Kura Technologies Privacy Policy 

Kura Technologies Privacy Policy Welcome to KuraTechnologies, https://www.kuratek.com (“Website”, “we”, “us” or“Site”) a website and service operated by Kura Technologies, whose principalplace of business office is in Boston, MA. Kura Technologies is a US-basedfintech company providing an innovative solution in the cross-border paymentindustry. 

This Privacy Policy explains howwe collect, store, use, share and process your personal data when you use ourwebsite, services or mobile application (the “App”). It also explains whatinformation we may collect through your use of our Site, how such informationmay be used and/or shared with others, how we safeguard it, and how you mayaccess and control its use in connection with our marketing communications andactivities.

It also describes the rights youhave over your personal data. Personal data means any information about anidentified or identifiable individual. It does not include anonymous data,which cannot be linked back to an individual. Pleaseread this Privacy Policy carefully, prior to using or accessing the Site.

BY USING THE SERVICES OR OTHERWISE PROVIDING US WITH YOURINFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD, ACCEPTED AND AGREEDTO BE BOUND BY THE PRACTICES AND POLICIES DESCRIBED IN THIS PRIVACY POLICY. YOUHEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, AND DISCLOSURE OF YOURINFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TOCHANGE, MODIFY, ADD OR REMOVE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY ATANY TIME, IN OUR SOLE DISCRETION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY ATANY TIME, DO NOT USE ANY OF THE SERVICES OR PROVIDE US WITH ANY OF YOURINFORMATION. IF YOU ARE USING THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH ASYOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU AREAUTHORIZED BY THAT PERSON OR ENTITY TO (I) AGREE TO THIS PRIVACY POLICY ONBEHALF OF THAT PERSON OR ENTITY (II) CONSENT ON BEHALF OF THAT PERSON OR ENTITYTO OUR COLLECTION, USE AND DISCLOSURE OF THEIR INFORMATION AS DESCRIBED IN THISPRIVACY POLICY. 
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Quick guide tocontent
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●      1. Why this privacy policy
●       2.Information we collect
●       3. Cookies
●       4. How we use the Information we collect
●       5. Disclosure of your personal information
●       6. Your Privacy Rights and Choices
●       7. Data Retention and Deletion
●       8. Children
●       9. Security of your information
●       10. Changing privacy policy
●       11. Consent to Processing and Transfer ofInformation

Why this privacy policy
This Privacy Policy is published in accordance withapplicable Laws and Regulations;
This Privacy Policy states the following:
i. The type of information collected from users, includingPersonal Information and Sensitive Personal Data or information about anindividual;
ii. The purpose, means and manner of collection, use,processing, retention and disposal of such information; and
iii. How and to whom Kura will disclose such information. 

Information we collect –
Certain Services generallyrequire us to know who you are in order to better serve your needs. When youaccess the Services, or through any interaction with us via e-mail, telephonecalls or other correspondence, we may ask you to voluntarily provide us withcertain information that personally identifies you or could be used topersonally identify you. You hereby consent to the collection of suchinformation by Kura.
Whenever you visit or interactwith the Site, we, as well as similar third-party vendors and/or serviceproviders alike, may use a variety of technologies that automatically orpassively collect information about how the Site is accessed and used (“UsageInformation”).
Usage Information may include, inpart, browser type, operating system, device type, an estimation of yourgeographic location associated with your IP address, the page served, the time,referring URLs and other information normally transmitted in HTTP requests.
This statistical data provides uswith information about the use of the Site, such as how many visitors visit aspecific web page on which the Site is used, how long they stay on that page,and the type of content on that page.
The categories of personalinformation we collect depend on how you interact with us, our Services, andthe requirements of applicable law. We collect information that you provide tous, information we obtain automatically when you use our Services, and informationfrom other sources such as third-party services and organizations, as describedbelow. We may collect personal information that you provide to us,including:
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●       Information that you provide by filling in formson our website. This includes information provided at the time of registeringto use our website, subscribing to our Services, requesting, applying for orentering further services (including, but not limited to, promotion), making anenquiry or reporting a problem. This may include, but is not limited to,information such as your name, address, phone and email address.
●       In order to improve our communications with youas well as improve our products and Services, we may ask you to provide us withadditional information about you such as your professional interests and yourexperiences with us as well as more detailed contact preferences. When youprovide us with any personal information you consent to us collecting and usingthat information according to your preferences.
●       If you contact us, we may keep a record of thatcorrespondence.
●       We may ask you to complete surveys that we usefor research purposes, although you do not have to respond to them.
●       Details of transactions you carry out throughour Services and of the fulfillment of your orders.
●       Details of your visits to our Services and theresources that you access and/or download.
●       To register for our Services, we may require youto provide the following categories of personal information: name of accountholder, email, address, phone number, financial details (e.g., credit cardnumbers, ACH, and billing address), and company/workplace details. Yourprovision of this personal information is always voluntary, but if certainpersonal information is not provided you may not be able to utilize theServices. 

“Sensitive Personal Information”is furthermore personal data or information of an individual such as:
●       Passwords;
●       Financial informationsuch as bank accounts, credit and debit card details or other paymentinstrument information;
●       Biometric information;
●       Information receivedby a legal entity pursuant to a legal contract or otherwise;
●       Visitor detailsprovided at the time of registration or subsequently. 

We may collect personalinformation automatically when you use our Services, including:
●       Automatic Data Collection. We may collect certain information automatically when you use ourServices, such as your Internet protocol (IP) address, user settings, MACaddress, cookie identifiers, mobile carrier, mobile advertising and otherunique identifiers, browser or device information, location information(including approximate location derived from IP address), and Internet serviceprovider. We may also automatically collect information regarding your use ofour Services, such as pages that you visit before, during and after using ourServices, information about the links you click, the types of content youinteract with, the frequency and duration of your activities, and otherinformation about how you use our Services.
●       Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content,advertising, or other functionality on our Services, may use cookies, pixeltags, local storage, and other technologies (“Technologies”) to automaticallycollect information through your use of our Services.

Our uses of these Technologiesfall into the following general categories:
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o   Performance-Related.We may use Technologies to assess the performance of our Services, including aspart of our analytic practices to help us understand how individuals use ourServices (e.g., Google Analytics, WordPress and Jetpack).
o   Functionality-Related.We may use Technologies that allow us to offer you enhanced functionality whenaccessing or using our Services. This may include identifying you when you signinto our services or keeping track of your specific preferences, interests, orpast items viewed;
o   Advertising-or Targeting-Related. We may use first party or third-party Technologies todeliver content, including ads relevant to your interests, on our Services oron third-party websites.
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●      Analytics.We may use Technologies and other third-party tools to process analyticsinformation on our Services. These Technologies allow us to better understandhow our digital Services are used and to continually improve and personalizeour Services. Some of our analytics partners include:

‍Google Analytics.For more information about how Google uses your personal information (includingfor its own purposes, e.g., for profiling or linking it to other data), pleasevisit GoogleAnalytics’ Privacy Policy. To learn moreabout how to opt-out of Google Analytics’ use of your personal information,please click here.

The collection anduse of data is crucial to providing our Services and keeping the Services safe.Data helps us increase the safety of your online payments, while reducing therisk of fraud, money laundering and other harmful activity.

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Information we collect

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‍Cookies –

Cookies are small text files placed on a Device when theDevice is used to visit the Site. We may place cookies or similar files on yourDevice for security purposes, to facilitate site navigation, and to personalizeyour experience while using the Site.Cookies allow us to collect technical and navigationalinformation, such as browser type, time spent on the Site and pages visited.Cookies may include a Device Identifier along with information about theparticular type of content in which you have shown interest.

Cookies also allowus to select which content is most likely to appeal to you and display thatcontent while you are using the Site.When interacting with the Site, if you click on a link toone of our promoted offer(s), the customer sponsoring the promoted link mayplace a cookie on your Device as well, in which case you will be subject totheir privacy policy.Please note that you are subject to the privacy policies ofeach site you visit, in addition to ours. If you click on a link to visitanother site, you are subject only to that site’s privacy policy while visitingthat site, and not to this Privacy Policy.

If you would prefer not to accept cookies, you can dothis by activating the settings on your browser that allows you to refuse thesetting of all or some cookies.Pixel Tags/Web Beacons - A pixel tag (also knownas a web beacon) is a piece of code embedded in our Services that collectsinformation about engagement on our Services. The use of a pixel tag allows usto record, for example, that a user has visited a particular web page or clickedon a particular advertisement. We may also include web beacons in e-mails tounderstand whether messages have been opened, acted on, or forwarded.

LogFiles - As is true of most websites, wemay gather certain information automatically and store it in log files. This
information may include IP addresses, browser type, internet service provider,referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, detec tfraud, administer the site, track users’ actions around theSite, and gather demographic information about our user base as a whole.
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How we use the Information we collect – 
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We use the information we collectabout and from you for a variety of business purposes, including for example:responding to your questions and requests; providing you with access to certain functions and features of the Site; to provide and maintaining your platformaccount(s); to verify your identity; to communicate with you about your accountand activities using the Site and, in our sole discretion for marketing orsolicitation purposes, to communicate changes to one of our policies; to tailorcontent or offer(s) we serve you; to improve the Site or Service for internalbusiness purposes; to process applications and transactions; and for otherlawful purposes we may disclose at the time you provide your PersonalInformation or to which you otherwise consent.
Kura reserves the right to useinformation provided by or about the End User for the following purposes:
- Publish such information on the Website;
- Contacting End Users to offernew products or services;
- Contact end users to receivefeedback on products and services;
- To process payments and provetransactions have been executed;
- To process information aboutyour contacts to make it easy for you to find and connect them and improvepayment accuracy;
- Analyze software usage patternsto improve product design and utility;
- Analyze anonymized practiceinformation for marketing purposes;
- To process paymentinstructions, including those through independent third-party service providerssuch as payment gateways, banking and financial institutions, prepaidinstrument and wallet providers for processing payment transactions ordeferring payment facilities.  

We also use personal information held about you in thefollowing ways:
●  Toprovide you with our Services, including to manage your information andaccounts; provide access to certain areas, functionalities, and features of ourServices; and answer requests for customer or technical support. 
●  Toensure that content from our Services is presented in the most effective mannerfor you.
●  Toprovide you with information, products or services that you request from us orwhich we feel may interest you, where you have consented to be contacted forsuch purposes.
●  Tonotify you about changes or updates to our Services.
●  Tocarry out our obligations arising from any contracts entered into between youand us.
●  Topursue our legitimate interests such as direct marketing, research anddevelopment (including marketing research), network and information security,and fraud prevention.
●  Toallow you to participate in interactive features of our Services, when youchoose to do so.
●  Tocomply with our legal obligations, including enforcing our agreements andpolicies.
●  Toprovide, maintain, personalize, optimize, and improve the Services, includingresearch and analytics regarding use of the Services, or to remember you whenyou leave and return to the Services.
●  Toprovide you with customer support (we may record and monitor any communicationsbetween you and us, including phone calls, to maintain appropriate records,check your instructions, analyze, assess and improve our Services for qualityand training purposes).We use your data to keep our Services up and running:
●To monitor websiteand App usage, including to determine enhancements and technical improvements.
● For customer analysis, to administer our Services, and for internaloperations, for example troubleshooting, data analysis, testing, research andstatistical purposes.


We use your data to meet our legal obligations andenforce our rights:
●To confirm youridentity and verify your personal and contact details.
● To comply with applicable laws, including anti-money laundering, counterterrorist financing and sanctions laws, including to verify your identity.
● To establish, exercise or defend a legal claim.
● To action any data subject right requests.
● To meet our legal and regulatory obligations.


We use your data to protect you and other usersagainst fraud:
●To detect,investigate and prevent activities which may be fraudulent or illegal, or whichmay misuse or Services or break our policies.
● To comply with financial crime laws and to confirm that you’re eligible touse our Services. We also use it to help us manage fraud risks related to youraccount.


We use your data to communicate with you:
●To communicate withyou in relation to our Services, including to notify you of changes, seek yourviews or comments on our Services and to handle any enquiry or complaint youmay have made.

‍We use your datafor marketing and providing Services that might interest you:
● To improve our Services and for general businessdevelopment, for example to develop new products and features and explore newbusiness opportunities.
● For marketing, product and customer analysis, including testing, for exampleto improve our product range and optimize our customer offerings.
● To be able to administer your participation in competitions, offerings, andevents.
● To provide you with information, news, and marketing about our Services,including where we partner with others to offer similar services.
● For advertising, including personalized advertising.

Disclosure of your personalinformation –
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-    We may disclose your personal information to any of oursubsidiaries, our parent company and any of our parent company’s othersubsidiaries.
 -   We may disclose yourpersonal information to third parties:

o To any current or future affiliates, parent companies, or subsidiaries.
o To vendors, service providers, agents, contractors, or others who performfunctions (e.g., maintenance, data analysis, customer relationship management,email marketing, surveys, credit card processing, data hosting, or frauddetection) on our behalf.
o To Customers. For example, we may provide advertisers with information to informthem about conversion rates for analytics purposes.
o Ifwe are involved in a merger, acquisition, financing due diligence,reorganization, bankruptcy, receivership, purchase or sale of assets, ortransition of service to another provider, your information may be sold or transferred as part of such a transaction.
o If said third party provide services for us,they are limited to the following purposes:

▪         Providing us with hosting, payment processing,and related services.
▪         Understanding the use of our Services and makingimprovements.
▪         Administering a mailing list for customers thathave registered for such a list.
▪         Responding to requests from or providing anynecessary notices to you.
▪         Protecting the security or integrity of ourServices.
▪         Otherwise administering or managing the softwarefor our Services.

●       If we are under a duty to disclose or share yourpersonal information in order to comply with any legal obligation or in orderto enforce or apply our terms of use and other agreements; or to protect therights, property or safety of us, our customers, or others. This includesexchanging information with other companies and organizations for the purposesof fraud protection and credit risk reduction.
●       We may also disclose Personal Information whenlegally required to do so, to cooperate with law enforcement investigations orother legal proceedings, to protect against misuse or unauthorized use of theWebsite, to limit our legal liability and protect our rights or to protect therights, property or safety of users of this Site, the Service or the public.
●       In addition, we may share non-PersonalInformation, such as aggregate user statistics, demographic information, andUsage Information with third parties. We may combine your Usage Informationwith those of other users of the Site to share trend information with thirdparties, in aggregated and anonymized form.

-   APIs/SDKs. We may usethird-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services.

Your Privacy Rights and Choices-
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We will provide reasonableopportunities for individuals to access, update, or delete Personal Informationabout them that we have in our possession. We will not use Personal Informationprovided to us for purposes incompatible with the purpose for which it wasprovided without obtaining authorization from the subject of the information.

Individuals’ principal rightsunder data protection law are:
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(a)the right to access;
(b)the right to erasure;
(c)the right to object toprocessing;
(f)the right to dataportability;

You have the right to confirm as to whether or not we process your Personal Information and, where wedo, access to the Personal Information, together with certain additionalinformation. That additional information includes details of the purposes ofthe processing, the categories of Personal Information concerned, and therecipients of the Personal Information. Providing the rights and freedoms ofothers are not affected, we will supply you with a copy of your PersonalInformation. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

Right to Erasure – In some circumstances you have the rightto the erasure of your Personal Information. Those circumstances include: The Personal Information is no longer necessary in relation to the purposes forwhich it was collected or otherwise processed; you withdraw consent toconsent-based processing; you object to the processing under certain rules ofapplicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.

There are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right offreedom of expression and information; for compliance with a legal obligation;or for the establishment, exercise, or defense of legal claims.

In some circumstances, you have the right to restrict theprocessing of your data. Those circumstances are: you contest the accuracy ofthe personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for our processing, but you require personal data forthe establishment, exercise, or defense of legal claims; and you have objectedto processing, pending the verification of that objection.

Where processing has been restricted on this basis, we maycontinue to store your Personal Information. However, we will only otherwiseprocess it: with your consent; for the establishment, exercise, or defense oflegal claims; for the protection of the rights of another natural or legalperson; or reasons of important public interest.

Subject to compliance with legal obligations, as soonas personal information is being processed, you also have the following rights:
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o   Right to rectification You have the right torequest correction of your personal information where it is inaccurate orincomplete. In some cases, we may provide self-service tools that enable you toupdate your personal information.
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o   Right to restriction of processing You have theright to demand a restriction of processing for your personal information. Thismay result in us being able to offer you services longer. However, if we stopprocessing the personal information, we may use it again if there are validgrounds under data protection law for us to do so (e.g., to comply withregulatory obligations, to defend against legal claims, to protect othernatural or legal persons, or for reasons of important public interest.

o   Right to data portability You have the right toreceive your personal information provided to us in a structured, commonly usedand machine-readable format. The relevant subset of personal information isdata that you provide to us with your consent or for the purposes of performingour contract with you.
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o   Right to object You have the right to object atany time, on grounds relating to your particular situation, to processing ofyour personal information. Kurashall no longer process your personal information unless it can demonstratecompelling legitimate grounds for the processing which override your interests,rights and freedoms, or if the processing is for the establishment, exercise ordefense of legal claims.
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o   Right to withdraw your consent You have theright to withdraw your consent under the data protection law at any time.Please note that your withdrawal will only take effect for future processingand will not affect the lawfulness of processing before the withdrawal. If yourefrain from providing personal information or withdraw your consent toprocessing, some features of our Service may not be available.

To conduct our Services, we use third party serviceproviders to provide Kura withnecessary services. We may transfer your personal information to these serviceproviders for further processing based on your consent with this privacy policyor on the basis of your agreement to use our services. All transfer of data isundertaken by way of secure connections to these service providers. Theseservice providers only receive your personal information that is adequate,relevant and limited to what is necessary in relation to the purposes for whichyour personal information is processed. These include the following categoriesof service providers: identification service providers, identity verificationproviders, monitoring services, server hosting providers, newsletter senders,customer relationship or support services, website hosting services, emailsending services, web traffic analysis providers. Additionally, throughour services your data may be transferred to third parties so that you mayregister and maintain an account and/or business relationship with thoseservices. You will be asked to consent to the transfer and continual transferof your personal information to those individual third-party services upon thefirst transfer of your personal information. You may revoke your consent totheir access to your personal information on our servers at any time. We mayhowever be required to store your personal information on their behalf and sendpersonal information to them again if there is a legal obligation to do so. 

Data Retention and Deletion-

We will not retain data longer than is necessary to fulfillthe purposes for which it was collected or as required by applicable laws orregulations.

We retain identifiable data, which is directly collectedfor purposes of providing our service to Customers or serving content toend-users, for twenty-four (24) months from the end-user’s last interaction with our Site or Service, after which time we will either de-identify the databy removing unique identifiers or aggregating the data or simply delete it.We may retain aggregated data, which cannot identify anindividual or device and is used for purposes of reporting and analysis, for aslong as commercially necessary.

Children-

The Site and/or Service is not directed to children under 13. We do not knowingly collect Personal Information from anyone under 13 years of age. If we determine upon collection that a user is under 13, we will notuse or maintain his/her Personal Information without the parent/guardian’sconsent. If we become aware that we have unknowingly collected PersonalInformation from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

If you are a parent or guardian and believe your child hasuploaded personal information to our site without your consent, you may contactus at info@kuratek.com. If we become aware that a child has provided us withpersonal information in violation of applicable law, we will delete anypersonal information we have collected, unless we have a legal obligation tokeep it, and terminate the child’s account.

If you’re a kid, please don’t use the Site or register forany of our Services or Platforms.

Security ofyour Information-
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We maintain tight controls over all the data we collect,retaining it in secured databases with limited and controlled access rights, toensure it is secure.

Where we have given you (or where you have chosen) apassword that enables you to access certain features of the Site or Service,you are responsible for keeping this password confidential.

Please remember that unfortunately, the transmission ofinformation via the internet is not completely secure, so although we will doour best to protect your personal data, we cannot guarantee the security of your data transmitted via the Site or Service; any transmission is at your ownrisk.
Once we have received your information, we will use strict procedures andsecurity features to try to prevent unauthorized access.

Kura takes every precaution to protect your PersonalInformation both online and offline and implements reasonable securitypractices and measures, including certain managerial, technical, operationaland physical security controls that are commensurate with the informationcollected and the nature of Kura’s business. NO Kura administrator will haveknowledge of your password. It is important that you protect yourself fromunauthorized access to your password, computer and cell phone. Be sure to logout of the website when you are finished. Kura is not responsible for anyunauthorized use of your account and password. If you suspect any unauthorizeduse of your account, you must immediately notify Kura by sending an email to support@kuratek.com. You will be liable to indemnify Kura for any loss thatKura suffers as a result of such unauthorized use of your account and password.Kura makes all User information available to its employees, agents or partnersand to third parties only on a need-to-know basis, and commits only itsemployees to strict confidentiality obligations.

Changing privacy policy –

Please note, we may modify the information presented viathe Site and/or this Privacy Policy from time to time. You should check backhere periodically to see if the Privacy Policy has been updated. We will alwaysshow the date of the latest modification of the Privacy Policy at the bottom ofthe page so you can tell when it was last revised. Kura may update this Privacy Policy at any time, with or without notice. In the event that there arematerial changes in the way Kura handles User Personal Information, or in thePrivacy Policy itself, Kura will post a notice on the Website or send Users anemail, as provided above, so that you may review the changes, terms andconditions before continuing to use the Services.

As always, if you object to any of the changes in our Termsand no longer wish to use the Services, you may contact support@kuratek.com todeactivate your account. Unless otherwise specified, Kura’s current privacypolicy applies to all information it has about you and your account. If a user uses the services oraccesses the website after notice of a change has been sent to that user orposted on the Website, that user hereby consents to the changed terms.

Consent to Processing and Transfer of Information-

Given that we are an international business, our use ofyour information may involve the transmission of data on an internationalbasis. By using the Site or Service, or providing us with any information, youconsent to the collection, processing, maintenance, and transfer of suchinformation in and to the United States and other applicable territories inwhich the privacy laws may not be as comprehensive as or equivalent to those inthe country where you reside and/or are a citizen.