PayEm Website Privacy Notice

Introduction

This privacy notice details how PayEm Card Ltd., Reg. No. 515963239 and PayEm, Inc. (collectively, "us", "we" or "Company") process information of our users (each, "you" or "User") collected through our website and in the Company's onboarding process (the "Services").‍

The details of the Company are as follows:

PayEm Card Ltd.
Derech Menachem Begin 23
Tel Aviv-Yafo, Israel, 6618356

PayEm, Inc.
1501 Broadway Paramount Building, 12th
Floor, New York, NY, 10036

Telephone Number: 646-657-9606
E-mail Address: info@payemcard.com

We may revise this privacy notice from time to time, in our sole discretion, and the most current version will always be posted on our website (as reflected in the "Last Revised" heading). We encourage you to visit this page regularly for any changes.

What types of information we collect

We collect two types of information from you: Personal Information ("Personal Information") and non-Personal information. Personal Information means any information that may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Information, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This section sets out how and when we collect those types of information from you.

We may collect Personal Information related to you as follows:

• Voluntary Information: We may collect information that you provide us voluntarily. For instance, when you communicate with us via the "Book a Demo" option and provide us with your name, phone, your company name, and email address.
• 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 unique device identifiers (e.g. MAC address) and IP address.
• Registration Information (KYC Information): as part of the onboarding process of our products, you will be asked to provide us certain details regarding your company's controlling officer and principals, and we may receive additional information about them from third parties. The information may include the following: full name, home address, zip code, Social Security Number or another personal identifier (e.g. passport number), date of birth, phone number and job title. We are required to collect and process this Personal Information under our Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory and contractual obligations.

Non-Personal Information collected by us may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). In addition, as part of the onboarding process of our products, you will be asked to provide non-Personal Information about your company, including its legal name, physical address, phone number, federal tax ID/EIN or company registration number, type of entity, type of ownership and country and date of incorporation.

Any non-Personal Information connected or linked to or associated with any Personal Information shall be deemed and treated as Personal Information as long as such connection, linkage or association exists

Legal basis

The Company processes Personal Information as is necessary for the performance of our contractual obligations towards you and to provide you with our Services, to protect our legitimate interests, and to comply with our legal obligations. In specific cases, we may also process your information based on your consent.

Cookies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Service's performance, assist in our marketing efforts, perform analytics, and customize your experience.

For further information about our use of Tracking Technologies, please refer to our Cookies Policy, which forms a part of this privacy policy.

Google Analytics

We use Google Analytics and Google Analytics 4 (GA4) to improve the Services.Here are two direct links that provide more information about how Google collects and processes data along with Google’s privacy practices:google.com/policies/privacy/partnerspolicies.google.com/privacy?hl=en-US You can opt-out from the relevant Google Analytics Advertising Features by visiting the following links: optout.networkadvertising.org/?c=1 or tools.google.com/dlpage/gaoptout .You can also review and manage your Google cookies preference in our Cookies Policy.

How we use the information

We use the information in the manner described in this Privacy Policy. In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

• 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 regard 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 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:‍

• our third party vendors engaged in providing services in connection with the Services;
• our subsidiaries and affiliated companies;
• auditors or advisers of our business processes; and
• 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); (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services; and (iv) we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.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.

Minors

The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not use the Services or provide any Personal Information to us in any other manner.We reserve the right to access and verify any Personal Information that is collected from you by us. In the event that we become aware that an individual under the age of 18 has shared any information, we will discard such information.If you have any reason to believe that a minor shared any information with us, it will be advisable to contact us at: info@payemcard.com.

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries other than the country in which the information was first collected. In these instances, we will transfer your data in accordance with applicable laws and regulations.

For how long we retain the information

We retain the information that we collect from our Users for as long as we are providing the Services to the applicable customer. Retention periods will be determined taking 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. We may rectify, replenish or remove incomplete or inaccurate information, at any time and in our sole 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 see what Personal Information about you we have;
• Right to 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 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);
• Right to object the processing of Personal Information by us; and
• Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at info@payemcard.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint about how we have handled your Personal Information, please contact us directly at info@payemcard.com.

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.