POLICY
CCPA Privacy Notice
APPLICABILITY: Pursuant with the California Consumer Privacy Act of 2018 as amended and revised by the California Privacy Rights Act of 2020 (collectively “CCPA”), and any other California privacy laws, this CCPA Notice applies to the collection, retention and otherwise processing of Personal Information (as defined below) by Mrkter Technologies L.B.O. Ltd., operating under the branded name Payouts.com (together with its affiliates companies – “Payouts”) from its website visitors, customers, including Customer’s users, vendors and payees, who are California residents (individually and collectively “consumer” or “you”). This CCPA Notice is an integral part of Payouts’ Privacy Policy (“Privacy Policy”), and thus, definitions used herein but not defined herein or under the CCPA shall have the same meaning as defined in the Privacy Policy.
As required under the CCPA, Payouts will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Last Updated” heading located at the top of the CCPA Notice.
PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:
- CATEGORIES OF PERSONAL INFORMATION PAYOUTS COLLECTS
Payouts collects Personal Information which is defined under the CCPA 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, all as detailed in the table below, and further includes Sensitive Personal Information (“SPI”) as detailed in the table below.
Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; and such information which is governed by additional legislation, such as: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
Payouts has collected the following categories of Personal Information within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes: A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. These types of Personal Information will be collected from: (i) Payouts prospects, website visitors – when, for example, they contact us for support, book a demo or any other inquiries, and when automatically when interacting with Payouts website and the services therein; (ii) Payouts customers – when, for example, registering for Payouts services and creating and account; automatically when using Payouts platform; and where Payouts conducts certain KYC checks; (iii) customers’ vendors and payees – when, for example, creating an account on Payouts platform; automatically when interacting with the platform; and where Payouts conducts certain KYV checks. All as further detailed under Payouts’ Privacy Policy. |
| 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, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes: A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial information. These types of Personal Information will be collected from: (i) Payouts prospects, website visitors – contact details including names will be collected when they contact us for support, book a demo or any other inquiries; (ii) Payouts customers – when, for example, registering for Payouts services and creating and account; Payouts will also have access to customers’ transactions and related financial information made and provided by the customer through Payouts services; and where Payouts conducts certain KYC checks; (iii) customers’ vendors and payees – when, for example, creating an account on Payouts platform; when using Payouts platform and related services Payouts will have access to the vendors’ or payees’ payment information and associated data such as SSN, Tax ID, bank account number, etc. ; and where Payouts conducts certain KYV checks. All as further detailed under Payouts’ Privacy Policy. |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | No |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes. These types of Personal Information will be collected from: (i) Payouts customers – when, for example, using Payouts platform and the services therein as Payouts will have access to the transactions conducted through the platform; and where Payouts conducts certain KYC checks; (ii) customers’ vendors and payees – when using Payouts platform and the services therein, including, for example, using the factoring services; and where Payouts conducts certain KYV checks. All as further detailed under Payouts’ Privacy Policy. |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes: Information on Payouts website visitors’, prospects’ interaction with Payouts website, or advertisement. As well information on Payouts customers’, including vendors and payees’ interaction with, the platform, including for example, certain webpages, and additional services therein. |
| G. Geolocation data. | Physical location, approximate location derived from IP address or movements. | Yes: Approximate location as derived by the consumer’s IP. |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | No |
| 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 |
- CATEGORIES OF SOURCES OF PERSONAL INFORMATION
- Information you provide us directly – for example, when you correspond with us, when creating an account, etc.
- Information received automatically from your device – Payouts will collect your Online Identifiers and Telemetry Data or other similar network activity as provided under category F under the table above automatically through Payouts’ use of first or third-party tracking and measurement tools.
- Information received from Payouts’ partners of from publicly available sources – Payouts will receive Personal Information about you from its partners and public sources such as Payouts Financial Business Partners.
- USE OF PERSONAL INFORMATION
Payouts will use each type of Personal Information collected as identified above, for the purposes outlined in the “THE DATA WE PROCESS ABOUT YOU” Section 3 of Payouts Privacy Policy, and may share such Personal Information as identified under “WITH WHOM WE SHARE YOU PERSONAL DATA” Section 6 of Payouts Privacy Policy, and for a “business purpose” as provided below:
| Business Purpose | Category (corresponding with the table above) | Category of Recipient |
| Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. | Category A Category D Category F | Those of Payouts service providers which are part of the ad-network eco-systems, including to performance measurement tools, data optimization services, advertisers, as well as social and advertising networks. |
| Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes. | Category A Category F Category G | Affiliated companies, operational partner, security and fraud prevention providers, and operating systems. |
| Debugging to identify and repair errors that impair existing intended functionality | Category A Category B Category F Category G | Analytic providers, operational partner, security and fraud prevention providers, operating systems. |
| Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us. | Category A Category B Category G | Advertising networks; data analytics providers; social media networks. |
| Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services. | Category A Category B Category D | Hosting and server co-location services, communications and content delivery networks, internet service providers, operating systems and platforms, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, capital providers, and correspondents, customer engagement services, billing, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with Payouts’ legal and regulatory obligations to screen and monitor transactions; and Payouts’ business, legal, tax, financial and compliance advisors. |
| Undertaking internal research for technological development and demonstration. | Category A Category B Category G | Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools. |
| Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business. | Category A Category G | Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools. |
Payouts will not collect additional categories of Personal Information or use the Personal Information collected as mentioned above for materially different, unrelated, or incompatible purposes without providing you appropriate notice.
- SALE OR SHARE OF PERSONAL INFORMATION
In the preceding twelve (12) months, Payouts did not “sell” information as most people would commonly understand that term. Payouts does not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment. Payouts may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, Payouts may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling Payouts’ partners to serve such personalized content.
Further, as Payouts promotes its service through online campaigns, Payouts places third-party marketing and analytic cookies on its website, sharing the unique identifier with such partners for analytic and marketing purposes may also fall under the definition or “share and sell”, and therefore, Payouts offers the opportunity to opt-out through the cookie setting presented on the website’s footer. For additional information regarding the tracking technologies, Payouts uses on the website please review Payouts’ cookies list presented in the website’s footer.
In the preceding twelve (12) months, Payouts “shared” the following types of Personal Information for cross-context behavioral advertising:
| Category of Personal Information Sold or Shared | Category of Third-Party Recipient |
| Identifiers under category A | Service providers (such as advertising networks, analytics providers, etc.) |
| Device information and online Activity under category F | |
| Geolocation under category G |
- CHILDREN UNDER AGE 16
Payouts does not knowingly collect information from children under the age of 16.
- DATA RETENTION
The retention periods are determined according to the following criteria:
- For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example: if you contacted Payouts, Payouts would retain your contact information at least until Payouts will address your inquiry.
- To comply with Payouts’ regulatory obligations.
- To resolve a claim Payouts might have or a dispute with you, including any legal proceeding between you and Payouts, until such dispute will be resolved, and following, if Payouts find it necessary, in accordance with applicable statutory limitation periods.
Please note that except as required by applicable law, Payouts will not be obligated to retain your data for any particular period, and Payouts may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.
PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM
- YOUR RIGHTS UNDER THE CCPA
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. Payouts may limit its response to your requests as permitted under applicable law, all as detailed herein and the in the Data Subject Request (“DSR“) available here.
| California Privacy Right | Details |
| The right to know what Personal Information the business has collected. | The right to know what Personal Information the business has collected about the consumer, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer. |
| Deletion Rights. | The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. |
| Correct Inaccurate Information | The right to correct inaccurate Personal Information that a business maintains about a consumer |
| Opt-Out of Sharing for Cross-Contextual Behavioral Advertising | You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising”. |
| Opt-out from selling | the right to opt-out of the sale or sharing of Personal Information by the business |
| Limit the Use or Disclosure of SPI | Under certain circumstances, if the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business. |
| Opt-Out of the Use of Automated Decision Making | In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information. |
| Non-Discrimination | The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. Payouts may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information. |
| Data Portability | You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. |
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
- HOW CAN YOU EXERCISE THE RIGHTS?
You may exercise your rights through the DSR available here. The instructions for submitting, the general description of the process, verification requirements, when applicable, including any information the consumer must provide are all detailed in the DSR.
Note, certain rights can be done by you independently without using the DSR. For example, depending on your interaction with Payouts:
- you can opt-out from receiving emails from Payouts by clicking the “unsubscribe” link within the email;
- you can click on the “Do Not Sell or Share My Personal Information” link within the cookies settings on the website in order to opt out from the use of certain cookies;
- Payouts is also able to process the Global Privacy Control preference signals.
- AUTHORIZED AGENTS
“Authorized agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, Payouts will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:
(i) When a consumer uses an authorized agent to submit a request to know or a request to delete, Payouts may require that the consumer do the following:
- Provide the authorized agent signed permission to do so or power of attorney.
- Verify their identity directly with Payouts.
- Directly confirm with Payouts that they provided the authorized agent permission to submit the request.
(ii) Payouts may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
CONTACT US
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to Payouts privacy practices, please contact us at:
Mrkter Technologies L.B.O Ltd.
Ha-Sadna’ot St 10, Floor 4, Herzliya, 4673304
PART III: OTHER CALIFORNIA OBLIGATIONS
Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires Payouts to notify you how it deals with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, Payouts does not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
