Privacy Policy

Last updated: January 17, 2022 

This Privacy Policy describes the types of information the Yuansfer, Inc. DBA Pockyt) and all subsidiaries and affiliates, (collectively, “Pockyt”, “we,” “our,” or “us”) collect through our websites, including the website at www.pockyt.io (our “Sites”), as well as all related websites, networks, applications, and other services provided by us and on which a link to this Privacy Policy is displayed (collectively, with the Sites, our “Services”). This Privacy  Policy describes the information that we gather from you in connection with our Services, how we use and disclose such information, the steps we take to protect such information, and how you can exercise your data protection rights. 

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided under the “Contacting Pockyt” section. 

1. Accessibility

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us using the contact details provided under the “Contacting Pockyt” section and we will arrange to supply you with the information you need for an alternative format that you can access. 

2. Information We Collect and How We Use It

2.1 Information you provide voluntarily

When you use our Services, you voluntarily provide us with information about you. We use this information for the following business and commercial purposes: 

• Account Registration. We collect information that is necessary for you to register an account with us, log in to your account, and use features of our Services, such as your name, contact details, company, geographic area, preferences, job title, and password. This information also allows us to manage your account. The legal bases on which we rely on are ‘performing a contract with you’ and ‘pursuing our legitimate business interests’ (operate, analyze, grow, and administer Services). We store such data until you amend it or delete your user account. 
• Merchant Application. When you apply for our Services, we collect your email address, website address, business name, legal name, address, contact name, phone number, fax number, tax ID, registration number, officer’s name, ID type and number, date of birth, contact number, bank name, account number, routing number, bank address, SWIFT code, and photos related to your ID, company, products, and services. We use such information to draft and conclude a contract with you, comply with our legal obligations, provide you with the requested services, and administer our business. The legal bases on which we rely are ‘performing our contractual obligations,’ (ii) ‘pursuing our legitimate business interests’ (administer our business), and ‘complying with our legal obligations’. We store such data until you terminate your contract with us unless we are required by law to store our records longer. 
• Order and purchase. We collect information that is necessary to fulfill your order features of our Services or the purchases you make through our Services, such as your name, contact details, job title, company, credit card or other billing information. 
• Customer communications and support: We collect information that is necessary to respond to enquiries, support requests or any other communications you submit through our Services, such as your name, contact details and the content of your communications. We also use that information to communicate with you via technical notices, updates, security alerts and support and administrative messages. 
• Promotions: We collect information that is necessary to process and deliver entries and rewards in connection with promotions that we may offer from time to time, such as your name, contact details, job title and company. 
• Operate and enhance our Services. We collect information that is necessary to operate, maintain, enhance and provide all features of our Services, such as your feedback or any other information related to your utilization of our Services that you provide us with. We also use that information to develop new products, services, features, and functionality. 
• Direct marketing: We collect information to send you direct marketing, in accordance with your marketing preferences. We use your name, contact details and account information to email you with marketing offers and resources, events, newsletters, whitepapers and other company updates about Pockyt and other third parties. 
• Other purposes. We may use the personal information you voluntarily disclose to us for any other purposes disclosed to you and with your consent. 

2.2 Information we collect automatically

When you use our Services, we may collect certain information automatically from your device, including information like your IP address, operating system, device type, unique device identification numbers, browser-type, broad geographic location (by use of GPS or other geolocation features of your device) and other technical information. We also collect information about how you use our Services for purposes of facilitating your use of our Services, including securing, managing, measuring, improving, and/or supporting our Services as well as to enable us to develop and market additional products and services. We may also collect information about how your device has interacted with our Services including our Sites, including the pages accessed and links clicked. Some of this information may be collected using cookies and similar tracking technology. We use these cookies or similar technologies to understand and analyze the usage trends and preferences of our users, enhance and develop new products, services, features, and functionality, administer our Services, track user’s movements around our Services, store preference information in our Services, serve targeted advertisements, and gather demographic information about our user community as a whole. For further information about the types of cookies we use, why, and how you can control cookies, please see our Cookie Policy. 

2.3 Information from Other Sources 

From time to time, we may receive personal information about you from third-party sources, but only where we have checked that these third parties either have your consent (where required by law) or are otherwise legally permitted or required to disclose your personal information to us. For instance, we may obtain information such as your contact details, job title, company and interest from third parties, such as our partners and advertisers, and from other sources outside of our Services, including from certain offline sources such as trade shows or publicly available sources, to market our Services or services and products offered by third parties, in accordance with your marketing preferences. 

2.4 Log Files, IP Addresses, URLs and Other Data 

Pockyt, like most websites, gathers certain information automatically to analyze trends in the aggregate and administer our Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages, and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Services. This information is used to analyze overall trends, to help us improve our Services, to track and aggregate non-personal information, and to provide the Services. 

2.5 Social Media Features and Single Sign-on 

We obtain your personal data from the following categories of sourcPockyt websites or other Services may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on our website and may set a cookie or other similar technologies to enable the feature to function properly. You may be given the option by  such Social Media Features to post information about your activities on our Services to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by a third- party or hosted directly on our Services. Information collected in the context of the Social Media Features is subject to the relevant social media platforms’ own data collection, use, and disclosure policies. Pockyt also allows you to log in to certain of our Services using sign-in services provided by social media platforms. These services authenticate your identity and may provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form. 

2.6 Hosted Data  

Pockyt’s obligations with respect to data that may be accessed as a function of Pockyt’s role as a cross-border payment gateway provider, such as data stored or transferred by Pockyt customers through Pockyt’s hosted Services are defined in our agreements with our customers and are not governed by this Privacy Policy. 

3. Your Rights and Choices 

Depending on your location and applicable data protection laws, you may have the right to request access to, or correction, deletion or removal of, information about you, by contacting us at privacy@Pockyt.io, by using the contact details provided under the “Contacting Pockyt” heading or by submitting a request through our online form available here. To protect your privacy and security, we may take steps to verify your identity before granting access, deleting or making changes to information you have provided us, including by requesting your name and email address. While we will make reasonable efforts to accommodate your request, we also reserve the right to reject such access requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law. 

If you receive marketing communications from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us by sending your request to us by email at unsubscribe@Pockyt.io or by writing to us at the address given at the end of this Privacy Policy. Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We do not discriminate against any individual based on the exercise of their data protection rights. 

4. Sharing Information 

Except as described in this Privacy Policy, we will not disclose information about you that we collect on or through our Services to third parties without your consent, unless legally required or permitted to do so. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances: 

Any information that you voluntarily choose to include in a publicly accessible area of the Sites or any of our Services will be available to anyone who has access to that content, including other users. 

We work with third-party service providers to provide you with our Services and website and assist us with our marketing and sales activities. Examples include customer relationship management providers, communications providers, maintenance and technical support providers, analytics companies, payment providers, security and fraud detection providers. These third parties may have access to or process information about you for the purpose of providing the Services mentioned above.  

We may share your information with our partners in connection with selling or distributing our Services, or engaging in joint marketing activities, in accordance with your marketing preferences. 

We may disclose your information if required to do so by any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary to comply with applicable law or regulation, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. 

We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Services and any facilities or equipment used to make our Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others. 

Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets in which case the acquirer, successor or assignee will use your personal information in line with this Privacy Policy. 

We may make certain aggregated, automatically collected, or otherwise non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through our Services.

5. Security

At Pockyt, security is a priority. We use physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect, process and maintain. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Security is an evolving area and Pockyt is constantly working to not only raise the level of security it deploys but also the security training of its employees. 

Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. 

6. Third-Party Services 

Our Services may contain features or links to websites and services provided by third- parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information. 

7. International Transfer of Information and International Visitors 

We may transfer and process your personal information in countries other than the country in which you are resident in connection with storage and processing of data, fulfilling your requests, and operating and providing our Services. These countries may have data protection laws that are different from the laws of your country. Specifically, our Services are hosted in the United States and China, and our subsidiaries and third-party service providers and partners operate around the world. However, we have taken appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Policy. 

In the event that we transfer personal information from the European Economic Area (“EEA”), UK and Switzerland (collectively “Europe”) to countries which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms to ensure adequate level of protection, including entering into the standard contractual clauses for the transfer of European data approved by the European Commission or, where required, asking you for your prior consent to such international data transfers. 

8. Data Retention 

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

9. EEA and UK Rights 

If you are a visitor/customer located in the EEA and the UK, Pockyt is the data controller of your personal information. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you. 

9.1 You have the following rights: 

• If you wish to access, correct, update or request deletion of your personal information, see ‘Your Rights and Choices‘ above.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights contact us or by email: privacy@Pockyt.io. 
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor  will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. 
• To exercise these rights contact us here or email privacy@Pockyt.io 

10. California Rights

Residents of California have the right to request a disclosure describing what types of personal information we have shared with third parties for their direct marketing purposes, and with whom we have shared it, during the preceding calendar year. You may request a copy of that disclosure by contacting us. 

10.1 California Consumer Rights Under The CCPA

The following disclosures apply only to California residents covered under the California Consumer Privacy Act (“CCPA”). 

Personal information collected for a business purpose and for a commercial purpose The purposes for which we collect your personal information are described under the heading “Information We Collect and How We Use It” above. This section describes the business purposes and commercial purposes for which we collect personal information. 

10.2 Personal information disclosed for a business purpose 

This Privacy Policy describes the categories of personal information that we have, disclosed for a business purpose and sold over the preceding twelve (12) months. Please refer to the sections headed “Information We Collect and How We Use It” and “Sharing Information” for more information. 

10.3 Personal information sold 

We do not and will not sell your personal information to any other business or third party. Pockyt will always seek your affirmative direction/consent to intentionally disclose personal information to third parties in ways that might otherwise be construed to be a “sale” under the CCPA. 

10.4 Right to know and right to delete 

You have the right to request that we disclose the personal information we collect, use, disclose and sell. To exercise this right, please follow the instructions described to access your information in the “Your Rights and Choices” section above. 

10.5  Children’s Privacy 

Protecting the privacy of young children is especially important to Pockyt. Our Sites are general audience websites not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 without obtaining parental consent. If you believe we have collected information belonging to an individual under the age of 16, please let us know by contacting Pockyt.   

11. Changes and Updates

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through our Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change and obtain your consent where legally required. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access one of our Services for the first time after such material changes are made. 

12. Contacting Pockyt 

If you have any questions or comments about this Privacy Policy, your Information, our use, and disclosure practices, or your consent choices, please contact us, by email to privacy@Pockyt.io, or you can contact us using the information provided here. 

Yuansfer, Inc. DBA Pockyt 

28 Liberty St 6th floor   

New York, NY 10005  

United States 

If you are a California resident, you can also reach us toll-free at (855) 982-6888