POLÍTICA DE PRIVACIDADE PAYJOY

Introdução

A privacidade dos indivíduos, incluindo nossos parceiros e clientes, é de extrema importância para PayJoy do Brasil Ltda. (a “Empresa”). Estamos empenhados em cumprir os regulamentos de privacidade que regem os cidadãos aos quais fornecemos produtos e serviços.

Esta Política visa estabelecer em termos claros os tipos de Informações coletadas, a finalidade da coleta, a fonte das Informações, as entidades com as quais tais Informações podem ser compartilhadas, os direitos do titular dos dados e também as práticas e procedimentos de segurança adotados pela a Empresa no manuseio de tais Informações.

Tipo de Informação coletada

A fim de fornecer os Serviços, a Empresa pode coletar e processar as seguintes categorias de Informações:

Informações sobre você, incluindo, mas não se limitando a:

(i) Dados de identificação: nome, identidade, e-mail, número de telefone, sua fotografia.

(ii) Relatórios de crédito, listas de sanções e serviços de validação para garantir a validade e qualidade dos dados de identificação que recebemos.

(iii) Dados de mídia social: dados fornecidos em suas contas de mídia social, incluindo foto, lista de amigos e nome.

(iv) Cópias de Documentos: incluindo RG e/ou CNH.

(v) Informações de pagamento: informações sobre os pagamentos devidos e realizados por você à PayJoy.

(vi) Atendimento ao cliente: informações que você nos fornece relacionadas aos Serviços, incluindo quando você se comunica conosco, por qualquer meio, para fins de suporte e atendimento ao cliente.

Informações a respeito de seu smartphone
Incluindo, mas não limitado a informações sobre o aparelho, o sistema operacional, identificador de aparelho, informações do cartão SIM, lista de aplicativos, estado da conexão à internet, estado do aplicativo, etc.

Se o aparelho for comprado, alugado ou arrendado via PayJoy então nós coletaremos e trataremos informações relacionadas a essa transação, como a loja onde a transação ocorreu, valor da transação, etc.

Informações sobre sua comunicação
Mediante consentimento, podemos coletar e processar informações de seu aparelho móvel relacionadas, mas não limitadas a registros de chamadas e SMS (mensagens de texto). Antes de fazer isso, entraremos em contato com você e solicitaremos seu consentimento específico.

Cookies
A Empresa usa cookies para garantir o funcionamento adequado do seu website e para fornecer uma experiência de serviços online individualizada. Você tem a capacidade de aceitar ou recusar cookies. A maioria dos navegadores oferece a opção de modificar as configurações do navegador para recusar alguns ou todos os cookies.

Observe que, de acordo com a lei, algumas das informações acima são consideradas dados confidenciais. A Empresa garante o cumprimento dos requisitos legais exigidos na legislação para o tratamento de dados sensíveis.

Retenção de Informações
A Empresa reterá e usará as Informações pelo período necessário para (i) atender às finalidades descritas nesta Política; (ii) cumprir as obrigações legais ou regulamentares aplicáveis a nós; ou (iii) exercer seus direitos em processos judiciais, administrativos ou arbitrais, inclusive para instrução de tais processos

Finalidades do Tratamento

A Empresa irá, ou poderá coletar e tratar as Informações para os seguintes fins:

1. Autenticar sua identidade e avaliar o risco de crédito envolvido nos Serviços.
2. Prevenção a fraudes, para garantir maior segurança.
3. Contatá-lo por qualquer meio disponível, incluindo meios eletrônicos, correio ou telefone (SMS e outros), sobre questões relacionadas aos Serviços enquanto mantivermos relacionamento comercial com você. Isso inclui notificar você sobre mudanças na plataforma e / ou nos Serviços. Também podemos entrar em contato com você para oferecer ou fornecer informações sobre produtos ou serviços que possam ser do seu interesse.
4. Gerenciar suas obrigações de pagamento e para fins de cobrança dos mesmos.
5. Análise de dados, pesquisa e estatísticas, para avaliar e estudar o perfil dos usuários do nosso Serviço, para fins de publicidade e marketing, retargeting e para desenvolver melhores produtos, ofertas e serviços.
6. Para melhoria de nossos Serviços e desenvolvimento de novos produtos ou serviços.

Decisões Automatizadas
Sistema eletrônico processa dados pessoais para uma avaliação da sua capacidade de pagamento e, por isso, garantimos o seu direito de solicitar a revisão de qualquer decisão tomada exclusivamente com base no tratamento automatizado dos seus dados, nos termos da lei.

Fontes de informação

A Empresa coleta Informações diretamente de você, do seu uso dos Serviços, bem como de quaisquer terceiros que você possa ter autorizado a compartilhar tais Informações com a Empresa.

Direta
Informações que você nos fornece diretamente, por qualquer meio, inclusive por telefone, e-mail ou outros canais de comunicação.

Indireta
Onde permitido por lei, a Empresa pode coletar Informações sobre você de terceiros.

Aparelho Móvel
A empresa coleta Informações de seu aparelho de celular por meio do aplicativo móvel PayJoy instalado em seu telefone celular. Você pode verificar quais Informações estão sendo coletadas pelo aplicativo PayJoy na seção de privacidade do seu aparelho celular.

Site
Quando você visita nossos sites, podemos coletar Informações automaticamente por meio de cookies ou tecnologia semelhante.

Compartilhamento

A Empresa pode compartilhar Informações sobre você com:

• Agências governamentais, tribunais ou órgãos reguladores, conforme exigido pela legislação aplicável;
• Qualquer agente, contratado, provedor de serviço ou terceiro em conexão com os negócios da Empresa ou em conexão com a prestação dos Serviços; e
• Qualquer outra pessoa sob o dever de confidencialidade para com a Empresa.

A empresa também pode intercambiar as informações coletadas com terceiros envolvidos na prestação dos serviços de cada cliente.

Transferências internacionais
Podemos transferir as Informações que coletamos sobre você para destinatários em países diferentes do país em que as Informações foram originalmente coletadas. Quando transferimos suas Informações para destinatários em outros países: (i) realizaremos essas transferências de acordo com os requisitos da lei aplicável; e (ii) protegeremos as Informações pessoais transferidas de acordo com esta Política de Privacidade.

Consentimento e outras bases

Poderemos tratar as suas Informações, independentemente do seu consentimento, desde que exista uma base legal para tanto prevista na lei, para cumprir com uma obrigação legal ou regulatória, executar um contrato celebrado com você, exercer regularmente nossos direitos em processo judicial, administrativo ou arbitral, proteção ao crédito ou para atender aos legítimos interesses da Empresa ou de terceiros.

Seus direitos como titular dos dados
A empresa gostaria de ter certeza de que você está totalmente ciente de todos os seus direitos relacionados aos seus dados pessoais. Você possui os seguintes direitos:

Direito de confirmar a existência de tratamento
Você tem o direito de confirmar se a Empresa está tratando seus dados.

Direito de acesso
Você tem o direito de solicitar acesso ou cópia das suas Informações.

Direito de retificação
Você tem o direito de solicitar que a Empresa corrija Informações incompletas, inexatas ou desatualizadas.

Direito de eliminação
Você tem o direito de solicitar que a Empresa elimine, anonimize ou bloqueie Informações desnecessárias, excessivas ou tratadas em desconformidade com a lei.

Direito de se opor ao processamento
Você tem o direito de se opor ao processamento de seus dados pessoais pela Empresa, quando aplicável, de acordo com a legislação.

Direito à portabilidade dos dados
Você tem o direito de solicitar que a Empresa transfira as Informações para outro fornecedor de produtos ou serviços sob certas condições.

Direito a informação sobre a possibilidade de não fornecer o consentimento
Você tem o direito de receber informações sobre a possibilidade de não fornecer o seu consentimento, quando aplicável, para o tratamento de suas Informações e as consequências da negativa.

Direito de revogar o consentimento
Quando as suas Informações forem tratadas com base no seu consentimento, voce tem o direito de revogá-lo a qualquer momento.

Direito de eliminação de dados tratados com base no consentimento
Você tem o direito de solicitar que a Empresa elimine Informações tratadas com base no seu consentimento, quando aplicável, após revogá-lo.

Direito a informação sobre compartilhamento das suas Informações
Você tem o direito de receber informações sobre as entidades públicas e privadas com as quais a Empresa realizou o uso compartilhado das suas Informações.

Direito de petição
Você tem o direito de peticionar em relação as suas Informações perante a Autoridade Nacional de Proteção de Dados.

Como exercer seus direitos
Qualquer solicitação para exercer seus direitos pode ser direcionada ao Encarregado de proteção de dados da PayJoy. A identidade e os detalhes de contato do Encarregado de proteção de dados podem ser encontrados no final desta Política.

Para atender a sua solicitação, precisaremos verificar sua identidade. Para tanto, a solicitação deve:

• Fornecer informações suficientes que nos permitam verificar se você é a pessoa sobre a qual coletamos as Informações ou um representante legal dessa pessoa.
• Descrever sua solicitação com detalhes suficientes que nos permitam entender, avaliar e responder adequadamente a ela.

Não podemos responder ao seu pedido ou fornecer-lhe informações pessoais se não pudermos verificar a sua identidade ou autoridade para fazer o pedido e confirmar que as informações pessoais dizem respeito a você ou alguém que você represente.

Responderemos à sua solicitação dentro de um prazo razoável, conforme definido pela legislação pertinente.

Privacidade de menores de idade

Nossos serviços não são direcionados a indivíduos com menos de dezoito anos e não coletamos intencionalmente informações pessoais de indivíduos com menos de dezoito anos. Se tivermos conhecimento de que dados de menores de dezoito anos nos foram fornecidos tomaremos as providências necessárias para excluir esses dados das nossas bases imediatamente.

Medidas de segurança

A Empresa implementou práticas e procedimentos de segurança razoáveis que estão em linha com os padrões internacionalmente aceitos para a segurança e proteção de dados pessoais. Essas práticas e procedimentos incluem medidas de controle de segurança gerenciais, técnicas, operacionais e físicas proporcionais à natureza das Informações coletadas e processadas pela Empresa.

Atualizações

A Empresa reserva-se o direito de adicionar, revisar, alterar, modificar ou excluir qualquer parte desta Política (em parte ou na íntegra) a seu critério. A versão atualizada desta Política em vigor será postada no site da Empresa periodicamente. Sempre que fizermos alterações materiais nesta Política, tais alterações serão válidas, eficazes e vinculativas após serem: (1) divulgadas em nossa plataforma; ou (2) comunicada a você por e-mail; ou (3) comunicada a você de qualquer outra forma. Se você decidir não continuar usando os Serviços após essa alteração, deverá solicitar o cancelamento de sua conta e / ou o encerramento de seu relacionamento legal com a Empresa.

Como entrar em contato conosco

Nos termos da Lei nº 13.709/2018 e da Resolução CD/ANPD nº 18/2024, informamos que: (i) o encarregado pelo tratamento de dados pessoais é Marjorie Avila Manfredini; (ii) Se você tiver dúvidas sobre seus dados pessoais – incluindo a solicitação de exercício de direitos com relação aos seus dados pessoais – você pode entrar em contato através do e-mail privacidadebrasil@payjoy.com

• PayJoy Mexico Privacy Policy
• PayJoy Ecuador Privacy Policy
• PayJoy South Africa Privacy Policy
• PayJoy Brazil Privacy Policy

Introduction

The privacy of individuals, including our customers and clients, is of utmost importance to PayJoy, Inc (“Company”). We are committed to adhering to the Privacy regulations governing the citizens to whom we provide products and services.

In compliance with fair and transparent principle and the data subject’s right to be informed, this PayJoy Privacy Policy (“Policy”) provides you, the data subject, with information on the processing for your personal information (“Information”) in a clear, suitable and conspicuous manner that is easily accessible.

This Policy aims to set out in clear terms the types of Information collected, the purpose of collection, the source of the Information, the entities with whom such Information may be shared, the data subject’s rights and also the reasonable security practices and procedures adopted by the Company in handling such Information.

Please read this Policy carefully as your proceeding with the use of this website or the use or purchase of any goods or services provided by us (“Services”), or your providing any Information to the Company on or through the use of our website or through any Services, are based upon the assumption that you are providing such Information to the Company voluntarily. further, the subsequent provisions of this Policy are based upon such an assumption

Type of Information Collected

In order to provide the Services, the Company may collect and process the following categories of Information:

Information about You

Including but not limited to,

• (i) Identification Data: name, government ID, e-mail, telephone number, your photograph.
• (ii) Credit Reports, Watchlists & Validation Services: requested copies of your credit history which may contain professional and financial information about you. We check for your information in public watchlists such as OFAC lists. We use Validation Services to ensure the validity and quality of Identification Data we receive.
• (iii) Social Media Data: data provided in your social media accounts, including photo, friends list and name.
• (iv) Copies of Documents: collected documentation. including government IDs
• (v) Payment Information: information about how you pay your obligation with PayJoy
• (vi) Customer Service: information you provide to us in connection with the Services, including when you communicate with us, by any means, for Customer service purposes.

Information Concerning Your Mobile Device

Including but not limited to information regarding the device, operating system, device identifier, SIM information, applications list, internet connection state, application foreground state, etc.

If the device is purchased, rented or leased via PayJoy then we collect information relating to that transaction such as store where transaction occurred, amount of transaction, etc.

Information Concerning Your Communication

If you provide specific authorization, we may collect and process information from your mobile device related but not limited to call logs and SMS messages. Before doing so we will contact you and request your specific consent.

Cookies

A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store data specific to a client or website and are designed to create a record of or “remember” online activity. The Company uses cookies to ensure the site functions properly and to deliver an individualized online services experience. You generally have the ability to accept or decline cookies. Most web browsers give you a choice to modify your browser settings to decline some or all cookies.

Please note under the law some of the information above is considered sensitive data. The Company ensures compliance with the legal requirements called out in the law for processing of sensitive data.

Retention of Information

The Company will retain and use the Information for the period necessary to (i) fulfill the purposes described in this Policy; (ii) comply with legal or regulatory obligations applicable to us; or (iii) fulfill evidentiary purposes in legal, administrative or arbitration proceedings. The criteria considered to determine the retention period include the duration of your relationship with the Company, legal retention periods applicable, and legal prescriptions with respect to possible claims, lawsuits, or administrative and arbitration proceedings in connection with the Services we provide.

Purpose of Collection

The Company will, or may, collect, use, receive, possess, process, store, deal, disclose, transfer or handle Information for the following purposes:

1. When you contract PayJoy Services, we need to process your Information to authenticate your identity and assess risk of repayment.
2. We process and store some of your Information for fraud prevention to ensure greater security to PayJoy, to you and to the financial system in general.
3. We also need your Information to contact you by any available means, including electronic means, mail or telephone (SMS and others), on matters related to the Services during your onboarding to our Services and later on throughout the services provision. This includes notifying you of changes in the Platform and/or in the Services. We may also contact you to offer or provide information on products or services that may be of your interest.
4. We also process your Information to manage your payment obligations for payment collection purposes.
5. We may process your Information for data analytics, research and statistics, for assessing and studying the profile of our Service’s users, and for developing better products, offers and services.
6. And in connection with other business of the Company from time to time.

Automated Decisions

Automated decision-making occurs when an electronic system processes personal data in order to make a decision without human intervention. Part of our procedures, especially the assessment of your ability to pay obligations, relies on automated decision mechanisms and, so, we guarantee your right to request the reviewing of any decision made exclusively based on automated processing of your data, according to the law.

Sources of Information

The Company collects Information directly from you, your use of the Services, as well as from any third parties whom you may have authorised to share such Information with the Company.

Direct

Information you directly provide to us.

Indirect

Where permitted by law, the Company may collect Information about you from third parties such as credit reporting agencies.

Mobile device

The Company collects Information from your mobile device via the PayJoy mobile application installed on your mobile phone. You may check what information is being collected by PayJoy’s app in the privacy section of your mobile device.

Website

When you visit our websites, we may collect information from you automatically through cookies or similar technology.

Sharing

The Company may share Information about you with:

• Governmental agencies, courts or regulators, as required under applicable law;
• Any agent, contractor, service provider or other third party in connection with the Company’s business and in connection with the provision of the Services; and
• Any other person under duty of confidentiality to the Company.

If the Company is involved in merger, acquisition, financial due diligence, corporate reorganization, bankruptcy proceedings, sale of assets or transition of outsourced services to another provider, your Information may be sold or transferred as part of such a transaction as permitted by applicable law. The Company makes no representations or warranties concerning how any such receiving entities may use or disclose your Information.

International Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Your Rights as a Data Subject

The company will like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

Right to Confirm Processing

You have the right to confirm whether the Company is processing your data.

Right to Access

You have the right to request access to or solicit a copy of any of your personal information that the Company may hold.

Right to Rectification

You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.

Right to Erasure

You have the right to request that the Company erase your personal data, under certain conditions.

The right to erasure is subject to certain exceptions under the law such as, but not limited to:

• Information required by the Company to fulfill statutory and regulatory obligations
• Information required to identify fraud, security incidents, exercise certain rights, etc.

Right to Restrict Processing

You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

Right to Object to Processing

You have the right to object to the Company’s processing of your personal data, under certain conditions.

Right to Data Portability

You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Right to Withdraw Consent

Where the Company has relied on your consent to process particular information and you have provided your consent to process such information, you have the right to withdraw such consent at any time.

Right to Lodge a Complaint

You have a right to bring a claim to the competent data protection authority.

How to Exercise Your Rights

Any request to exercise your rights can be directed to the data protection officer at PayJoy. The identity and contact details of the data protection officer can be found at the end of this Policy.

We will need to verify your identity before processing your request. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or a legal representative of that person
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We do not charge a fee to process your request. We will respond to your request within reasonable time, as defined by the relevant law.

Children’s Privacy

Our services are not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen.

Security Measures

The Company has implemented reasonable security practices and procedures that are in line with internationally accepted standards for the security and protection of Information. These practices and procedures include managerial, technical, operational and physical security control measures commensurate with the nature of Information collected and processed by the Company.

Updates

.The Company reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Company’s website from time to time. In the event of any change or in case of any requirement arising under applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the applicable law or to meet any requirement under such applicable laws. Whenever we make material changes in this Policy, such changes will be valid, effective and binding after being: (1) disclosed in our Platform; or (2) communicated to you by e-mail; or (3) communicated to you in any other way. If you decide not to continue using the Services after such change, you must apply for the cancellation of your account and/or termination of your legal relationship.

How to Contact Us

If you have queries concerning your personal data – including requesting access to or correcting the details of your personal data – you may contact:

Email us at: privacy@payjoy.com

To report security vulnerabilities:
Please email us at: security@payjoy.com

Call us: 888-632-1922

Or write to us at:

PayJoy, Inc

655 4th Street, San Francisco, CA 94107

‍

• PayJoy Mexico Privacy Policy
• PayJoy Ecuador Privacy Policy
• PayJoy South Africa Privacy Policy
• PayJoy Brazil Privacy Policy

Introduction

The privacy of individuals, including our customers and clients, is of utmost importance to PayJoy, Inc (“Company”). We are committed to adhering to the Privacy regulations governing the citizens to whom we provide products and services.

In compliance with fair and transparent principle and the data subject’s right to be informed, this PayJoy Privacy Policy (“Policy”) provides you, the data subject, with information on the processing for your personal information (“Information”) in a clear, suitable and conspicuous manner that is easily accessible.

This Policy aims to set out in clear terms the types of Information collected, the purpose of collection, the source of the Information, the entities with whom such Information may be shared, the data subject’s rights and also the reasonable security practices and procedures adopted by the Company in handling such Information.

Please read this Policy carefully as your proceeding with the use of this website or the use or purchase of any goods or services provided by us (“Services”), or your providing any Information to the Company on or through the use of our website or through any Services, are based upon the assumption that you are providing such Information to the Company voluntarily. further, the subsequent provisions of this Policy are based upon such an assumption

Type of Information Collected

In order to provide the Services, the Company may collect and process the following categories of Information:

Information about You

Including but not limited to,

• (i) Identification Data: name, government ID, e-mail, telephone number, your photograph.
• (ii) Credit Reports, Watchlists & Validation Services: requested copies of your credit history which may contain professional and financial information about you. We check for your information in public watchlists such as OFAC lists. We use Validation Services to ensure the validity and quality of Identification Data we receive.
• (iii) Social Media Data: data provided in your social media accounts, including photo, friends list and name.
• (iv) Copies of Documents: collected documentation. including government IDs
• (v) Payment Information: information about how you pay your obligation with PayJoy
• (vi) Customer Service: information you provide to us in connection with the Services, including when you communicate with us, by any means, for Customer service purposes.

Information Concerning Your Mobile Device

Including but not limited to information regarding the device, operating system, device identifier, SIM information, applications list, internet connection state, application foreground state, etc.

If the device is purchased, rented or leased via PayJoy then we collect information relating to that transaction such as store where transaction occurred, amount of transaction, etc.

Information Concerning Your Communication

If you provide specific authorization, we may collect and process information from your mobile device related but not limited to call logs and SMS messages. Before doing so we will contact you and request your specific consent.

Cookies

A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store data specific to a client or website and are designed to create a record of or “remember” online activity. The Company uses cookies to ensure the site functions properly and to deliver an individualized online services experience. You generally have the ability to accept or decline cookies. Most web browsers give you a choice to modify your browser settings to decline some or all cookies.

Please note under the law some of the information above is considered sensitive data. The Company ensures compliance with the legal requirements called out in the law for processing of sensitive data.

Retention of Information

The Company will retain and use the Information for the period necessary to (i) fulfill the purposes described in this Policy; (ii) comply with legal or regulatory obligations applicable to us; or (iii) fulfill evidentiary purposes in legal, administrative or arbitration proceedings. The criteria considered to determine the retention period include the duration of your relationship with the Company, legal retention periods applicable, and legal prescriptions with respect to possible claims, lawsuits, or administrative and arbitration proceedings in connection with the Services we provide.

Purpose of Collection

The Company will, or may, collect, use, receive, possess, process, store, deal, disclose, transfer or handle Information for the following purposes:

1. When you contract PayJoy Services, we need to process your Information to authenticate your identity and assess risk of repayment.
2. We process and store some of your Information for fraud prevention to ensure greater security to PayJoy, to you and to the financial system in general.
3. We also need your Information to contact you by any available means, including electronic means, mail or telephone (SMS and others), on matters related to the Services during your onboarding to our Services and later on throughout the services provision. This includes notifying you of changes in the Platform and/or in the Services. We may also contact you to offer or provide information on products or services that may be of your interest.
4. We also process your Information to manage your payment obligations for payment collection purposes.
5. We may process your Information for data analytics, research and statistics, for assessing and studying the profile of our Service’s users, and for developing better products, offers and services.
6. And in connection with other business of the Company from time to time.

Automated Decisions

Automated decision-making occurs when an electronic system processes personal data in order to make a decision without human intervention. Part of our procedures, especially the assessment of your ability to pay obligations, relies on automated decision mechanisms and, so, we guarantee your right to request the reviewing of any decision made exclusively based on automated processing of your data, according to the law.

Sources of Information

The Company collects Information directly from you, your use of the Services, as well as from any third parties whom you may have authorised to share such Information with the Company.

Direct

Information you directly provide to us.

Indirect

Where permitted by law, the Company may collect Information about you from third parties such as credit reporting agencies.

Mobile device

The Company collects Information from your mobile device via the PayJoy mobile application installed on your mobile phone. You may check what information is being collected by PayJoy’s app in the privacy section of your mobile device.

Website

When you visit our websites, we may collect information from you automatically through cookies or similar technology.

Sharing

The Company may share Information about you with:

• Governmental agencies, courts or regulators, as required under applicable law;
• Any agent, contractor, service provider or other third party in connection with the Company’s business and in connection with the provision of the Services; and
• Any other person under duty of confidentiality to the Company.

If the Company is involved in merger, acquisition, financial due diligence, corporate reorganization, bankruptcy proceedings, sale of assets or transition of outsourced services to another provider, your Information may be sold or transferred as part of such a transaction as permitted by applicable law. The Company makes no representations or warranties concerning how any such receiving entities may use or disclose your Information.

International Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Your Rights as a Data Subject

The company will like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

Right to Confirm Processing

You have the right to confirm whether the Company is processing your data.

Right to Access

You have the right to request access to or solicit a copy of any of your personal information that the Company may hold.

Right to Rectification

You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.

Right to Erasure

You have the right to request that the Company erase your personal data, under certain conditions.

The right to erasure is subject to certain exceptions under the law such as, but not limited to:

• Information required by the Company to fulfill statutory and regulatory obligations
• Information required to identify fraud, security incidents, exercise certain rights, etc.

Right to Restrict Processing

You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

Right to Object to Processing

You have the right to object to the Company’s processing of your personal data, under certain conditions.

Right to Data Portability

You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Right to Withdraw Consent

Where the Company has relied on your consent to process particular information and you have provided your consent to process such information, you have the right to withdraw such consent at any time.

Right to Lodge a Complaint

You have a right to bring a claim to the competent data protection authority.

How to Exercise Your Rights

Any request to exercise your rights can be directed to the data protection officer at PayJoy. The identity and contact details of the data protection officer can be found at the end of this Policy.

We will need to verify your identity before processing your request. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or a legal representative of that person
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We do not charge a fee to process your request. We will respond to your request within reasonable time, as defined by the relevant law.

Children’s Privacy

Our services are not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen.

Security Measures

The Company has implemented reasonable security practices and procedures that are in line with internationally accepted standards for the security and protection of Information. These practices and procedures include managerial, technical, operational and physical security control measures commensurate with the nature of Information collected and processed by the Company.

Updates

.The Company reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Company’s website from time to time. In the event of any change or in case of any requirement arising under applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the applicable law or to meet any requirement under such applicable laws. Whenever we make material changes in this Policy, such changes will be valid, effective and binding after being: (1) disclosed in our Platform; or (2) communicated to you by e-mail; or (3) communicated to you in any other way. If you decide not to continue using the Services after such change, you must apply for the cancellation of your account and/or termination of your legal relationship.

How to Contact Us

If you have queries concerning your personal data – including requesting access to or correcting the details of your personal data – you may contact:

Email us at: privacy@payjoy.com

To report security vulnerabilities:
Please email us at: security@payjoy.com

Call us: 888-632-1922

Or write to us at:

PayJoy, Inc

655 4th Street, San Francisco, CA 94107

‍

• PayJoy Mexico Privacy Policy
• PayJoy Ecuador Privacy Policy
• PayJoy South Africa Privacy Policy
• PayJoy Brazil Privacy Policy

Introduction

The privacy of individuals, including our customers and clients, is of utmost importance to PayJoy, Inc (“Company”). We are committed to adhering to the Privacy regulations governing the citizens to whom we provide products and services.

In compliance with fair and transparent principle and the data subject’s right to be informed, this PayJoy Privacy Policy (“Policy”) provides you, the data subject, with information on the processing for your personal information (“Information”) in a clear, suitable and conspicuous manner that is easily accessible.

This Policy aims to set out in clear terms the types of Information collected, the purpose of collection, the source of the Information, the entities with whom such Information may be shared, the data subject’s rights and also the reasonable security practices and procedures adopted by the Company in handling such Information.

Please read this Policy carefully as your proceeding with the use of this website or the use or purchase of any goods or services provided by us (“Services”), or your providing any Information to the Company on or through the use of our website or through any Services, are based upon the assumption that you are providing such Information to the Company voluntarily. further, the subsequent provisions of this Policy are based upon such an assumption

Type of Information Collected

In order to provide the Services, the Company may collect and process the following categories of Information:

Information about You

Including but not limited to,

• (i) Identification Data: name, government ID, e-mail, telephone number, your photograph.
• (ii) Credit Reports, Watchlists & Validation Services: requested copies of your credit history which may contain professional and financial information about you. We check for your information in public watchlists such as OFAC lists. We use Validation Services to ensure the validity and quality of Identification Data we receive.
• (iii) Social Media Data: data provided in your social media accounts, including photo, friends list and name.
• (iv) Copies of Documents: collected documentation. including government IDs
• (v) Payment Information: information about how you pay your obligation with PayJoy
• (vi) Customer Service: information you provide to us in connection with the Services, including when you communicate with us, by any means, for Customer service purposes.

Information Concerning Your Mobile Device

Including but not limited to information regarding the device, operating system, device identifier, SIM information, applications list, internet connection state, application foreground state, etc.

If the device is purchased, rented or leased via PayJoy then we collect information relating to that transaction such as store where transaction occurred, amount of transaction, etc.

Information Concerning Your Communication

If you provide specific authorization, we may collect and process information from your mobile device related but not limited to call logs and SMS messages. Before doing so we will contact you and request your specific consent.

Cookies

A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store data specific to a client or website and are designed to create a record of or “remember” online activity. The Company uses cookies to ensure the site functions properly and to deliver an individualized online services experience. You generally have the ability to accept or decline cookies. Most web browsers give you a choice to modify your browser settings to decline some or all cookies.

Please note under the law some of the information above is considered sensitive data. The Company ensures compliance with the legal requirements called out in the law for processing of sensitive data.

Retention of Information

The Company will retain and use the Information for the period necessary to (i) fulfill the purposes described in this Policy; (ii) comply with legal or regulatory obligations applicable to us; or (iii) fulfill evidentiary purposes in legal, administrative or arbitration proceedings. The criteria considered to determine the retention period include the duration of your relationship with the Company, legal retention periods applicable, and legal prescriptions with respect to possible claims, lawsuits, or administrative and arbitration proceedings in connection with the Services we provide.

Purpose of Collection

The Company will, or may, collect, use, receive, possess, process, store, deal, disclose, transfer or handle Information for the following purposes:

1. When you contract PayJoy Services, we need to process your Information to authenticate your identity and assess risk of repayment.
2. We process and store some of your Information for fraud prevention to ensure greater security to PayJoy, to you and to the financial system in general.
3. We also need your Information to contact you by any available means, including electronic means, mail or telephone (SMS and others), on matters related to the Services during your onboarding to our Services and later on throughout the services provision. This includes notifying you of changes in the Platform and/or in the Services. We may also contact you to offer or provide information on products or services that may be of your interest.
4. We also process your Information to manage your payment obligations for payment collection purposes.
5. We may process your Information for data analytics, research and statistics, for assessing and studying the profile of our Service’s users, and for developing better products, offers and services.
6. And in connection with other business of the Company from time to time.

Automated Decisions

Automated decision-making occurs when an electronic system processes personal data in order to make a decision without human intervention. Part of our procedures, especially the assessment of your ability to pay obligations, relies on automated decision mechanisms and, so, we guarantee your right to request the reviewing of any decision made exclusively based on automated processing of your data, according to the law.

Sources of Information

The Company collects Information directly from you, your use of the Services, as well as from any third parties whom you may have authorised to share such Information with the Company.

Direct

Information you directly provide to us.

Indirect

Where permitted by law, the Company may collect Information about you from third parties such as credit reporting agencies.

Mobile device

The Company collects Information from your mobile device via the PayJoy mobile application installed on your mobile phone. You may check what information is being collected by PayJoy’s app in the privacy section of your mobile device.

Website

When you visit our websites, we may collect information from you automatically through cookies or similar technology.

Sharing

The Company may share Information about you with:

• Governmental agencies, courts or regulators, as required under applicable law;
• Any agent, contractor, service provider or other third party in connection with the Company’s business and in connection with the provision of the Services; and
• Any other person under duty of confidentiality to the Company.

If the Company is involved in merger, acquisition, financial due diligence, corporate reorganization, bankruptcy proceedings, sale of assets or transition of outsourced services to another provider, your Information may be sold or transferred as part of such a transaction as permitted by applicable law. The Company makes no representations or warranties concerning how any such receiving entities may use or disclose your Information.

International Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Your Rights as a Data Subject

The company will like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

Right to Confirm Processing

You have the right to confirm whether the Company is processing your data.

Right to Access

You have the right to request access to or solicit a copy of any of your personal information that the Company may hold.

Right to Rectification

You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.

Right to Erasure

You have the right to request that the Company erase your personal data, under certain conditions.

The right to erasure is subject to certain exceptions under the law such as, but not limited to:

• Information required by the Company to fulfill statutory and regulatory obligations
• Information required to identify fraud, security incidents, exercise certain rights, etc.

Right to Restrict Processing

You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

Right to Object to Processing

You have the right to object to the Company’s processing of your personal data, under certain conditions.

Right to Data Portability

You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Right to Withdraw Consent

Where the Company has relied on your consent to process particular information and you have provided your consent to process such information, you have the right to withdraw such consent at any time.

Right to Lodge a Complaint

You have a right to bring a claim to the competent data protection authority.

How to Exercise Your Rights

Any request to exercise your rights can be directed to the data protection officer at PayJoy. The identity and contact details of the data protection officer can be found at the end of this Policy.

We will need to verify your identity before processing your request. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or a legal representative of that person
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We do not charge a fee to process your request. We will respond to your request within reasonable time, as defined by the relevant law.

Children’s Privacy

Our services are not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen.

Security Measures

The Company has implemented reasonable security practices and procedures that are in line with internationally accepted standards for the security and protection of Information. These practices and procedures include managerial, technical, operational and physical security control measures commensurate with the nature of Information collected and processed by the Company.

Updates

.The Company reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Company’s website from time to time. In the event of any change or in case of any requirement arising under applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the applicable law or to meet any requirement under such applicable laws. Whenever we make material changes in this Policy, such changes will be valid, effective and binding after being: (1) disclosed in our Platform; or (2) communicated to you by e-mail; or (3) communicated to you in any other way. If you decide not to continue using the Services after such change, you must apply for the cancellation of your account and/or termination of your legal relationship.

How to Contact Us

If you have queries concerning your personal data – including requesting access to or correcting the details of your personal data – you may contact:

Email us at: privacy@payjoy.com

To report security vulnerabilities:
Please email us at: security@payjoy.com

Call us: 888-632-1922

Or write to us at:

PayJoy, Inc

655 4th Street, San Francisco, CA 94107

‍

• PayJoy Mexico Privacy Policy
• PayJoy Ecuador Privacy Policy
• PayJoy South Africa Privacy Policy
• PayJoy Brazil Privacy Policy

Introduction

The privacy of individuals, including our customers and clients, is of utmost importance to PayJoy, Inc (“Company”). We are committed to adhering to the Privacy regulations governing the citizens to whom we provide products and services.

In compliance with fair and transparent principle and the data subject’s right to be informed, this PayJoy Privacy Policy (“Policy”) provides you, the data subject, with information on the processing for your personal information (“Information”) in a clear, suitable and conspicuous manner that is easily accessible.

This Policy aims to set out in clear terms the types of Information collected, the purpose of collection, the source of the Information, the entities with whom such Information may be shared, the data subject’s rights and also the reasonable security practices and procedures adopted by the Company in handling such Information.

Please read this Policy carefully as your proceeding with the use of this website or the use or purchase of any goods or services provided by us (“Services”), or your providing any Information to the Company on or through the use of our website or through any Services, are based upon the assumption that you are providing such Information to the Company voluntarily. further, the subsequent provisions of this Policy are based upon such an assumption

Type of Information Collected

In order to provide the Services, the Company may collect and process the following categories of Information:

Information about You

Including but not limited to,

• (i) Identification Data: name, government ID, e-mail, telephone number, your photograph.
• (ii) Credit Reports, Watchlists & Validation Services: requested copies of your credit history which may contain professional and financial information about you. We check for your information in public watchlists such as OFAC lists. We use Validation Services to ensure the validity and quality of Identification Data we receive.
• (iii) Social Media Data: data provided in your social media accounts, including photo, friends list and name.
• (iv) Copies of Documents: collected documentation. including government IDs
• (v) Payment Information: information about how you pay your obligation with PayJoy
• (vi) Customer Service: information you provide to us in connection with the Services, including when you communicate with us, by any means, for Customer service purposes.

Information Concerning Your Mobile Device

Including but not limited to information regarding the device, operating system, device identifier, SIM information, applications list, internet connection state, application foreground state, etc.

If the device is purchased, rented or leased via PayJoy then we collect information relating to that transaction such as store where transaction occurred, amount of transaction, etc.

Information Concerning Your Communication

If you provide specific authorization, we may collect and process information from your mobile device related but not limited to call logs and SMS messages. Before doing so we will contact you and request your specific consent.

Cookies

A cookie is a small text file that a web server places on your computer or device when your browser accesses a website. Cookies store data specific to a client or website and are designed to create a record of or “remember” online activity. The Company uses cookies to ensure the site functions properly and to deliver an individualized online services experience. You generally have the ability to accept or decline cookies. Most web browsers give you a choice to modify your browser settings to decline some or all cookies.

Please note under the law some of the information above is considered sensitive data. The Company ensures compliance with the legal requirements called out in the law for processing of sensitive data.

Retention of Information

The Company will retain and use the Information for the period necessary to (i) fulfill the purposes described in this Policy; (ii) comply with legal or regulatory obligations applicable to us; or (iii) fulfill evidentiary purposes in legal, administrative or arbitration proceedings. The criteria considered to determine the retention period include the duration of your relationship with the Company, legal retention periods applicable, and legal prescriptions with respect to possible claims, lawsuits, or administrative and arbitration proceedings in connection with the Services we provide.

Purpose of Collection

The Company will, or may, collect, use, receive, possess, process, store, deal, disclose, transfer or handle Information for the following purposes:

1. When you contract PayJoy Services, we need to process your Information to authenticate your identity and assess risk of repayment.
2. We process and store some of your Information for fraud prevention to ensure greater security to PayJoy, to you and to the financial system in general.
3. We also need your Information to contact you by any available means, including electronic means, mail or telephone (SMS and others), on matters related to the Services during your onboarding to our Services and later on throughout the services provision. This includes notifying you of changes in the Platform and/or in the Services. We may also contact you to offer or provide information on products or services that may be of your interest.
4. We also process your Information to manage your payment obligations for payment collection purposes.
5. We may process your Information for data analytics, research and statistics, for assessing and studying the profile of our Service’s users, and for developing better products, offers and services.
6. And in connection with other business of the Company from time to time.

Automated Decisions

Automated decision-making occurs when an electronic system processes personal data in order to make a decision without human intervention. Part of our procedures, especially the assessment of your ability to pay obligations, relies on automated decision mechanisms and, so, we guarantee your right to request the reviewing of any decision made exclusively based on automated processing of your data, according to the law.

Sources of Information

The Company collects Information directly from you, your use of the Services, as well as from any third parties whom you may have authorised to share such Information with the Company.

Direct

Information you directly provide to us.

Indirect

Where permitted by law, the Company may collect Information about you from third parties such as credit reporting agencies.

Mobile device

The Company collects Information from your mobile device via the PayJoy mobile application installed on your mobile phone. You may check what information is being collected by PayJoy’s app in the privacy section of your mobile device.

Website

When you visit our websites, we may collect information from you automatically through cookies or similar technology.

Sharing

The Company may share Information about you with:

• Governmental agencies, courts or regulators, as required under applicable law;
• Any agent, contractor, service provider or other third party in connection with the Company’s business and in connection with the provision of the Services; and
• Any other person under duty of confidentiality to the Company.

If the Company is involved in merger, acquisition, financial due diligence, corporate reorganization, bankruptcy proceedings, sale of assets or transition of outsourced services to another provider, your Information may be sold or transferred as part of such a transaction as permitted by applicable law. The Company makes no representations or warranties concerning how any such receiving entities may use or disclose your Information.

International Transfers

We may transfer the personal information we collect about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Your Rights as a Data Subject

The company will like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

Right to Confirm Processing

You have the right to confirm whether the Company is processing your data.

Right to Access

You have the right to request access to or solicit a copy of any of your personal information that the Company may hold.

Right to Rectification

You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.

Right to Erasure

You have the right to request that the Company erase your personal data, under certain conditions.

The right to erasure is subject to certain exceptions under the law such as, but not limited to:

• Information required by the Company to fulfill statutory and regulatory obligations
• Information required to identify fraud, security incidents, exercise certain rights, etc.

Right to Restrict Processing

You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

Right to Object to Processing

You have the right to object to the Company’s processing of your personal data, under certain conditions.

Right to Data Portability

You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Right to Withdraw Consent

Where the Company has relied on your consent to process particular information and you have provided your consent to process such information, you have the right to withdraw such consent at any time.

Right to Lodge a Complaint

You have a right to bring a claim to the competent data protection authority.

How to Exercise Your Rights

Any request to exercise your rights can be directed to the data protection officer at PayJoy. The identity and contact details of the data protection officer can be found at the end of this Policy.

We will need to verify your identity before processing your request. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or a legal representative of that person
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We do not charge a fee to process your request. We will respond to your request within reasonable time, as defined by the relevant law.

Children’s Privacy

Our services are not directed to children under the age of sixteen and we do not knowingly collect personal information from children under the age of sixteen.

Security Measures

The Company has implemented reasonable security practices and procedures that are in line with internationally accepted standards for the security and protection of Information. These practices and procedures include managerial, technical, operational and physical security control measures commensurate with the nature of Information collected and processed by the Company.

Updates

.The Company reserves the right to add, revise, amend, modify or delete any part of this Policy (in part or in full) at its discretion. The updated version of this Policy in force will be posted on the Company’s website from time to time. In the event of any change or in case of any requirement arising under applicable law, this Policy shall be deemed to be amended or modified to the extent necessary to comply with such amendment to the applicable law or to meet any requirement under such applicable laws. Whenever we make material changes in this Policy, such changes will be valid, effective and binding after being: (1) disclosed in our Platform; or (2) communicated to you by e-mail; or (3) communicated to you in any other way. If you decide not to continue using the Services after such change, you must apply for the cancellation of your account and/or termination of your legal relationship.

How to Contact Us

If you have queries concerning your personal data – including requesting access to or correcting the details of your personal data – you may contact:

Email us at: privacy@payjoy.com

To report security vulnerabilities:
Please email us at: security@payjoy.com

Call us: 888-632-1922

Or write to us at:

PayJoy, Inc

655 4th Street, San Francisco, CA 94107

‍