Your privacy is vital to our long-term relationship with you, and protecting your privacy is just one part of our mission to provide you with highly personalized and valuable service. In addition, in an effort to comply with the Children's Online Privacy Protection Act (COPPA), we will not knowingly collect personally identifying information from children under the age of 13.

This statement describes our privacy policy with respect to:

• What Information is Collected; How Information is Collected; and by Whom is Information Collected
  
  
• The Sharing of Collected Information
  
  
• How You Can Access, Change or Limit the Information Collected About You
  
  
• Security of Information
  
  
• Amendments to Our Privacy Policy
  
  

What Information is Collected; How Information is Collected; and by Whom is Information Collected

Required Personally Identifiable Information
To register on our Web site, you must submit your name and e-mail address. In addition, to purchase a calling card, you must submit additional information, including your address, phone number and credit card information. This required personally identifiable information is necessary for us to process transactions for you, protect you against credit card fraud and contact you. When you register with DeltaPay™, we will ask you for a "e-mail." The e-mail you select may appear on the web site in connection with future services we provide, such as discussion forums in which you may voluntarily participate.

We will never share the information stored on that database, as well as other information we collect or you provide with any business partners or third parties, including those who offer services that complement those provided by us or which we believe may be of interest to you.

Transaction Information
When you authorize a purchase transaction, we will collect certain information related to that transaction such as the location from which you are requesting the search or transaction, the product or service involved, the quantity or amount of the product or service and certain personally identifiable information, such as your password, your credit card information and any special handling requests. This personally identifiable information will never knowingly appear in public areas of our Web site.

Third Party Information
During the processing of your transactions, we collect verification information from our credit card authorization services. Credit card authorization services verify that credit card information and address that they have on file for you matches the information that you have provided to us.

General Information
We collect general information about you when you visit our web site. This information includes technical information related to your computer and the manner in which you are accessing our site and includes such information as the internet protocol (IP) address of your computer, what operating system your computer is using, what browser software (e.g., Explorer, Netscape or other) your computer is using, and who your Internet service provider is, the Uniform Resource Locator ("URL") of the web site from which you just came and the URL to which you go next and certain operating metrics, such as the amount of time you use our Web site.

The general information that we gather about you may be aggregated with general information of all users to help us better understand how our site is used. In addition, we aggregate the general information and the personal information. We compile and analyze this aggregated information so that we can provide more meaningful information to corporate partners and more relevant content and advertisements to you.

The Sharing of Collected Information

Personally Identifiable Information
As noted above, we only share certain information about you with those of our vendors who are responsible for handling your account or performing other necessary services that you require. We will not share your personally identifying information with other third parties without your consent, except for the following limited purposes:

1. We are compelled to do so by law or by an order of a court or governmental authority.
   
   
2. In order to cooperate with law enforcement authorities or governmental regulatory bodies, and if we find any fraudulent activities.
   
   
3. As necessary to complete a transaction for you.
   
   
4. As we deem necessary to protect the rights, safety or property of DeltaPay, our users or others o r to enforce our terms of use agreement or privacy policy.
   
   
5. If you use our Web site through a link from one of our promotional partners, then we may be required to share your user registration information or other personally identifying information about any search or transaction that you initiate through such promotional partner with that partner.

Third Party Sites
We may publish links to other sites from our web site. Please note that DeltaPay does not control the content, practices or policies of any other site, including what information those sites collect about you. Accordingly, we do not endorse or hold ourselves responsible for the privacy policies or information gathering practices of any site that you may link to from our site. In addition, you may choose to respond to advertisements that are posted on our web site or made available via our service or to direct marketing offers from third party sponsors or advertisers. We do not control the content, practices or policies of our sponsors or advertisers and, accordingly, do not endorse or hold ourselves responsible for the privacy policies or information gathering practices of any sponsor or advertiser who may collect information about you.

How You Can Access, Limit or Change the Information Collected About You

Security
DeltaPay uses the highest security standard available (SSL) to encrypt all of your credit card and personally identifiable information while it is in transit to us. All data stored on the DeltaPay server is protected by a secure "firewall" so that no unauthorized use or activity can take place. Although DeltaPay will make every effort to safeguard your personal information from loss, misuse or alteration by third parties, you should be aware that there is always some risk that thieves may find a way to thwart our security system or that transmissions over the Internet will be intercepted.

Amendments to Our Privacy Policy
We may, from time to time, amend our Privacy Policy. If we do, then we will post such amendments to this document so that you may always have access to our most recent policy. We reserve the right, at our discretion, to change, modify, add or remove portions of our Privacy Policy at any time and from time to time. If at any point we decide to disclose personal information in a manner different from that stated at the time it was collected, we will notify users by email. You will be given t he choice at that time to "opt-out" of any disclosures of your personal information that you made available to us prior to the change in our policy.

Acknowledgment and Acceptance of our Privacy Policy
This Privacy Statement is incorporated into and subject to the Terms of Use contained on this web site (the "Terms"). As you know, your use of the DeltaPay web site is subject to the Terms. When you register with us, you affirmatively agree to all terms of the Terms, including this Privacy Policy. Your continued use of this Web site constitutes your continued agreement to the terms of the Terms, including this Privacy Policy. If you do not agree with the terms of our Privacy Policy, you should cease using our Web site.

General Data Protection Regulation (GDPR)
We are a Data Controller of your information. DELTAPAY LTD legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information: • DELTAPAY LTD needs to perform a contract with you • You have given DELTAPAY LTD permission to do so • Processing your personal information is in DELTAPAY LTD legitimate interests • DELTAPAY LTD needs to comply with the law DELTAPAY LTD will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies. If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights: • The right to access, update or to delete the information we have on you. • The right of rectification. • The right to object. • The right of restriction. • The right to data portability • The right to withdraw consent

Trademark Usage Guidelines
As the owner of its trademarks, DELTAPAY LTD has the exclusive right to use its trademarks, as well as the right to stop others from using its trademarks improperly or without authorization. Identification of DELTAPAY LTD products or services is the sole permissible use of DELTAPAY LTD trademarks and logos. The following is a non-exhaustive list of impermissible uses of DELTAPAY LTD trademarks and logos: • No DELTAPAY LTD trademark or logo may be incorporated into or used as part of a another party’s own logo, company name, product logo or otherwise. • No DELTAPAY LTD trademark or logo may be used in any way that is likely to be confusing, misleading or deceptive as to the true identity or source of products, services, materials, courses or programs. • No mark that is misleadingly similar in design or appearance to any DELTAPAY LTD mark or infringes on DELTAPAY LTD trademark rights may be used. • No DELTAPAY LTD trademark or logo may be used in any manner that is likely to disparage, dilute or negatively affect DELTAPAY LTD’s reputation or any of it products or services. • No DELTAPAY LTD trademark or logo may be used in a way that is likely to imply that the user, its products, or its services are endorsed by, sponsored or affiliated with DELTAPAY LTD, without written permission from DELTAPAY LTD. Acknowledgment and Acceptance of our Privacy Policy This Privacy Statement is incorporated into and subject to the Terms of Use contained on this web site (the "Terms"). As you know, your use of the DeltaPay web site is subject to the Terms. When you register with us, you affirmatively agree to all terms of the Terms, including this Privacy Policy. Your continued use of this Web site constitutes your continued agreement to the terms of the Terms, including this Privacy Policy. If you do not agree with the terms of our Privacy Policy, you should cease using our Web site.

AML/CFT Policy
Deltapay is committed to combat money laundering and terrorist financing and ensure that products and services products enlisted at the Deltapay are not misused for the purpose of money laundering, terrorism financing and other fraud events. It is also prohibited to provide any product or service or proceed any transaction for the benefit of individuals or entities included in the international sanctions lists. As such, the adherence with applicable laws and regulations in relation to prevention of money laundering and terrorist financing (hereinafter referred to as “AML”) is mandatory and fundamental to Deltapay’s strategy and program. Deltapay has strict and transparent standards and continuously strengthens Deltapay’s processes so as to ensure compliance with applicable AML laws and regulations.

Monitoring
Deltapay’s AML policy includes customers and beneficial owner’s due diligence and ongoing AML monitoring and AML reporting policies. At various points in time, Deltapay may request information regarding the transactions carried out through the customer’s account opened at Deltapay and the parties of the respective payment. If the customer may not respond sufficiently or within a timely manner, Deltapay also reserves the right to reject any respective payments subject to the requirements of the applicable AML laws and regulations.

AML Laws and Regulations
In accordance with AML regulations, the customer is required to provide Deltapay an accurate and complete information and documentation that assists in determining customer’s identity and verifying the customer, as well as information on payers and payees of each monetary operation and transaction processed through the customer’s account in the Company. The customer may be required to provide to the Deltapay additional information or document regarding the customer, respective monetary operation or other transaction, or counterparty of such transaction.

Restrictions
Deltapay has no AML risk appetite for customers who engage in any of the following: