INTRODUCTION:

Paydala, Inc. (“Paydala” or “we”) has prepared this notice (this “Privacy Policy”) to explain the privacy practices of Paydala. You (“you” or “your”) should read this Privacy Policy carefully to understand how Paydala collects and uses personal information and data. This Privacy Policy applies to your use of Paydala’s website(s) and hosted software services (“SaaS” or Software as a Service) that we provide or that are provided on our behalf that link to this Privacy Policy.

Changes to Privacy Policy. We review this Privacy Policy regularly and may update it from time to time. We will post any changes on this page and may also provide notice of material changes to our Privacy Policy on our website home page or through our online SaaS subscription service. The date of the last update is stated at the top of this Privacy Policy. You should regularly check this page for any changes to this Privacy Policy.

PERSONAL INFORMATION THAT WE COLLECT:

In connection with our business, we may collect and process the following categories of personal information of individuals (“Personal Information”):

• Contact information, such as your name, mailing address, physical address, telephone, and email address.
• Demographic Information, such as your age, gender, zip code, and country.
• Other individual identifiers, including date of birth, social security number, and government-issued identification (such as driver’s license or passport), which we collect through our website.
• Biometric information, such as Face ID, fingerprint, and behavioral biometrics.
• Payment information, such as credit card type and number, bank account number. However, please note that Paydala and its employees will not have access to payment data or store such data on Paydala’s servers, other than minimal information such as the last four digits of a credit card or bank account. Additional payment information is accessed and collected only by Paydala’s payment processor, as explained further below.
• Criminal convictions and offences.
• IP Information, including information regarding your electronic device(s) and IP address.
• Subscription Information, including information regarding your use of our subscription service or other services.
• Internet use information, such as browsing or search history and other information regarding your interactions with our website(s), emails, and advertisements
• Regulatory information (to satisfy regulatory obligations such as tax and other reporting obligations).
• Account credentials, including your username, password, password hints, and information used for authentication and account access.
• Profile information, such as your interests, preferences, and transaction history including deposits, withdrawals, transfers, favorites.
• Communications content, such as any messages you send to us such as feedback and questions to customer support, information you publicly post on our websites or other websites (such as product reviews or blog comments), e-mail messages, and recordings of telephone calls with customer service or other Paydala representatives, and interactions with us on our social media channels.

Data of Minors Not Collected. We do not actively collect or otherwise process Personal Information from minors and include in our subscription agreement a condition that the customer will not provide any Personal Information of minors to us. The age of a minor varies by jurisdiction. For the purposes of Personal Information collected from the European Union, the age of a minor is under age sixteen (16). For purposes of the Children’s Online Privacy Protection Act (COPPA) in the U.S., the age of a minor protected by such law is under age thirteen (13).

We collect and process certain special categories of Personal Information, including biometric information, such as Face ID, fingerprint, and behavioral biometrics, to enhance protection of users. Also, where money laundering or fraud is suspected we may collect and process information relating to criminal convictions and offences for use by our investigation team and legal authorities.

HOW WE COLLECT YOUR PERSONAL INFORMATION:

General. We collect Personal Information when you register an account with us, when you visit our website, when you use our services or SaaS software, participate in a feature of our website that requests or requires your Personal Information, and when you otherwise transact business with or communicate with Paydala.

Information Collected Automatically. When you visit our websites, information about your device hardware and software is automatically collected, including your IP address, device, browser type, domain name, access times, geographic location, referring website address and other technical information. For more information about how we collect this information through the use of cookies and related technologies, see Cookies & Related Technologies below. see Cookies & Related Technologies below.

Information Collected from Third Parties. We use a variety of third-party companies in connection with providing our website, SaaS software, and services, including analytics providers, and may collect information about you from such third parties for providing our products and services, fraud protection purposes, credit checks, address verification, account authentication and verification, and other business and commercial purposes.

Third-party Payment Processor/E-Commerce Provider. Your payment card information, such as account numbers, is collected and processed via a third-party vendor that specializes in payment processing and has committed to PCI DSS compliance.

Data Received from Paydala Platform Users. Our customers who subscribe to use our Paydala SaaS software platform (the “Paydala Platform”) have employees who are granted administration rights to create user accounts for other employees and designated persons. These customers act as data controllers (“Controllers”) in the use of the Paydala Platform and the collection and processing of Personal Information to be able to effectively operate the Paydala Platform. In such cases, our role in processing the Personal Information provided by our customers is as a “Processor,” since we are processing data on behalf of the Controller (who is the customer). As a Processor, we are obligated to process this Personal Information as part of our subscription agreement entered with the customer. The Personal Information collected in this scenario generally includes the name, physical address and phone number of each assigned user, but may also include information related to employment, such as job title and role, scheduling information assigned to an individual and maintenance tasks performed by an individual. Processing of this Personal Information is performed on behalf of the customer and for the purpose of providing the services requested by the customer.

Data Obtained for Marketing Purposes. We obtain marketing data from third parties that we use to reach out to inform potential customers and others of the services offered by our organization. The Personal Information collected generally includes the email address of a potential customer and may also include their name and phone number. We also use the contact information provided to us by our customers to communicate information about our products and services, which may include marketing our products and services.

Cookies and Other Tracking Technologies: We use analytics providers, including Google Analytics, and other tracking technologies and cookies to collect information. Tracking technologies are used collect information from your web browser through our servers or filtering systems when you visit our website(s).

Cookies store small text files onto a user’s computer hard drive with the user’s browser, containing the session ID and other data. Cookies enable a web site to track a user’s activities on the website for the following purposes: (1) enable essential features; (2) provide analytics to improve website performance and effectiveness; (3) store user preferences; and (4) facilitate relevant targeted advertising on advertising platforms or networks. Users are free to change their web browsers to prevent the acceptance of cookies. Cookies may also be set within emails in order to track how often our emails are opened.

What Types of Cookies Do We Use?

• Necessary Cookies. These cookies are necessary for you to browse the websites and use their features, such as accessing secure areas of the websites. Without these cookies, certain aspects of the websites may not be available to you.
• Preferences Cookies. These cookies collect information about how you have used the websites in the past and allow the websites to remember the choices you have made. These cookies allow us to improve how the websites work for you and tailor the websites to your preferences.
• Statistics Cookies. These cookies collect information about how you use the websites, such as which pages you most often visit on the websites, the time you spend on the websites, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the websites. All information collected is aggregated and do not identify you.
• Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.

Analytics. We may use several web analytics services to facilitate our ability to provide you with services. Among the others we may use, we may use Google Analytics, a web analytics service provided by Google, Inc. (“Google“). Google Analytics uses “cookies” to help the website analyze how users use and view the website. Any information generated by the cookie about your use of our website (including your IP address, and particulars about your browser and configuration as reported by your browser) may be transmitted to and stored by Google on servers in the United States. Please note any information collected by Google Analytics cookies do not include personalized identification information (such as names, e-mail addresses, and payment information). Google may use the information collected for the purpose of enabling us to evaluate your use of our website, certain aspects of your user experience thereon, compiling reports on activity for us and providing other services relating to our website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. More information on the Google Analytics cookies are available from Google at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage​​.

A clear GIF or pixel is a small or transparent graphic image placed on a website. The use of clear GIFs allows us to monitor your actions when you open a web page and makes it easier for us to follow and record the activities of recognized browsers. Clear GIFs are used in combination with cookies to obtain information on how visitors interact with our websites.

Information collected from these technologies may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our site, the date and time of each visitor request, and information you search for on our sites. We can also track the path of page visits on a website and monitor aggregate usage and web traffic routing on our sites. We collect this information to better understand how you use and interact with our sites in order to improve your experience. We also collect this information to better understand what services and marketing promotions may be more relevant to you. We may also share this information with our employees, service providers, business partners and affiliates.

You can change your web browser settings to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, you may not be able to use some sections or functions of our sites.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

HOW WE USE YOUR PERSONAL INFORMATION:​

We may use and process Personal Information for any purpose that is permitted under applicable data protection laws in accordance with this Privacy Policy. “Processing” of Personal Information includes collecting, recording, organizing, structuring, storing, altering or modifying, retrieving, transmitting, disclosing or otherwise making available to third parties, deleting, and otherwise using or dealing with your Personal Information. We may process your Personal Information with or without automatic means.

These purposes include:

• Our Business Purposes, including providing and processing payments; Know Your Customer requests; geolocation, anti-money laundering and fraud risk management services; addressing customer service issues; collecting debts; planning and conducting marketing activities; responding to inquiries; conducting web analytics, security monitoring, and business operations and administration; and addressing tax and other regulatory requirements.
• •Purposes Related to Our Services, Including the Paydala Platform. These purposes include operation of the Paydala Platform, remote management, education and information services, training, webinars, communication, customer service, system monitoring and data security. We use Personal Information to enable use of Paydala Platform features and related services, including through use of third-party service providers. We also use Personal Information to communicate with our users to inform them of Paydala Platform updates and service enhancements, educational information, available Paydala Platform features and modules, and other information that may be helpful or informative for our users.
• Marketing. From time to time, we may offer you the option of signing up, or having us sign you up, for various subscription and/or mailing lists used to send communications from our Paydala for purposes of keeping users, and other registered recipients updated with respect to information about our organization, news and developments, our organization’s products and services, and other communications about our organization and our affiliates (“Updates”). In order to register you on such subscription and/or mailing lists, we will ask for your name and email address. If you provide your Personal Information specifically to subscribe to a particular Update (e.g., a particular Newsletter), we will use the Personal Information you provide specifically to send you the requested Updates. If you would like to stop receiving information about Updates from Paydala, please see the “YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION” section of this Privacy Policy below.
• For the Protection of Paydala and Others. If Paydala, in good faith, determines that you have used the service to menace, threaten, harass, intimidate or otherwise deceptively pose as another person, or in any other way in violation of law. Simply, if you attempt to use the website or purchase or use a product or service for any unlawful means, you have no expectation of privacy and we may use and disclose any and all information for the protection of Paydala and others.
• Pursuant to Law, Rule or Regulation. If required or permitted to do so by law or if, in good faith, Paydala believes that such action is necessary to: (1) comply with laws and regulations or with legal processes; (2) protect and defend Paydala’s rights and property or prevent money laundering and fraud; (3) protect Paydala against abuse, misuse or unauthorized use of Paydala’s products or services; (4) protect the personal safety or property of our personnel, users of our website or the public; and/or (5) comply with tax reporting requirements, then Paydala may use and disclose any and all information as needed. The servers that serve our website automatically identify a computer or device by its IP address.
• Aggregated and De-identified Data. We may anonymize data to create statistical data or system usage data, by removing all personal identifiers and/or aggregating your data with other’s data so that it is not identifiable as to any particular person. Such de-identified or anonymized data may be retained and used by Paydala to improve its products and services and for other proper purposes, provided that such retention and use is permitted by applicable laws.
• Legal Basis. We base our processing of Personal Information on the need to perform our contractual obligations under our Paydala Platform subscription agreements and our legitimate activities as a provider of SaaS services and related services. We also process Personal Information to comply with applicable law and to exercise our legal rights. We may also use your Personal Information for internal purposes, including auditing, data analysis, system troubleshooting, and research. In these cases, we base our processing on legitimate interests in performing the activities of the organization.

HOW WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION:

No Sale of Personal Information. We never sell or rent Personal Information to third parties. However, certain of our online tracking technologies may be considered a “sale” or a “share” of your information to third parties under the California Consumer Privacy Act (CCPA) or other applicable privacy laws. Visitors to our website can opt out of being tracked by these technologies by following the instructions below under YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION or by contacting us as set forth in the PAYDALA CONTACT INFORMATION section below.

Disclosures of Personal Information. Depending on the circumstances, we may share your information in the following circumstances:

• With Your Consent. We may disclose, share, or make available your information with your consent, which may be obtained in writing, online, through “click-through” agreements, when you accept our terms for our websites, orally (including over the telephone), or by other means such as communications through our various social media channels.
• With Service Providers and Business Partners. We may disclose, share, or make available your information with our third-party service providers, business partners, and other third parties, such as payment processing partners, risk management partners, data service providers, partners that facilitate billing, and customer service, third-party auditors and law firms, marketing and advertising networks (including those that provide ad measurement services), internet service providers, data analytics providers, companies that help debug and identify and repair errors that may impair the functionality of our websites, and third parties that help protect against malicious, deceptive, fraudulent, or illegal activity.
• In a Business Transfer. We may disclose, share, or make available your information as part of a business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of Paydala assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction.
• For Legal Process and Protection. We may disclose, share, or make available your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) enforce or apply agreements, or initiate, render, or bill for use of the websites; (2) protect our rights or interests, property or safety or that of others; (3) in connection with claims, disputes, or litigation – in court or elsewhere; (4) protect users of our websites and other carriers, providers, or partners from fraudulent, abusive, unlawful, or otherwise improper use of our websites; (5) facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.
• Aggregated and De-identified Data. We reserve the right to disclose aggregated user statistics as well as non-personally identifiable information (such as anonymous usage data), in order to describe our services to prospective partners, subscribers, licensees, advertisers, and other third parties.

HOW WE PROTECT PERSONAL INFORMATION:

We take commercially reasonable steps to protect your Personal Information in accordance with all applicable laws and regulations, as appropriate to the sensitivity of your information. Paydala uses technical and organizational measures to protect the personal data that we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. Although we are committed to employing reasonable technology in order to protect the security of our website, even with the best technology, no website is 100% secure. In transacting business with us through our website, you assume the risk inherent in transacting business online.

RETENTION OF PERSONAL INFORMATION:

We keep your information for as long as necessary in accordance with the purposes for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is commercially reasonable, taking into account the sensitivity of the information.

Paydala reserves the right to retain usage data relating to our products and services, as well as data that has been anonymized and/or aggregated, to the extent permitted by applicable laws. With respect to any Personal Information collected by us for marketing or for our own internal purposes, we will retain that data for a reasonable time in order to fulfill those purposes.

YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION:

General. If you wish to opt out from any of the uses of Personal Information that are specified in this Privacy Policy, except in the case of legal proceedings or where your data is required for tax and transactional purposes, please contact us as described in the “PAYDALA CONTACT INFORMATION” section below. Please note that your subsequent disclosure of Personal Information to us may override prior opt-out requests. Paydala does not discriminate against those who opt out. However, opting out may prevent us from conveniently and efficiently providing further product support services and information to you.

Unsubscribing to Marketing Communications: In particular, if we are sending you email communications of a marketing nature, an ‘unsubscribe’ option is provided in the footer of every email. You may also contact us directly to unsubscribe to marketing emails or other marketing communications, at the contact information set forth in the “PAYDALA CONTACT INFORMATION” section below. If you have agreed to receive marketing communications, you may always opt out at a later date.

Phone & SMS Text Messaging. You can opt out of receiving any promotional or marketing text messages or calls to your phone number at any time by: (i) for text messages, texting “STOP” in response to any marketing text message you receive from us or contacting us as set out in the PAYDALA CONTACT INFORMATION section below and specifying you want to opt out of marketing text messages; and (ii) for marketing phone calls, requesting opt-out during any call you receive from us or contacting us as set out in the PAYDALA CONTACT INFORMATION section below and specifying you want to opt out of marketing calls. In order to provide our Services to you, we will still have the right to contact you by phone and texting for Services-related purposes.

Analytics. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

Your California privacy rights. This section applies to California residents only.

• Shine the Light law. Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of Personal Information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. Paydala does not presently share any information with third parties for direct marketing purposes. However, to submit such a request, you can contact us as set forth below.
• California Minors. California residents under age 18 (“California Minors”) have additional privacy rights under California law. A California Minor who uses the Services has the right to either remove content or information posted on the Services by such user, or, if removal of such information by the user himself or herself is not enabled or possible, the user may request and obtain removal of such content or information. To have any content or information provided by a California Minor removed by us, contact our Data Privacy Officer at the contact information provided below. This removal does not ensure complete or comprehensive removal of any such content or information posted.

PRIVACY POLICIES OF OTHER WEBSITES AND THIRD-PARTY SERVICES:

Our websites may contain links to third-party websites and services. Please note that these links are provided for your convenience and information, and may operate independently from us and have their own privacy policies and/or notices. You are strongly encouraged to review such policies or notices. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within, or linked to, a page of our websites.

PAYDALA CONTACT INFORMATION:

If you have any questions about this Privacy Policy or your Personal Information that we hold, would like to cease receiving marketing materials from us, have any complaints, or would like to exercise any of your other rights related to your Personal Information, please contact us:

Paydala Legal Affairs

Email: legal@paydala.com

Phone: (480)269-0114

Mail:

Paydala, Inc.

20551 N. Pima Road, Suite 200

Scottsdale, AZ 85255

If you wish to report a complaint or if you feel that Paydala has not addressed your concerns in a satisfactory manner, you may also contact your state or local data protection authority.

Last updated: May 30, 2025