LAYA Terms of Use and Privacy Policy for travel payments platform

Last updated: May 10, 2023

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Introduction:

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1. The LAYA application is a travel payments platform ("Digital wallet" or "E- wallet") operated by LAYA 2022 Ltd. (hereinafter, respectively, the "App" or the "Company" or "Us"). The App is used by worldwide travelers and enables smart, easy and centralized expense management of an individual traveler or a group.

2. IDT Financial Services Limited ("IDT") is the issuer of the card associated with LAYA. Accordingly, IDT is a joint controller of some of your personal information as it relates to, and is required for, the administration and operation of the card. A copy of IDT's privacy policy may be found at http://www.idtfinance.com/privacypolicy.pdf.

3. We respect your privacy and are committed to protecting the personal information you share with us in connection with your use of the App. 

4. This Privacy Policy provides details regarding the collection, use, and disclosure of personal information, in compliance with the Israeli Protection of Privacy Law, 5741-1981, and the Regulations enacted therefrom.

5. The provisions of this Privacy Policy shall apply to any information about the User provided by the Company through the App, whether provided by the User himself at the time of registration to the App or collected during the use of the App Services or received from third parties, as part of the provision of the Service, such as other users of the App, authorities, companies, third-party Apps, issuers or operators of the debit cards you have entered into the App (hereinafter collectively: "The Information"). 

6. Please note that the use of the App is subject to your agreement to its current Privacy Policy and Terms of Use, as well as changes thereto. 

7. The app is limited to people aged 18 and over. Minors are not allowed to use the service. 

8. We may change the Privacy Policy and Terms of Use from time to time, jointly or severally, to reflect technological, business, legal, or regulatory changes. 

9. Updates to our Privacy Policy will be published in this document, which will be found in its updated format in the App or our website. Therefore, we recommend reviewing the Privacy Policy from time to time.​
    

​Personal Information Collection:

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1. All information provided by you when registering for or using the App is provided with your consent and free will. It is clarified that you are not obligated to provide us with the information (unless otherwise specified as required by law), but your refusal to provide information may prevent you from using some or all the App Services.

2. As part of receiving the services, you will be required to give us, among other things, your full name, phone number, date of birth, and ID number. In the case of issuing a digital credit card, you will also be required to provide the following details: email address, photocopy of passport, means of proof of residential address (attachment of identification card or confirmation of property tax payments in the last three months or your listed address on your driver's license), PIN CODE as defined by you (It is recommended to change it to a fingerprint or facial pattern identification. In addition, you may be asked for your credit card information (hereinafter - "the information"). The details that will be provided by you can and will be verified against information about you that is already in possession of AU10TIX or will be in its possession or will be lawfully handed over to it. IT IS HEREBY CLARIFIED THAT YOU ARE UNDER NO LEGAL OBLIGATION TO PROVIDE THE STATED INFORMATION UNLESS OTHERWISE SPECIFIED, AND THAT THE TRANSFER OF THE INFORMATION DEPENDS ON YOUR WILL AND CONSENT.

3. To the extent that you do not wish us to use the information collected about you as mentioned, you are requested not to use the services in the application or on the website.

4. We collect the information to provide you with the services and to help customize and improve your experience in the various services.

5. Information that is collected automatically, and which does not identify you personally (Usage Data): When you use the Services, information that is automatically sent by the computer, mobile phone, or other device that you use to access the Services is collected. The information included, among others: data on the pages you access, the IP address of the device from which the connection to the website was made, identification number or unique identifier of the device, device type, geographic location information, computer and connection information, network information for mobile devices, statistical data on views On pages, traffic to and from the sites, referral URL, advertisement data as well as weblog data and other standard details. You can avoid the collection of the information through your private web browser settings. 

6. You may manage the access permissions as you wish, whether through the App and/or the settings on your device, but please be aware that blocking certain permissions may impair your ability to use the App and/or impair your ability to enjoy its services to the maximum. For example, you can turn off and activate access to the NFC component at any time by changing the settings in the digital wallet, but without providing access to the App to the NFC component when making a payment through the digital wallet, it will not be possible to make the transaction through it; You may also turn off and activate your phone book access permissions at any time, but if you do so you will not be able to continue using the Services of the App.
    

Use of Personal Information:

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1. We collect and use your personal information for the following purposes:

   • Providing our services and communicating with you (the User). 

   • Credit risk management, analysis, and rating, including fraud detection monitoring actions, and prevention of misuse of services.

   • Supervised and security of the App's resources and its use, including identity verification, detection, and prevention of fraudulent activities.

   • Conducting research, data analysis, and statistics, and improving the services.

   • Sending you notices, updates, and advertising and marketing offers that may interest you in connection with our Services, all under the law.

   • Detection, prevention, and treatment of any technical problem or malfunction and/or complaint and/or request of the user related to the provision of the services in the App.

   • We may process your user and usage data that is collected automatically to facilitate, operate, maintain, and improve our service, and is as necessary for the performance of our services, to comply with our contractual obligations; to provide technical and customer service and securing you, ourselves and our services

2. Some of your information will be transferred to our sub-provider, AU10TIX Ltd., for verification of details and fraud prevention. 
    

Sharing information with third parties

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1. To provide the service, we may transfer your information, including personal details and financial details, to third parties who provide support services to the App, to provide the service, verify the details, or operate the credit card. Some of these third parties may be located outside of Israel. 

2. We share your information with external providers while confirming compliance with the law, the company's Privacy Policy, and the use of all appropriate means of confidentiality and security.

3. We may share your information with third parties in any of the cases listed below: 

   1. In case the company has transferred and/or terminated to a third party its activity and/or its rights and obligations to the user, to third parties, provided that such third parties accept the provisions outlined in this Privacy Policy.

   2. In any case, the user has violated the Terms of Use, including the terms of the Privacy Policy and/or the designated Terms of Use, and/or in cases where the user has proposed or attempted to execute the user and/or anyone acting on the user’s behalf, through the app and/or in connection with, actions contrary to the provisions of the Terms of Use, including the Privacy Policy, including the designated Terms of Use and/or the provisions of any law.

   3. Due to any dispute, claim, demand, and/or legal proceedings that will be conducted between the user and/or on the user’s behalf and the company and/or anyone acting on its behalf.

   4. If a judicial order is obtained instructing you to provide your details or information about you to a third party.

   5. When, according to our discretion, the disclosure of the information is necessary to prevent serious damage to the company's property and/or body, to the user and/or to third parties, and/or to prevent other serious damage.
       

Security Measures:​

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1. We maintain a strict information management structure and framework to prevent any unauthorized access to and loss, falsification, or leakage of Personal Information mainly by:

   • Maintaining updated sets of information security policies and procedures related to the collection, use, maintenance, provision, deletion, and disposal of personal information.

   • Information security in human resources including screening according to suitability for the position, training to raise awareness, and periodic awareness level checks.

   • Other organizational security measures.

   • Physical security measures-

     • No personal information is stored on local servers or on paper.

     • When contracting with information storage providers, we make sure that they meet accepted standards for information security such as ISO27001 and/or SOC2 type 2. 

     • Measures are put in place to prevent theft or loss of devices, electronic media, and paper documents which contain Personal Information.

   • Technical security measures

     • Access controls are put in place to limit the number of access privilege holders and the scope of the Personal Information database that they are authorized to access.

     • The information system which processes Personal Information is protected from unauthorized access by external parties and malicious software.

   • We operate designated protection and monitoring systems to alert and prevent unauthorized intrusion or information leakage.

2. We store your information only in Israel and the European Union and take the protective measures prescribed by Israeli law when transferring information outside the borders of the country. 

3. We implement appropriate security measures to protect personal information from unauthorized access, disclosure, alteration, and destruction. We use industry-standard encryption technologies to secure information transmission and storage.

4. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

5. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

6. All use of third-party Apps or services is at your own risk and subject to such third party's terms and privacy policies. 
    

Information Retention:
 

1. We retain personal information for as long as necessary to provide our services and as required by law. If a user requests the deletion of their personal information, we will delete it within a reasonable time, subject to any legal or regulatory requirements.

2. The Company maintains lawfully registered databases to store the details and information provided and/or collected about users of the App and/or Services.

3. The databases are used, inter alia, to manage and operate the App and the Services, operational, marketing, and/or statistical needs, providing service to customers and users, operating, and managing sales, conducting surveys, conducting research, direct mail, etc., all subject to the provisions of this Privacy Policy.

4. The Company will retain the personal information about you for as long as the information is necessary to achieve the goals and perform the actions specified in this Privacy Policy above, as well as for period that may be required or permitted by law, and generally for a period of 7 years, ​​from the date the relationship terminates, unless a specific request was submitted by the data subject and/or following other legal requirements made by a third party such as lawsuit and/or abiding by contractual commitment.

5. The Company will also retain some of your Usage Data that are collected automatically for internal analysis purposes. Such Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

6. Please note that deleting the App from your smartphone does not constitute the termination of the contract between you and the Company, and therefore if your engagement with the Company is not terminated by the Terms of Use, the Company will be entitled to use the existing information about you in the Company's databases.

7. In addition, after the termination of the engagement, the Company will continue to keep in its databases the existing personal information about you under the provisions of the law and/or as permitted by law, but the Company will not make commercial use of such information.
    

Transfer and receipt of funds within a group:
 

1. A user may open a joint expenses group and request recipients for payments. Payments will be transferred by group members ("recipients") to the digital wallet of the group initiator, according to the details entered by him. A recipient is not obligated to be a User.

2. The initiator of the group will be able to send the request to join the group by sending an SMS message. A recipient who accepts the invitation will be added to the group and become a member of the group. A recipient who is not registered for the service will enter the details required to join the service and respond to the order. Joining the group is conditional on the group member's consent to our Terms of Use and Privacy Policy, and the disclosure of his details to the initiator of the group and its other members.
    

Direct mail:
 

1. When downloading the App, the User may approve, or deny, the receipt of notifications on the device on which the App is installed; These notices will also include advertisements from time to time. You can block receiving these messages at any time through the settings in the App and/or blocking the notification service in the operating system of the device on which the App is installed. Please note that even if you choose not to receive advertising or marketing messages or personalized offers from us, we may send messages of service and/or operational nature required for the provision of services in the App.
    

Chatbot:
 

1. We use chatbots to provide automated customer support. A chatbot is a computer program that communicates with you via text in a digital messaging interface and artificial intelligence. Our chatbot is supported by Intercom, a third-party chatbot service provider based in 55 2nd Street, 4th Fl., San Francisco, CA 94105, USA which provides services on our behalf. The Chatbot uses an automated decision-making process, deciding the right answer based on your question, and will receive message logs and usernames during your interaction with the chatbot. Message logs contain information such as your account information, including your username, email address, phone number, and address, as well as any other content you choose to provide when contacting customer support via the chatbot. This information will be retained for as long as necessary to fulfill the purposes set out in this Privacy Policy and will only be used to provide customer support and improve the quality of chatbot services. 

2. If you have any questions or concerns about our Privacy Policy, please contact us through our chatbot Services. 
    

Other sites and Apps:
 

1. The Services may contain links to other websites or resources. When you click on one of these links you will connect to a website or other Internet resource, which may collect information about you voluntarily or through cookies or other technologies. Any use of third-party content, including any entry by the user to third-party websites by referring to the services, will be carried out at your sole responsibility and there will be no claim and/or claim against the company in connection therewith, including but not limited to any damage, direct or indirect, resulting from use and/or entry as mentioned and/or due to a breach of privacy and/or any collection of information and/or use thereof by third parties. We encourage you to read those third parties' privacy policies and terms of use.
    

Payment services on the site:
 

1. The payment services on the app are carried out through a dedicated link for clearing on third-party websites. Clearing of credit cards is done in an encrypted and secure manner through an external credit clearing company, which uses modern encryption methods and by encryption mechanisms that are in accordance with international standards and according to the instructions of the relevant credit companies. You can review the privacy policies of these sites.
    

User Rights:

1. Users have the right to access and correct their personal information, as well as request its deletion, subject to any legal or regulatory requirements. Users can also opt out of marketing communications at any time.

2. If you wish to exercise your rights, please contact us through our Chatbot. You will be asked to provide your details, such as your name, telephone number, address, e-mail address, and the information you wish to review or which you wish to correct or delete. Insofar as you wish to allow another person to review the information for you, we will also ask you to attach an explicit power of attorney in this regard.
    

Limitation of liability:
 

1. The contents of the application and the website can be used as they are ('As Is'), and the company does not undertake to adapt the service on the website to the user's needs. The user of the website will not have any claim, claim or demand against the company regarding the features of use, the limitations or the manner of its use. The company reserves the right to remove the application or to change from time to time its structure, its appearance, and the availability of the services and content provided in it, without the need for prior notification. The company does not guarantee that the service provided in the application will be provided as usual without interruptions and interruptions, or will be immune from damages, breakdowns, malfunctions, hardware or software failures, or harm from any other reason, and the company will not be responsible for any damage, direct or indirect, caused to the user or his property as a result. The company's website is limited to personal use, and you may not make any commercial use of it without express written permission from the company. It is strictly forbidden to make changes to the website or to copy, distribute, transmit, display, perform, reproduce, publish, issue a license, or sell any item of information, software or services originating from the website. For the avoidance of doubt, it is hereby clarified that the user alone will be responsible for the manner in which he uses the service and information, the company is not responsible for any illegal activity that may be carried out, to the extent that it may be carried out, by any of the users of the website and/or any other party on the internet over which it has no control. Without exception, the user may not:

   • Make commercial use of the website and/or through it.

   • Disrupt or violate any right of another user on the website and/or the Internet, including the right to privacy and/or collect personal information about the users on the website, including by automatic means.

   • Harm the dignity or privacy of another user and/or use the site to damage the good name of any person and/or publish inflammatory, fraudulent, fraudulent, defamatory, and/or any other information that is false, unreliable or has the purpose of intentionally harming.

   • To use the wireless network to harm any person and/or company, in any way.

2. Failure to comply with these limitations may lead to preventing the user's access to the site and even expose him to civil and/or criminal liability, according to any law.
    

Intellectual Property:
 

1. Full copyright and intellectual property on the website, including the name and trademarks, in the design of the website, in the content published on it by the company or anyone on its behalf, in any software, application, computer code, graphic file, text and any other material contained therein, whether it belongs to the company alone or to a third party who granted the company the right to use them, and their use by you is prohibited without receiving express prior written permission from the company. You may not copy, distribute, publicly present or hand over to a third party any part of the above without obtaining the company's prior written consent. The trademarks and advertisements of advertisers on the app and the site belong to these advertisers only. They also may not be used without the prior written consent of the advertiser.
    

Indemnification/Compensation:
 

1. You undertake to indemnify and compensate the company and/or anyone on its behalf for any damage, expense, or loss, direct or indirect, including court costs and attorney's fees, that the company incurs due to violating any condition of the terms of use, or performing any other action contrary to any law in connection with the website.
    

Force majeure:
 

1. Any delay or blocking of access to the website due to force majeure, such as war, strike, fire, power outage, weather, etc., will not be considered a violation of this agreement by the company and will not give you compensation and/or the right to sue.
    

Law and place of jurisdiction:
 

1. The use of the website will be governed exclusively by the laws of the State of Israel. The exclusive place of jurisdiction for anything and everything arising from the above terms of use or from the website is in the competent courts in the city of Tel Aviv.
    

Changes to the terms of use and the Privacy policy:
 

1. he company reserves the right to change or adjust the terms of use and privacy policy from time to time at any time and in accordance with its sole discretion. The changes will take effect on the date of the last update of the document. Continued use of the services after the last update date will constitute the user's acceptance of the changes.
    

Contact Us:
 

1. You are welcome to contact us through the means of communication published on our app and website.
   You are welcome to contact us with any questions, at the email address Laya@layavision.com.