Payment Financial Technologies Ltd., Company No. 515166544 (hereinafter: the “Company”), respects the privacy of users of the website, as defined in the Terms of Use, which is operated and managed by the Company, or of any other website established and/or to be established by the Company, whether independently or jointly with others, that does not have its own specific regulations (hereinafter: the “Website”). Accordingly, the Company has resolved to publish its policy regarding the protection of Website users’ privacy.
The purpose of this Privacy Policy is to explain the Company’s practices regarding the privacy of Website users, and how the Company uses information provided by users or collected during their use of the Website.
Browsing and using the Website and any services offered therein constitutes your consent to the Company’s Privacy Policy as set forth in this document, and shall be deemed implied acceptance of its provisions. Accordingly, if you do not agree to any of the terms/provisions of this document, you are requested to refrain from using the Website.
This Privacy Policy is drafted in the masculine form solely for convenience and applies equally to women and men. Terms not expressly defined in this document shall be interpreted in accordance with the definitions set out in the Website’s Terms of Use. The provisions of this document complement the Terms of Use and shall be interpreted together with them.

1. Information Entered into and/or Collected in Connection with the Website
1.1. In order to use the Website and operate as a registered user, whether as a borrower or a lender, you will be required to choose a username and personal password, which will serve for access to your personal area on the Website.
1.2. Use of the system on the Website requires registration. As part of the registration process, you will be required to provide personal information such as your name, identification number, contact details, email address, occupation, payment method details, bank account information, financial data, and other personal details (hereinafter: “Personal Information”). It is not possible to register for certain services on the Website without providing the information requested in the mandatory fields. The Company may request only specific Personal Information necessary for the service for which you are registering, and upon registering for another service, you may be required to provide additional Personal Information. The Company may also contact you after registration to request further Personal Information.
1.3. When using the Website and the system, information about you is collected. Some of this information may personally identify you, such as your name, address, and similar details. Other information does not personally identify you and is not stored together with your personal details. This may include statistical and aggregated data. The information may also include additional details, such as the geographic location of the computer during use of the Website, details regarding the computer and browser, information about the services you used and how you used them, actions performed, pages viewed, offers and services of interest to you, advertisements viewed on the Website, the Internet address from which you accessed the Website (IP), and more, primarily for the purposes of business research, learning, and service improvement, as further detailed below.
1.4. Under applicable law, you are not obligated to provide the Company with your personal details; however, the Company will be unable to grant you access to the Website without receiving the required information.
1.5. Such details, as well as information regarding the actions you perform on the Website, shall be stored in the Company’s database.
1.6. For the avoidance of doubt, it is clarified that the Company is not obligated to retain such information and may delete it, in whole or in part, from time to time, at its sole discretion.

2. Consent to the Provision of Information (Section 11 of the Privacy Protection Law)
You are providing the information voluntarily and with your full consent, without any legal obligation to do so. The information will be stored in the Company’s databases and/or by its representatives solely for the purpose of providing services to you. If you choose not to provide the information, the Company will, naturally, be unable to provide the requested service and/or the service offered by it. You may, at any time, review and correct information concerning you in accordance with privacy laws. The methods for contacting us are specified under the heading “Contact Us.”

3. The Company’s Database
3.1. The Company’s database is registered in accordance with the Privacy Protection Law, 5741-1981 (hereinafter, respectively: the “Database” and the “Privacy Protection Law”), and the Company operates in compliance with said Law and with any other applicable law.
3.2. By providing Personal Information, you consent to the inclusion of such information in the Database, and to the Company’s right to use it in accordance with the Terms of Use, this document, and any applicable law.
3.3. In accordance with the Privacy Protection Law, every person is entitled to review information concerning him, either personally, through an authorized representative holding written authorization, or through his legal guardian, subject to the provisions of the law. A person who has reviewed such information and found it to be incorrect, incomplete, unclear, or not up to date may contact the owner of the database with a request to amend or delete the information. If the owner of the database refuses to comply with such a request, he must notify the applicant in the manner and form prescribed by regulation. A refusal by the owner of a database to permit review, or a notice of refusal to amend or delete information, may be appealed by the applicant to the Magistrates’ Court in the manner prescribed by regulation.
3.4. In the event of termination of the service and a request for deletion of information, the information required by the Company for the conduct of its business — including records of commercial and other transactions carried out by you on the Website — shall continue to be retained in the Company’s databases in accordance with the law, but shall no longer be used for marketing communications directed to you. If, within 30 days, you do not receive notice that the information requested for deletion has in fact been deleted pursuant to this section, you shall be entitled to apply to the Magistrates’ Court, in the manner prescribed by regulation under the law, to instruct the Company to act accordingly.

4. Use of Information Collected Based on Use of the Website
4.1. We use the information we collect, inter alia, for the following purposes: Analyzing your risk profile as a borrower, determining your credit rating, and constructing a borrower portfolio if you have registered on the Website for the purpose of receiving a loan; or analyzing your risk preferences and constructing a lender portfolio if you have registered on the Website for the purpose of granting a loan. Such analysis is carried out by the Company using methods it has developed, which constitute its trade secrets. Accordingly, the analysis and its results are not subject to disclosure or review, and by registering on the Website you waive your right to review them.
Administering the loan process, including the transfer of payments in connection therewith and the undertaking of collection actions by all lawful means.
Collecting fees payable to the Company in accordance with the Terms of Use and the applicable tariff schedule.
Improving the services and content offered on the Website, creating new services or content tailored to user needs, or discontinuing existing services or content. For this purpose, the Company will primarily use statistical information that does not personally identify you.
Customizing the content of the Website to your fields of interest.
Sending you messages by email or SMS (or by any other medium); for example, to notify you of changes or improvements to the Website, as well as marketing and promotional information — whether relating to the Company or information the Company receives for immediate distribution on behalf of other advertisers. At any time, you may request to cease receiving such information by submitting a written request to the Company.
Contacting you when necessary. Please note that we may also record communications with you, inter alia, to assist in resolving issues you may encounter.
Analyzing statistical data and providing it to third parties, including advertisers. Information provided to third parties shall not personally identify you.
Sending marketing offers on behalf of the Company and/or its representatives.
Ensuring the proper operation and development of the Website or of other websites that may be established in the future by the Company.
Any other purpose specified in this Privacy Policy or in the Website Terms of Use.

4.2. Cookies
Cookies are small files containing a string of characters that are sent to your computer when you visit a particular website. Upon a return visit to the Website, cookies enable the Website to recognize your browser. Cookies may contain various types of information, including details regarding your preferences as a user and activities you have carried out on the Website. We use the information collected through cookies for the ongoing operation of the Website, for verifying details and information security, and to improve the user experience and the overall quality of the services we offer on the Website.
You may, at any time, block or delete cookies by changing the settings of the browser through which you access the Website, so that it rejects all cookies or notifies you when such a file is sent to your computer. However, if you do so, certain functions or services on the Website may not operate properly, and your personal details may not be retained on the Website, requiring you to re-enter them upon a return visit.

5. Publications and Advertisements
5.1. The Company shall be entitled to send you, from time to time, by various means, including SMS and email, advertisements, in accordance with and subject to the provisions of the Communications (Telecommunications and Broadcasting) Law, 5742-1982 (the “Spam Law”).
The Company may use information received through the Website and information collected regarding patterns of use of the Website for the purpose of improving the services on the Website and/or in any other manner it offers, and for contacting you when necessary, subject to the provisions of the Spam Law. Pursuant to said Law, you are entitled to notify the Company in writing that you do not wish to receive commercial advertisements.

6. Direct Marketing of Promotional Offers
6.1. The Company may, from time to time, send you, by email or any other medium, information concerning its services, as well as marketing and promotional material, including professional materials, updates, publications, notices, and various offers, based on the information contained in its databases, including by use of different data profiling methods.
6.2. Such information will be sent to you only if you have provided your consent, whether at the time of registration to the Website or at another time, and so long as you have not revoked such consent, or to the extent permitted by applicable law.
6.3. The Company does not provide direct mailing services on behalf of others and shall not transfer your details, or the information collected about you to third parties for the purpose of direct mailing services, unless your consent has been obtained. However, the Company may use your details for the purpose of sending marketing offers on behalf of third parties, provided that your details shall not be transferred or disclosed to such third parties in any manner without your consent. The Company may also engage service providers on its behalf and, in this framework, transfer to them such details and information, subject to their undertaking of confidentiality.

7. Disclosure of Information to Third Parties
The Company does not share Personal Information or information collected regarding your activities on the Website (to the extent such details and information personally identify you), and shall not transfer such information to third parties, except in the following cases:
7.1. We have obtained your consent. For this purpose, “consent” means informed consent, whether explicit or implied.
7.2. For the purpose of assessing your eligibility for registration as a borrower or lender in the system, as well as for additional inquiries intended to determine your credit rating and risk profile, including for the purpose of detecting identity fraud and verifying the accuracy of the details you have provided.
7.3. We will not disclose to other users any information containing your identifying details, including name, identification number, address, photograph, etc.; however, we will disclose information concerning the loan terms, its purpose, your profile, and similar information. In addition, in the event of a breach of the loan agreement and/or the initiation of debt collection proceedings, we shall be entitled to disclose your full details.
7.4. For the operation of the system, including the transfer of funds and fees between users — for which purpose details shall be provided to the trustee, to the bank managing the clearing account, and similar entities.
7.5. Transfer of information to the tax authorities, to the extent such transfer is required by law. This may include, inter alia, disclosure of information relating to withholding tax and VAT charges.
7.6. If you participate in third-party content activities or in joint activities of the Company and a third party presented on the Website. In such cases, the relevant third party will be provided with the information necessary for managing the relevant activity and for establishing or maintaining contact with you.
7.7. We may enable you to share your activities on the Website with your friends on social networks such as Facebook, through tools and features such as “Share” and “Like.” We will not provide Personal Information to such social networks; however, you should be aware that they may cross-reference the above information with the data already held in your social network profile. Any such sharing shall be subject to the terms of use of the relevant social network.
7.8. For statistical purposes – we provide Personal Information to entities or companies we trust to process the information on our behalf, in accordance with our instructions and in a manner consistent with this Privacy Policy. As a rule, and unless you have consented to the transfer of Personal Information, information transferred for statistical purposes does not include identifying details that could reasonably enable a third party to identify you.
7.9. For the purpose of managing collection proceedings: in such case, the Company shall be entitled to provide your details to parties engaged by it or by the lenders for the purpose of carrying out collection actions.
7.10. For legal reasons:
If the Company receives a court order requiring it to disclose your details or information concerning you to a third party.
If, in the Company’s opinion, disclosure is required for and/or in connection with any dispute, claim, demand, or legal proceedings, whether between you and the Company or between a third party and the Company.
If you breach or attempt to breach the Terms of Use of the Website or any of the services offered by the Company, or if you directly, or through another party, engage in conduct that appears to be unlawful, the Company shall be entitled to disclose the information to any competent authority.
In any case where the Company considers disclosure of the information to be reasonably necessary in order to prevent harm to you or your property, or to a third party or its property, or to the Company.
In any case where there is an authorization and/or obligation under law to disclose the details.
7.11. For the avoidance of doubt, it is hereby clarified that the databases are used by all entities comprising the Company for the purposes set forth in this document and in the Terms of Use.
7.12. If the Company organizes the operation of the Website within another corporation — or if it engages an operating company or trustee company, or merges with another entity, or consolidates or transfers the operation of the Website with the operations of a third party (hereinafter: the “Additional Corporation”) — it shall be entitled to transfer to the Additional Corporation the information collected about you on the Website or any statistical information collected by it, provided that the Additional Corporation to which the information is transferred assumes the obligations of this Privacy Policy, the Terms of Use, and the contractual documents.
8. Third-Party Advertisements
8.1. The Company permits, or may permit, third parties to manage the advertising display system on the Website and/or to assist in managing such system, and also uses, or may use, systems of other companies to manage the advertising display system on the Website.
8.2. For the purpose of managing advertisements, these companies may place on your computer various objects such as cookies and “web beacons” embedded in advertisements or Website pages. Web beacons are tiny graphic files with a unique identifier embedded in the Website pages, designed to assist in collecting information regarding the use of the Website. The information collected does not personally identify you, but rather adapts the advertisements displayed to you according to topics that may be of interest to you. The use these companies make of cookies and web beacons is subject solely to their own privacy policies, and you are invited to review the privacy policies of such companies through their websites.

9. Collection of Information for Statistical Purposes
The Company may engage various companies that provide it with statistical data regarding the use of the Website. Such companies collect and analyze information concerning the volume of use of the Website, the frequency of such use, the sources of user access to the Website, and similar information. The information collected is statistical in nature, does not personally identify the user, and is intended for purposes of analysis, research, and monitoring.
Confidentiality of Information
9.1. The Company invests resources and implements stringent measures to prevent unauthorized intrusion into the Website and to avert potential harm to the privacy of customers and users of the Website. Nevertheless, disruptions cannot be entirely ruled out. You shall have no claim and/or demand and/or cause of action against the Company and/or its representatives for any such disruptions, malfunctions, and/or failures, and you hereby waive any such claim.
9.2. The Company employs accepted precautionary measures in order to maintain, to the extent possible, the confidentiality of information. Any transfer of credit card details from the Website is conducted in accordance with the PCI DSS (Payment Card Industry Data Security Standard), a standard established by the credit card companies that sets forth security rules for companies collecting payment by credit card. Notwithstanding the foregoing, breaches of confidentiality may occur as a result of circumstances beyond the Company’s control or due to force majeure or malicious acts of third parties. You acknowledge, confirm, and agree that the Company shall not be liable for any damage of any kind, whether direct or indirect, incurred by you and/or anyone acting on your behalf, in the event that information is lost, exposed, or otherwise used without authorization.
9.3. Beyond the foregoing uses, the Company undertakes not to make any use of the details specified above without your authorization, unless such use is required by law or court order and/or is necessary to protect the rights of the Company and/or its representatives and/or to enforce the provisions of this document and the Terms of Use and/or to act in order to protect the interests of Website users and/or to prevent misuse of the Website. The Company shall permit access to the information only to those of its employees and advisors who require the information for the purpose of providing the service. Without derogating from the generality of the foregoing, it is hereby clarified that in any case of dispute between you and the Company, for any reason whatsoever, the Company shall be entitled to use such information to the extent necessary for its defense, subject to applicable law.

10. Changes to the Privacy Policy
Our Privacy Policy may change from time to time. If changes are made to the Privacy Policy that reduce your rights or involve a different use of the Personal Information you have provided, notice thereof shall be published on the Website.

11. Contact
For any questions or issues relating to the Privacy Policy on the Website, please contact: info@payment-pay.co.il.
Controller of the Database: Payment Financial Technologies Ltd. | Address: 4 HaSadnaot St., Herzliya | Telephone: 03-5511177