SensePass Privacy Notice
SensePass Ltd. (“SensePass”, “we”, “us”, “our”) developed and operates a platform connecting and allowing merchants to receive payments via e-wallets and mobile payment apps (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 websites with respect to their personal data.
Please note that this Notice covers the Platform’s privacy practices in general matters. The merchant and e-wallet you are using usually have an additional privacy notice explaining their own specific privacy practices related to the personal data of its users.
DATA CONTROLLER AND DATA PROCESSOR
The merchant and e-wallet are the data controllers of your personal data on the Platform. they determine the purposes and means of processing your data. You can review their privacy practices in their privacy notices.
SensePass is the data processor of your personal data on the Platform, as it is processing the data on behalf of the merchant and/or e-wallet. However, SensePass is the data controller for the Inquiry Information and Analytics Information, as explained below collected via our Websites.
PERSONAL DATA PROCESSED
We process information you provide us when you submit an inquiry on our Websites or request a demo of our service.
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 (“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 solely in order to provide our service and transfer your payment order to the merchant via the e-wallet.
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.
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 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.
Necessary. Cookies that are strictly necessary for the functioning of the Websites. The Websites 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 may not function properly.
Statistics. Analytics cookies that help us understand how you and other users interact with our Websites 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 the information collected via the platform for as long as required to provide the services the merchant and/or e-wallet and as per their instructions.
We will retain your Inquiry Information for the duration needed to support our ordinary business activities operating the Websites 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, such as Privacy-Shield certified companies in the United States.
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:
Midtown Tower, 39th floor
144 Derech Menachem Begin
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 of 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 firstname.lastname@example.org . 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.
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
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: May 21th, 2020.