PayEm Website Privacy Notice
Last Revised: Nov 12, 2024
Introduction
Welcome to the PayEm Platform and App!
PayEm, Inc. and PayEm Card Ltd. (“PayEm”, “we”, “our” or “us”) develops a holistic finance operating system which includes a platform, which can be found on https://app.payemcard.com/ ("Platform") and a mobile app (“App”, and collectively with the Platform – the “Services”). As part of the Services, we will be required to process various types of information, including information that may lead to the identification of a specific individual ("Personal Data").
This Privacy Notice ("Notice") was designed to help you understand how we use, collect and store Personal Data that we collect or receive from or about you in connection with the Services.
1. What types of Personal Information we collect
In order to provide you with our Services, and in order to ensure our compliance with applicable laws we collect and process the following data:
1.1. Account Information. When our customer creates an account for you on the Services and when you login to the Services, we collect your full name, email address, phone number, date of birth, company name, your department name, password, and job title. If you choose to log in to the Services through a third party (such as Google), we may collect Personal Data (e.g. full name and email address) associated with that this service, as the service allows us to access.
1.2. Communication Information. When you send us an email or contact us via our Services, we collect the Personal Data you provide us. This may include your name, email address, and any other information you choose to provide.
1.3. When you visit or access our Services, we may use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). More information regarding our use of Tracking Technologies can be found on our Platform Cookie Policy here.
2. We process information for the following purposes:
a. To provide you access to the Services. We will use the information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you the Services and to process your requests; (iii) communicate with you about your use of the Services and for support purposes; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Platform and the App, including, updates pertaining to your subscription, and related to the Services we provide you with; (vi) to personalize your experience with our Services; (vii) to allow you to create more users and administrate your users; (viii) to generally administer and improve the Services;
b. For Administrative Purposes. PayEm uses your Personal Data (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future Services; (ii) to provide you with the Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) to generally administer the Services;
c. To Market our Services. PayEm uses information to market the PayEm’s Services. Such use includes (i) notifying you about offers and Services that may be of interest to you (iii) developing and marketing new products and Services, and to measure interest in PayEm’s Services; (iv) other purposes disclosed at the time you provide information; (vi) as you otherwise consent;
d. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
e.De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve PayEm’s Services (including through the use of artificial intelligence) and for research purposes. We will use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our Services and enhance your experience with them and/or to develop new product features and improve existing offerings).
f. Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the PayEm’s Services, use Technologies to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Services. If you would like to opt out of the cookies and similar technologies we employ on the Services, you may do so by blocking, deleting, or disabling them as your browser or device permits or by changing your setting and preferences here
g. The lawful bases we rely on for processing personal information are (if and when applicable):
The data subject has given consent to the processing of his or her personal data;
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
Processing is necessary for the purposes of the legitimate interest.
3. With whom we share your data?
3.2.1 We share your Personal Data as follows: The information PayEm gathers is shared with our partners and other third parties.
3.2.2 We also share information with our affiliated companies about you.
3.3.3 We use third party service providers to process your information for the purposes outlined above, including, without limitation:
With cloud service providers for hosting purposes;
With websites and web based platforms in order to help us manage our Services;
With email providers, marketing, CRM and other similar tool providers;
With analytics companies, in order to help us understand and analyze information we collect in accordance with this policy; and
We also share your information with service providers like Airwallex for the purposes of providing financial services and payment processing.
3.2 To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of PayEm, our Services, customers, employees, property, and the public.
3.3 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
Where you have otherwise provided your consent to us for sharing or transferring your information
4. Your rights
4.1 The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
4.1.1 You have the right to withdraw consent to the processing, where consent is the basis of processing.
4.1.2 You have the right to access the Personal Data that we hold and request further details about how we process it, under certain conditions.
4.1.3 You have the right to demand rectification of inaccurate Personal Data about you. We will promptly correct any information found to be incorrect.
4.1.4 You have the right to object to unlawful data processing under certain conditions.
4.1.5 You have the right to the erasure of past data about you (your “right to be forgotten”) under certain conditions.
4.1.6 You have the right to demand that we restrict the processing of your Personal Data, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your Personal Data is inaccurate.
4.1.7 You have the right to data portability of Personal Data concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
4.1.8 The Personal Data we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by PayEm by contacting PayEm directly or by following the instructions through the unsubscribe options in our email messages.
4.2 You can exercise your respective rights by contacting us at info@payemcard.com. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.3 Deleting your account: Should you ever decide to delete your account, you may do so by emailing legal@payemcard.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account.
4.4 Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to info@payemcard.com. Please note that the email must come from the email account you wish to block OR if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
5. How we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems.
6. Retention
Your Personal Data will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.
7. International transfers of Personal Data
a. We store the Personal Data with the following storing companies: AWS – North Virginia – US.
b. In order to run our business and provide our Services to you, we transfer Personal Data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your Personal Data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your Personal Data by implementing at least one of the following safeguards:
i. making sure the destination country has been deemed to provide an adequate level of protection for Personal Data; and/or.
ii. by executing implement data onward transfer instruments such as data processing and protection agreements.
8. USE BY CHILDREN.
We do not offer our products or Services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@payemcard.com.
9. Interaction with Third Party products.
We enable you to interact with third party websites, mobile software applications and products or Services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party. Please be aware that Third Party Platform can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
10. Analytic tools/Cookies
We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.
11. Updates to this Notice
We reserve the right to change this Notice at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly.
12. Contact Us
If you have any further questions, please contact us by email at info@payemcard.com.
PayEm, Inc.
Physical address: 3739 Balboa Street, Unit #5044, San Francisco, CA 94121