This is information we obtain through the Marketing Platforms when Customers and/or Visitors access or interact with the Marketing Platforms, which is derived, learned, or detected as a result of such access and/or interaction.
Keep in mind – Most devices allow you to control or disable the use of certain collectable information including location services, in the device’s settings menu.
3.3. Personal information collected from other sources
We may collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information. For example, we may collect and use demographic and other information that is publicly available in an applicable jurisdiction, additional contact information, credit/check information, and information from credit bureaus, as allowed by applicable national laws.
Please Note – While most of the information we collect from you is not Personal Information, we acknowledge that under certain jurisdictions the data we do receive when a Customer and/or Visitor are using the Marketing Platform may be deemed personal data as it is associated with a Technical Identifier, and therefore, where applicable, will be treated as such.
You have the rights to choose how we collect and use your Information. See “Your Rights” at section 12 below for more information.
4. THE PURPOSES
4.1 Legal basis for collecting and processing of Personal Information:
When performing an agreement with: Your information may be processed on the basis that such processing is necessary for the establishment and performance of our contractual engagements with you. Under such engagement we shall provide Customers and Visitors with the Marketing Platforms, maintain and improve our Marketing Platforms, develop new services and features for our Customers and Visitors.
With consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to send you our marketing offers and communications.
We use Information for the following purposes:
● To process your inquiries and to respond to your requests. For example, when you contact us to learn more about our products or services or when you request to receive certain materials from us (e.g. white papers, research papers, product and services information). Additionally, if you submit your CV, we use it to evaluate your candidacy (including by assessing your qualifications and skills).
● To send you information related to our services and products that we believe may interest you, such as newsletters or product and service updates. Such communications will be sent to you when you have chosen to receive such communication or when we have a legitimate interest to market our products and services. In any event, you will always be able to opt-out of receiving such communications. Opting out may be done either directly in the communication received or through the ways described in the instructions in the “Your Rights” section, at section 12 below.
● To understand how you have used our Marketing Platforms and to customize them in accordance with your interests and past actions and choices. We do this based on our legitimate interest to operate our Marketing Platforms, diagnose any problems with the Marketing Platforms and to improve the Marketing Platforms and your experience when navigating through them.
● In our legitimate interest to prevent fraud or harm to us or to any third party, and ensure the security of our network and services.
● Where it is necessary for PayKey to comply with its legal obligations and to exercise and enforce its legal rights.
● We may use certain third-party marketing and advertising networks to help us market our products on our own Website and on third party websites (e.g. re-marketing ads across the Internet by Google).
5. TO WHOM WE SHARE PERSONAL INFORMATION?
We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:
5.1. Third Party Services:
We are partnering with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (e.g., Google Cloud, AWS, data analytics services (e.g. Google Analytics), e-mail and text message distribution and monitoring services (e.g. Gmail), payment processors and analytics (e.g. PayPal), advertising, affiliation and related analytics services (e.g. Facebook, Twitter, Google), research and development services (consultants hired by PayKey), customer support services, and our business, legal and financial advisors (collectively, “Third Party Service Providers“).
Such Third Party Service Providers may receive or otherwise have access to your personal information through your use of our Marketing Platforms, depending on each of their particular roles and purposes in facilitating and enhancing the Marketing Platforms, and may only use your personal information for such purposes. Such disclosure or access is strictly subject to the recipient’s or user’s undertaking of confidentiality and appropriate safeguards obligations, the prevention of any independent right to use your personal information except as required to help us to provide the Marketing Platform and subject to applicable law. We remain responsible and liable for any personal information processing done by Third Party Service Providers on our behalf, except for such Third Party Service Providers with whom you have a direct contractual relationship.
5.2. Governmental/Law Enforcement Agencies and Legal Requests or Duties:
We may disclose or otherwise allow access to personal information pursuant to a legal requirement or request, such as a subpoena, search warrant or court order, or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to the data subject or the Customer, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
5.3. Protecting Rights and Safety:
We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of our Company, any of our Customers and Visitors, or any members of the general public.
5.4. Our Affiliated Companies:
For the removal of doubt, we may share Personal Information in additional manners, pursuant to the applicable relevant approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use non-personal information in our sole discretion and without the need for further approval.
6. DIRECT MARKETING
By providing us with your e-mail address or any other contact information Customers and Visitors hereby agree that PayKey may use your contact details for the purpose of informing you of our events, products and services offered by us and to send you newsletters or marketing materials. You may withdraw your consent by sending a written notice to PayKey by email to the following address: firstname.lastname@example.org or by opting out by clicking “unsubscribe”. Please note that we may notify you (through any of the means available to us) of changes or updates to our platforms and our other services, payment issues, service maintenance, etc., and you will not be able to opt-out of receiving such service messages.
PayKey does not knowingly collect or process personal data from or with respect to children under the age of 18, and you must be 18 years of age or older in order to contact us through our Marketing Platforms. If you are a parent or legal guardian and believe that your child under the age of 18 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.
8. INFORMATION SECURITY
We take a great care in implementing and maintaining the security of the Website and the Marketing Platforms. PayKey employs industry standard procedures to ensure the safety of Personal Information and prevent unauthorized use of any such information (such as Firewall). However, we do not and cannot guarantee that unauthorized access will never occur.
If you have any questions regarding the security of our Marketing Platforms, please feel free to contact us at email@example.com.
9. THIRD PARTY SERVICES, COOKIES AND OTHER TRACKING TECHNOLOGIES
These technologies are used in order to maintain, provide and improve our Marketing Platforms on an ongoing basis, and to provide a better experience to our Customers and Visitors. For example, these technologies enable us to: (i) keep track of and apply our Customers’ and Visitors’ authenticated sessions, (ii) better secure our Marketing Platforms by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Marketing Platforms, (iv) monitor and analyze our ads’ performance; and (v) create and monitor analytics relating to use of and interaction with our Marketing Platforms.
In this context Customers and Visitors should note that we may use Google Analytics, Facebook, Twitter and LinkedIn’s functionality of re-marketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook, Twitter or LinkedIn (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Marketing Platforms, outside of Marketing Platforms and across the internet. In such event the Social Ad Platforms, will place cookies on your web browser and use such cookies to serve you ads based on past visits to our Marketing Platforms.
Google Adwords: https://policies.google.com/technologies/ads
If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so at the following links:
Google Adwords: https://adssettings.google.co.il/authenticated
PLEASE NOTE – such tracking and targeting by Social Ad Platforms, is provided pursuant to your engagement with such Social Ad Platforms and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms is not transparent to us. If you would like to learn more or make further inquiries with respect to such nature or scope please refer to each of such Social Ad Platforms directly.
Learn more about your choices and how to opt-out of tracking technologies:
You may opt-out of multi session tracking by changing your applicable Technical Identifiers between sessions. To learn how to opt-out through changing the Do Not Track Settings, click on the following links:
For iPhone: https://support.apple.com/en-us/HT202074
10. INFORMATION STORAGE AND RETENTION
Personal information regarding the Customers and Visitors will be maintained, processed and stored by us and our authorized affiliates and service providers in Israel and as necessary, in other territories in secured cloud storage, provided by our third party service provider.
Specifically, each of our services providers who stores or processes your personal information either, (i) assured us that it provides adequate safeguards to protect your rights to privacy, or (ii) holds and processes such information on our behalf in a jurisdiction which has been determined to ensure an adequate level protection by the EU Commission which if in the US, includes certification under the EU-US Privacy shield framework.
You hereby accept the transfer and storage of information as described above.
11. MODIFICATIONS TO THIS POLICY
12. YOUR RIGHTS: UPDATING, OBTAINING A COPY OF, DELETING OR WITHDRAWAL OF CONSENT FOR PROCESSING OF, PERSONAL INFORMATION
If the law applicable to you grants you such rights, you may ask to access, correct, or delete your personal information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether we process your personal information, or ask to withdraw any consent you have previously provided to us in connection with our use and processing of your personal information.
Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.
Subject the limitations in law, you may also be entitled to obtain the personal information you directly provided us in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.
If for any reason you wish to modify your Personal Information you can do so by sending us an email to: firstname.lastname@example.org. If for any reason you wish to delete your information you can send us an email to email@example.com. We will make reasonable efforts to modify or delete any such Personal Information pursuant to any applicable privacy laws.
Note that unless you instruct us otherwise we may retain your personal information for a period for as long as reasonably needed to provide the Marketing Platforms and/or as legally required.
To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.
13. HAVE ANY QUESTIONS?
By contacting us, and accessing the Marketing Platforms, you warrant and agree that you are free to do so, and that you are not providing us with information which violates any third party intellectual or privacy rights.