Recently Updated: December 2019
Splitit Ltd. or any of its subsidiaries or affiliates (“Splitit” or “us”) is committed to your right to privacy.
- You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.
- Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately.
- You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the Services may be restricted or disabled.
- We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances as specified herein.
- If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: email@example.com.
1. What is Personal Data, and what data is collected about me by Splitit?
“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.
We collect non-Personal Data regarding Users concerning their use of the Website and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.
- When you use the Services in order to pay for purchases through monthly installments, certain Personal Data will be collected about you, including contact information (such as full name, address, email address, phone number, etc.) and billing information (such as credit cards information). This information may be requested by us directly or transferred to us by the merchant you are making the purchase from, depending on the process of implementation of the Splitit solution in the merchant’s payment process.
- If you register as a merchant for our Services, we will collect and process the information requested of you during the registration process, such as region, business information, contact person information, bank information, etc.
- We may collect and process Personal Data when you respond to surveys, provide your feedback, rate or review the Services, such information include, but not limited to, your name, email address, and the content of your feedback. This information may be requested by us directly or by our service providers who provide us with third party review services and platforms.
- We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.
Please note, that the Website and/or Services may contain links to other websites maintained by third parties, which may not be governed by this Privacy Notice. This Privacy Notice does not be apply to the practices of entities which are not controlled by Splitit.
2. What will Splitit do with my data?
- Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Website and Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.
- Personal Data. Personal Data is used only for the following limited purposes:
- To provide you with the Services, process transactions, and collect fees.
- To resolve any disputes, communicate with you regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.
- To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.
- To send our customers and their users who have purchased or used Splitit’s Services offers and marketing materials in connection with the Services. Please note that you may opt-out from receiving such communications at any time, by sending us a notification to: firstname.lastname@example.org.
- To improve the Services, and to develop new features, products and services.
- To improve your experience on the Website and customize our Services to your interests, including by way of targeted advertising.
- For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, as permitted under applicable law.
- To provide updates with respect to material changes to this Privacy Notice or our Terms and Conditions.
Yes, we use data files such as cookies, pixel tags, “Flash cookies,” or other local storage files provided by your browser or associated applications (“Cookies”). We use these technologies in order to recognize you as a customer; customize our Services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our sites and Splitit Services.
We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent Cookies remain on your device until you erase them or they expire.
You may also encounter Splitit Cookies on websites that we do not control. Likewise, certain third parties may place their own Cookies in the Website and Services. Such third party Cookies are not subject to our control and this Notice does not cover them. You may at any time program your browser to block cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to you. These cookies help us track how visitors use the Website and our Services.
4. How Can I Control My Personal Data?
- Reviewing and amending your Personal Data. If you are a merchant, you may review the information included in your account on the Website. If you are a buyer, you may send us a request in connection with reviewing your Personal Data to: email@example.com. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Website, as applicable to you.
- Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.
- Retention of We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.
- You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.
5. Will Splitit Share My Personal Data With Others?
WE DO NOT SELL OR RENT ANY OF YOUR PERSONAL DATA TO NON-AFFILIATED THIRD PARTIES FOR THEIR MARKETING PURPOSES.
- Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.
- We share Personal Data only under the following limited circumstances:
- With partners who are an integral part of our Services, such as the merchant you placed a purchase with, credit card processer, banking institution, etc.
- With trusted third parties who assist us in operating the Services and conducting our business. Such as service providers who provide us with fraud prevention services, bill collection, account maintenance, marketing services, review and feedback services and platforms, and technology services.
- For personalizing your experience of the Services, including by way of targeted advertising on the Website.
- As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about the products, services and communications.
- Credit bureaus and collection agencies to report account information, as permitted by law.
- To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.
- Other third parties with your consent or direction to do so.
6. What is the lawful basis under which Splitit processes Personal Data?
- Certain processing activities conducted by us are based on the necessity of such activities for the performance of our Services and the contract between us and our Users.
- Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.
- There may be certain processing activities based on your consent. In connection with such activities, you may rescind your consent, by sending us an email to: firstname.lastname@example.org. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.
7. Will Splitit transfer my Personal Data internationally?
Our databases are currently located in the United States. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.
Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.
8. Will I receive promotional materials from Splitit?
Splitit may send you offers that may be of special interest to you via email or SMS. You may unsubscribe from receiving such communications at any time, by sending us a notification to: email@example.com, for following the instructions for unsubscribing included in such communications.
We may also engage with third parties to track and report performance of advertising and marketing campaigns to and from Splitit and third party web sites. We may combine your information with information we collect from third parties and use it to improve and personalize our Services, content, and advertising.
9. Persons under 16
Our Website is a general audience Website, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.
10. Applicable Laws
The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.
11. Questions or concerns regarding privacy
If you have any questions or concerns regarding privacy issues, please send us a detailed message to firstname.lastname@example.org and we will make every effort to resolve your concerns without delay.
Splitit may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice will be posted on the Website, and shall be effective as of the date in which they are posted on the Website.