Prontapay Ltd Privacy Policy

Last updated: 17^th May 2018

Prontapay LTD and its affiliates (hereinafter, "Prontapay", "we", "us" or "our") are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms and Conditions of Use) collects, uses, discloses and protects your information. We de?ne "Personal Information" as information which identi?es you personally, e.g. your name, address, e-mail address, trades etc.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some circumstances, we may provide you with additional notice, including, for example by sending you an email noti?cation. We strongly encourage you to review the Privacy Policy whenever you access or use Prontapay to stay informed about our information practices and your privacy rights and choices.

The purpose of this Privacy Policy is to inform you of:

1. The kinds of Personal Information which we may collect about you and how it may be used; 2. Our use of information regarding IP Addresses and our use of cookies; 3. Any disclosure of Personal Information to third parties; 4. Your ability to correct, update and delete your Personal Information; and 5. The security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control.

Gathering and Use of Personal Information We may collect your Personal Information if you use the Site, open an Account to use the Platform or perform any Transactions on the Platform. The types of Personal Information which we collect may include:

1. Your name, your date of birth, your mailing address, your telephone number, and email address;

We may use your Personal Information for the following purposes:

1. To allow you to open and operate an Account on the Platform; 2. To enable you to complete Transactions on the Platform; 3. If you contact us, to reply to your queries; 4. To analyse use of our Site; 5. As required for regulatory purposes; 6. To provide you with information about products and promotions that may be of interest to you, from ourselves and third parties, although only if you have speci?cally agreed to receive such information; 7. For market research e.g. surveying our Users' needs and opinions on issues, such as our performance etc. We will process your Personal Information only for the purpose(s) for which it has been provided to us.

Disclosure of Personal Information The transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks may not always be secure, and is subject to possible loss, interception, or alteration while in transit. Accordingly, Prontapay does not assume any liability, without limitation, for any loss or damage you may experience or costs you may incur because of any transmissions over the Internet or other publicly accessible networks, including but not limited to transmissions involving the Platform or e-mail with Prontapay containing your personal information. While Prontapay will take commercially reasonable efforts to safeguard the privacy of the information you provide to Prontapay and will treat such information in accordance with PRONTAPAY Privacy Policy, in no event will the information you provide to Prontapay be deemed to be con?dential, create any ?duciary obligations for Prontapay, or result in any liability for Prontapay in the event that such information is negligently released by Prontapay or accessed by third parties without PRONTAPAY consent.

LIMITATION OF LIABILITY We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, trusted service providers and contractors for these limited purposes. We may also share Users’ Personal Information with ?nancial institutions, insurance companies or other companies in the case of a merger, divestiture, or other corporate reorganisation. We may also share Users' Personal Information with law enforcement or regulatory agencies, as may be required by law. Any third party which receives or has access to Personal Information shall be required by us to protect such Personal Information and to use it only to carry out the services they are performing for you or for Prontapay, unless otherwise required or permitted by law.

We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

Privacy Policy Your privacy is important to us. We only share your information with third parties as outlined in our Privacy Policy or as required to do so by law enforcement, court order, or in compliance with identity veri?cation or legal reporting obligations in PRONTAPAY sole judgment.

Correction/Updating/ Deletion of Personal Information You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us at: [email protected]. You may also request the deletion or destruction of both the Account and Personal Information by sending an email to us at: [email protected]. However, please note that if you close your account, we may retain your information as required by law or for our legitimate business purposes, such as to collect fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or enforce our user agreements.

Security We have implemented security measures to ensure the con?dentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction. Only authorised personnel of Prontapay have access to your Personal Information, and these personnel are required to treat the information as con?dential. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Retention of Personal Information We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with our record keeping obligations we will retain Accounts and Personal Information for, at least a period of ?ve years after they are closed by Users.

Links There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third-party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

Marketing You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. You can exercise the right at any time by contacting us at [email protected]

Changes Our Site policies, content, information, promotions, disclosures, disclaimers and features may be revised, modi?ed, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Prontapay. If we change this Privacy Policy, will take steps to notify all users by a notice on our Site and will post the amended Privacy Policy on the Site.

Contact Us If you have any questions, comments, or concerns regarding our Privacy Policy please contact us at E-Mail: [email protected]