This Privacy Policy (“Privacy Policy”), is an integral part of our End User License Agreement (“EULA”), and governs the processing and transfer of personal data collected or processed by PassbookWallet.io (“Company”, “we”, “us” or “our”) when you accessing or using our mobile application or our services, all as detailed in the applicable EULA (respectively the “App” and “Service”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: [email protected]

This Privacy Policy explains our data collection practices that are applicable toward any users of our App or our Services (“you” or “your”).

For the purpose of operating our Services and App, we use several service providers as detailed in this Policy (collectively “Service Providers”):

In app payment providers;

- App Store by Apple
- Play Store by Google

Advertising partners;

- No in-app advertising existed in PassbookWallet.

Fraud prevention and analytic tools; and

- Google Analytics, Firebase

Tracking tools.

- Google Analytics, Firebase

We contractually ensure our Service Providers comply with applicable data protection laws.

1. OVERVIEW OF THE INFORMATION WE PROCESS FROM YOU

We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, session duration and page impressions, etc.

The second type of information is identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Push Notifications:

We may store Firebase Cloud Messages token. If you wish to stop getting push notifications, you may do so simply by disables push notifications on your device’s settings or uninstall the app. This information will be processed to allow us to send push notification to users from our server. As the token is Non-Personal Data it does not require a lawful basis.

In-App Payment Information:

When you make a payment through our App and offered Services, all payment are in-app payments and are subject to the applicable App Store terms and privacy policy.

Google Terms of Service

Google Privacy Policy

App Store Terms of Use<

App Store Privacy Policy<

We use in app payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment.

We receive an order number which is connected to a user ID which was generated when installing the app (non identifiable). NA

Log Data and Unique Identifiers:

In case of an error in the App we collect data and information (through third-party service providers) such as “Log Data” or “Crash Data”. This data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our Service, the time and date of your use of the Service, and other statistics. In most cases, this data will not include Personal Data, however we treat this information as Personal Data as we may be able to reasonably identify you.

Profiling Data:

When you using our App we may display advertisement, our partners, the advertisers may place an SDK (as detailed below) and collect certain data on you for the purpose of displaying advertisement.

If you wish to prevent the display of advertisements or other identifiers for interest-based advertising, you may change your device settings to reset such advertisement or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).

Please note that if you reset your advertising settings or opt-out of interest based advertising, you may still see advertisements in our App, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience. Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes. We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.

Technical Data:

We also collect certain technical Non-Personal Data which relates to your use of our App such as: the type and version of device, application, or browser used, operating system, or time zone setting, country, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs. We use this data in order to maintain, support, improve, protect and manage our App and Services. This information does not include Personal Data. As the technical data is Non-Personal Data it does not require a lawful basis.

2. HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with the App and Services, we may collect information as follows:

2.1. Automatically – we may use SDK (as elaborated below) or similar tracking technologies to gather some information automatically when you interact with our App and Services.

2.2. Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the Services, contact us communications, etc.

3. SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, other than as specifically mentioned herein:

Subject to your consent - we may share your Personal Data upon your explicit consent. Once we share your Personal Data under these circumstances, that data becomes subject to the other third party’s privacy practices.

Policy enforcement and third party rights - we may share your Personal Data in the event required to enforce our policies and agreements or to establish and exercise our rights to defend against legal claims, including investigations of potential violations and in order to detect or prevent illegal activities or other wrongdoing, security or technical issues. In addition, we may share your Personal Data to prevent harm to the rights or safety of our users or any applicable third party.

Law enforcement - we may share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request.

Affiliate company and corporate transaction – in the event required, we may share your Personal Data with our parent company, any subsidiaries, joint ventures, or other companies under common control (“Affiliated Companies”) or in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). Our Affiliated Companies or acquiring company will assume the rights and obligations as described in this Policy.

Service Providers - we may disclose Personal Data to our service providers to perform requested services on our behalf. Certain of our service providers shall include servers, payment processors, advertisement services, governmental agencies and representatives. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services and are all signed on applicable data protection agreements limiting their use of the Personal Data.

4. SDK & TRACKING TECHNOLOGIES

Our Services and some of our Service Providers utilize “cookies” or “software development kits (“SDK”)” anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:

NAME PURPOSE PRIVACY AND OPT OUT

Google Play In-app billing Google Play Privacy Policy: https://play.google.com/about/privacy-security-deception https://policies.google.com/privacy?hl=en

Firebase • Remote Config- data

• storage and processing location

• Crashlytics- data

• Cloud Messaging

• data encryption

• security purpose

• a/b testing

• in-app mesging

• predictions

• analytics Firebase Privacy Policy: https://firebase.google.com/support/privacy

Advertisers:

• AdMob

• AdColony

• Applovin

• Chocolate Platform

• Facebook Audience Network

• Index Exchange

• Media.net

• Mobfox

• OpenX

• PubMatic

• Rubicon

• Sharethrough

• Yieldmo

And as may be updated from time to time (collectively “Advertisers”). The Advertisers are advertising Service Providers. Their targeted advertising SDKs collect information about your browsing activity across multiple websites and online services in order to provide you with relevant advertisements on the App and Services of third parties. The information collected using these advertising SDK does not disclose your identity, and helps us analyze the effectiveness of our advertising. • AdColony: https://www.adcolony.com/privacy-policy/

• AdMob: https://policies.google.com/privacy?hl=en

• Applovin: https://www.applovin.com/privacy/

• Chocolate Platform: https://chocolateplatform.com/privacy-policy/

• Facebook Audience Network: https://www.facebook.com/about/privacy/

• Index Exchange: https://www.indexexchange.com/privacy/

• Media.net: https://www.media.net/privacy-policy/

• Mobfox: https://www.mobfox.com/privacy-policy/

• OpenX: https://www.openx.com/legal/privacy-policy/

• PubMatic: https://pubmatic.com/legal/privacy/

• Rubicon: https://www.rubicon.com/privacy-policy/

• Sharethrough: https://www.sharethrough.com/privacy-center

• Yieldmo: https://yieldmo.com/privacy-policy/

5. USER RIGHTS

According to data protection and privacy laws may grant you with certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please fill out the Data Subject Request Form (“DSR”) available here and send it to our email at: [email protected]

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

6. DATA RETENTION

We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, with or without previous notice to you.

7. SECURITY

We take great care in implementing physical, technical, and administrative security measures for the services that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

8. DATA TRANSFER

We use Google Cloud which are located in EU, US and Asia. Further, certain processing activities are conducted in United States, or other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

9. CHILDREN

Our App and Services are intended for general audience and is not directed to persons under 13 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 13 years old. If we become aware that a person under 13 years old has provided us with Personal Data, we will delete such data from our databases.

10. DO NOT TRACK DISCLOSURE

The App and the App’s Services do not respond to Do Not Track signals. For information about Do Not Track, please see: http://www.allaboutdnt.com/

11. CHANGES AND UPDATES

We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Amended” heading located at the top of this Privacy Policy.

12. 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 our privacy practices, please contact us: [email protected]