Privacy Policy
Privat Technologies Inc
Last Update: January 2nd, 2023.
At Privat Technologies Inc. we are committed with the protection and respect of your privacy; Because of that; we will:
a)Always keep your personal data safe and private.
b)Never sell your personal information or data.
c)Allow you to manage and review your personal data from the app.
We may update this Policy from time to time and we will provide updates as the Delaware’s Law requires.
1.- ABOUT US.
PRIVAT TECHNOLOGIES INC. (herein after referredas “PRIVAT”) is a company founded in the State of Delaware, and will be the responsible for processing your personal data for the product or service for which you have registered. PRIVAT has relationships with certain service providers in order to bring our services to you; Financial Institutions; among other services related to “Know Your Customer” requirements and other obligations.
2.- SCOPE OF THIS PRIVACY POLICY
This Policy will apply to your information when you visit or use our Mobile Phone App. This Policy will not apply to online websites that we don’t own or control; all information provided to any third party must be controlled by their respective privacy policy/notice.
3.- WHY DO YOU NEED TO READ THIS POLICY
In order to provide our product or services to you (herein after the “Services”). We may require from you certain personal information and documents; Also we collect personal data when you use the PRIVAT App; any kind of service available to you through the PRIVAT App.We may also collect your personal data from other people or companies; Through this document we will explain how we collect information from you; for which purposes are going to use it and your rights when we use your personal information/ data.
4.- COLECCTING YOUR PERSONAL DATA
The types of personal information we may obtain about you (which in some case can be sensitive information) include:·
-Identifiers such as name, date of birth, postal and email address, and phone number;·
-Government-issued photo ID, such as a driver’s license or passport;
-Login credentials for your account;
-Certain Financial information, including your account number from our Bank Partners,
-Account transaction history, information about your linked non-Privat accounts (such astransaction information and balances, payroll account information, etc.), and payment card information
-Information included on a tax return you provide;
-Employment information, including occupation, information about your employer, and income details (such as source of income, approximate annual income and how frequently you are paid)
-Physical characteristics, demographic information and similar details (such as sex,gender, race, color, marital or family status, citizenship status, signature,language preference and national origin) present in documents (e.g., IDs, tax returns) you provide
-Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or services;
-Voice recordings (such as when you call PRIVAT customer services)
-Biometric information (such as a facial image collected for identity verification, if you use certain features of our App)
-Social media handles;
-Information you provide through customer services interactions and that you provide about your experience with PRIVAT, including via questionnaires, surveys, participation in user research or other feedback
-Geolocation data;
-Information provided by marketers and other websites on which PRIVAT advertises;
-Information you provide through contacts integration, including a list of contacts from your phone’s operating system; and
-Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with member services), referrals, onsocial media pages, or in registrations and sign-up forms.
-Device Information, such as hardware, model, operating system.
5.- HOW YOUR PERSONAL DATA ISCOLLECTED.
We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with our member services representatives. In addition, we may obtain information about you when you send or receive payments to or from one ofour members.
PRIVAT will also collect information about you when you:
a) Fill any form;
b) Respond any of our surveys;
c) Register to our app or create anaccount through our website;
d) Use any of the Services;
e) Take part of any online discussion or promotion;
f) Contactus for any reason;
g) Contact with people in charge of PRIVAT Social media by phone or chat; In addition to the foregoing; we collect certain information in other ways like:
a) Automatically collected info: whenyou access to PRIVAT Services we maycollect certain information such as your IP address, browser type, operating system, etc.
b) Cookies and similar Technologies: we may use cookies technology to collect certain information about how you interact and use our Services; Cookies are stored in your device and allow a better interaction withour services; Although Cookies can be disabled through your browser system; but this may limit the functionability of certain features.
c) We may also collect personal information from publiclyavailable sources, such as government records or publicly available websites.
6.- USE OF YOU PERSONAL INFORMATION
PRIVAT use your collected personal information to:
-Provide Services in general, perform obligations, under this agreement, carry outrelated business functions, performing data and transaction processing,background check and security concerns, analyzing transactions history orsecurity concerns.
-To develop andimprove, modify, add functions or develop in multiple ways our Services.
-To comply withlegal obligations that apply to the Services we offer to you; to fulfill allobligations related to “Know your Customer” policies, anti-money laundering andanti-terrorism requirements, economic and trade sanctions, due diligence,suspicious activity reporting and related obligations.
-To confirmyour identity, your data provided by you and prevent fraud.
-To confirm aperson’s authority or faculties to represent a user of our Services.
-Send you updates, promotional materials, and other communications related to ourServices.
-To defend our legal rights and the rights of others.
-To investigateany misuse of our Service, including criminal activity.
7.- SHARING YOUR PERSONAL INFORMATION
PRIVAT may share certain personal information with third parties, which can be:
a) Business Partners and complementary Services.
b) Legal Compliance.
c) Direct Service Providers.
d) Financial Institutions.
e) Payment Networks.
f) Payment Processors.
g) User Account Registration and Authentication Services
Your personal information shared with these thirdparties is shared for these reasons:
-To provide youwith the Services.
-To improve Customer Support.
-“Know Your Costumer Policies.
-Legal Complience and Governmental request.
-To improve our website
-To create anddeliver Cards.
-To send you emails.
-To prevent,investigate, and protect against error, fraud or other criminal activity.
8 CHILDREN PRIVACY POLICY
PRIVAT Services, webpage and Apps are not intended for individuals under theage of 18 (herein after “Children”), we do not knowingly collect any Children information, if you are aware that a Children has provided us with their personal information, please contact us.
9.- INTERNATIONAL DATA TRANSFER
PRIVAT operatesinternationally and may transfer information to the United States and other countries for the purposes described in this Privacy Policy; the United Stateand other countries may have privacy laws that are different each; and can be more or less protective than. As a consequence of the foregoing if you are located in other country different from United States we may be required to send data to other countries authorities or institutions.
10 CAN-SPAM ACT COMPLIENCE
PRIVAT will provide services and communicate with you always in compliance of the Can-Spam Act of 2003, PRIVAT is committed to maintaining a clean and spam-free environment for our Services and communications.This applies to all electronic communications,including emails SMS messages, push notifications, and any other possible electronic messaging, sent on behalf of PRIVAT, covering communications with potential customers, users, and other individuals that have interaction with PRIVAT webpage or App.
-PRIVAT don’t use false or misleading subject lines or email address.·
-We provide clear identification of an advertisement email that comes from us.
-We provide a visible and functional unsubscribe option for opt-out of futureemails.
-Honor a request to unsubscribe within 5 working days.
-Unsubscribing does not require the payment of a fee.
11.- RIGHTS AND CHOICES
If you used or use our service you have right to access to your information, know which personal Data we have; You have also right to modify your personal information through your account settings or in some specific cases you can write us an email. As mentioned before in this Policy you can opt-out of receiving promotional emails or marketing communications from us.PRIVAT don’t respond for “Don’t track me” signals that come from browsers.
12.- GRAMM-LEACH BLILEY ACT COMPLIENCE.
Your non-public information is safe with us, in compliance with the Gramm-Leach Bliley Act we implement safeguards to protect the confidentialityand integrity of the information we collect, because of this we
-Designated a Privacy officer responsible for overseeing how your personal information is threatening.
-Created controls and protocols to mitigate risks in personal data leaks.
-Trained our employees and personal about Personal data and security topics, Disclosure alteration and unauthorized access topics.
-Created a Physical and digital safeguard to protect your personal information from any person not related to PRIVAT or the treatment of your information.
13.- PRIVAT CONTACT INFORMATION
In order to execute any right that comes from this Privacy Policy you can contact us to the following email: support@privat.com
14.- CHANGES IN THIS POLICY.
As it is needed and requested by law, from time to time we may update this Privacy Policy if there’s additional information we need to collect or if the purposes have changed, we will notify you through email or through PRIVAT’s App; please check this Policy periodically for any changes.
15.- CALIFORNIA PRIVACY RIGHTS.
The following information will be only applied to California residents, as established in The California ConsumerPrivacy Act, as amended by the California Privacy Rights Act of 2020.This California Privacy Notice Supplements our Privacy Notice and applies solely to California Residents.
-Categories of Personal Information Collected.
In the last 12 months we have collected the following type of data, we do not collect all categories of personal information for each source; each one provides different type of personal information.
Last Update: January 2nd, 2023.
At Privat Technologies Inc. we are committed with the protection and respect of your privacy; Because of that; we will:
a)Always keep your personal data safe and private.
b)Never sell your personal information or data.
c)Allow you to manage and review your personal data from the app.
We may update this Policy from time to time and we will provide updates as the Delaware’s Law requires.
1.- ABOUT US.
PRIVAT TECHNOLOGIES INC. (herein after referredas “PRIVAT”) is a company founded in the State of Delaware, and will be the responsible for processing your personal data for the product or service for which you have registered. PRIVAT has relationships with certain service providers in order to bring our services to you; Financial Institutions; among other services related to “Know Your Customer” requirements and other obligations.
2.- SCOPE OF THIS PRIVACY POLICY
This Policy will apply to your information when you visit or use our Mobile Phone App. This Policy will not apply to online websites that we don’t own or control; all information provided to any third party must be controlled by their respective privacy policy/notice.
3.- WHY DO YOU NEED TO READ THIS POLICY
In order to provide our product or services to you (herein after the “Services”). We may require from you certain personal information and documents; Also we collect personal data when you use the PRIVAT App; any kind of service available to you through the PRIVAT App.We may also collect your personal data from other people or companies; Through this document we will explain how we collect information from you; for which purposes are going to use it and your rights when we use your personal information/ data.
4.- COLECCTING YOUR PERSONAL DATA
The types of personal information we may obtain about you (which in some case can be sensitive information) include:·
-Identifiers such as name, date of birth, postal and email address, and phone number;·
-Government-issued photo ID, such as a driver’s license or passport;
-Login credentials for your account;
-Certain Financial information, including your account number from our Bank Partners,
-Account transaction history, information about your linked non-Privat accounts (such astransaction information and balances, payroll account information, etc.), and payment card information
-Information included on a tax return you provide;
-Employment information, including occupation, information about your employer, and income details (such as source of income, approximate annual income and how frequently you are paid)
-Physical characteristics, demographic information and similar details (such as sex,gender, race, color, marital or family status, citizenship status, signature,language preference and national origin) present in documents (e.g., IDs, tax returns) you provide
-Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrollment in products or services;
-Voice recordings (such as when you call PRIVAT customer services)
-Biometric information (such as a facial image collected for identity verification, if you use certain features of our App)
-Social media handles;
-Information you provide through customer services interactions and that you provide about your experience with PRIVAT, including via questionnaires, surveys, participation in user research or other feedback
-Geolocation data;
-Information provided by marketers and other websites on which PRIVAT advertises;
-Information you provide through contacts integration, including a list of contacts from your phone’s operating system; and
-Other information you choose to provide, such as through our “Contact Us” feature, emails or other communications (such as with member services), referrals, onsocial media pages, or in registrations and sign-up forms.
-Device Information, such as hardware, model, operating system.
5.- HOW YOUR PERSONAL DATA ISCOLLECTED.
We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with our member services representatives. In addition, we may obtain information about you when you send or receive payments to or from one ofour members.
PRIVAT will also collect information about you when you:
a) Fill any form;
b) Respond any of our surveys;
c) Register to our app or create anaccount through our website;
d) Use any of the Services;
e) Take part of any online discussion or promotion;
f) Contactus for any reason;
g) Contact with people in charge of PRIVAT Social media by phone or chat; In addition to the foregoing; we collect certain information in other ways like:
a) Automatically collected info: whenyou access to PRIVAT Services we maycollect certain information such as your IP address, browser type, operating system, etc.
b) Cookies and similar Technologies: we may use cookies technology to collect certain information about how you interact and use our Services; Cookies are stored in your device and allow a better interaction withour services; Although Cookies can be disabled through your browser system; but this may limit the functionability of certain features.
c) We may also collect personal information from publiclyavailable sources, such as government records or publicly available websites.
6.- USE OF YOU PERSONAL INFORMATION
PRIVAT use your collected personal information to:
-Provide Services in general, perform obligations, under this agreement, carry outrelated business functions, performing data and transaction processing,background check and security concerns, analyzing transactions history orsecurity concerns.
-To develop andimprove, modify, add functions or develop in multiple ways our Services.
-To comply withlegal obligations that apply to the Services we offer to you; to fulfill allobligations related to “Know your Customer” policies, anti-money laundering andanti-terrorism requirements, economic and trade sanctions, due diligence,suspicious activity reporting and related obligations.
-To confirmyour identity, your data provided by you and prevent fraud.
-To confirm aperson’s authority or faculties to represent a user of our Services.
-Send you updates, promotional materials, and other communications related to ourServices.
-To defend our legal rights and the rights of others.
-To investigateany misuse of our Service, including criminal activity.
7.- SHARING YOUR PERSONAL INFORMATION
PRIVAT may share certain personal information with third parties, which can be:
a) Business Partners and complementary Services.
b) Legal Compliance.
c) Direct Service Providers.
d) Financial Institutions.
e) Payment Networks.
f) Payment Processors.
g) User Account Registration and Authentication Services
Your personal information shared with these thirdparties is shared for these reasons:
-To provide youwith the Services.
-To improve Customer Support.
-“Know Your Costumer Policies.
-Legal Complience and Governmental request.
-To improve our website
-To create anddeliver Cards.
-To send you emails.
-To prevent,investigate, and protect against error, fraud or other criminal activity.
8 CHILDREN PRIVACY POLICY
PRIVAT Services, webpage and Apps are not intended for individuals under theage of 18 (herein after “Children”), we do not knowingly collect any Children information, if you are aware that a Children has provided us with their personal information, please contact us.
9.- INTERNATIONAL DATA TRANSFER
PRIVAT operatesinternationally and may transfer information to the United States and other countries for the purposes described in this Privacy Policy; the United Stateand other countries may have privacy laws that are different each; and can be more or less protective than. As a consequence of the foregoing if you are located in other country different from United States we may be required to send data to other countries authorities or institutions.
10 CAN-SPAM ACT COMPLIENCE
PRIVAT will provide services and communicate with you always in compliance of the Can-Spam Act of 2003, PRIVAT is committed to maintaining a clean and spam-free environment for our Services and communications.This applies to all electronic communications,including emails SMS messages, push notifications, and any other possible electronic messaging, sent on behalf of PRIVAT, covering communications with potential customers, users, and other individuals that have interaction with PRIVAT webpage or App.
-PRIVAT don’t use false or misleading subject lines or email address.·
-We provide clear identification of an advertisement email that comes from us.
-We provide a visible and functional unsubscribe option for opt-out of futureemails.
-Honor a request to unsubscribe within 5 working days.
-Unsubscribing does not require the payment of a fee.
11.- RIGHTS AND CHOICES
If you used or use our service you have right to access to your information, know which personal Data we have; You have also right to modify your personal information through your account settings or in some specific cases you can write us an email. As mentioned before in this Policy you can opt-out of receiving promotional emails or marketing communications from us.PRIVAT don’t respond for “Don’t track me” signals that come from browsers.
12.- GRAMM-LEACH BLILEY ACT COMPLIENCE.
Your non-public information is safe with us, in compliance with the Gramm-Leach Bliley Act we implement safeguards to protect the confidentialityand integrity of the information we collect, because of this we
-Designated a Privacy officer responsible for overseeing how your personal information is threatening.
-Created controls and protocols to mitigate risks in personal data leaks.
-Trained our employees and personal about Personal data and security topics, Disclosure alteration and unauthorized access topics.
-Created a Physical and digital safeguard to protect your personal information from any person not related to PRIVAT or the treatment of your information.
13.- PRIVAT CONTACT INFORMATION
In order to execute any right that comes from this Privacy Policy you can contact us to the following email: support@privat.com
14.- CHANGES IN THIS POLICY.
As it is needed and requested by law, from time to time we may update this Privacy Policy if there’s additional information we need to collect or if the purposes have changed, we will notify you through email or through PRIVAT’s App; please check this Policy periodically for any changes.
15.- CALIFORNIA PRIVACY RIGHTS.
The following information will be only applied to California residents, as established in The California ConsumerPrivacy Act, as amended by the California Privacy Rights Act of 2020.This California Privacy Notice Supplements our Privacy Notice and applies solely to California Residents.
-Categories of Personal Information Collected.
In the last 12 months we have collected the following type of data, we do not collect all categories of personal information for each source; each one provides different type of personal information.
Type of Information
Information Collected
How it is collected
Information you give to us
Name, Address, SNN, Date of Birth, Email Address, phone number, copies of your identification documents, bylaws, certificates of incorporation; country of residence, tax residency, Tax Identification number; photo as required in some Know Your Customer Policies;
-When you open a PRIVAT account-When you fill any form.
-You responded any of our surveys
-Contacted us for any reason
-Used our customer Service
-Communicated with our Social Media department or through any social media.
-You responded any of our surveys
-Contacted us for any reason
-Used our customer Service
-Communicated with our Social Media department or through any social media.
Information collected by use of our Services
Technical information about your device and Internet Protocol; Login information, time zone, IMEI number, mobile operating system, downloads, errors, lengths of your visit in our app, transactions made with our Services, certain information stored in your device; your location
The regular use of our Service through a mobile device or a computer.
Information from others
Credit Record, information about late payments, information that help us to check your identity, information about your company or the company you are representing;
The Service itself involves certain communications with third party partners, payment networks, and financial institutions that may have your personal information.
- Purposes of Collection and Use.
We collect your Personal Information for the following but not limited purposes:
-Verify your Identity.
-Provide you with the Services
-Develop and Improve the Services.
-Comply with legal obligations.
-Create your account.
-Understand and study your spending behavior.
-Provide you with customer service.
-Create adverrtising campaings.
-Social media interaction.
-To create and deliver your cards.
-Prepare private data sets.
-Protecting your account against fraud.
-In case you agree, to provide you with our partner’s promotions.
The legal basis of the use of your personal information, comes from keeping contracts and agreements between you and the Company; legal obligations; Know your Customer Policies; anti money laundry obligations, legitimate interest, and consent (in some cases we are legally required to have your consent to send you information about productsand services).
-Share of personal information with Third Parties.
In order to bring to you our Services we may need to share your personal data with partners that help us to keep the Service working, payment processors, payment networks and Financial Institutions;We do not sell or have sold in the past 12 months any personal information to Third Parties.
- Your California Consumer Privacy Act Rights
a. Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which we obtained the information, the purposes for collecting it, and the categories of third parties with whom we share it.
b. Right to Delete: You have the right to request the deletion of your personal information that we have collected and retained, subject to certain exceptions.
c. Right to Opt-Out: You have the right to opt-out of the sale of your personal information if we engage in such activities.
d. Right to Non-Discrimination: We will not discriminate against you for exercising your California Consumer Privacy Act rights, including denying services, charging different prices, or providing a different quality of services.
- How to exercise your rights.
In order to exercise the rights that the California Consumer Privacy Act gives to you send us an email to support@privat.com; take into consideration that we may ask you for certain information in order to verify your identity.
- Children Personal Information
Our Services are not intended to be used by any person under the age of 18 years old, we don’t collect any personal information for any person under age of 18; if you know any children is using the Services send us an email.
END OF PRIVACYPOLICY.
We collect your Personal Information for the following but not limited purposes:
-Verify your Identity.
-Provide you with the Services
-Develop and Improve the Services.
-Comply with legal obligations.
-Create your account.
-Understand and study your spending behavior.
-Provide you with customer service.
-Create adverrtising campaings.
-Social media interaction.
-To create and deliver your cards.
-Prepare private data sets.
-Protecting your account against fraud.
-In case you agree, to provide you with our partner’s promotions.
The legal basis of the use of your personal information, comes from keeping contracts and agreements between you and the Company; legal obligations; Know your Customer Policies; anti money laundry obligations, legitimate interest, and consent (in some cases we are legally required to have your consent to send you information about productsand services).
-Share of personal information with Third Parties.
In order to bring to you our Services we may need to share your personal data with partners that help us to keep the Service working, payment processors, payment networks and Financial Institutions;We do not sell or have sold in the past 12 months any personal information to Third Parties.
- Your California Consumer Privacy Act Rights
a. Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which we obtained the information, the purposes for collecting it, and the categories of third parties with whom we share it.
b. Right to Delete: You have the right to request the deletion of your personal information that we have collected and retained, subject to certain exceptions.
c. Right to Opt-Out: You have the right to opt-out of the sale of your personal information if we engage in such activities.
d. Right to Non-Discrimination: We will not discriminate against you for exercising your California Consumer Privacy Act rights, including denying services, charging different prices, or providing a different quality of services.
- How to exercise your rights.
In order to exercise the rights that the California Consumer Privacy Act gives to you send us an email to support@privat.com; take into consideration that we may ask you for certain information in order to verify your identity.
- Children Personal Information
Our Services are not intended to be used by any person under the age of 18 years old, we don’t collect any personal information for any person under age of 18; if you know any children is using the Services send us an email.
END OF PRIVACYPOLICY.