Privacy Policy

Last Updated: February 13th, 2024

The Privacy Policy describes how Papaya (“Papaya,” “we” and “us”) collects, uses, protects, and discloses information when you visit or use our website, www.papayadash.com, our marketplace site, marketplace.papayadash.com or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media or otherwise interact with us, purchase our products or services. This Privacy Policy applies to all users of the website. By using the website and the marketplace sites, you are consenting to this Privacy Policy. Please read it carefully.

Personal Information We Collect

Listed below are details about the categories of information we collect:

• Contact Information: name, email address, mailing address, and telephone number
• Demographic information: We may collect information like your gender and age. We may also collect your zip/postal code.
• Financial Information: tax identification number, financial or bank account information, tax- related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address
• Identifiers: IP address, user name, account number, password and other security information for authentication and access
• Geolocation Data: the general region or area from which you access our site
• Usage Data: data concerning your Internet or other electronic activity including browsing and click history, device types, operating system, browser settings, IP address, language settings, and Site use data including information about how you navigate the Sites, other websites, and the Internet
• Audio/Visual Data: audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings
• Commercial Information: records of products or services purchased, obtained or considered, or other purchasing or consuming histories;
• Inferences: we may use information from the categories described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.

Business Purposes for Collecting Personal Information

We use your personal information for the following purposes:

• Transactional Purposes: We use your contact information, demographic information, financial information, identifiers, commercial information and inferences to:

• Provide you with the requested products or services
• Provide a quote for our products or services
• Fulfill your order
• Process payments
• Send confirmations and shipping or transit information and track your shipment
• Communicate with you
• Respond to customer service requests and inquiries; and
• Administer an online account.

• Analytical Purposes: We use your identifiers, usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
• Marketing and Promotional Purposes: We use your contact information, identifiers, commercial information, usage data, geolocation data, audio/visual data, and inferences to send you improve our marketing efforts, create social media posts or advertisements, and provide you with information about us, including personalized marketing communications.
• Maintenance and Improvement of the Sites: We use your contact information, commercial information, identifiers, employment information, geolocation data, audio/visual data, and usage data to improve our Sites, provide and maintain functionality on our Sites, and help us diagnose technical and service problems and administer our Sites.
• Develop and Improve Our Products and Services: We use your contact information, demographic information, financial information, identifiers, geolocation data, usage data, audio/visual data, commercial information and inferences to help us develop new products and services and to improve and analyze our existing products and service offerings.
• Security and Fraud Prevention: We use your contact information, identifiers, commercial information, financial information, geolocation data, usage data, audio/visual data, and inferences to protect our Sites, products and services; protect us, our affiliated companies, our employee, our carriers and others; and to prevent fraud, theft and misconduct.
• Legal: We use your contact information, identifiers, financial information, employment information, geolocation data, usage data, audio/visual data, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.

Methods of Collecting Information

We collect information in a variety of ways:

• Directly from you: We collect contact information, demographic information, financial information, identifiers, commercial information that you provide directly to us.
• Automatically: When you access our Sites, we collect identifiers, geolocation data, and usage data using tools like browser cookies.
• From third parties: We may collect contact information, identifiers, commercial information, audio/ visual data, and inferences from third parties, including investor relations companies, research institutions, service providers, and public authorities.
• From social media platforms and networks: We may collect contact information, identifiers, geolocation data, usage data, commercial information, and audio/visual data from social media platforms and networks that you use in connection with our websites or mobile applications, or that share or allow you to share information with us, such as Facebook, Twitter, and Instagram.

We Combine Information

We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

How We Share Information With Others

We will share personal information in the following circumstances or as otherwise described in this Privacy Policy:

• Service Providers: We may share personal information with vendors and service providers who support the operation of the Services, the Sites, and our business and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, payment processing, order fulfillment, email delivery, marketing, insurance, transportation, storage and warehouse services, shipping, background check, credit verification, and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.

• Affiliates: We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.

• Commercial Partners: We may share personal information with third party commercial partners for commercial purposes such as completing transactions on their respective sites and mobile applications.

• Marketing/Analytics/Advertising Partners: We may share personal information with third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails and advertisements.
• Corporate Transaction Recipients: We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.
• With Your Consent or At Your Direction: We may share information with third parties whenever you consent to or direct such sharing.
• Other Reasons: We may share information for other reasons we may describe to you.

How Long We Keep Personal Information

We will retain and use your information for as long as your account is active, as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer use your information to provide you services or products, please contact us at privacy@papayadash.com.

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology

We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our Sites. We receive and store certain types of information when you visit our Sites. When you access the Sites, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications. These tracking technologies, which are often referred to collectively as cookies, allow us to understand how users navigate to and around our Sites, view different pages, access content and request Services. We may use them, for example, to keep track of your preferences and profile information and collect general usage and volume

statistical information. If you want to remove or block cookies, you may be able to update your browser settings. You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org. Please click on the banner at the bottom of the page of https://papayadash.com/cookies to review our cookies policy.

Do Not Track Signals

Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Third-party Analytics and Advertising

We allow others to provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Sites and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked and conversion information. We use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity.

Google Analytics

We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

Links to Other Websites

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

This Website is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13,

we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to privacy@papayadash.com.

Marketing Communications

You can opt out of marketing or advertising emails and newsletters by using the "unsubscribe" link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the Contact Us section of this Privacy Statement. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.

Processing in other countries

By using the Sites or Services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own, including the United States, as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country. Information we transfer from the European Economic Area, the United Kingdom or Switzerland to the United States will be subject to appropriate safeguards under applicable law. Those safeguards may include standard data protection clauses approved by the European Commission/ICO and available on their website.

Country/Region Specific Provisions

European Economic Area (EEA), the United Kingdom, and Switzerland

For residents of the European Economic Area (EEA) the United Kingdom, and Switzerland, the following additional privacy elements apply to you. We are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation.

Lawful Basis for Processing Personal Information: The lawful basis for our collection and use of your personal information described in this Statement is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary, on your consent.

Disclosure and Cross-Border Transfer: We are a global company, and your personal information will be shared among us and transferred outside of your country of residence. Personal information that is transferred outside of the European Economic Area, Switzerland, or the United Kingdom is conducted in accordance with compliant transfer arrangements such as data transfer agreements that contain standard contractual clauses adopted by the European Commission that provide safeguards for such transfers.

Special Categories of Data: We request that you do not send to us (unless we specifically request) any Special Categories of Data, which is defined under relevant data protection laws as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.

Segmentation and Automated Decision Making: We do not use segmentation or automated decision- making without human intervention, including profiling.

Your Rights Over Your Personal Information: You have the right to request that we:

• confirm whether we are processing your personal information;
• provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format;
• update or correct your personal information when it is inaccurate or incomplete;
• cancel or delete your personal information in certain circumstances;
• to limit the processing of or stop processing your personal information in certain circumstances;
• or to revoke consent previously granted to the extent permitted by law.

To exercise any of these rights please contact our please email our Data Protection Officer at privacy@papayadash.com.

You can also write to us at: 

Papaya Technologies

Attn: Data Protection Officer 

Studio 304, 3rd Floor Mare Street Studios, 203-213 Mare Street, Hackney, London, England, E8 3JS

You must use “GDPR Request” in the subject line of your email or letter. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.

Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request.

Filing a Complaint: If you are in the EU, Switzerland, or UK, you may lodge a complaint concerning our data processing activities by contacting your local data protection authority - contact information may be found here. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any matters related to the use and disclosure of your personal information.

Contact Us

If you have any questions about this Policy or our data practices, please email our Data Protection Officer at  privacy@papayadash.com.

You can also write to us at: Papaya Technologies 

Attn: Data Protection Officer 

Studio 304, 3rd Floor Mare Street Studios, 203-213 Mare Street, Hackney, London, England, E8 3JS

Updates

From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates.

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