Privacy Policy

ZOOZ Mobile Ltd. (“ZOOZ” or, “us“, “our“, “we“) is the creator and owner of software for payment solutions (the “Solution”).  We recognize and respect the importance of maintaining the privacy of our customers (each a “Customer“) as well as our Customers’ end users, using Customer’s website or mobile application (“App“), in which the ZOOZ code required to implement the Solution in Customer’s App (each an “End User“) has been integrated. This Privacy Policy describes the types of information we collect from you when you visit and use our website (“Site“) and/or use the Solution and associated code, documentation and services provided by ZOOZ in respect of the Solution (“Services“). This Privacy Policy also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. ZOOZ is the data controller in respect of the processing activities outlined in this Privacy Policy relating to information collected and/or provided by users through the Site and the data processor relating to any information provided by a Customer relating to its End Users.  Our registered office is Derech Begin 121, Tel Aviv, Israel and our registration number 514473248. The Customer is the data controller in respect of processing activities outlined in this Privacy Policy relating to any information provided by a Customer relating to its End Users. “You” means any adult user of the Site or Services, using the Site or Services on behalf of an entity, individual or yourself or any parent or guardian of any minor whom you allow using the Site (as defined below) or Services, and for whom you will be held strictly responsible.

 

When visiting this Site or using the Services, you shall be asked to accept the terms of this Privacy Policy.  If you do not agree with the terms hereof, please do not use the Site and/or Services.

 

It is your voluntary decision whether to provide us with any Personal Information (as defined below), but if you refuse to provide such information we may not be able to register you to the Site and/or provide you with the Services.

 

Privacy Policy Key Points

 

The key points listed below are presented in further detail throughout this Privacy Policy. These key points do not substitute the full Privacy Policy.

 

  • Personal Information We Collect. When contact us through the Site, we collect Personal Information provided by you, such as your name, email address, information regarding your (requested) use of the Services and title. We also collect information about your use of the Services and our Customers’ End Users (including as provided by the Customer). If you contact us for questions or complaints, we will collect the information related to your inquiry.
  • Basis for Processing Your Personal Information. Processing your Personal Information is necessary for the provision of the Site and Services to you. Processing for the purposes of developing and enhancing our products and Services, for analytics and usage analysis, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
  • How We Use the Information We Collect. We use the information (including Personal Information) we collect mainly to administer and provide the Site and Services, contact you with administrative information and improve the Site and Services.
  • Sharing the Personal Information We Collect. We may share the Personal Information we collect with our service providers and subcontractors who assist us in the operation of the Site and Services and process the information on our behalf and under our instructions, as well as with the specific Customer through which an End User is using our Services. We may share your information with any third party that you instruct us to provide such information with. You hereby warrant that any such instructions and transfer shall be in accordance with applicable law, including with regard to international transfer. [add warranty of Merchant that instructions will be in accordance with applicable law also add to DPA, TOs and Services agreement – also in template]
  • International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Information. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Policy. You hereby consent to such international transfer.
  • Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Information and obtain a copy of the Personal Information we have collected about you.
  • Use of Cookies. We use cookies to help personalize your experience. You can adjust your settings to determine which cookies you do or do not allow. Changing your settings and/or deleting existing cookies may affect the Services.
  • Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Policy.
  • Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Information, but they do not provide absolute information security.
  • Changes to the Privacy Policy. We may change this Privacy Policy from time and shall notify you of such changes.

 

Information We Collect

 

We collect information from you when you choose to use our Site or Services.  In order to use our Site, contact us and/or receive Services, you may be required to register and/or provide us with certain Personal Information (as defined below). We also collect Personal Information when you make use of the Site and Services, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.

 

Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. Examples of the Personal Information that we collect from you, if you register on the Site, include your name, e-mail address, IP address, information regarding your (requested) use of the Services and title. In addition, we collect the company name you work for. The Services collect information and data in respect of our customers’ end users and transactions processed through the Services, including name, address, e-mail address, credit card number (encrypted), if applicable, Device ID, IP address, and such end users’ transactions and purchase histories, as well as any additional data regarding End Users supplied to us by our Customers (“End User Data”).   

 

ZOOZ complies with the Payment Card Industry Data Security Standard (“PCI DSS”).

 

How We Use Information

General

ZOOZ and any of our trusted third-party subcontractors and service providers may use the information we collect from and about you for any of the following purposes: (1) to provide you with the Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) subject to your consent as may be required under applicable law, to contact you with informational newsletters and promotional and marketing materials relating to our Site and Services; (5) to review the usage and operations of our Site and Services; (6) to use your data internally only in an aggregated and/or personalized and/or non-personalized format for analytical purposes and externally in an aggregated, non-specific format for analytical purposes (as detailed below); and (7) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services.

 

Statistical Information

By analyzing all information we receive, including all information concerning users and customers, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information transferred to third parties is anonymous and aggregated and we will not link any such transferred Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion. In addition, our Customer may request Statistical Information and Analytics (as detailed below) regarding their respective End Users, which may include aggregate and/or personalized and/or non-personalized information regarding such Customer’s End Users.

 

Analytics

We, or our service providers or subcontractors, may use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the Site and/or Services. Such Tools collect information such as how often users and/or customers visit the Site, what pages they visit when they do so, and what other sites and apps they used prior to coming to this Site. The Tools may collect certain Personal Information, and may link such Personal Information to specific information stored in our Customer database. We use the information we get from the Tools (“Analytics“) to improve our Site and Services and may share with Customers the Analytics (aggregate and/or personalized and/or non-personalized) relating to such Customer’s End Users. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use located at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at http://www.google.com/policies/privacy/.

 

Legal uses

We may use your Personal Information as required or permitted by any applicable law.

 

Disclosure of Information

Except as expressly set forth herein, we will not share your Personal Information with third parties without your explicit permission, except when required by law, regulation, subpoena, court order or other law enforcement related issues, as specified below.

 

We may share your information, including Personal Information, as follows:

Business Partners, Service Providers, Affiliates, and Subcontractors

We may disclose information, including Personal Information we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Services; and (2) aid in their understanding of how users and/or customers are using our Site and Services.

 

Instructions

We may share your information with any third party that you instruct us to provide such information to (“Merchant Third Party”). You hereby warrant that any such instructions and transfer shall be in accordance with applicable law, including with regard to international transfer. ZOOZ shall not be liable for any such transfer to a Merchant Third Party and you hereby represent and warrant that solely you (and not PaymetsOS) shall be responsible and liable for any such (international) transfer of data, including Personal Information to a Merchant Third Party.

 

International Transfer

We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own, and send them information we receive (including Personal Information). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Policy. You hereby consent to such international transfer.

 

End User Data

We may disclose information, including Personal Information we collect from and/or about End Users, to the specific Customer through which an End User is using our Services, as well as to our trusted subcontractors and service providers, as detailed in this Policy.

 

Business Transfers

We may transfer our databases containing your Personal Information if we sell our business or part of it.

 

Law Enforcement related disclosure

We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Policy), or to protect the rights, property or safety of third parties. You can request such Personal Information as specified herein by emailing us at legal@zooz.com. We may also share information in order to comply with legal and/or regulatory obligations, to protect and defend our rights and property and/or with your permission.

 

Other Uses or Transfer of Your Information

We allow you to use our Site and Services in connection with third-party services, sites, and/or applications. If you use our Site and/or Services with or through such third-parties, we may receive information about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.  

 

Data Retention

We retain information as necessary for the purposes set forth above and in accordance with our regulatory, audit and other requirements (including but not limited any PCI requirements), in accordance with applicable law. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.

 

How We Protect Information

We make efforts to follow generally-accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, 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.

 

How to Access and Limit Our Use of Certain Information

You have certain rights in relation to the Personal Information that we hold about you, as detailed below. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:

 

  • Right of Access and Data Portability. You have a right to know what Personal Information we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Information to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
  • Right to Correct Personal Information. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Information and/or that we suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request thereof.
  • Deletion of Personal Information. In certain circumstances you have a right to have Personal Information that we hold about you deleted. Should you wish to have any Personal Information about you deleted, please contact us, using the contact information specified in this Privacy Policy. Subject to applicable law, we will delete Personal Information provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Information. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Information, you should also delete our Solution and Services from your devices and terminate your account with us and clear our cookies from any device where you have used our Site. We may retain certain Personal Information (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
  • Account Deactivation. You can ask us to deactivate your account by contacting us using the information below. In order to deactivate your account, we may ask you for additional information.
  • Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Information for certain purposes.
  • Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.

 

Cookies

 

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. ZOOZ uses cookies to help personalize your ZOOZ experience. A “session” cookie may be used to help save your settings and customizations across visits for a limited period of time while you are visiting the Site.

 

How to Adjust Your Preferences

Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. Also, you are free to delete any existing cookies at any time. Please note that some features of the Site may not function properly when cookies are disabled or removed.

 

Communications

Subject to your consent and applicable law, we may send you e-mails or other messages about us or our services.  As a registered member, you may remove your Personal Information from our mailing list and stop receiving future communication from us by following the unsubscribe link located at the bottom of each communication or by emailing us at hello@zooz.com and nati@zooz.com. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send.  Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages, relating either to your account, if any, or to your transactions on this Site, without offering you the opportunity to opt out of receiving them unless you cancel your account, if you have one.

 

Third Party Sites and Services

Portions of the Site (including, without limitation, advertisements) or Services may involve linking to or using web sites, applications or services belonging to third parties. The Site may also provide you with links to access the applications of third party vendors or companies. We have no control over third-party applications or services, and all use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.  We are not responsible for content or available by means of such applications, sites or services. ZOOZ does not endorse any products or services offered by third parties and we urge our users to exercise caution in using third-party sites or services.

 

Children

ZOOZ does not knowingly collect Personal Information from children under the age of sixteen (16). In the event you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.  

 

Changes

We may update this Privacy Policy from time to time – in which case, we shall notify Customers of such changes. We encourage our Customers and Customers’ End Users to review this Privacy Policy periodically. By continuing to access or use the Site, App and/or Services after any changes to the Privacy Policy become effective, such end users agree to be bound by the revised privacy policy. Any new Privacy Policy will be effective from the date it is accepted by you.  

 

Comments and Questions

 

If you have any comments or questions about our privacy policy, please contact us at legal@zooz.com.

 

Last updated: May 2018

 

 

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