This Privacy Notice is intended to describe the privacy practices Pagotronic LLC follows when you use our digital wallet (the “wallet”), mobile application (the “app”), website (the “site”), and when you provide information through any other interactions and communications you have with us (collectively, the “Services”). Please read this Privacy Notice carefully.
Information collected as part of the Services is hosted in the U.S.
Your personal data processed in connection with the Services is used to:
- Provide, maintain, and improve the Services, including to establish and maintain our relationship with you, conduct a background check on you, develop new features, respond to your inquiries, develop risk management features, and send product updates and administrative messages.
- Perform internal operations, including, for example, to prevent fraud and abuse of the Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; to maintain the security of the Services; and to monitor and analyze usage and activity trends.
- Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.
- Comply with applicable legal, regulatory, or processional regulations and perform other lawful activities as disclosed or with your consent.
Pagotronic relies on your consent to legitimize the processing of your personal data as contemplated herein. The provision of your personal data to Pagotronic is optional. However, if you do not provide all or part of your personal data, we may be unable to carry out the purposes for processing. You have the right to withdraw your consent at any time.
Pagotronic processes these personal data categories as part of providing the Services:
Information You Provide to Us
We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include personal data such as: name, date of birth, email address, password, phone number, postal address, tax documents (e.g., Form W-2, Form 1099, etc.), tax returns, wage and income information, personal identifiers (e.g., SSN, Tax ID, etc.), copy of ID, bank account information, credit card or other payment method, US citizenship/permanent residency status, and other information you choose to provide. In providing the Services, Pagotronic relies on the accuracy of the information that you provide. Accordingly, if you provide an inaccurate email address during the process of creating a Pagotronic account, Pagotronic will not be able to provide the Services.
Information We Collect through Your Use of Our Services
When you use our Services, we collect information about you in the following general categories:
Background Check and Photo Information (for Direct-to-Consumer users of the Services): Pagatronic will collect and share the following information with a third-party service provider for the purpose of conducting a background check on some or all your following information: name, date of birth, physical address, copy of photo ID, and email address. As part of the background check process, to verify your identity Pagotronic may receive a copy of the results of your background check, including information such as political exposure and criminal/fraud activity. In addition, where we make Biometric Mobile Verify (“Selfie” check) available, we will capture your photo while you are asked to interact with the application, such as to blink/smile, and will retain facial images.
Usage and Preference Information: We collect information about how you and website visitors or app users interact with our Services, preferences expressed, and settings chosen. In some cases, we do this using cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
Device Information: We may collect non-personally identifying information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, and mobile network information. Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent, and these platforms have different permission systems for obtaining your consent.
Log Information: When you interact with the Services, we may collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
Cookies: We may use both session cookies (which expire once you close your web browser) and persistent cookies to make the Service easier to use. You can instruct your browser, by changing its options, to stop accepting cookies at any time or to prompt you before accepting a cookie from the websites you visit. If you do this, however, it may impact the performance of the Services.
Sensitive personal data
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data concerning sex life or sexual orientation, or sensitive personal identifiers.
The following sensitive personal data may be collected and processed in connection with the Services:
Social Security Number/other identifier (e.g., driver’s license or passport number)
Background check results may include data relating to criminal convictions/offenses – for example if an individual is on a sanctions list or an Interpol wanted list, or if adverse media searches return results relating to criminal activity. We process this data to determine whether we can lawfully provide services – for example to ensure we are not facilitating money laundering or other criminal activity.
Where we make Biometric Mobile Verify (“Selfie” check) available, this involves the processing of biometric facial comparison data. The potential client will take photos of themselves where they will be asked to interact with the application, such as to blink/smile, and these images will be automatically compared to the image on the photo ID document they have provided (e.g., driver’s license/passport). The system will then use facial recognition technology to determine if the two images match and hence can be accepted, or if they do not match, they will need to retake the images until they match.
Your personal data is accessed by Pagotronic personnel located in the U.S. and some countries of Latin America. Additionally, third-party service providers may have access to your data. We may also transfer or disclose the personal data we collect to third-party service providers (and their subsidiaries and affiliates) who are engaged by us to support our internal ancillary processes. It is our policy to only use third-party service providers that are bound to maintain appropriate levels of data protection, security and confidentiality, and that comply with any applicable legal requirements for transferring personal data outside the jurisdiction in which it was originally collected. We may share information that has been deidentified or aggregated so that it does not identify you or your device, without limitation.
Security. Pagotronic is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, Pagotronic has technical and organizational measures designed to safeguard the personal data from loss, mis use and improper disclosure.
You may be legally entitled to request details of and a copy of personal data Pagotronic possesses about you, as well as deletion of your personal data. To confirm whether your personal data is processed in connection with the Services, to access your personal data, to request deletion of your personal data, or (where applicable) to withdraw your consent for processing, email your request to email@example.com.
California Privacy Rights. If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:
Exercising the Right to Know. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months:
the categories and specific pieces of personal information we have collected;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected it;
the categories of third parties with whom we shared the personal information; and
the categories of personal information about you that we disclosed for a business purpose.
Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may contact Pagotronic either via email to firstname.lastname@example.org or contact us via postal mail, proper postage prepaid, at:
Attn: Your Privacy Rights
5798 SW 68th St. South Miami, Florida 33143.
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Complaints. If you are concerned about an alleged breach of privacy law or any other regulation, contact email@example.com
Contact us. If you have additional questions or concerns, contact Pagotronic at firstname.lastname@example.org