Updated February 2021

GENERAL

In this privacy policy (“Policy”), we describe:

  • the information that we collect and process about you (that you provide directly to us or is provided to us by third parties);
  • the purposes for which we collect and process information about you; and
  • the basis on which we collect and process information about you, when you use this website (our “Website”) and the services available through this Website, our mobile website, or our Mobile Application provided to our registered users (collectively, our “Services”).

In this Policy, the term “personal information” or “personal data” means personal information or data that relates to an identified or identifiable person.

We recommend that you read this policy carefully in order to understand what Payoneer Inc. and its subsidiaries, including Payoneer Europe Limited and Payoneer Australia Pty Ltd. (“we”, “us”, “Payoneer”) do with your personal information. Your use of our Website and Services and any dispute over privacy, is subject to this Policy and any of our applicable Terms and Conditions for use of our Services. Our Terms and Conditions for our Services are incorporated by reference into this Policy.

Important Notes:

  • SPECIFIC TERMS FOR EUROPEAN UNION (“EU”), UNITED KINGDOM (“UK”) AND EUROPEAN ECONOMIC AREA (“EEA”) CUSTOMERS ONLY: Please note that the whole of this Policy applies to you, together with additional provisions which are specific to EEA and UK customers, and can be found at Appendix 1.
  • SPECIFIC TERMS FOR AUSTRALIAN CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to Australian customers, and can be found at Appendix 2.
  • SPECIFIC TERMS FOR CUSTOMERS FROM THE STATE OF CALIFORNIA ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to residents of California, and can be found at Appendix 3.
  • SPECIFIC TERMS FOR BRAZILIAN CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to Brazilian customers, and can be found at Appendix 4.
  • SPECIFIC TERMS FOR CHINESE CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to Chinese customers (Mainland China) and can be found at Appendix 5.
  • SPECIFIC TERMS FOR HONG KONG CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to customers from the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong") and can be found at Appendix 6.
  • SPECIFIC TERMS FOR JAPANESE CUSTOMERS ONLY: Please note that the whole of this Policy applies to you together with additional provisions which are specific to Japanese customers of Payoneer Inc., and can be found at Appendix 7. Kindly note however that this Privacy Policy does not apply to our customers in Japan who have subscribed to a Payoneer Card. If you are a holder of a Payoneer Card in Japan please review your applicable Policy here. 

You may find a copy of this Privacy Policy in PDF format here. 

HOW, WHEN AND WHAT WE COLLECT?

How does Payoneer collect my personal information?

We collect personal information directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity, other Payoneer users and other Payoneer clients or customers for the purpose of providing the Payoneer Services to you or as part of a customer referral program, and automatically as you use our Website and the Services.  At this time, use of our Services through our Mobile Application is only available to users who register for our Services.

When does Payoneer collect my personal information?

  • When you apply for and use our Services, you contact us with questions, and you otherwise choose to provide personal information to us.
  • We receive personal information about you from banking references, credit reporting agencies, affiliates, other Payoneer users, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you.
  • We, and our third party service providers, automatically collect the following information about your use of our Website and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Website or use our Services, your activities on our Website, and the referring URL or the webpage that led you to our Website. If you are a registered user using our Mobile Application, we also may collect the following information about you: mobile device ID; device name and model; operating system type, name, and version; your activities within the Mobile Application, the length of time that you are logged into our Mobile Application, and, with your permission, your precise geo-location information. Please see our Cookies Policy for more information.
  • When you apply for a job with Payoneer.

What personal information does Payoneer collect?

The types of personal information we collect about you depends on your particular interaction with our Website and our Services, and includes, where permitted by applicable law:

Categories of Personal Information CollectedSpecific Personal InformationSource of Personal Information
IdentifiersName, email address, phone number, billing or mailing address, IP address, date of birth, national identification numbers and documents that may include your photograph.Directly from you, third parties on your behalf and as instructed by you, other Payoneer users and customers, our service providers and affiliates.
Financial InformationBank and credit account information, Credit history as applicable, Details of any transactions carried out using any of the ServicesDirectly from you, third parties on your behalf and as instructed by you, other Payoneer users and customers, our service providers and affiliates.
Internet or Other Simliar Network ActivityYour interaction with our website. Other information collected through Cookies and other tracking technologies as listed above and as described in our “Cookies PolicyFrom you directly and our third party analytic tools and cookies usage (See our “Cookies Policy” for more information).
Commercial InformationInformation about your businessDirectly from you, third parties on your behalf and as instructed by you, other Payoneer users and customers, our service providers and affiliates.
Geolocation DataGeolocationDirectly from you and/or through your use of the Mobile Application and/or our third party analytic tools and cookies usage (See our “Cookies Policy” for more information).
Professional or Employment Information (for Job Candidates)Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters and other information of the type included on a resume, curriculum vitae or cover letter.Directly from you or when another party, such as a recruiter or external website, provides it to us.
Other categories Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us).
Calls/emails/other correspondence.
Directly from you, third parties on your behalf and as instructed by you.
Special categories of Personal DataBiometric Data in the form of ‘selfies’ (self-photographs) processed for the purposes of identity verification when you become a customer.Directly from you, third parties on your behalf and as instructed by you, or from our service providers.

You are responsible for providing accurate and up-to-date information. If you choose to participate in our Refer a Friend program, you acknowledge that you have the right and are duly authorized to provide us with your friend’s personal information.

HOW AND WHY WE USE YOUR INFORMATION?

  • To validate your identity (including via SMS or Voice Call, as applicable).
  • To register you and provide our Services to you, to communicate with you about your use of our Services and KYC verification process (including via SMS or, for users of our Mobile Application, via “push” notifications) or any changes in our Terms and Conditions or this Policy that apply to you.
  • For the purpose for which you specifically provide the personal information to us, including, to respond to your inquiries, to provide any information that you request, and to provide customer support (including via SMS, as applicable).
  • To tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), personalized help and instructions, and to otherwise personalize your experiences while using our Website and our Services, such as developing and offering you with new and/or additional Payoneer services to the services we are providing you or new and/or additional features to existing Payoneer services, based, where appropriate, on your eligibility for such new and/or additional Payoneer services or features, as would be evaluated by us from time to time.
  • For marketing and promotional purposes, for example, we may use your personal information, such as your email address, phone number (including via SMS, as applicable), or mailing address to send you newsletters, special offers and promotions, or to otherwise contact you about services or information we think may interest you (unless you are opted-out from our marketing communications), or to conduct draws for campaigns and the like and deliver prizes and rewards.
  • As permitted by applicable law, to assist us in advertising our products and services in various mediums including, without limitation, sending you promotional emails, advertising our services on third party sites and social media platforms, sending you direct mail, and by telemarketing (unless you are opted-out from our marketing communications).
  • To better understand how users, access and use our Website and our Services, both on an aggregated and individualized basis, to administer, monitor, and improve our Website and Services, for our internal purposes, and for other research and analytical purposes. Please see our Cookies Policy for more information.
  • To protect us, our customers, employees, partners or property — for instance, to investigate fraud and prevent fraudulent activity, abuse of the Services, harassment or other types of unlawful activities involving us or other companies that we do business with, to enforce this Policy, as well as our Terms and Conditions.
  • We process personal data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as evaluating a job candidate for a position with us and communicating with you regarding your application and future opportunities.

WHEN DO WE SHARE YOUR INFORMATION?

We share your personal information with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners as set out in the table below. In the table below, we also list the reasons why we share information.

How and Why We Share Your InformationDoes Payoneer Share?
With our service providers and affiliates – for our business purposes, such as to assist us with the provision of the Services and to verify your identity, prevent, detect and protect against fraudulent activity or abuse of the Services, conduct internal research and analytical assessments, process your transactions, maintain your account(s) and provide you with customer care services. These include internet service providers, data and cyber security services, banks, financial institutions, payment processors, financial services providers, remote access services; service providers that help us verify your identity and help us comply with our legal and regulatory obligations; and our business, legal, tax, financial and other advisors, on a confidential basis. Such service providers may differ based on the services provided to you and your jurisdiction.Yes
With fraud prevention and detection service providers – which provide fraud prevention, detection, protection services, or other similar services, on our, or our service provider’s, behalf. Such service providers may keep records of information provided and use it when providing fraud detection and prevention services to other users of their databases.Yes
For marketing purposes:
1. With our service providers and our affiliates – to market our own products and services; and
2. With non-affiliated third parties for joint marketing purposes.
Yes*
With other Payoneer clients, customers or third parties using our Services - to perform the Services, assist in carrying out your transactions with such clients, customers or third parties or for purposes of our refer-a-friend program(s). In addition, where a Payoneer card is issued to you as an expense card under a Corporate Client expense card program (in accordance with our Terms and Conditions) - we may share information related to usage and balance of the card with such client.Yes
In response to legal process – to comply with the law, a judicial proceeding, subpoena, court order, or other legal process.Yes
In connection with business transfers – to another entity if we are acquired by or merged with such other entity, if substantially all of our assets are transferred to such other entity, or as part of a bankruptcy proceeding.Yes
To protect the rights, property, or safety of us and others – we may disclose personal information to our business partners, service providers and other third parties when we believe it is necessary or appropriate. This includes exchanging and/or jointly using information with other companies, businesses and organizations when you use our Services in connection with such third parties’ or their affiliates’ services, for the purpose of us and/or them investigating, preventing, or taking actions regarding suspicious or high risk transactions, illegal activities, suspected fraud or fraudulent operations connected to such other entities’ businesses and/or our Services, situations involving potential threats to the safety of any person, violations of our or their Terms and Conditions or this Policy, or as evidence in or otherwise connected to litigation in which we or they are involved.Yes
Aggregated and de-identified information – we may disclose aggregate or de-identified information about users for marketing, advertising, research, or similar purposes.Yes
With consumer reporting agencies, as permitted by law, with respect to users from the United States.Yes
As a participant in Amazon’s Payment Service Provider Program, designed to enhance its ability to detect, prevent and take action against bad actors so Amazon and participating PSPs can continue to protect customers and sellers from fraud and abuse, if your Payoneer account is registered with Amazon, we would share with them certain data collected during the account sign-up process and as you use our Services. This may include, as applicable, “Know Your Client” data such as identity data (e.g. name, nationality), contact information (e.g. address) and details regarding your accounts with Payoneer and your bank account(s). If your Amazon account is deactivated or terminated by Amazon due to abuse, fraud or illegal activity, we may share additional information, including limited transaction related information. Please see Amazon’s PSPP Policy Help page for important details here.Yes

If you do not want us to use your details for marketing purposes, and/or to pass your details on to third parties for joint marketing purposes, please contact us through the various communication channels available, as listed under the Section titled “CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT” below. You will also be able to unsubscribe from any marketing emails sent to you by Payoneer using a link provided in such emails.

We do not sell your personal information.

WHERE WE STORE YOUR DATA?

All information you provide to us is stored on our secure servers or our third-party cloud service providers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent un-authorized access. 

CHANGES TO OUR PRIVACY POLICY

We keep this Policy under regular review and may update it from time to time. You will be notified of changes to this Policy via the posting of an updated version on our Website and, where appropriate, via email and/or message to “My Account”.  Changes will take effect upon the date on which an updated Policy is posted on our Website. We recommend that you regularly check for updates or changes to our Policy and that you review this Policy when visiting our Website. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention.

CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT

If you are a Payoneer Services customer and would like to update your personal information, please log into your “My Account” in order to update certain information or contact us through the contact information below. If you are not a Payoneer Services customer, but have provided us with personal information or if your personal information was provided to us by third parties, and you would like to update your personal information, you may contact us through the phone number or email address listed below. From time to time, we may email you or send you with special offers; you may opt-out of those offers by using either the Notification Settings page in “My Account”, the unsubscribe link provided in the email, or by contacting us as noted below.

Payoneer Customer Care:

Payoneer Inc.

150 West 30th Street, Suite 600,

New York, NY, 10001

Phone: 1-800-251-2521 (within the USA) or 1-646-658-3695 (outside the USA)

Email: Email us

Web: www.payoneer.com

 

For EEA and UK Customers:

Payoneer Europe Limited

6th floor, 2 Grand Canal Square

Dublin 2, D02 A342, Ireland

Email: Email us

Web: www.payoneer.com

 

For Australian Customers:

Payoneer Australia Pty Ltd

c/ MAZARS (NSW) PTY LIMITED L 12 90 Arthur Street North Sydney NSW 2060 Australia

Email: Email us

Web: www.payoneer.com/au/

Privacy Matters:

  • For requests related to your personal data, you can contact us at any time by using this online form.
  • For additional queries related to privacy and personal data you can also contact our Data Protection Officer at DPO@payoneer.com.

GOVERNING LAW & JURISDICTION

This Policy shall be exclusively governed by and interpreted in accordance with the laws of the State of Delaware, and any dispute hereunder shall be brought exclusively in the courts of the State of Delaware except where prohibited by US law.

Notwithstanding the above, for our Australian customers only, this Policy shall be governed by and interpreted in accordance with the laws of Victoria, Australia, and any dispute hereunder shall be brought exclusively in the courts of Victoria.

DATA RETENTION

We retain your personal data for at least such period required in order to meet our obligations under applicable laws or regulations and, to the extent not prohibited under applicable law, such additional period in accordance with our internal policies and procedures for purposes of prevention of fraudulent activities, risk management and security.

DISCLAIMER

Any and all content provided on this Website or the Services, including links to other websites is provided for information purposes only and does not constitute advice, recommendation or support of such content or website. Payoneer makes every effort to provide true and accurate content on its Website. However, Payoneer provides no warranty, express or implied, of the accuracy, completeness, timeliness, or applicability of such content. Payoneer accepts no responsibility for and excludes all liability in connection with information provided on the Payoneer website, including but not limited to any liability for errors, inaccuracies or omissions.

APPENDIX 1: ADDITIONAL TERMS FOR EEA AND UK CUSTOMERS

The information below is required pursuant to EEA law regarding privacy and data protection. The terms below apply to our EEA and UK customers and Website visitors, in addition to the terms in the rest of the Policy.

For the purposes of the General Data Protection Regulation (“GDPR”), the data controller is Payoneer Europe Limited of 6th floor, 2 Grand Canal Square Dublin 2, D02 A342 Ireland, a company established in Ireland and regulated for data protection purposes by the Data Protection Commission. If you have any questions about this Policy, please contact our Data Protection Officer (DPO) at DPO@payoneer.com.

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the Irish Data Protection Commission (DPC) or your local supervisory authority.  You can find more details about how to contact the DPC on their website.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

The table headed “How and Why We Share Your Information” in the main part of the Policy under the heading WHEN DO WE SHARE YOUR INFORMATION? lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our Services.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside the EEA or the UK, as applicable.

Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. Payoneer will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

  • assessing the security measures taken at any place your personal data is transferred to;
  • having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions;
  • having monitoring, reporting and resolution procedures in place with regard to ongoing security; and
  • only transferring your data via an appropriate safeguard as described in Article 46 of GDPR, including:
  • Standard Contractual Clauses adopted by the European Commission (Article 46.2)

Please contact us at DPO@payoneer.com. if you require more detailed information about international transfers of your personal information, and the particular safeguards used.

LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We process your personal information based on the following legal bases, as recognised by and in compliance with the applicable data protection laws:

  • the processing is necessary to perform our contract with you (i.e. the Terms and Conditions that apply as applicable with respect to Payoneer Services, for the provision of our Services), or to take steps requested by you before entering into said contract;
    • you are obliged to provide us with personal data as it is necessary to enter into and perform our contractual agreements. In the event that you do not wish to provide us with your personal data for the purposes outlined above in the "How and why we use your information?" section, we will not be able to perform our contractual agreement with you;
  • the processing is in Payoneer's or someone else's legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data. This may include processing your data for identification or prevention of suspicious or high risk transactions or fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;
    • before we process your personal data to pursue our legitimate interests for the purposes outlined above in the "How and why we use your information?" section, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.
  • you have given your consent to the processing of your data;
  • the processing is necessary to meet a legal obligation which applies to Payoneer.

Sometimes we process data about you which the law considers to fall within special categories (see section "HOW, WHEN AND WHAT WE COLLECT?" for more details), in which case, we use one of the following grounds:

  • the processing is necessary for the establishment, exercise or defence of legal claims;
  • you have freely given your informed, specific consent to the processing; or
  • the processing is necessary for reasons of substantial public interest, based on applicable law.

If you would like more information about the legal grounds used to process your information, or about the legitimate interests referred to above, please contact us.

In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time.  You can do this by contacting our DPO at DPO@payoneer.com.

DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?

In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our Services. For example, we need details such as your name, address and bank account details so that we can make payments to you and receive payments from you. In other cases, you have a choice over whether we collect your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our Website).

PROFILING AND AUTOMATED DECISION MAKING

We use automated decision making as part of our process to evaluate eligibility for the use of the Payoneer Services. We use these tools as a measure of fraud prevention and for the purposes of security and risk assessment relating to the performance of the Payoneer Services, and to verify your identity when you become a customer:

  • Automated tools incorporated in our process of approval of your registration application: based on the information you provide, the tool may advise if additional information is required for purpose of approval of your application.
  • Automated tools incorporated in our process of approval of certain payment transaction of registered users: such tools may advise if additional information is required for purpose of performance of the payment transaction.
  • Automated tools used to verify your identity to enable us to comply with “Know Your Customer” (KYC) rules applicable to us as a financial services provider: we carry out this process using selfies (self-photographs) and other forms of ID when you register to open an account with us.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Payoneer retains your personal data for the duration of your engagement with us and for a period following termination of your engagement with us, as required by applicable laws or regulations and/or in accordance with Payoneer’s internal policies and procedures for purposes of prevention of fraudulent activity, risk management and security. Payoneer will periodically review the necessity of retention of your personal data.

YOUR RIGHTS UNDER GDPR

You have several rights in relation to your personal data which are described in more detail below.  You can exercise your rights at any time by using this online form.

Accessing your data

You can ask us to:

  • Confirm whether we are processing your personal data.
  • Give you a copy of that personal data.
  • Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it outside of the EEA and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling.  We aim to give you all this information in this Policy, although if anything is unclear, please contact our Data Protection Officer at DPO@payoneer.com.

You do not have to pay a fee for a copy of your personal information unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances.  We will let you know of any charges before completing your request.

Correcting your personal data

You can ask us to correct any personal data which is inaccurate or incomplete.  This is free of charge.

If we have shared the personal data with anyone else, we will tell them about the correction wherever possible.

If we cannot action a request to correct your personal data, we will let you know and explain why this is.

Erasing your personal data

This right is sometimes referred to as "the right to be forgotten".  This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.

You can ask for your personal data to be erased where:

  • it is no longer necessary for the purpose for which it was originally collected or processed;
  • we are processing your personal data based on your consent, and you withdraw that consent;
  • you object to the processing and we do not have an overriding legitimate interest for continuing;
  • your personal data has been unlawfully processed;
  • your personal data must be erased to comply with a legal obligation;
  • the personal data was processed to offer information society services to a child.

There are some exceptions to this right.  If one of these applies, we do not have to delete the personal data.

If we have shared your personal data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.

Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.

Restricting the processing of your personal data

You can ask us to restrict the processing of your personal data in some circumstances, free of charge.  This is not an absolute right.  If processing is restricted we can store the personal data and retain enough information to make sure the restriction is respected unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or for reasons of important public interest, but we cannot further process your personal data.

You can restrict the processing of your personal data in the following cases:

  • if you contest the accuracy of your personal data, we will restrict processing until we have made sure the personal data is accurate;
  • if you object to our processing pending the verification of whether or not our legitimate interests override your interests, rights and freedoms or in connection with legal proceedings;
  • if the processing is unlawful but you do not want us to erase your personal data;
  • if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort.  We will tell you if we decide to lift a restriction on processing your personal data.

Objecting to the processing of your personal data

You have a right to object to the processing of your personal data at any time. This request will befree of charge.  It is not an absolute right, but you can object to our processing of your personal data where it is:

  • based on the legitimate interest ground; or
  • for the purposes of scientific/historical research and statistics.

We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the personal data for the establishment, exercise or defence of legal claims.

You can require us to stop using your personal data for direct marketing purposes.  We will stop as soon as we receive your request.  There are no exemptions or reasons for us to refuse.

Data Portability

This allows you to obtain and reuse your personal data for your own purposes across different services.  It applies where the following conditions are met:

  • you provided the personal data to us yourself;
  • we are processing the personal data either based on your consent or because it is necessary for the performance of a contract; and
  • the processing is carried out by automated means.

We will provide your personal data free of charge in a structured, commonly used and machine-readable form.

Automated decision making and profiling

You have the right not to be subject to a decision which is based solely on automated processing and which produces a legal (or similarly significant) effect on you.

We will tell you about any automated decision making that affects you.  You have the right to:

  • request human intervention;
  • express your point of view;
  • ask for the decision to be explained; and
  • challenge the decision.

These rights are not absolute. We may not be able to comply with this request if the processing of personal data is:

  • necessary for us to enter into or perform a contract with you;
  • authorised by law (e.g. for fraud prevention) and which also lays down suitable measures to safeguard your right, freedoms and legitimate interests; or
  • based on your explicit consent.

Dealing with requests to exercise your rights

We will respond to your request without undue delay at the latest within one (1) month of receiving your request unless it is particularly complicated or you have made several requests, in which case we may extend this by two (2) months.  We will let you know if we are going to take longer than one (1) month in dealing with your request.  If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive.  This will help us action your request more quickly.

For the purpose of complying with your requests to exercise the rights listed above, we shall perform the necessary internal processes to identify you.

APPENDIX 2: ADDITIONAL TERMS FOR AUSTRALIAN CUSTOMERS

We are bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other laws that govern the handling of personal information. The terms below apply to Australian customers in addition to the terms in the rest of the Policy.

We may also disclose such information as required or permitted by any law, for example to meet our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth).

You may request to access or correct any personal information we hold about you. We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information, and you disagree, you may ask us to make a note of your requested correction with the information.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside Australia including but not limited to the United States of America.

Please note that where data is transferred outside of Australia, other countries may not offer the same level of protection for personal data as is available in Australia under the Privacy Act 1988 (Cth). Nonetheless, Payoneer will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

  • assessing the security measures taken at any place your data is transferred to;
  • having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions; and
  • having monitoring, reporting and resolution procedures in place with regard to ongoing security.

We may also collect, hold, use and disclose certain credit-related personal information about you which may include:

  • permitted identification information e.g. names, date of birth, sex, 3 most recent addresses, employer and driver's licence number;
  • your applications for credit - the fact that you have applied for credit and the amount and type of credit;
  • the identity of your current and previous credit providers;
  • records of previous requests made by credit providers to credit reporting bodies (“CRBs”) for information about you in connection with consumer or commercial credit applications, guarantees and securitisation arrangements;
  • information about defaults (where repayments are more than 60 days overdue, in certain circumstances);
  • where those default repayments are no longer overdue, or new payment arrangements have been agreed;
  • a credit provider’s opinion that you have committed a serious credit infringement (that is, acted fraudulently or shown an intention not to comply with your credit obligations);
  • the start and end dates, credit limits and certain terms and conditions of your credit arrangements;
  • information about court judgments against you;
  • publicly available information relevant to your credit worthiness;
  • certain insolvency information from the National Personal Insolvency Index;
  • information derived by CRBs from the above information (e.g. assessments and ratings in respect of your credit worthiness); and
  • information we derive from the above information (e.g. our own assessments and ratings in respect of your credit worthiness), (“credit-related personal information”).

This may also include information about your arrangements with other credit providers as well as with us.

We may disclose some of these types of information to CRBs. CRBs may use credit-related personal information to maintain records on individuals which they may share with other credit providers for those providers’ own credit assessments.

We will notify you of the CRBs that we use.

We may also be required to check the validity of your identification documents with the Australia Document Verification Service (DVS).

Where you express any concerns that we have interfered with your privacy or conducted ourselves inconsistently with this Policy, we will respond to let you know who will be handling your matter and when you can expect a further response. We aim to resolve your concerns in a fair and efficient manner within 30 days.

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner (OAIC). You can find more details about how to contact the OAIC in writing as set out below:

Website:          https://www.oaic.gov.au/

Address:         GPO Box 5218 Sydney NSW 2001

Fax:                  +61 2 9284 9666

Email:             enquiries@oaic.gov.au

APPENDIX 3: ADDITIONAL TERMS FOR STATE OF CALIFORNIA CUSTOMERS

The information below is required pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”). The terms below apply to residents in the State of California in addition to the terms in the rest of the Policy.

CCPA REQUESTS

Under the CCPA residents in the State of California are provided with specific rights regarding the collection and storage of their personal information.

You or your authorized agent may apply to us with requests as detailed below by contacting us though phone:  1-800-251-2521 (within the USA) or though the online form on our Website.  We do not discriminate against any individual based on the exercise of his/her privacy rights.

CCPA Information Request Rights

You have the right to request that we provide to you the following information about our collection and use of your personal information over the preceding twelve (12) months. Once your verifiable consumer request has been confirmed through our review of the information you provide in your request, we will disclose to you:

1.      The categories of personal information we have collected about you.

2.      The categories of sources for the personal information we have collected about you (e.g., use of cookies, third party, etc.).

3.      Our business or commercial purpose for collecting that personal information.

4.      The categories of third parties with whom we share or have shared that personal information.

5.      The specific pieces of personal information we collected about you (also called a data portability request).

6.      We do not sell your personal information. In addition, if we have not disclosed your personal information for a business purpose, we will disclose this fact to you.  If we have disclosed your personal information for a business purpose, including direct marketing, we will provide you with a listing that identifies the personal information categories that each category of recipient obtained.

CCPA Deletion Request Rights

You have the right to request that we delete any of the Personal Information collected from you and retained, subject to certain exceptions and your verification. Your request to delete the Personal Information collected may be denied if it is necessary for us to retain your information under one or more exceptions listed in the CCPA.

WE DO NOT SELL YOUR PERSONAL INFORMATION

We do not sell personal information collected about you to third parties. We may share your personal information with our service providers or as instructed by you from time to time for purpose of providing you the Services and as detailed above under the section titled “WHEN DO WE SHARE YOUR INFORMATION?”.

CCPA SPECIFIC CATEGORIES OF PERSONAL INFORMATION COLLECTED

In addition to the Categories of Personal Information Collected specified in the table under the section titled “HOW, WHEN AND WHAT WE COLLECT?”, to the extent we receive from you an identification document with your photo see additional disclosure below:

Categories of Personal Information CollectedSpecific Personal InformationSource of Personal Information
Biometric InformationPhotograph incorporated in your photo IDDirectly from you, third parties on your behalf, as instructed by you.

APPENDIX 4: ADDITIONAL TERMS FOR BRAZILIAN CUSTOMERS

The information below is required pursuant to the Brazilian General Law on Data Protection (“LGPD”) regarding privacy and data protection. The terms below apply to our Brazilian customers and Website visitors, in addition to the terms in the rest of the Policy.

WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

The table headed “How and Why We Share Your Information” in the main part of the Policy under the heading “WHEN DO WE SHARE YOUR INFORMATION?” lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our Services.

You should be aware that when sharing your information, it may be transferred to, and stored at, a destination outside Brazil.

Please note that where data is transferred outside Brazil, such third countries may not offer the same level of protection for personal data as provided in LGPD. Payoneer will take various measures to ensure that your data is treated securely.

Please contact us at DPO@payoneer.com if you require more detailed information about international transfers of your personal information, and the particular safeguards used.

LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA

We process your personal information based on the following legal bases, as recognised by and in compliance with LGPD:

  • the processing is necessary to perform our contract with you (i.e. the Terms and Conditions that apply as applicable with respect to Payoneer Services, for the provision of our Services), or to take steps requested by you before entering into said contract;
    • you are obliged to provide us with personal data as it is necessary to enter into and perform our contractual agreements. In the event that you do not wish to provide us with your personal data for the purposes outlined above in the "How and why we use your information?" section, we will not be able to perform our contractual agreement with you;
  • the processing is in Payoneer's or someone else's legitimate interests, and these interests are not overridden by your fundamental rights and freedoms in the protection of your personal data. This may include processing your data for prevention of fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;
    • before we process your personal data to pursue our legitimate interests for the purposes outlined above in the "How and why we use your information?" section, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.
  • you have given your consent to the processing of your data;
  • the processing is necessary to meet a legal obligation which applies to Payoneer.

Sometimes we process data about you which the law considers sensitive data (see section "HOW, WHEN AND WHAT WE COLLECT?" for more details), in which case, we use one of the following grounds:

  • the processing is necessary for the establishment, exercise or defence of legal claims;
  • you have freely given your informed, specific consent to the processing; or
  • the processing is necessary for reasons of substantial public interest, based on applicable law.

If you would like more information about the legal grounds used to process your information, or about the legitimate interests referred to above, please contact us.

In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time. You can do this by contacting our DPO at DPO@payoneer.com.

DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?

In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our Services. For example, we need details such as your name, address and bank account details so that we can make payments to your account. In other cases, you have a choice over whether we collect your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our Website) – for additional details regarding cookies and cookie preferences kindly refer to the “Our Cookies Policy”.

PROFILING AND AUTOMATED DECISION MAKING

We use automated decision making as part of our process to evaluate eligibility for the use of the Payoneer Services. We use these tools as a measure of fraud prevention and for the purposes of security and risk assessment relating to the performance of the Payoneer Services, and to verify your identity when you become a customer:

  • Automated tools incorporated in our process of approval of your registration application: based on the information you provide, the tool may advise if additional information is required for purpose of approval of your application.
  • Automated tools incorporated in our process of approval of certain payment transaction of registered users: such tools may advise if additional information is required for purpose of performance of the payment transaction.
  • Automated tools used to verify your identity to enable us to comply with “Know Your Customer” (KYC) rules applicable to us as a financial services provider: we carry out this process using selfies (self-photographs) and other forms of ID when you register to open an account with us.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Payoneer retains your personal data for the duration of your engagement with us and for a period following termination of your engagement with us, as required or permitted by applicable laws or regulations and/or in accordance with Payoneer’s internal policies and procedures for purposes of prevention of fraudulent activity, risk management and security. Payoneer will periodically review the necessity of retention of your personal data.

YOUR RIGHTS UNDER LGPD

You have several rights in relation to your personal data which are described in more detail below.  You can exercise your rights at any time by using this online form.

Confirming and accessing your data

You can ask us to:

  • Confirm whether we are processing your personal data.
  • Give you a copy of that personal data.

You do not have to pay a fee for a copy of your personal data unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances.  We will let you know of any charges before completing your request.

Rectifying your personal data

You can ask us to correct any personal data which is incomplete, inaccurate or out-of-date.  This is free of charge. If we have shared the personal data with anyone else, we will tell them about the correction wherever possible. If we cannot action a request to correct your personal data, we will let you know and explain why this is.

Anonymizing, blocking and erasing your personal data

Subject to the retention provisions above, you may request anonymization, blocking or erasure of unnecessary or excessive personal data, or personal data processed in non-compliance with the provisions of the LGPD. If we have shared the personal data with anyone else, we will tell them about the anonymization, blocking or erasure wherever possible. If we cannot action a request to anonymize, block or erase your personal data, we will let you know and explain why this is.

Erasing your personal data processed on the basis of your consent

Subject to the retention provisions above, you can ask us to delete your personal data where it is being processed based on your consent. This right does not arise to the extent that we use another legal basis for processing, such as where processing is necessary for compliance with a legal or regulatory obligation. If we have shared the personal data with anyone else, we will tell them about the erasure wherever possible.

Information about shared use of your personal data

This allows you to obtain information about the entities and third parties with which we have shared your personal data. This right is not absolute. We may not be able to comply with this request if the shared use of personal data is related to an investigation or a processing activity subject to a secrecy obligation.

Information about not giving your consent

You have the right to be informed about the possibility of denying your consent and the consequences of such denial.

As mentioned under the heading “DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?” above, in most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our Services.

Withdrawing your consent

Where we are processing your personal data based on your consent, you may withdraw it at any time.  If we have shared the personal data with anyone else, we will tell them about the withdrawal of your consent wherever possible.

Objecting to the processing of your personal data

You have a right to object to the processing of your personal data at any time. This request will be free of charge.  It is not an absolute right, but you can object to our processing of your personal data where you believe it is in breach with LGPD provisions. You can require us to stop using your personal data for direct marketing purposes. We will stop as soon as we receive your request. There are no exemptions or reasons for us to refuse.

Data Portability

This allows you to obtain and reuse your personal data for your own purposes across different services, subject to the protection of our commercial or industrial secrets.  It applies where the following conditions are met:

  • you provided the personal data to us yourself;
  • we are processing the personal data either based on your consent or because it is necessary for the performance of a contract; and
  • the processing is carried out by automated means.

We will provide your personal data free of charge in a structured, commonly used and machine-readable form.

Revision of automated decision making

You have the right to request the revision of any decisions that we have taken solely based on automated processing of your personal data.

This right is not absolute. We may not be able to comply with this request if the processing of personal data is:

  • necessary for us to enter into or perform a contract with you;
  • authorised by law (e.g. for fraud prevention) and which also lays down suitable measures to safeguard your right, freedoms and legitimate interests; or
  • based on your explicit consent.

Dealing with requests to exercise your rights

We will respond to your request without undue delay at the term provided by LGPD, ANPD’s guidelines or specific regulations.  We will let you know if we are going to take longer than the required term in dealing with your request.  If we have a lot of information about you, we might ask you if you can tell us what exactly you want to receive.  This will help us action your request more quickly.

For the purpose of complying with your requests to exercise the rights listed above, we shall perform the necessary internal processes to identify you.

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to ANPD.

APPENDIX 5: ADDITIONAL TERMS FOR CUSTOMERS FROM MAINLAND CHINA

The information below is required pursuant to the Cybersecurity Law as well as other applicable laws and regulations regarding privacy and data protection in People’s Republic of China, which for the purpose of this Policy, shall exclude Hong Kong, Macaw and Taiwan (“China”). The terms below apply to our Chinese customers and Website visitors in Mainland China, in addition to the terms in the rest of the Policy.

WHEN DO WE SHARE YOUR INFORMATION?

By your continued use of our Services and subject to applicable law, you expressly consent to and direct Payoneer to share necessary information with any and all of third parties listed under the “WHEN DO WE SHARE YOUR INFORMATION?” section of this Policy, which could be located outside China and to store your information outside China. Such sharing includes, for the avoidance of doubt, sharing with third parties, such as the merchants, e-commerce platform and their service providers, in order to facilitate transactions and to assist and support such other parties’ detection and prevention of fraud, fraudulent and other illegal activities and of activities which are in breach of such other parties’ code of conduct and/or terms of use. We will make efforts to protect your information as described in this Policy when sharing of your information.

APPENDIX 6: ADDITIONAL TERMS FOR HONG KONG CUSTOMERS

The information below is required pursuant to Hong Kong law regarding privacy and data protection. The terms below apply to our Hong Kong customers and Website visitors, in addition to the terms in the rest of the Policy.

HOW, WHEN AND WHAT WE COLLECT?

The provision of your personal information to us in accordance with the Policy is voluntary. However, if you do not provide us with the information requested, we may not be able to deliver the Services to you, or the delivery of the Services may be affected.

HOW AND WHY WE USE YOUR INFORMATION?

The section "How and why we use your information?" in the main part of the Policy lists uses of personal information that include direct marketing. We comply with the direct marketing requirements of the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”).

If we intend to use your personal data (i.e. your name and contact information) for marketing purposes, we must first obtain your express consent. If we intend to disclose such information to any third party for marketing purposes, we must first obtain your written consent.

You can exercise your right to prevent such use or transfer of personal data for direct marketing by checking certain boxes when we ask you whether you object to our using or transferring your personal data in this way. If you consent to such use or transfer, you may also exercise the right to withdraw your consent at any time by contacting us through the various communication channels available, as listed under the section titled “CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT” in the main part of the Policy, or by unsubscribing from any marketing emails sent to you by Payoneer using a link provided in the email.

The third item in the table headed “How and Why We Share Your Information” in the main part of the Policy under the heading “WHEN DO WE SHARE YOUR INFORMATION?” lists whom we may share your personal data with for marketing purposes (with your consent). To elaborate, we may share your personal data with the following third parties for marketing purposes:

  1. With our affiliates;
  2. With our service providers; and
  3. non-affiliated third parties (such as other financial institutions and platforms) for joint marketing purposes.

We and the listed third parties may send you marketing information with respect to any of our products and services, including such which are in provided in collaboration with said third parties.

YOUR RIGHTS UNDER THE PDPO

The PDPO gives you the right to access and to be supplied with a copy of personal data held about you and the right to rectify that personal data if it is inaccurate. 

You can exercise your rights at any time through the various communication channels available, as listed under the section titled  “CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT.

APPENDIX 7: ADDITIONAL TERMS FOR JAPANESE CUSTOMERS

When using our payment services on Amazon, we will jointly use the categories of personal data listed under (i) below with Amazon for the purposes listed under (ii) below in accordance with Article 23.5.3 of Act on Protection of Personal Information. Each of us and Amazon will be responsible for the management of the jointly used personal Data held thereby. 

(i) Categories of Personal Data Jointly Used 

We may share all or part of the details collected during the account sign-up process and when you use your account as below. 

  • “Know Your Client” data and other which includes identity data (e.g. name, nationality), contact information (e.g. address) and details regarding your Payoneer accounts and bank accounts. 
  • If your Amazon account is deactivated or terminated by Amazon due to abuse, fraud or illegal activity, we may share additional information, including limited transaction related information. 


(ii) Purposes of the Joint Use
 

The data will be used for the purposes of Amazon’s Payment Service Provider Program, designed to enhance its ability to detect, prevent and take action against bad actors so Amazon and participating PSPs can continue to protect customers and sellers from fraud and abuse.