PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT
Recently Updated: April 2024
This privacy notice (“Privacy Notice”) for California residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CCPA”) describes the way we process information collected from our Customers, Business Partners, Visitors and Authorized Users who reside in the State of California (“Consumers” as defined under the CCPA, and which will be referred to herein as “you”), and supplements the information contained in our Privacy Policy. This Privacy Notice is an integral part of our Privacy Policy and thus, definitions used herein but not defined herein shall have the meaning ascribed to them in our Privacy Policy.
Types of PERSONAL information we COLLECT
Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. The categories of Personal Information that we collect (and have collected within the last 12 months) are detailed in the table below. Note that, certain categories may not apply to you as it depends on the nature of your interaction with us.
| Category | Examples (note that these are merely examples in accordance with the CCPA’s definitions, and we do not collect all such information types) | Collected
|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | Yes
|
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information,
Some personal information included in this category may overlap with other categories. |
Yes
|
| C. Protected classification characteristics under California or federal law. | National origin, citizenship, religion or creed, marital status,). | Yes
|
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes
|
| E. Biometric information. | Physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | No
|
| F. Internet or other similar network activity. | Browsing history, search history, information regarding a consumer’s interaction with an Internet website, application, or advertisement. | Yes
|
| G. Geolocation data. | Approximate geolocation data | Yes
|
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes
|
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | Yes
|
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No
|
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No
|
We collect (and have collected within the last 12 months) the following categories of sensitive Personal Information:
| A. Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number | SSN, passport, I.D. number or driving license number | Yes |
| B. Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. | financial information (credit and/or debit card number and banking information) | Yes
|
| C. Personal information that reveals a consumer’s racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership. | Citizenship country and nationality | Yes
|
NAYAX does not use or disclose the above sensitive Personal Information for any purpose other than those permitted under the CCPA.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows: (i) directly from you, for example, when you subscribe to our Services as a Customer you will fill your Personal Information as part of the onboarding process; and (ii) automatically when you browse through our websites.
USE OF PERSONAL INFORMATION
We may collect, use, or disclose the Personal Information, including sensitive Personal Information, listed above for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you contact us with an inquiry and provide us with your name and contact information, we will use that Personal Information to respond to your inquiry.
- To provide, support, personalize, and develop our websites and Services, as well as improve our websites, products and Services.
- For security and fraud detection purposes, and to maintain the safety, security, and integrity of our websites and Services.
- For testing, research, analysis, and product development, including to develop and improve our websites, products and Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
For further details please see our Privacy Policy.
We will not collect additional categories of Personal Information, including sensitive Personal Information, or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
THIRD PARTIES WITH WHOM WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your Personal Information, including sensitive Personal Information, to a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
We disclose your Personal Information, including sensitive Personal Information with the following categories of third parties:
- When we process Personal Information on behalf of Customers and Business Partners, including merchants, we disclose Personal Information collected in the framework of such services with the relevant Customer or Business Partner. If you made a purchase as a consumer of goods or services with a certain merchant using our cashless payment services, you should take into consideration that your Personal Information will be disclosed with the merchant from which you made the purchase.
- We also disclose certain Personal Information in the framework of processing cashless payments, such as with credit card providers, certain acquirers and credit card clearing services, payment gateways, banks, etc.
- We disclose Personal Information with our service providers, data processors and sub-processors, and with distributors of our services and products. These service providers assist us in operating our services, conducting our business, expanding our business or servicing our customers, and for personalizing user experiences of the services, and include for example fraud prevention, cloud storage services, billing services, marketing, maintenance and technology services.
You can see a list of such third parties available here. While we strive to keep this list current, updated and complete, it is possible that there are additional processors which we have not yet added to the list. If you have any inquiries related to our service providers, please contact us.
- We may disclose Personal Information where required to in order to comply with a legal requirement (e.g., a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process), for the administration of justice, to protect the vital interests of data subjects or the vital interests of others, to protect the security or integrity of our databases or the services, to take precautions against legal liability, to enforce our rights, protect our property or protect the property or safety of others, or as needed to support external auditing, compliance and corporate governance functions.
- In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale), we may disclose Personal Information with our affiliated companies or acquiring company, which will assume the rights and obligations as described in this privacy policy.
- We may also disclose certain Personal Information within the NAYAX Group, where certain affiliated companies provide services to assist others in the provision of our Services. For example, Nayax Ltd. headquarters the group’s activities, and may have access to Personal Information collected by its subsidiaries.
- Additionally, NAYAX can disclose Customer’s information with NAYAX affiliated companies, including NAYAX Capital, for the purpose of providing financing solutions.
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE OR FOR SELLING PURPOSES
In the preceding twelve (12) months, NAYAX has disclosed each of the categories of Personal Information, including sensitive Personal Information, listed above in the Section entitled “Types of PERSONAL information we COLLECT”.
SALES OR SHARING OF PERSONAL INFORMATION
In the preceding twelve (12) months NAYAX has sold and shared the following categories of Personal Information (“selling” under the CCPA is defined as any disclosure, transfer, and sale of Personal Information for monetary or other valuable consideration and “sharing” under the CCPA is defined as any disclosure, transfer and sharing of Personal Information, for cross-context behavioral advertising, whether or not for monetary or other valuable consideration):
Category A: Identifiers
Category F: Internet or other electronic network activity information
Category G: Geolocation data.
Such information is sold to or shared with our third-party website analytics and digital advertising service providers.
We share or sell such information to:
- Provide our websites to you and to improve the websites;
- Operate, improve and personalize the products we offer, and to give each user a more consistent and personalized experience when interacting with us;
- Personalize our advertising and marketing communications and to deliver information about our products and Services to you that we think may interest you;
- For security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of our websites;
- For our business purposes, such as data analytics, audits, enhancing our websites, improving our products and services, identifying website usage trends, and determining the effectiveness of our promotional campaigns;
- As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce our Privacy Policy and this Privacy Notice; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
NAYAX does not have actual knowledge that it sells or shares personal information about minors under the age of 16.
RETENTION
Unless you or our Customer (as the case may be) instruct us otherwise, and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements, if applicable.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The CCPA provides consumers with specific rights regarding their Personal Information. Please review our User Rights Policy regarding your rights under applicable law.
You may exercise any or all of your above rights in relation to your Personal Information by filling out the Data Subject Rights Form or by calling us at the toll-free telephone numbers listed below.
To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.
You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.
If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
Contact Us:
By email: [email protected]
By Toll-Free Telephone:
Direct Dial
- English-speaking USA and Canada: 833-204-4684
- Spanish-speaking USA and Canada: 800-216-1288
- French-speaking Canada: 855-725-0002
- Spanish-speaking Mexico: 01-800-681-5340
AT&T USA Direct
All other countries: 800-603-2869 (must dial country access code first click here for access codes and dialing instructions)
