Privacy and Data Protection
Policy and Notice

nSure.ai Payment Assurance Ltd.

Privacy Policy

nSure.ai Payment Assurance Ltd.

nSure.ai Payment Assurance Ltd. (“nSure.ai”, “we”, “our” or the “Company”, and their cognates) respects the privacy of its customers and their consumers, and is committed to protecting the personal information you may share with us. (these and any others with respect to whom we collect personal data, shall collectively be referred to as “Customers” or “you” or “Data Subjects”).

nSure.ai provides a fraud prevention solution which provides insurance-backed protection against digital fraud for fraud-attractive goods and services, such as gift cards and digital games (the “Services”).

This privacy policy and notice (the “Privacy Policy”) explains the types of information we may collect from you, that we may receive about you or that you may provide in the course of your interest in our Services, business transactions and the use of our website. We are transparent about our practices regarding the information we may collect, use, maintain and process and describe our practices in this Privacy Policy. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purposes of EU General Data Protection Regulation (the “GDPR”), and other applicable privacy laws: nSure.ai is usually a data controller (the “Controller”) in relation to the personal data of our customers and prospective customers. However, we will usually be a data processor (the “Processor”) in relation to the personal data of consumers’ data provided to us by our customers.

1.     WHICH INFORMATION MAY WE COLLECT?

Summary: we collect various categories of personal data in order to meet our contractual obligations, and also to meet various legitimate interests, such as fraud prevention and marketing.
We may collect data about you in connection with your transactions with us, or in processing data for our Customers. One type of data is non-identifiable and anonymous information (“non-personal data”). We also collect several categories of personal data (“Personal Data”).

Data we collect about you from your transactions with us:

Personal Data which is being gathered consists of any details which are personally identifiable provided consciously and voluntarily by you, or by an organization you represent or are associated with or through your use of our website (as described below). This may include your name (first and last), email address, phone number, position and organization name and other information you may choose to provide to nSure.ai. Additionally, we may obtain location data related to the geographic location of your laptop, mobiledevice or other digital device on which the nSure.ai website is used.

You do not have any legal obligation to provide any information to nSure.ai, however, we require certain information in order to perform contracts, or to provide any services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the Services.

2.    HOW DO WE COLLECT PERSONAL DATA OF YOURS THROUGHNSURE.AI SERVICES?

Summary: we collect personal data when you or your organization send it to us, or when a vendor sends it to us so; we collect personal data through our website and services.

We collect Personal Data required to provide Services when you register interest, or when you provide us such information by entering it manually or automatically, or through your use of our website and Services, in the course of preparing a contract, or otherwise in engaging with us. We also may collect Personal Data when you call us for support, in which case we collect the information you provide us.

We also collect Personal Data through your use of our website. In other words, when you are using the website, we are aware of it and may gather, collect and record the information relating to such usage,either independently or through the help of third-party services as detailed below. This may include technical information and behavioral information such as the user’s Internet protocol (IP) address used to connect your computer to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the user’s ‘clickstream’ on the website, the period of time the user visited the website, methods used to browse away from a page, and any phone number used to call our customer service number. We likewise may place cookies on your browsing devices (see 'Cookies' section below).

3. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

Summary: we process personal data to meet our obligations, protect our rights, and manage our business.
We will use Personal Data to provide and improve our Services to our Customers and others and meet our contractual,ethical and legal obligations. All Personal Data will remain accurate complete and relevant for the stated purposes for which it was processed, including for example (divided here based on the applicable lawful basis for the processing):
Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:

  • Carrying out our obligations arising from any contracts entered into between you or your employer or organization and nSure.ai and/or any contracts entered into with nSure.ai and to provide you with the information, products and Services that you request from nSure.ai;
  • Administering your account with nSure.ai including to identify and authenticate you and users from your organization;
  • Verifying and carrying out financial transactions in relation to payments you make in connection with the products;

Processing which is necessary for the purposes of the legitimate interests pursued by nSure.ai orby a third party of providing an efficient and wide-ranging service to customers:

  • Notifying you about changes to our Services and products;
  • Contacting you for the purpose of providing you with technical assistance and other related information about the products;
  • Replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
  • Contacting you to give you commercial and marketing information about events or promotions or additional services and products offered by nSure.ai;
  • Soliciting feedback in connection with your use of the Services;
  • Tracking use of nSure.ai Services to enable us to optimize them;
  • Contacting you to inform you of additional services which may be of interest to you;

Processing which is necessary for compliance with a legal obligation to which nSure.ai is subject:

  • Compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, Customers, facilities etc;
  • If necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding;

We may also collect Personal Data of our Customers’ personnel, which will be used for the purposes set out above.

4. SHARING DATA WITH THIRD PARTIES

Summary: we share Personal Data with our service providers, partners, and authorities where required.
We may transfer Personal Data to:

Third Parties. We transfer Personal Data to third parties in a variety of circumstances. Weendeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties may include business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any contract we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our website, and our marketing.

We periodically add and remove third party providers. At present our third-party providers to whom we may transfer personal data include also the following:

                -      Website analytics (such as Google Analytics);
                -      Customer ticketing and support (such as HubSpot);
                -      On-site and cloud-based database services (such as AWS);
                -      Data security, data backup, and data access control systems;
                -      Project Management system;
                -      Customer service providers;
                -      Our lawyers, accountants, and other standard business software and partners.

In addition, we may disclose your Personal Data to third parties if some or all of our company or assets are acquired by a third party including by way of a merger, share acquisition,asset purchase or any similar transaction, in which case Personal Data may be one of the transferred assets. Likewise, we may transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of nSure.ai, our Customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For avoidance of doubt, nSure.ai may transfer and disclose non-personal data to third parties at its own discretion.

5. WHERE DO WE STORE YOUR PERSONAL DATA?

Summary: we store your personal data across multiple locations globally.

We store your Personal Data in servers owned or controlled by nSure.ai, or processed by third parties on behalf of nSure.ai,by reputable cloud-service providers in the US (see the following section regarding international transfers).

6. INTERNATIONAL DATA TRANSFERS

Summary: we transfer personal data within and to the EEA, USA, Israel and elsewhere,with appropriate safeguards in place.
EU Personal Data may be transferred to, and stored and used at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data protection laws to those of the EU. Where your Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Data is subject to appropriate safeguards, and that it is treated securely and in accordance with this privacy policy. nSure.ai transfers data to other jurisdictions as follows:

  • To the United States of America. nSure.ai stores Personal Data on AWS servers, which are located in the US, and all transfers of EU data to them, as well as to other third party vendors located within the US, are subject to the EU Standard Contractual Clauses.
  • To the state of Israel, subject to GDPR adequacy decision.
  • Verifying and carrying out financial transactions in relation to payments you make in connection with the products;

We may transfer your personal data outside of the EEA, in order to:

  • Store or backup the information;
  • Enable us to provide you with the services and products and fulfil our contract with you;
  • Fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer;
  • Facilitate the operation of our group businesses, where itis in our legitimate interests and we have concluded these are not overridden by your rights; and
  • To serve our Customers across multiple jurisdictions;

7. DATA RETENTION

Summary: we retain personal data according to our data retention policy, as required to meet our obligations, protect our rights, and manage our business.
nSure.ai will retain Personal Data it processes only for as long as required in our view, to provide the Services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.

Personal Data that is no longer retained may be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our Services are not subject to the deletion procedures mentioned in this Privacy Policy and may be retained by nSure.ai. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy and their retention policy.

8. SERVICES AND WEBSITE DATA COLLECTION AND COOKIES

Summary:with your consent, we place cookies on your device. You control our use of cookies through a cookie management tool on our website, or through your device and browser.

When you access or use our Services or website, nSure.aimay use industry standard technologies such as cookies,pixels and similar technologies, which store certain information on your computer or browsing device and which will allow us to identify the computer or device and, in some cases, to identify them with the user, and to enable automatic activation of certain features, and make your user experience more convenient and effortless. We use different types of cookies: some cookies are strictly necessary, they are required for the operation of our website and Services under our terms with you; We also use analytical and performance monitoring cookies, which allow us to recognize and count the number of visitors and to see how visitors move around our website and services when they are using it. Finally, we use functionality cookies which are used to recognize you when you return to our Site. This enables us to personalize content to your preferences, including for example, your choice of language or region.

Different cookies are kept for different periods. Session cookies are used to keep track of your activities online in a given browsing session; these cookies generally expire when the browser is closed but may be retained for a period on your device. Permanent cookies remain in operation even when you have closed the browser; they are used to remember your login details and password. Third-party cookies are installed by third parties with the aim of collecting certain information to research behaviour, demographics. Third party cookies on our site include, for example, Google Analytics.

We use cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them isin our legitimate interests of improving,optimizing and personalizing our services, and these are not overridden by your rights.

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience on our website and services will be limited.
How to disable cookies: the effect of disabling cookies depends on which cookies you disable but, in general, the website and some services delivered through them may not operate properly, may not recognize your device,may not remember your preferences and so on, if cookies are disabled or removed.

However, allowing or disabling cookies is your choice and in your control. If you want to disable cookies on our site, you need to change your browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies can be found here: Microsoft Edge, Google Chrome, Firefox, Safari.

Our services and website may, from time to time, contain links to external sites. We are not responsible for the operation, privacy policies and practices or the content of such sites.

9. SECURITY AND STORAGE OF INFORMATION

Summary: we take data security very seriously,invest in security systems, and train our staff. In the event of a breach, we will notify the right people as required by law.

We take great care in implementing, enforcing and maintaining the security of the personal data we process. nSure.ai implements,enforces and maintains security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification,use or disclosure of personal data. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary inlight of the nature of the data in question and the risks to data subjects, we may encrypt data. Likewise, we take industry standard steps to ensure our website and services are safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within nSure.ai, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for nSure.ai to fulfil its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.

nSure.ai shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by nSure.ai is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. nSure.ai shall promptly take reasonable remedial measures.

10 EU DATA SUBJECT RIGHTS

Summary:depending on the law that applies to your personal data, you may have various data subject rights, such as rights to access, erase, and correct personal data, and information rights. We will respect any lawful request to exercise those rights.

Data subjects with respect to whose data GDPR applies, have rights under GDPR and local laws, including, indifferent circumstances, rights to data portability, rights to access data, rectify data, object to processing,and erase data. It is clarified for the removal of doubt, that where personal data is provided by a customer being the data subject's employer, such data subject rights will have to be effected through that customer. In addition,data subject rights cannot be exercised in a manner inconsistent with the rights of nSure.ai employees and staff, with nSure.ai proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects generally have a right to withdraw their consent.

A data subject who wishes to modify, delete or retrieve their Personal Data, may do so by contacting nSure.ai (privacy@nsure.ai). Note that nSure.ai may have to undertake a process to identify a data subject exercising their rights.nSure.ai may keep details of such rights exercised for its own compliance and audit requirements. Please note 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. Such information may continue to be used by nSure.ai.Data subjects in the EU have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy.

11. GENERAL

Minors. We do not knowingly collect or solicit information or data from or about children under the age of 16 or knowingly allow children under the age of 16 to register for nSure.ai services. If you are under 16, do not register or attempt to register for any of the nSure.aiService or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16, we will delete that Personal Data as soon as reasonably practicable without any liability to nSure.ai. If you believe that we might have collected or been sent information from a minor under the age of 16, please contact us at: privacy@nsure.ai, as soon as possible.

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the services, website, and any information collected in connection with them. nSure.ai may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.nsureai.com/privacy-policy. Changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of our services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

nSure.ai aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. nSure.ai only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions or comments concerning this Privacy Policy, you are welcome to contact us at privacy@nsure.ai and we will make an effort to reply within a reasonable time frame.

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Last Revised: July 5, 2021

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