Pamo (“Pamo”, “we”, or “us”) is committed to protecting the privacy of our customers, and we take our data protection responsibilities with the utmost seriousness. This Privacy Policy applies to your use of the Site, the Platform, and any of the Services offered by Pamo.

By using the Site, the Platform, and/or the Services, you accept the terms of this Privacy Policy and our Terms of Service (“Terms”), and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms. The Terms contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

This Privacy Policy shall be read and interpreted in conjunction with our Terms. Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, voice message, text message or other electronic messages or any other methods of communication online or offline.

1. DEFINITION

For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual or natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person, and it does not include de-identified or aggregated information and, to the extent permitted by law, does not include publicly available information that is lawfully made available to the general public or information that is lawfully made available from government records.
This Privacy Policy does not apply to Personal Information collected from employees, consultants, agents, advisors, or candidates for employment with Pamo.

2. PERSONAL INFORMATION DOES PAMO COLLECT AND PROCESS

3. WHAT OTHER INFORMATION WE DO COLLECT AND NEVER COLLECT

We are committed to the privacy of our Users. Except as otherwise stated, we DO NOT actively collect Personal Information or any information that will lead to the identification of any User. We collect certain information through tracking technologies used on the Site and/or the Platform such as cookies, analytic tools and log files (data files placed on a Device when it is used to visit the Site and/or the Platform), mobile analytics software and pixel tags (transparent graphic images, sometimes called web beacons or tracking beacons, placed on a web page or in an email, which indicates that a page or email has been viewed, and which may tell your browser to get content from another server). We do this to analyze trends, track user movement around the Site and/or the Platform, gather demographic information, and to generally collect information that we may find insightful or helpful. We, or our third-party service providers, may place cookies or similar files on your device for security purposes, and to facilitate site navigation. We may use social media platform cookies to improve our users’ experience. When you use any of our Services, we NEVER COLLECT OR STORE:
- Your private keys
- The password to your wallet account
- Your seed phrase

4. HOW WE USE INFORMATION

We use your information in accordance with your instructions, including any applicable terms in the Terms of conditions, and as required by applicable law. We may also use the information we collect for:
- Providing Our Services and Features. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as described in the Terms of Use. This includes using information to:
- operate, maintain, customize, measure, and improve our Services, and manage our business;
- create and update users’ accounts;
- process transactions;
- send information including confirmations, notices, invoices, technical notices, updates, security alerts, and support and administrative messages; and
- to create de-identified or aggregated data.
- Safety and Security. We may use your information to help maintain the safety, security, and integrity of our Services, including to:
- protect, investigate, respond to, and deter against fraudulent, unauthorized, or illegal activity;
- monitor and verify identity or service access;
- protect against spam, malware, or security risks;
- perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational issues;
- enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other Services; and
- comply with applicable laws and regulations.
- Customer Support. We may use the information we collect to provide customer support, including to:
- direct questions to the appropriate customer support person;
- communicate with you, including via social media channels;
- investigate and address user concerns; and
- monitor and improve our customer support responses and processes.
- Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience, enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes, develop new features and products, and facilitate payment solutions in connection with our Services.
- Legal and Regulatory Compliance. Many of our Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our Services in order to comply with anti-money laundering and anti-terrorism laws. This includes collection and storage of your photo identification. We also use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you attempt to link a bank account to your account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide information required by law, we will have to close your account. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
- Direct Marketing. We may use the information we collect to market our Services to you. This may include sending you communications via emails or mobile app notifications about our Services, features, promotions, surveys, news, updates, and events; managing your participation in these promotions and events; and to deliver targeted marketing. Our marketing will be conducted according to your advertising and marketing preferences and as permitted by applicable law.

5. ONLINE TRACKING OPT-OUT GUIDE

Like many companies, we use cookies, pixels, web beacons, SDKs, and other tracking technologies to collect information about your browsing activities, your interactions with websites and apps, and to serve tailored ads. There are a number of ways to opt out of having your online activity and device data collected through these services which we summarize below:
- Blocking Cookies In Your Browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- Blocking Advertising ID Use In Your Mobile Settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using Privacy Plug-ins Or Browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers.
- Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info.
- With Each of Our Service Providers or Advertising Partners Individually. The following website service providers or advertising partners offer opt-out features that let you opt-out of use of your information for analytics or targeted advertising:
- Analytics Cookies:
 - Google Analytics Google Analytics Opt Out
 - Microsoft Analytics Microsoft Privacy Statement
- Advertising Cookies:
 - Google: Google Advertising Opt Out
 - Microsoft/Bing: Microsoft Personalized Ads Opt Out
 - Facebook: Facebook Advertising Preferences
Please note that this list may be regularly updated, and because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use and we can not explicit details informing you that your information would be sent external service providers via API,

6. PROHIBIT TO COLLECTING OF CHILDREN'S DATA

Pamo does not allow anyone under the age of 18 to use our Services and does not knowingly collect personal information from children under 18.

7. COOKIES AND OTHER IDENTIFIERS

We use cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts, and understand how customers use our services so we can make improvements. Depending on applicable laws in the region you are located in, the cookie banner on your browser will tell you how to accept or refuse cookies.

8. SHARING YOUR INFORMATION WITH THIRD PARTIES

We may share your Personal Data with third parties (including other entities in our corporation) if we believe that sharing your Personal Data is in accordance with, or required by, any contractual relationship with you or us, applicable law, regulation, or legal process. When sharing your Personal Information with other entities in our corporation, we will use our best endeavors to ensure that such entity is either subject to this Privacy policy or follow practices at least as protective as those described in this Privacy Policy. We may also share personal information with the following persons:
1. Third-party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. These third-party service providers can only access personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
2. Legal Authorities: We may be required by law or by Court or competent agencies to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.
3. Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy policy (unless, of course, the user consents otherwise). Also, in the unlikely event that Pamo or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.
4. Protection of Pamo and others: We release accounts and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Pamo, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

9. SECURE YOUR INFORMATION

We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We work to protect the security of your personal information during transmission and while stored by using encryption protocols and software. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your personal information. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know.
Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account password. We recommend using a unique password for your Pamo account that is not utilized for other online accounts and signing off when you finish using a shared computer.

10. ADVERTISING

In order for us to provide you with the best user experience, we may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising. You have a right to object at any time to the processing of your personal information for direct marketing purposes.

11. USER RIGHTS

Subject to applicable law, you have a number of rights in relation to your privacy and the protection of your personal information. You have the right to request access to, correct, and delete your personal information, and to ask for data portability. You may also object to our processing of your personal information or ask that we restrict the processing of your personal information in certain instances. In addition, when you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time. If you want to exercise any of your rights please contact us at [email protected]. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal data.

12. HOW LONG DOES Pamo KEEP YOUR PERSONAL INFORMATION

We keep your personal information to enable your continued use of Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy policy, and as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or as otherwise communicated to you.

13. CONTACT INFORMATION

Our data protection officer can be contacted at [email protected] and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.

14. NOTICES AND REVISIONS

We reserve the right to change or modify the terms and conditions contained in this Privacy Policy, at any time and at our sole discretion. We may provide notice of these changes by posting the revised Privacy Policy and changing the "Last updated" date at the top of the Privacy Policy, or by any other means as determined by us at our sole discretion. Any changes or modifications will be effective immediately upon posting the revisions to the Site and/or the Platform. These changes will apply at that instant to all then current and subsequent use of or access to the Site, the Platform, and/or the Services. You hereby expressly and irrevocably waive any right you may have to receive specific notice of such changes or modifications. Your continued use of the Site, the Platform, and/or the Services acts as acceptance of such changes or modifications. We encourage you to frequently review this Privacy Policy to ensure that you understand the terms and conditions that apply to your access to, and use of, the Services.