Gaviti Platform and Website Privacy Policy

Last Revised: April 3, 2025

Gaviti AKYL LLC and its affiliates d/b/a Gaviti (collectively, “Gaviti”, “Company”, “we”, “our”, “us”) respects the privacy of users of our website (“Site”) and online platform (“User(s)” or “you”), intended for facilitating payment options (the “Platform and “Services”, respectively). We believe that you have a right to know our practices regarding the Personal Information we may collect and process when you access and use the Platform and Services.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at https://gaviti.com/terms-of-use-website/ and https://gaviti.com/terms-of-use-platform/ (the “Terms of Use”), into which this Privacy Policy is incorporated by reference.

Please note: The Platform and Services are made available to you through an agreement between Gaviti and the person or entity that invited you to make payments to them through our Platform (the “Gaviti Customer“).

The Personal Information (as defined below) collected from you via the Platform and Services is collected and processed exclusively on behalf of the Gaviti Customer, and is used by Gaviti solely for the purposes set forth in this Policy and to fulfill our contractual obligation towards the Gaviti Customer. All such Personal Information may be made available by Gaviti to Gaviti Customer and thereafter Gaviti Customer shall process such Personal Information in compliance with its distinct privacy policy and the data governance standards it maintains as an independent controller of such Personal Information. We disclaim any responsibility for Gaviti Customer’s use of the Personal Information, data processing activities, or compliance obligations which reside fully with Gaviti Customer based on its receipt and subsequent control of any transferred Personal Information from Gaviti. If you have any questions regarding Gaviti Customer’s Personal Information processing activities, or if you wish to exercise any of your right under applicable law with respect to your Personal Information, please contact Gaviti Customer directly.

1. Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, ACCESSING OR USING THE SITE AND/OR PLATFORM AND/OR SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS OR USE THE PLATFORM.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US. NOTE THAT IF YOU FAIL TO PROVIDE US WITH YOUR PERSONAL INFORMATION, OR YOU CONSENT TO THE PROCESSING THEREOF, WE MAY NOT BE ABLE TO CONTACT YOU, NOR PROVIDE YOU WITH CERTAIN FEATURES OF OUR SITE AND/OR THE PLATFORM AND/OR THE SERVICES.

2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

2.1. Non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering into and/or using the Site and/or Platform and/or Services, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, device browser and keyboard language, Wi-Fi connectivity and the type and name of your device and/or browser, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site or Platform, the activities of the User on the Site, Platform and Services and additional information of a similar nature.

2.2. Personally identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

Contact Details: Personal Information is collected from the details the Users provide in the “Contact Us” tab available on the Site. Such Personal Information includes your full name, email address, company name. You may provide via the contact form any text you wish to insert into the “message” box. We may also receive your contact details from your employer in the context of a transaction, or negotiations for a transaction, or collect your information in the context of other marketing activities, such as in tradeshows, or through our agents and distributors, or through our social network accounts. Additional information may be requested via the contact form in the future.
Communications with Gaviti: Personal Information is collected from the details the Users provide as part of any communications with Gaviti, by any means, including without limitation, by email, telephone, or through our social media pages or otherwise. Such Personal Information may include your name and contact details and any other information which you may voluntarily provide to us.
Book a Demo: you may request a demo of our services by providing us your full name, business email address and company website link. You may provide via the contact form any text you wish to insert into the “message” box. We may request additional information to complete your application.
Our newsletter and other commercial materials: you may voluntarily provide us with your full name, email address, job title and company name in order to subscribe to our newsletter and to receive commercial materials from Gaviti and our partners.
Information collected from the Gaviti Customer: In order to grant you access to the Platform, we are required to receive certain Personal Information about you from the Gaviti Customer, including your name and information related to your payment to be made to the Gaviti Customer. It should be noted that the transfer of this information to us is done in accordance with the Gaviti Customer’s policies and the lawful bases for collecting the relevant information and its transfer to Gaviti, which apply to the Gaviti Customer. Please note that we do not verify, and cannot verify, the accuracy or completeness of the aforementioned information.
Information collected directly from you via the Platform: We will collect any information you voluntarily provide as part of your use of the Platform and Services, including without limitation personal details, contact details, and payment information. Please note that all this information may be transferred and made available to the Gaviti Customer for its independent use.
Personal Information collected via technology:

- IP address: Users of the Site and/or Platform may automatically provide their IP address (or MAC Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below, as well to provide you with targeted advertising.
- Identifiers: during your use of the Site and/or Platform, we will access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for statistical and metric purposes, and in order to provide you with targeted advertising of our services.
- Geolocation data: during your use of the Site and/or Platform, we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of IP addresses and other similar information to determine your general location for analytics and security purposes.
- Technical and Behavioral Information: to the extent that the Technical and Behavioral Information detailed above under Section ‎2.1 will be linked to or associated with a specific individual, then such information will be considered as Personal Information.

2.3. Please note:

We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

3. How do we collect information about our Users?

There are a few main methods we use to collect information:

3.1 We collect information through your entry, connection, access and/or use of the Site, Platform and the Services. In other words, when you access or use the Site or Platform, we are aware of your usage of the Site or Platform, and may gather, collect and record the information relating to such usage. For example, when you use the Platform, we gather your Technical and Behavioral Information.

3.2 We collect information which you provide us voluntarily. For example, we collect contact details via the Site.

3.3 We collect information from Gaviti Customer. We receive certain Personal Information from the Gaviti Customer in order to enable the operation of the Platform and Services.

4. What are the Purposes of the Collection of Information?

4.1. Non-personal Information is processed in order to:

Enhance the User’s experience on the Site and Platform;
Create statistical information and learn about the preferences of Users and general trends on the Site and Platform and Services (e.g. understand which features are more popular than others); and
Keep the Site, Platform and Services safe and secured against fraudulent and criminal activity.

4.2 .Personal Information is collected in order to:

Enable the operation of the Site and Platform and to provide the Services;
Transfer certain information to the Gaviti Customer when you use the Platform, and provide our services to Gaviti Customer in accordance with our services agreement with the Gaviti Customer;
Respond to your inquiries, requests, comments and suggestions;
Display ads and send you offers. We may also use your Personal Information in delivering third party advertisements to you. This may include “targeted ads” based upon your interactions with our Site and/or Platform that may be displayed on third party platforms and across devices;
Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: privacy@gaviti.com;
Send notifications to Users, including push notifications, text messages and emails;
Keep the Site and Platform safe and secured and for prevention of fraud and crime;
Personalize your experience on the Site and Platform;
Ensure that content on the Site and Platform is presented in an optimal way for you and for your device (e.g. tablet, mobile phone);
Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;
Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests; and
Maintain our data processing records and general administrative purposes.

5. Sharing Information with Third Parties

5.1 Gaviti respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.

5.2 In addition to using the information collected by us for the purposes described under Section 4 above, we may also share your information in the following cases:

Gaviti Customer: we share some of your Personal Information with the Gaviti Customer, as described above.
Service Providers: note that we collect, hold and/or manage Personal Information through Gaviti’s authorized third parties vendors of certain products or services (such as, cloud services) (including, as applicable, their affiliates) solely and limited to providing us with such requested services, and not for any other purposes. Such vendors may be located in a country that does not have the same data protection laws as your jurisdiction. For more information regarding our Service Providers, please refer to Section ‎10 below.
In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy and/or the Terms of Use, including investigation of potential violations thereof, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (e) to protect the rights, property, or personal safety of Gaviti, its Users or the general public; (f) by virtue of undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Gaviti, so long as such acquirer maintains the same privacy terms hereunder; or (g) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, Gaviti may use Non-personal Information and transfer and disclose it to third parties at its discretion, including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of the Platform.

6. Cookies and Tracking Technologies

When you access or use the Site and/or Platform, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies) (collectively, “Cookies“) which may enable us, amongst others, to recognize your device from those of other Users of the Site and/or Platform, to improve the Site and/or Platform ‘s performance, to deliver a better and more personalized service according to our Users’ individual interests and the device or browser used, to track Users’ use of the Site and/or Platform, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern, to provide targeted and behavioral based advertising, and perform other analytics and to develop our Site and/or Platform.

Cookies may locally store certain Technical and Behavioral information and other Personal Information on your device and we and/or our authorized third party service providers may access such information for the purposes detailed under this Privacy Policy. We and/or our authorized third party service providers may use both session Cookies (which expire once you close the web-browser) and persistent Cookies (which stay on the User’s device until he/she deletes them).

Most devices and browsers will allow you to erase Cookies from your device’s hard drive, block acceptance of Cookies, or receive a warning before a Cookie is stored on your device. However, if you block or erase Cookies, your experience of the Site may be limited.

For detailed instructions regarding the blocking of Cookies, please refer to your browser’s ‘help’, ‘tool’ or ‘edit’ sections or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers: Chrome, Internet Explorer and Microsoft Edge, Mozilla Firefox and Safari.

It is possible to opt-out of having your browsing activity within the Site and the Platform recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users’ activities on the Site, including by use such services’ persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

7. Minors

The Platform is intended for Users over the age of sixteen (16). Therefore, Gaviti does not intend and does not knowingly collect Personal Information from children under the age of sixteen (16). We reserve the right to request proof of age at any stage so that we can verify that minors under this age are not using the Platform. Please contact us at privacy@gaviti.com if you have reasons to suspect that we collected Personal Information from minors under the age of sixteen (16) and we will make best efforts to delete that information as quickly as possible.

8. Deletion or Modification of Personal Information

Gaviti acknowledges that under certain circumstances you may have the right to access and to request an amendment or deletion of the Personal Information we collect and process about you. If you wish to access or to correct, amend, or delete Personal Information, please send us an email with adequate details of your request to: privacy@gaviti.com and we will enable you to fulfill such rights, to the extent it is required under applicable laws.

9. Security

We take reasonable measures to maintain the security and integrity of our Site, Platform and Services and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Your Personal Information is hosted on third parties’ servers, which provide advanced strict security standards (both physical and logical). Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur. GAVITI SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION.

10. Third Party Service Providers

While using the Site, Platform and/or Services we may be using third party service providers, who may collect, store and/or process the Personal Information detailed herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. Gaviti uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties’ software or services may include without limitation the following categories of service providers:

Cloud Hosting Providers: Google Cloud

Payment Processors: Bluesnap, Stripe, Jassby, Cybersource, CWA

Email and Communication Tools: SendGrid, HubSpot, Gmail, Intercom

Analytics Tools: Google Analytics

CRM Systems: HubSpot CRM

Customer Support and Ticketing Platforms: Intercom

Marketing and Advertising Partners: Google Ads, LinkedIn Ads

Fraud Prevention and Security Tools: Cloudflare

11. International Data Transfer

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third party service provides (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information. Any transfer of data will be in accordance with the safeguards permitted under applicable privacy laws.

12. Links to Third Party Websites

Certain links provided in the Site and Platform permit Users to leave our Site or Platform and enter non-Gaviti sites or services. Those linked sites and services are provided solely as a convenience to you. Those linked sites and services are not under the control of Gaviti and it is not responsible for the availability of such external sites or services, and does not endorse and is not responsible or liable for any content advertising, products, services or other information on or available from such linked sites and services or any link contained in a linked site or service. Gaviti reserves the right to terminate any link at any time. You further acknowledge and agree that Gaviti shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such linked sites or resource. Most of such linked sites and services provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

13. Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the Site, Platform and Services and any information collected therein. Gaviti reserves the right to change this policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes to this policy on the Site. Such substantial changes will take effect seven (7) days after such notice was provided on our Site. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site and/or Platform after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Privacy Policy should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by law and without any prior notice.

14. Direct Marketing

You hereby agree that we may use the contact details you provided us with (including, without limitation, e-mail address) for the purpose of providing you with commercial and/or non-commercial materials related to our current and/or future activities and/or services, through e-mails, SMS or regular mail. You may withdraw your consent by sending a written notice to our e-mail address at: privacy@gaviti.com or alternatively follow the instructions for removing yourself from the mailing list which are available in the message transmitted to you.

15. Data Retention

Gaviti will retain the Personal Information for as long as we are confident that it is accurate and can be relied upon. Personal Information which is no longer required for the purpose for which it was initially collected will be deleted, unless we have a valid justification to retain it which is permitted under applicable law, such as to resolve disputes or comply with our legal obligations.

16. Got any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: privacy@gaviti.com and we will make an effort to reply within a reasonable timeframe. All notices given by you or required from you under this Privacy Policy shall be in writing and addressed to: Gaviti Akyl LTD., Abba Hillel 21 Floor 7, Ramat Gan, Israel.

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