Payoneer Inc. and Payoneer Early Payments Inc. (collectively, “Payoneer”, “we”, “us”, “our”) complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from any European Union member countries (as well as Iceland, Liechtenstein, and Norway), and Switzerland transferred to the United States pursuant to the Privacy Shield (collectively, “Privacy Shield Frameworks”).  Payoneer has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Payoneer is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

We collect, in accordance with the Privacy Shield principles, the categories of information described in the “HOW, WHEN AND WHAT WE COLLECT?” section of our privacy policy.   We process this information for the purposes stated in the “HOW WE USE YOUR INFORMATION” section of our privacy policy, available at https://www.payoneer.com/legal/privacy-policy/ (“Privacy Policy”).

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also may correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, may contact us at DPO@payoneer.com.  If requested to remove data, we will respond within a reasonable timeframe in accordance with our Privacy Policy.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please contact us at through the phone number or email address listed in the “CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT” section of our Privacy Policy.

As described in more details in the “WHEN DO WE SHARE YOUR INFORMATION” section of our Privacy Policy, we transfer personal information from the EU, EEA or Switzerland to third parties such as service providers (e.g., to process your transactions), non-affiliated third parties (e.g., for joint marketing purposes), to other customers or third parties using our service (e.g., to assist in carrying out transactions) and to appropriate vendors (e.g., to investigate suspected fraud, verifying identity, potential threats to safety, illegal activities, violations of Terms & Conditions). We contractually require third parties to whom we transfer personal information to provide the same level of protections as those found in this policy.

Payoneer’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Payoneer remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Payoneer proves that it is not responsible for the event giving rise to the damage.

In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes.

In compliance with the Privacy Shield Principles, Payoneer commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union, EEA and Swiss individuals with inquiries or complaints relating to our Privacy Shield policy should first contact us by either email at DPO@payoneer.com or customercare@payoneer.com,  or mail at Payoneer (EU) Limited, 9/2 ICC, 2A Main Street, Gibraltar GX 11 1AA.  We will work to resolve your issue as quickly as possible, but in any event we will respond no later than 45 days of receipt. In addition, Payoneer has committed to cooperate with the panel established by the EU data protection authorities (“DPA”) and the Swiss Federal Data Protection and Information Commissioner (“FDPIC”) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Payoneer has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction