SensePass Ltd. (“SensePass“, “we”, “us”, “our”) developed and operates a platform connecting and allowing merchants to receive payments via e-wallets, mobile payment apps, credit cards and other payment methods (the “Platform”).

We respect the privacy of our users and are committed to protect the personal information that our users share with us.

This Privacy Notice (the “Notice“) describes the types of information we may collect from users of our Platform as well as information that may be collected via our websites www.sensepass.com and www.sense-pay.com (the “Websites”). It also describes our practices for collecting, using, maintaining and processing such information, and the rights and options available to users of our Platform and websites with respect to their personal data.

Please note that this Notice covers Sensepass’ privacy practices only. The merchant and e-wallet and/or payment methods you are using usually have an additional privacy notice explaining their own specific privacy practices related to the personal data of their customers and users.

PERSONAL DATA PROCESSED
When you tap your mobile phone to make a payment order to a merchant that uses our platform, you will be automatically directed to a payment landing page where you can choose your preferred payment method. We will then collect and process the following information about you in order to process your payment to the merchant: your customer ID and the details of your payment order, your ID number, email address, authentication token and information of your payment methods (Pay Pal, Venmo, Bit, etc.); when paying with credit card, we will obtain your credit card token, expiration date and 4 last digits of your credit card (“Platform Information”).

When using our Websites, you can submit an inquiry through our online contact form or by calling or writing to us. You may also request a demo of our service. When contacting us or requesting a demo, you will be asked to provide information such as your name, company, email address, phone number, and the text of your message. The mandatory fields for completion will be marked as such (“Inquiry Information”).

When you use the Platform and Websites, we record and collect certain information about your interaction with the Platform and Websites, including the IP address from which you access the Platform or Websites, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Platform or Websites (“Analytics Information“).

HOW YOUR PERSONAL DATA IS USED
We will use your Platform Information to provide our service and facilitate your payment order to the merchant.

We will use your Inquiry Information to contact you about your inquiry and handle your inquiry.

We will use the Analytics Information for its quality assurance and for development and enhancement of the Platform. We will use the Analytics Information collected via our Websites to improve the Websites, our email communications and the products and services we offer to customers. We also use the Analytical Information to adapt the Websites or Platform (as applicable), its content, our services, and our email communications to users’ preferences. Finally, we will use the Analytics Information to understand the market in which SensePass operates in and for managerial reporting and business planning.

WHO WILL PROCESS YOUR DATA
We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We will share your personal information with our service providers who assist us with the internal operations of the Platform and Websites. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes. We do not sell your personal information to third parties.

We will share your Platform Information with the merchants you make a transaction with. We will only share the relevant information for the specific transaction such as the date, time, amount, payment method, transaction ID or reference ID, customer ID etc.

We will share your Platform Information with third parties necessary to facilitate your payment order such as e-wallets, credit card companies or companies operating other payment methods you choose to use, payment gateways and other payment authentication and clearing companies. We will only share the relevant information required to facilitate the specific transaction such as the date, time, amount, payment method, transaction ID or reference ID, customer ID etc.

If you have abused your rights to use the Platform or Websites, or violated any applicable law, we may share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.

If we are required to disclose your information by a judicial, governmental or regulatory authority.

If the operation of the Platform or Websites is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information only as required to enable the structural change in the operation of the Platform or Websites.

COOKIES
Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various websites.

The information that the cookies maintain is read by the website you visit, during the session of your visit to the website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use techniques called web beacons and web pixels for purposes similar to the use of cookies.

We use cookies when you visit our Website and/or when you visit our payment page on the Platform for a number of purposes, as briefly explained below:

Necessary. Cookies that are strictly necessary for the functioning of the Websites or Platform. The Websites and Platform cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of the Websites or Platform may not function properly.

Statistics. Analytics cookies that help us understand how you and other users interact with our Websites or Platform by collecting data that does not directly identify you.

You can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.

SECURITY AND DATA RETENTION
We will retain your Information for the duration needed to support our ordinary business activities operating the Websites and Platform and interacting with existing and potential customers. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Platform and/or Websites will be immune from information security risks.

INTERNATIONAL DATA TRANSFERS
If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

If you are an EU resident, any transfer of your personal data out of the EU will be in accordance with adequate safeguards determined by the EU Commission.

FRAUD PREVENTION
Any merchant and e-wallet using the SensePass Platform is obligated to use it only for transactions made by its customers in good faith.

If you have any reason to believe that any transaction made via the Platform is fraudulent or in any way infringes on your rights, please contact us at: support@sensepass.com

In addition to any other remedy SensePass or any third party may have by law, SensePass reserves the right to immediately terminate a merchant or e-wallet’s license to use its Platform if it receives a complaint of any fraud or deception on their behalf, without prior notice, and may report such complaint to the relevant authorities.

SensePass will bear no responsibility to any damage caused to you by such fraudulent transaction or report to the authorities.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EU
The following is the data controller for the purposes of the personal data we collect via the Websites and Platform:
SensePass Ltd.
Midtown Tower, 39th floor
144 Derech Menachem Begin
Tel-Aviv, Israel

The legal basis under EU law for processing your Platform Information is the fulfilment of our contract with you to facilitate your payment to the merchant.

The legal basis under EU law for processing your Analytics Information is our legitimate interest in maintaining, developing and enhancing the Platform and/or Websites.

The legal basis for collecting and processing your Inquiry Information is our legitimate interests in responding to your inquiry.

The legal basis under EU law for processing your data for the purpose of handling instances of abusive use of the Platform is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.

The legal basis under EU law for processing your data where we are legally required to share it, is our legitimate interests in complying with mandatory legal requirements imposed on us.

The legal basis under EU law for us processing your data in the event of a change in our corporate structure is our legitimate interests in our business continuity.

If you are in the EU, you have the following rights under the GDPR:

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims.

Right to Restrict the processing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact the merchant/e-wallet through the channels listed on their privacy notices.

If you wish to exercise any of these rights with regards to your Inquiry Information you may contact us at info@sensepass.com . We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

MINORS
The Platform and Websites are not directed to users under the age of 18. We do not knowingly collect information or data from children under the age of 18 or knowingly allow children under the age of 18 to use the Platform and/or Websites.

CHANGES TO THIS PRIVACY NOTICE
From time to time, we may change this Notice. The latest version of the Notice will always be accessible at www.sensepass.com/privacy-policy.

Last Update: Nov 18th, 2020.