KUBRA EZ-PAY PRIVACY NOTICE

Last updated: December 30, 2019

This Privacy Notice (the “Notice”) describes how KUBRA Data Transfer Ltd. (“KUBRA”, “we”, “our” or “us”) handles personal information in connection with the operation of the KUBRA EZ-PAY services offered to individuals through https://www.ez-pay.co or through the KUBRA EZ-PAY mobile app (collectively, the “KUBRA EZ-PAY Services”).

This Notice applies only to information that KUBRA obtains through the KUBRA EZ-PAY Services and describes how we can use the information we obtain and with whom we may share it. KUBRA does not sell any personal information to third parties. This Notice does not describe the privacy practices of the utilities, insurance companies, government agencies and other service providers for which you use the KUBRA EZ-PAY Services as a payment platform (collectively, the “Service Providers”). We encourage you to review their privacy policies and other similar statements.

WHAT INFORMATION WE OBTAIN
We obtain different types of information, including personal information, when you use the KUBRA EZ-PAY Services. This information may be provided by you, such as when you create an account, it may be automatically collected from your browser or mobile device using technologies such as cookies, or it may be obtained from other sources.

Information you provide:
We obtain information you provide in relation to your use of the KUBRA EZ-PAY Services, including when you make a one-time payment or create an account. This may include:

• your contact information, including your name, email address and phone number;
• your account numbers for the Service Providers with whom you engage; and
• your bank account number or debit or credit card number information (including payment card number, expiry date, security code).

We may also obtain information you provide us about others, such as the phone number and email address of the recipients to whom you want to send a receipt of the bill payment, if you choose to share the receipt with others.

If you contact us with any questions or requests relating to the KUBRA EZ-PAY Services, we obtain the information you provide to us in connection with your inquiry or request.

Cookies and Internet Technology:
We may use internet technologies such as cookies and web beacons or other similar technologies to automatically obtain certain information when you access the KUBRA EZ-PAY Services from your web browser or mobile device, such as information about the number and frequency of visitors, technical information about browsers and devices used to access the KUBRA EZ-PAY Services, and information about crashes or other technical issues. In addition, we may automatically collect certain information across the browsers and devices you use to access the KUBRA EZ-PAY Services as well as across third-party sites, apps or other media. These technologies may assign or collect a unique identifier on your browser or device, and may reside, among other places, on your computer or device, within webpages or mobile apps. We may use these technologies to administer the KUBRA EZ-PAY Services, understand usage of the KUBRA EZ-PAY Services and improve the content and offerings of the KUBRA EZ-PAY Services.
For more information about the use of automated means in the context of interest-based advertising and how you can limit tracking on your browser or mobile device, see Interest-based advertising .

Information we obtain from other sources:
We may obtain information about you from third parties, including the Service Providers with whom you engage.

HOW WE USE INFORMATION WE OBTAIN
We may use the information we obtain through the KUBRA EZ-PAY Services for a number of purposes, including, but not limited to:

• providing you with the KUBRA EZ-PAY Services, as well as information you may request;
• marketing and advertising the KUBRA EZ-PAY Services and other KUBRA products and services;
• sending you communications, including informational and marketing communications;
• improving the KUBRA EZ-PAY Services we provide and customizing the user experience;
• generating and analyzing statistics about your use of the KUBRA EZ-PAY Services;
• detecting, preventing, and responding to violations of this Notice or the Terms of Use, violations of law, or other misuse of the KUBRA EZ-PAY Services; and
• supporting our business operations.
  
  

KUBRA has relationships with advertising companies who may use technology such as cookies and web beacons to provide you with advertising related to the use of KUBRA EZ-PAY. To learn more about your rights in relation to this ad network interest-based advertising on your browser, including your choice to opt out, you can follow the instructions provided by the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”) to place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser. If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt-out choices for that specific browser.

To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “Limit Ad Tracking” for iOS or “Opt-out of interest-based ads” for Android.

These opt-out mechanisms are provided by third parties. KUBRA does not control or operate these mechanisms or the choices provided through these mechanisms.

WITH WHOM WE SHARE INFORMATION
We may share the information we obtain from you through the KUBRA EZ-PAY Services:

• with the Service Providers with whom you engage;
• with our affiliates and subsidiaries;
• with third parties that provide services or handle transactions on our behalf;
• as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the KUBRA EZ-PAY Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities;
• we reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation; and
• we may share your information with third parties when you consent to or request such sharing.

HOW WE PROTECT YOUR INFORMATION
We maintain reasonable administrative, technical, and physical safeguards to protect the personal information we obtain through the KUBRA EZ-PAY Services. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. If you create an account to use the KUBRA EZ-PAY Services, you are responsible for keeping your password secure.

THIRD-PARTY LINKS AND FEATURES
The KUBRA EZ-PAY Services may contain links to third-party websites, mobile apps or features, including through social media features and widgets on our website. KUBRA is not responsible for the collection and use of your information by such third parties. We encourage you to review the privacy policies or other similar statements applicable to third-party websites, mobile apps or features.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

Under California law, specific disclosures are required and California residents have additional rights regarding their personal information. Please review this section to learn more.

Residents of California may have the following rights:

1. Right to access your personal information. You may request to access the categories and specific pieces of personal information that we collected about you in connection with your use of the KUBRA EZ-PAY Services.
2. Right to deletion. Subject to certain exceptions, you may ask us to delete the personal information we collected about you in connection with your use of the KUBRA EZ-PAY Services.
3. Right to disclosure. You may request to receive additional details about the sources from which we collect your personal information, the reasons we collect and share your personal information, and the types of third parties with which we share the information we collected about you in connection with your use of the KUBRA EZ-PAY Services.
4. Right to opt out of sales. Under the CCPA, certain types of sharing of personal information may constitute a “sale” of your personal information. Kubra does not “sell” the personal information we collected about you in connection with your use of the KUBRA EZ-PAY Services.
5. Right to be free from discrimination. You may exercise any of the above rights without fear of being denied goods or services, including access to the Tools. We are permitted to provide a different level of service or charge a different rate if the difference is reasonably related to the value of your data.

If you would like to exercise any of your CCPA rights related to your use of the KUBRA EZ-PAY Services, please contact us by email as indicated in the Contact Us section below.

Please note that KUBRA is not responsible for the data handling practices of the utilities, insurance companies, government agencies and other service providers for which you may use the KUBRA EZ-PAY Services as a payment platform (i.e., the Service Providers). If you want to exercise your CCPA rights with respect to the personal information the Service Providers collect and maintain about you, you will need to contact them directly to exercise your CCPA rights.

Your Shine the Light California Rights (CA Civil Code § 1798.83)

Residents of California may request a list of third parties to which certain personal information (as defined by applicable California law) obtained through the KUBRA EZ-PAY Services and disclosed by KUBRA during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please write to us at 40 E Rio Salado Pkwy, Suite 535, Tempe, AZ, 85281. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via other contact channels, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Do Not Track
KUBRA does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

NON-U.S. VISITORS
The KUBRA EZ-PAY Services are intended for U.S. users. If you are located outside of the United States, please note that the personal information we collect in connection with your use of the KUBRA EZ-PAY Services will be transferred to the United States and other countries.

CHILDREN’S INFORMATION
The KUBRA EZ-PAY Services are not directed to, nor do we knowingly collect personal information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us as indicated below.

CHANGES TO THIS PRIVACY NOTICE
We may update this Notice from time to time to reflect changes in our privacy practices or applicable laws. We will notify you of these changes by publishing the updated version on our website and indicate at the top of the Notice when it was most recently updated. Your use of the KUBRA EZ-PAY Services will be governed by the current version of this Notice.

DISPUTES
Any dispute you may have arising under this Notice will be resolved in accordance with the Terms of Use.

CONTACT US
If you have any questions about this Notice or you would like to review or request changes to the information collected in connection with your use of the KUBRA EZ-PAY Services, please contact us.

SUPPLEMENTAL NOTICE TO EU RESIDENTS

Lawful Grounds

If you are a resident of the EU, this notice describes how KUBRA acts in accordance with the General Data Protection Regulation (“GDPR”). KUBRA relies on legitimate interest to process your data for the purposes described in the Use of Personal Information section above.

Transfer of Data

KUBRA operates its Services from the United States and Canada, meaning your personal data may be transferred to the US, Canada and/or to countries outside of the EU. Whenever your personal data is transferred outside the EU, KUBRA will take all reasonable steps necessary to ensure the data is secure and treated in accordance with KUBRA’s privacy policy.

Where required by the GDPR, appropriate safeguards, such as the standard contractual clauses approved by the European Commission will be put in place.

Right to Withdraw Consent

In the circumstance where KUBRA may require your consent in processing your personal data, you have a right to withdraw your consent for such processing at any time. To withdraw your consent, please contact us. Once your withdrawal notification is received, KUBRA will no longer process the information for the specific purpose(s) for which the original consent was given, unless it is done for a legal basis.

Requests

Under the GDPR you have the right to:

• Request access to your personal data
• Request the rectification of personal data
• Object to the processing of your personal data
• Request the erasure of your personal data
• Request the transfer of your personal data to another party
• File a complaint with a supervisory authority

Please contact us, if you would like to exercise any of these rights. We will respond to your request within a month.