PRIVACY POLICY

ALEPHPAY TECHNOLOGIES LTD. PRIVACY POLICY

The Alephpay Technologies Ltd. Privacy Policy was last updated on January 18, 2018.

We, Alephpay Technologies Inc. and our corporate affiliates (“Alephpay”, “we” or “us”), are committed to protecting and respecting your privacy. We believe in transparency, and we are committed to being upfront about our privacy practices, including how we treat your personal information. This Privacy Policy (“Policy“) explains which information we collect from you, when you (“you” or “your”, the user of our Services) access and use the mobile application (the “App“), website (www.alephpay.com) (the “Site“), products and services provided by us (which, together, are referred to as the “Services“), will be processed by us, and how we use such information and protect it. The Policy also wishes to make sure that you are aware of the options available to you when you access and use our Services.

This Policy is a part of our Terms of Use found on our website. By using the App or visiting our Site, you consent to our collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this policy. This includes any information you choose to provide that is deemed sensitive under applicable law. This Policy only applies to Alephpay’s Services. We are not responsible for the content or the privacy policies of any third-party websites, or apps.

Our Terms of Use require all account owners to be at least 18 years of age (or have the permission and supervision of a responsible parent or legal guardian), therefore, this Policy does not discuss use of our Services by minors.

Export of Data

By using the Services, you authorize Alephpay to transfer and use your information in all countries where Alephpay operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those applying in the country in which you reside. We will take steps to ensure that your personal information continues to enjoy appropriate protections.

 

The information we collect from you and how we obtain it

  1. Information you provide us or give us permission to obtain

As a Alephpay member you are required to provide your full name and a valid email address when you register to any of our Services

Depending on which services you choose to use, the information you give us may include your physical postal address, phone number, billing and payment information, personal description, Gender, Birthday, phone number and ID photo.

Any information you provide us is provided by you voluntarily. However, certain information is required in order for you to register and enjoy the full benefits of our Services.

  1. Information we collect from your use of the Services

Website Log and Device Information – When you use our Services, we may automatically collect certain information, including information that your browser sends whenever you visit a website. This information may include, for example, (a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and the geographic location of the computer system that you are using to log-in; as well as (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, the frequency and scope of your use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content you viewed (including advertisements you clicked on) and pages you visited, your communications with other users and third parties, and cookie data. 

As such, the information we collect may be “personally identifiable” (meaning it can be used to specifically identify you as a unique person) or “non-personally identifiable information” (meaning it can’t be used to specifically identify you). We use both types of information, and combinations of both types, as described above.

When you use the Services, you may choose to share your geo-location details with us in order to use our location-based services. We will only share your geo-location details with third parties (like our mapping providers) for the sole purpose of providing you with those services.

Mobile Device – When you use a mobile device like a tablet or phone to access our Services, we may automatically collect and store certain technical information, such as your operating system, version, device manufacturer and model, and other information about your mobile device, as well as the frequency and scope of your use of the App. We may also generate a unique device identifier for use by Alephpay to operate the Service. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. We may also collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), including personal information, and may use that information to customize the Services. You hereby authorize us to access such components of your mobile device. You can grant or revoke your consent at any time and prevent us from continuing to access your GPS information by disabling the GPS or other location-tracking functions on your device, provided your device allows you to do this.

Information collected by Cookies and similar technologies – A cookie is a small text file that is stored on a user’s device for record keeping purposes. Cookies can only be read by the server that sent them, and they cannot read data from the hard drive. We or our service providers may use cookies, web beacons and similar technologies to collect and store certain information, such as your registration information, language preferences and other account settings, so you don‘t have to set them up every time you use our Services.

We may also use these technologies to recognize your browser type as you navigate on the Internet and to collect aggregate and statistic information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. This allows us to better serve you with more tailored information and facilitate your ongoing access to and use of the Services.

Any user IDs, passwords, and any other user- or account-related data that we store in such cookies are encrypted for security purposes. We may allow our authorized service providers to access the information collected by cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising.

To learn more about cookies, please visit http://www.allaboutcookies.org/. You may delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

Collaboration with Google. We may collaborate with Google as a business partner. “DoubleClick” cookie is used by Google in the ads served on the websites of its partners, such as websites displaying AdSense ads or participating in Google certified ad networks. When users visit such partner’s website and either view or click on an ad, a cookie may be dropped on that end user’s browser.

  • Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to websites.
  • Google’s use of the DoubleClick cookie enables it and its partners to serve ads to users based on users’ visits to our site and/or other sites on the Internet.
  • Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings.

Please be advised that the cookies of other third-party vendors or ad networks may also be used to serve ads, and therefore, please be informed as follows:

How we use the information we collect and store

We respect your privacy. Alephpay will not disclose your name, email address or other personal information to third parties without your consent, except as specified in this Policy. We generally use the information to provide and improve our services and products, for billing and payments, for identification and authentication, for targeted online and offline marketing, to contact members or interested parties, and for general research and aggregate reporting.

Alephpay limits access to your personal information by Alephpay personnel to those whom we believe reasonably need that information to provide products or services to you or in order to do their jobs.

We use information held about you in the following ways:

  1. Information you give to us.
    • When we store your registration information and account settings, we are able to save you the trouble of having to fill and set them up every time you access and use our Services.
    • We use the information to help us to:
      • better customize and improve the Service and the information and products provided to you;
      • the Services and the user experience provided to you.
      • help you complete a transaction, or provide services or customer support;
      • understand your needs and create content that is relevant to you;
      • communicate back to you;
      • enforce terms of use; and
      • allow you to access Services, or otherwise engage in activities in the App and the Site that you select.
    • Depending on your notification settings, we may send you newsletters, updates, marketing materials and other information by e-mail and/or via mobile devices in order to notify you about changes to our service, the Site and the App or because we think the specific information is interesting for you.
  2. Information we collect about you.
    • We use the information to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure.
    • The information helps us measure and research the effectiveness of the Services’ features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
    • We may also use it to make suggestions and recommendations to you and other users of our site about services that may interest you or them.
  3. [Information we receive from other sources.We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive
  4. Storage of Information. In addition, please be aware that we may host or store your data and information (including personally identifiable information) in the United States and other countries through certain third parties that we use to operate and manage the App, the Site and Services, including Amazon Web Services (“AWS”). By using the Site, you acknowledge and expressly consent to the transfer and processing of your personally identifiable information in this way. We may store your information also after your membership has been terminated. Such information may be used for any internal purpose, such as quality control efforts or customer analysis.
  5. Respond and handle your questions and requests. If you have any questions or concerns about Alephpay Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at:

ALEPHPAY Technologies Inc.  

c/o CorpCo

910 Foulk Road, Suite 201

Wilmington, DE  19803

Email  customer support

Please include the full name and contact information in your request.

DISCLOSURE OF YOUR INFORMATION

We value your privacy and will not share your personal information with third parties except in the following instances:

  1. When we received your consent. This includes sharing information with other service providers, e.g. the issuer of the pre-paid card.
  2. When we employ third parties to process personal information on our behalf. Alephpay may engage third party companies and individuals (such as payment processors, research companies, analytics and security providers) to help provide our Services. Such third parties’ use will be subject to instructions given by us and in compliance with this Policy. For instance, we may provide data to our accountants to make sure we are keeping our books right, or we may engage a security consultant to help us better identify spam. These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to Alephpay not to disclose or use your information for other purposes.
  3. With our affiliates. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group.
  4. Non-Personally Identifiable Information. We may also share aggregated or non-personally identifiable information that we collect under any of the above circumstances with our business partners, affiliates or other third parties to develop and deliver targeted advertising on our websites and on websites of third parties. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customize content and advertising.

We may disclose your personal information to third parties:

  1. If Alephpay or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
  2. We may disclose Personal Information (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud, intellectual property infringement, piracy, or other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm. In such events, Alephpay may disclose a name, address, country, phone number, email address and company name.
  3. Alephpay is affiliated with a variety of businesses and works closely with them. These businesses may offer promotions (including e-mail promotions) or sell items or services to you through our Services. When an affiliated business is associated with your transaction, we may share information related to the transaction with that affiliated business to facilitate your transaction.

                                                   

YOUR RIGHTS TO ACCESS YOUR INFORMATION       

 

You can change your information at any time by editing your profile.

In addition, if you find that the information on your account is not accurate, complete or updated, then you are responsible to make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from registering to our Services and impair our ability to provide you with Services.

You can close or deactivate your account at any time. Following termination or deactivation of your account, we may (a) retain information (including your profile information) for various purposes including statistics, analytics, backup, archival Terms of Use enforcement, (b) take actions we deem necessary to protect the integrity of our website or our users, or take other actions otherwise permitted by law.

Please also note that after you close or deactivate your account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time, subject to the Terms of Use.

YOUR CHOICES WITH RESPECT TO YOUR INFORMATION

Our goal is to enable you to decide over your information and with whom such information is shared. When you open an Alephpay account, many of the choices that you have are built directly into your account settings.

Here are some examples to how you can manage your information and the access of others to it:

  1. You can add or update information and close your account as described above.
  2. You can modify your e-mail notification settings at any time. You also will be given the option to unsubscribe from promotional messages in any such e-mail we send.
  3. As mentioned above, the “Help” function on most browsers indicates how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services.

DATA RETENTION

Alephpay will retain your information only for as long as is necessary for the purposes set out in this Policy, for as long as your account is active, or as needed to provide you services. If you no longer want Alephpay to use your information to provide you services, you may close your account. Alephpay will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements

You may inform us of any changes or requests regarding your personal data, and in accordance with our obligations under applicable data protection law, we may update or delete your personal data accordingly. We’ll respond to your request within a reasonable timeframe.

 

HOW DO WE SECURE YOUR INFORMATION? 

We consider data security a top priority and we do our best to keep your Personal Information secure. For that purpose, we:

  1. Encrypt many of our services using SSL.
  2. Employ firewalls and intrusion detection systems.
  3. Practice administrative, technical, and physical security procedures to help protect the information you provide us.

Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your personal information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to their standard terms and conditions that are generally non-negotiable; and accordingly, although we seek to conduct reasonable due diligence on such service providers, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.

                                                   

PROTECTION OF CHILDREN’S PRIVACY        

Our Services are not directed to children under 18.

If it comes to our attention through reliable means that a registered user is a child under 18 years of age, we will cancel that user’s account and/or access to the Services.

                                                   

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. Your continued use of our Services following the posting of changes to this Policy or providing notice to you, whichever occurs first, means that you accept those changes.

GENERAL

We reserve the right to discontinue or modify any aspect of the Services at any time. This Policy, together with our Terms of Use and any other legal notices published by us on the Site and in the App, shall constitute the entire agreement between us concerning the Services. If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

           

GOVERNING LAW AND JURISDICTION

This Policy shall be governed by the laws of the State of Israel, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the courts located in Tel Aviv, Israel, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.

Our Services are controlled and operated from Israel, and we make no representations that they are appropriate or available for use in other locations.

NOTE TO INTERNATIONAL USERS

We are an USA private company headquartered in SF, USA. If you are located outside of USA, the personal information you provide to us will be transferred to Israel and governed by applicable US laws and regulations and this Privacy Policy. Some of this information may be transferred to, processed and stored by our service providers in other countries. By submitting your personal information, you consent to its transfer to and storage in US and other countries designated by us, its governance by USA laws and regulations, and its use in accordance with this Privacy Policy.