Last Revised: June [ ], 2013

PAAY LLC (“PAAY” “we” or “us”) is the owner and operator of the PAAY website, mobile application and is the provider of the PAAY services. PAAY respects your privacy, and we created this privacy policy (the “Policy”) to explain how we collect, use and disclose your information. The Policy is only applicable to our Services and not to any other website, service or online platform. Capitalized terms that are not defined in this Policy have the meaning given them in our User Agreement. BY ACESSING THE PAAY WEBSITE, DOWNLOADING THE MOBILE APPLICATION, UTILIZING ANY OF THE SERVICES AND/OR REGISTERING WITH US, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS POLICY, INCLUDING OUR USER AGREEMENT, WHICH IS INCORPORATED HEREIN BY REFERENCE.

1.     Types of Information Collected

A.    Personal Information.

PAAY may ask you for some or all of the following types of information which may be identifiable to you when you register for our services: your name, email address, mailing address, wireless phone number, credit card information, and any addition information for the purpose of authenticating yourself or your account if we have reason to believe, in our sole discretion, that you may be violating the User Agreement or for any other reason we deem necessary (collectively “Personal Information”). You are responsible for ensuring the accuracy of all Personal Information you submit to PAAY.

B.    Non-Personal Information

Cookies and Other Technologies. We may utilize cookies and other technologies, such as, web beacons (also known as “clear gifs” and “pixel tags”) to recognize you, customize your experience, and serve advertisements. Cookies are very small files placed on your computer, and they allow us to count the number of visitors to PAAY and distinguish repeat visitors from new visitors. They also allow us to save user preferences and track user trends. We do not link cookies or web beacons to any Personal Information. We may also enable advertisers and ad servers to promote third party products and/or services by placing advertisements on PAAY. These advertisers and ad servers may use cookies and/or web beacons to monitor information related to served advertisements. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by PAAY and does not cover the use of cookies by any advertisers.

Information Collected Automatically We automatically receive and collect information such as your IP address, the URLs of websites you arrive at PAAY from or leave PAAY to go to, your type of browser and language, access times, the content of any undeleted cookies that your browser previously accepted from us, your operating system, your mobile provider, your mobile device, and your ISP. We may use such information to better understand how PAAY visitors use the Site, to analyze trends, administer the website, prevent fraud, and gather broad demographic information.

2.     Our Use of Your Information 

Our primary purpose in collecting information, both Personal Information and other, is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your information to:

  • Allow you to open and operate an account with us.
  • Enable you to complete transactions.
  • Provide customer support.
  • Troubleshoot problems and prevent potentially prohibited or illegal activities.
  • Customize, measure and improve our Platform, content and advertising.
  • Tell you about our services, targeted marketing, service updates, and promotional offers based on your communication preferences.
  • Monitor and enforce our User Agreement.
  • Communicate with Members about products and/or services they may be interested in.
  • Verify your eligibility to use the services.

3.     Our Disclosure of Your Information

PAAY is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. We may disclose personal information to respond to legal requirements, enforce our policies, respond to claims that certain user content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We may also share your personal information with:

  • Merchants to the extent necessary to facilitate a transaction.
  • With the financial institutions that issued the credit cards you enrolled for use of PAAY’s services for the following purposes: customer service, usage analysis, fraud prevention, and PAAY related marketing.
  • Service providers under contract who help with our business operations (we employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and services to you).
  • Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).
  • Certain PAAY’s program participants under confidentiality agreement, as we in our sole discretion believe necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, we will disclose name, street address, city, state, zip code, country, phone number, email address and company name.
  • Other business entities, should we plan to merge with or be acquired by that business entity.

4.     Account Protection

The Personal Information we collect is stored on a secure, password-protected server and only authorized personnel have access to your Information. We use industry-standard encryption technologies with respect to the receipt and transfer of Personal Information you submit. Nevertheless, despite our best efforts, no transmission over the Internet and no data storage method can be guaranteed to be safe 100% of the time. PAAY cannot ensure or warrant the security of any information you transmit to PAAY or guarantee that your End User data stored on the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. When you enter sensitive information (such as a credit card number) we encrypt such information using secure socket layer technology (SSL). The PAAY website and software is hosted on servers in the United States. Only users located within the United States may use the PAAY services. By submitting your Personal Information, you consent to its transfer and storage in the United States and its use in accordance with the purposes for which it was originally collected.

Your authentications credentials, including your password, are the key to your account. Use unique numbers, letters and special characters, and do not disclose your password or other authentication credentials to anyone. If you do share your password, authentication credentials, remember that you are responsible for all actions taken in the name of your account. If you lose your authentication credentials, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. Therefore, if your authentication credentials have been compromised for any reason, you should immediately notify us and change them.

5.     Editing Your User Account and Personal Information 

You can see, review and change most of your Personal Information through the PAAY Mobile Wallet App. You agree that you will take all measures to promptly update your Personal information if it changes or becomes inaccurate. Upon your request, we will deactivate your account and remove your account from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We do retain Personal Information from closed accounts to comply with law, prevent fraud, collect any fees owed, troubleshoot problems, assist with any investigations, enforce our User Agreement, and take other actions otherwise permitted by law.

6.     Email and SMS Text Message Communications

We may use your email and phone number for both transactional (e.g., order confirmation) and promotional (e.g., newsletters, new product offerings, special discounts, special offers by certain third parties) purposes. Email and SMS text messages we send you may contain code that enables our database to track your usage of the emails we send you, such usage includes whether the email was opened and what links (if any) were clicked. If you send an email to us, or fill out our “Feedback” form, we will collect your email address and the full content of your email, including attached files, and other information you provide.

You may “Opt Out” of receiving most emails and SMS text messages by going to your user account page and selecting the “Opt Out” preference. You acknowledge that it may take up to 10 days for us to process an opt-out request.  However, we reserve the right to send you transactional emails, certain service announcements and administrative messages, without offering you an opportunity to opt out. In the case of an important message from us regarding a transaction or your user account, we reserve the right to contact you by email or SMS text message provided you have submitted a wireless number to us. You may opt out of such SMS texts by updating your account preferences or removing such numbers from your Personal Information.

7.     Third Parties

Except as otherwise expressly included in this Policy, this document addresses only the use and disclosure of information we collect from you. We do not control the privacy policies of our Merchants or other third parties, and you are subject to the privacy policies of the Merchants and third parties where applicable.

8.     Children 

Protecting the privacy of young children is especially important to us. For that reason, PAAY does not knowingly collect or solicit Personal Information from anyone under the age of 13.

9.     California Residents

California Civil Code Section 1798.83 permits residents of the State of California to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please email us at or write us at: PAAY LLC, Attn: Legal – California Privacy Compliance, 125R Cedarhurst Ave, Cedarhurst, NY 11516

10.  Changes to this Policy

We reserve the right, at any time, to add to, change, update, or modify this Privacy Policy. Any such changes to this Privacy Policy will be posted here on our Site so we urge to please visit this page frequently. In all cases, use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Copyright © 2013 PAAY LLC. All Rights Reserved.