PANAX PRIVACY POLICY
Last modified: 5 March 2025
Panax Ltd. (collectively, “Panax”,"us","our" or "we") iscommitted to respecting its clients andusers’ privacy rights (collectively, “you”,“your” or “user”). This PrivacyPolicy applies to our website, www.thepanax.com anditsassociated subdomains, as well as our application, panaxco-pilot(collectively, our “Service”).
This Privacy Policy (the "Policy") explains howwecollect, store and use your information. We encourage you to read thisPrivacyPolicy carefully and use it to make informed decisions.
By accessing or using the Service and/or accepting our Termsof Service, you confirm that you have read,understood and agreed to thecollection and use of your information as we haveoutlined in this Policy.
Capitalized terms used and not otherwise defined herein,shall have therespective meanings ascribed to them under our Termsof Service.
1. THE INFORMATION WECOLLECT
1.1. Panax collects information that identifies individuals or that may,withreasonable effort, identify individuals, including (the“PersonalInformation"):
1.1.1. Yourname, gender,identification number, billing address and other information youmay provide tous when you use the Service.
1.1.2. Your contact details; postal address telephone numbers (including mobile numbers) and e-mail address.
1.1.3. Your online browsing activities through the Service (for example, device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation).
1.1.4. Your Account password(s)and usernames.
1.1.5. If you choose to set up an account when using the Service by logging through your Google, Facebook or other social network account (Single Sign On),we may receive personal information about you from the social network.
1.1.6. Your,preferences, feedbackand survey responses.
1.1.7. Yourcorrespondence and communicationswith Panax.
1.2. Non-Personal Information. Panax alsocollectscertain unidentified, non-personal information that relatesto youronline browsing activities through your use of the Services (the“Non-PersonalInformation”). Non-Personal Information is non-identifiableinformation that, when taken alone, cannot be used toidentify you. As such, weare not aware of the identityof the user from which the Non-PersonalInformation was collected. We alsocollect aggregate user data regarding youruse of our Services. We mayanonymize or de-identify the information collectedthrough the Service or viaother means so that the information cannot, on itsown, personally identifyyou. Our use and disclosure of such aggregated or de-identifiedinformation isnot subject to any restrictions under this Policy, and we maydisclose it toothers without limitation and for any purpose. For the avoidanceof doubt, ifwe combine Personal Information with Non-personal Information(e.g., analyticaldata), the combined information will be treated as PersonalInformation so longas it remains combined.
2. HOW DO WE COLLECTYOUR PERSONAL INFORMATION?
2.1. Panax may collect PersonalInformationand/or Non-Personal Information (collectively, “Information”)duringyour access and/or use of the Service, including through yourinteractions andcommunications with the Service, in thefollowing ways:
2.1.1. Information You Provide toPanax. Panax collects Information that you provide it, forexample, when you usethe Services; when you answer questionnaires and surveys;send request customersupport; or communicate with us for other purposes.Please be aware that theInformation you choose to provide, may reveal, oridentify, information that isnot expressly stated (for example, your name mayreveal your gender).Accordingly, you should carefully consider whichinformation you wish to shareabout yourself.
2.2. Information Collected Automatically.When you access or use the Services, we may automatically collect Informationabout you, including:
2.2.1. Usage Information. Panaxmonitors users’ activity in connection with theServices and may collect loginformation about you when you access and use theServices including your IPaddress, time of access, browser type and language,Internet Service Provider("ISP"), informationabout the applications and features you use, thecontent you access, and anyactions taken in connection with the access and useof your content in theServices.
2.2.2. Device Information. If youaccess the Services from a mobile device, Panax maycollect information aboutthe device, including the hardware model, operatingsystem and version, uniquedevice identifiers, mobile network information (as allowed by the mobilenetwork) or platform information(as allowed by the specific platform type).
2.2.3. Cookies and Other TrackingTechnologies.
2.2.3.1. Like most websitesand onlineplatforms, our Service uses “cookies” to collect Information.“Cookies” aresmall text files containing strings of letters and numbers thatare downloadedonto your device (such as, computer, tablet or smartphone) whenyou use theService. These files allow to store Information about you. Some“cookies” willexpire when you exit the Service, and others will be saved inyour device’smemory.
Ifyou want to disable or change your “cookies” settings, you will have to access your device’s browser settings. Please note that if you disable all cookies, some (or all) of the features and functionality of the Service may not be available to you.
2.2.3.2. Other than “cookies”, when you use our Service, you consent to our use (and authorize third parties to use) of various technologies to collect Information, which may include web beacons (also known as "tracking pixels"), events and other technologies (collectively, “Tracking Technologies”). Such Tracking Technologies allow us to automatically collect Information about you, your device and your online behavior, in order to enhance your navigation and improve our Services’ performance, perform analytics and customize your experience. In addition, we may merge data we have with Information collected through these Tracking Technologies and data we may obtain from other sources and, as a result, such combined data may constitute Personal Information.
3.1. Panax uses your Informationfor thelimited purpose of providing the Service and related functionality andservices,or as otherwise specifically described in this Policy and aspermitted byapplicable laws, all of which serve the legitimate interests ofPanax,including:
3.1.1. Providing,operating,maintaining, improving, promoting and auditing the Service (by Panaxor any thirdparty acting on its behalf), from time to time.
3.1.2. Sendingyoutransactional messages, technical notices, updates, security alerts andsupportand administrative messages.
3.1.3. Identifying you, so that we can interact with you, as well as providing and delivering services and features that you request, processing and completing transactions, and sending you related information.
3.1.4. Responding to your comments, questions, and requests and provide customer service and support.
3.1.5. Communicating with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Panax and ours elect partners.
3.1.6. PersonalizingtheService, providing content, features, and/or advertisements that matchyourinterests and preferences or otherwise customize the Services.
3.1.7. Monitoring and analyzing trends, usage, and activities in connection with the Services for research, marketing or advertising purposes.
3.1.8. Linking or combining the Information with other information we receive from third parties to help understand your needs and provide you with better service.
3.1.9. Forcrimeand fraud prevention, detection and related purposes.
3.1.10. Wherewehave a legal right or duty to use or disclose your information (for exampleinrelation to an investigation by a public authority or in a legal dispute).
3.1.11. Forcustomerrelations, queries, complaints or disputes and Service’s operations.
3.1.12. Internalrecordkeeping.
3.1.13. Formanaginginsurance claims by our customers.
3.1.14. Cybersecurityneeds,fraud detection and misuse of our website.
3.2. Marketing(Promotional communications)
3.2.1. Ifyou indicated youragreement to receive promotional materials from Panax, thenwe may use your email address to sendyou electronic mail for marketing purposesand update you about promotionaloffers, products and services which we thinkmay be of interest to you as anindividual (the "Newsletters"), and byaccepting the terms ofthis Privacy Policy you agree to Panax sending you suchNewsletters, from timeto time.
3.2.2. Youarenot obligated by law or otherwise to receive our Newsletters, and you havetheright to opt out of receiving such communications, at any time, by:
3.2.2.1. following theunsubscribe instructionsincluded in each Newsletter; or
3.2.2.2. contacting Panax viaprivacy@thepanax.com and request to be removed from our mailing list.
3.2.3. Nonetheless, please note that even if you choose to unsubscribe from our mailing list, we may continue sending you notices (a) to update you on revisions made to this Privacy Policy or our Terms of Service; and (b) related to the ongoing Service, for example, promotions regarding products and services used by you, notices concerning your accounts and any additional operational notices as required.
3.2A Third-Party Payment Services. Panax may offer access to third-party payment services through the Service (“Third-Party Payment Services”). Such Third-Party Payment Services are provided by third-party providers, including Airwallex and Airwallex’s regional banking partners, and not by Panax. Panax does not control or assume responsibility for these Third-Party Payment Services. By using any Third-Party Payment Service ,you (i) agree to be bound by the applicable terms and policies of the provider, including Airwallex’s Terms of Service and Privacy Policy available HERE ,; and (ii) acknowledge and consent to the transfer of your Personal information to such third-party providers as necessary for transaction processing.
3.3. Sharing your Information with Third Parties
3.3.1. Wemayuse and share your Information with certain third parties that help usoperateour Service, (e.g., deliver customer support, monitor and analyzetheperformance of our Services, such as newsletter distribution and otherservice providers). When Panax uses such thirdparties, it restricts them fromusing or disclosing Personal Information,except as required to perform theservices on behalf of Panax or to comply withlegal requirements. Specifically,we do not permit such third parties to useany Personal Information we sharewith them for their own marketing purposes orfor any purpose other than inconnection with the services they provide to us.Third parties with which we mayshare your Information will be required to meetour standards on processinginformation and security. Personal Information weprovide them will only beprovided in connection with the performance of theirfunction.
3.3.2. Wemay also share yourInformation with:
3.3.2.1. credit referenceagenciesand payment card issuers (such as Visa, Mastercard and AmericanExpress) wherenecessary for card payments.
3.3.2.2. governmentalbodies,regulators, law enforcement agencies, courts/tribunals and insurerswhere weare required to do so (a) to comply with our legal obligations; (b) toexerciseour legal rights (for example in court cases); (c) for theprevention,detection, investigation of crime or prosecution of offenders; and(d) for theprotection of our employees and customers.
3.3.2.3. If Panax becomesinvolvedin a merger, acquisition, or any form of sale of some or all of itsassets, itmay transfer all the Information that was collected from users inconnectionwith such a transaction.
3.3.3. Ourcloud service providers. Theserver(s) on which the Service are hosted arewithin the United States. Pleasenote that some of the Information may bemanaged by third parties, including, Amazon Web Service (AWS)technology, whosemailing address is Amazon Web Services, Inc., 410 Terry AvenueNorth, Seattle,WA 98109-5210, ATTN: AWS Legal. You can find more details onAWS' Privacy Policyhere. We have configured ourdata to be stored in Northern Virginia (US-EAST-1).
3.4. International Transfer ofInformation.To provide you with our Service, it may be necessary for Panax togrant thirdparties fromjurisdictions outside of your country of residency, with access toyourInformation. By agreeing to the terms of this Privacy Policy, you agree toPanaxsharing your Information outside of your country of residency.
3.5. We reserve the right todisclose yourInformation as required by law and when we believe thatdisclosure is necessaryto protect our rights and/or comply with a judicialproceeding, or court order.
3.6. Also, please note that wemay disclosegeneral, aggregated, non-personal and non-identifiable informationabout ourusers to potential business partners, investors, or the public.
4. HOW LONG DO WE KEEPYOUR INFORMATION?
4.1. Panax will retain yourInformation foras long as needed to provide you and our clients with ourService, or to complywith legal and regulatory obligations (e.g., audits,accounting and statutoryretention terms), enforcing our Terms of Service, dispute resolutions and fortheestablishment, exercise or defence of legal claims in the countries where wedobusiness. This isalso the case for any third party with which we share yourInformation whenthey carry out services on our behalf.
4.2. While different retentionperiods mayapply with respect to different types of data, the longest we willnormally holdPersonal Information is ten (10) years. When we no longer needyour PersonalInformation and there is no need for us to keep it to fulfil thepurposesdescribed in this Privacy Policy, we will either remove it from oursystems oranonymize such Information so that it cannot identify you.
4.3. When you send an email orothercommunication to privacy@thepanax.com, or any other correspondence that youhavewith us, we may retain those communications in order to process and respondtoyour requests and improve our Service.
4.4. Please DO NOT sendus anycommunication which contains confidential or sensitive information,since we areunable to evaluate whether your content constitutes asconfidential or sensitiveinformation, or not, and we may retain or use suchcommunication as describedhereinabove, and such retention or use shall not bedeemed as a breach of any ofour obligations pursuant to this Policy.
5. INFORMATION SECURITYSTANDARD
5.1. Because we value your privacy, Panax uses industry standard measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of data which is stored in our records. These measures include internal reviews of our data collection, storage and processing practices and standard measures, sensitive information is transmitted via Secure Socket Layer (SSL) technology, making our systems accessible only by those authorized with special access rights to such systems,and are required to keep the information confidential.
5.2. Nonetheless, we cannotguarantee aperfect and absolute security of your Information, as no method oftransmissionover the Internet and or electronic storage is perfectly secure orinvulnerable.However, should we become aware of a security breach, we willnotify anyaffected user, so that they can take appropriate protective steps. Suchnotifications shall beissued by Panax in accordance with the applicable (local)laws and regulations,as well as Panax's internal policies.
5.3. Physical Standard. Panax followsAmazon’sPrivacy and Security Policy security standards with respect to physicalaccess. You canread more about it here.
6. HOW CAN YOU HELPTO PROTECT YOUR DATA?
6.1. First, please remember thatPanax willnever ask you for any password, bank account or credit card details.If youreceive such communicating asking you to provide suchinformation,please ignore it and do not respond. You can let us knowthat you havereceived such communication viaprivacy@thepanax.com.
6.2. If you are using yourdevice in apublic location, we highly recommend that you always log out andclose thebrowser after completing your session.
7. WHAT RIGHTS YOU HAVE IN CONNECTION WITH YOUR INFORMATION?
7.1. You have the right to ask that Panaxwill provide you with a copy of anyPersonal Information that we keep about you.
7.2. You have the right to ask that Panaxshall update and correct anyoutdated or inaccurate Personal Information that wekeep about you. Should youfind that the Personal Information related to you isnot accurate, complete, orupdated, then please provide us the necessary informationto correct it.
7.3. If you wish to exercise any of therights described above, please notifyus by email to privacy@thepanax.com, and wewill usecommercially reasonable efforts to accommodate your request. Panaxshall notcharge you for requesting to exercise any of theaforementioned rights.
8. SPECIFIC PROVISIONSFOR EU-RESIDENTS
8.1. This Section 8 applies to you, if you are from the European Union. Panaxadopted thefollowing provisions, to comply with the EU 2016/679 DirectiveGeneral DataProtection Regulation (“GDPR”), pursuant to which Panax willbeconsidered as a "Data Controller" with respect to our use ofPersonalInformation of residents of the European Union.
8.2. Legal Basis. We baseour processing ofany personal data as “Data Controllers” based on thefollowing lawful grounds:
8.2.1. Panax relies, primarily, onyour consent tothe terms of this Policy and the terms set forth under our Terms of Service, asa legal basis for processingany Personal Information related to you orcommunicating any other promotionalmaterial.
8.2.2. Panax may collect and useyour PersonalInformation when it is necessary for one of the legitimate usesset out inSection 3 above, which we believe are not overriddenby your fundamental rights.
8.2.3. We may process yourPersonal Information tocomply with a legal obligation and to protect ourusers' vital interests.
8.2.4. If, at any time, you wishto exercise yourrights in accordance with the provisions provided by law(including as providedunder Section 7 of this Policy) you may send us an email tovia privacy@thepanax.com,andrequest:
8.2.4.1. to access your Personal Information together with information about how, and on what basis, such information is being processed. Should you desire to receive such information in a different format than the one that was provided to you, you can contact us viaprivacy@thepanax.com and we shall use commercially reasonable efforts to accommodate your request, if applicable.
8.2.4.2. to rectify any of the Personal Information being held when such information is inaccurate.
8.2.4.3. to delete or restrict access to your Personal Information in limited circumstances as described under the GDPR. Please note that if we need to delete any Personal Information related to you, as per your request, it can take time until we completely delete residual copies of such data from our servers and backup systems.
8.2.4.4. to withdraw your consent to the processing ofyour Personal Information.However, please note that exercising this right willnot affect the lawfulnessof any previous processing activities based on consentthat was lawfullyobtained before its withdrawal.
8.2.4.5. to obtainand reuse your Personal Informationfor your own purposes across differentservices, as part of your right to dataportability.
8.3. Please note that you havethe right tocomplain to a Data Protection Authority about our collection anduse of yourPersonal Information. For more information, please contact yourlocal dataprotection authority in the European Economic Area (EEA).
8.4. If you have any concernswith respectto our methods of processing any Personal Information related toyou, or if wishto withdraw your consent, for any reason, kindly let us know bysending an emailto privacy@thepanax.com.
8.5. If you reside in a countryfrom theEuropean Economic Area, then, by agreeing to the terms of this PrivacyPolicy,you agree to Panax sharing your Information outside of the EuropeanEconomicArea. These transfers are subject to special rules under data protectionlaws.If this happens, we will ensure that the transfer will be compliant withdataprotection law and all personal data will be secure. Our standard practiceis touse ‘standard data protection clauses’ which have been approved by theEuropeanCommission for such transfers. Those clauses can be accessed here.
8.6. Panax shall not charge you forrequesting to exercise any of theaforementioned rights.
9. SPECIFIC PROVISIONFOR CALIFORNIA RESIDENTS
This Section9 applies to you only if you reside in the State of California, United States. Panax adopted the following provisions to comply with the California Consumer Privacy Act (“CCPA”)and any terms defined in the CCPA have the same meaning when used in this Section 9.
9.1. The following categories reflect the type of personal information which Panax has collected within the last twelve (12)months:
9.1.1. Identifiers and Personal information as listed in the California Customer Records statute(Cal. Civ. Code § 1798.80(e)), for example, first names, surnames, telephone numbers, address, online Identifier, Internet Protocol address, business or private email addresses, account usernames, as well as Personal Information as such term is defined in this Privacy Policy.
9.1.2. Electronic network activity information, including, but not limited to, browsing history and any additional information related to your interaction with our Service.
9.2. Panax has obtained such informationasset forth in Section 9.1above and Personal Informationas provided under Section 1.1above (for the purpose of thisSection 9,the “Personal Data”).
9.3. Panax may use the Personal Dataitcollects or receives for its legitimate interests (as set out in Section 3above), which Panax believes are notoverridden by your fundamental rights.Panax may also disclose such PersonalData to third parties for its legitimatepurposes as described in Section 3above.
9.4. In the preceding twelve (12)months, Panax has disclosed the following Personal Data for our business purposes:
9.4.1. Identifiers(including your name, email address, profession).
9.4.2. Personal Data's categories as listed in the California Customer Records statute.
9.4.3. Inferences.
9.5. In the preceding twelve (12)months, Panax has not sold any of your Personal Data.
9.6. Your rights as a California Resident. You are entitled to request the following specific rights under the CCPA, solely with respect to Personal Data related to you:
9.6.1. Request to know (a) what categories and specific components of Personal Data we collect about you and from which sources; (b)categories of Personal Data that we disclosed for the purpose described in Section 3 above, and the categories of third parties with whom we have shared any particular category of your Personal Data. If we disclose any of your Personal Data to a third-party, we will provide you, after authenticating your identity, with a list that will identify the specific category of your Personal Data which was disclosed.
9.6.2. Requestthat we delete any Personal Data we collectabout you. After authenticatingyour identity, we will delete (and direct ourservice providers to delete) anyPersonal Data related to you from our records,unless an exception applies.Please note that if we need to delete any PersonalData related to you following your request, it can take time until wecompletelydelete residual copies of Personal Data from our servers and backupsystems.
9.6.3. Instructus not to sell any Personal Data related toyouthat was collected by us.
9.6.4. Youhave the right not to bediscriminated against byPanax, for exercising your rights under the CCPA.
9.7. If you have anyconcerns about how weprocess Personal Data related to you, or if you wish towithdraw your consent,for any reason, kindly let us know by sending an emailto privacy@thepanax.com. Please note thatexercising this right will not affect thelawfulness of any previous processingactivities based on consent that waslawfully obtained before its withdrawal.Also, please note that Panax shall notcharge you for requesting to exercise anyof the rights set forth in thisSection 9.
10. SPECIFIC PROVISIONS FOR USERS FROM ISRAEL,UNDER THE ISRAELI PROTECTIONOF PRIVACY ACT, 5741-1981.
10.1. If you are an Israel resident, you should note that we collect, use, disclose, and otherwise process Information as described above with your consent where required by applicable law.
10.2. Users are under no legal obligation to provide Panax with any Personal Information, however, if you choose not to provide us the data categories we request, some(or all) of the features and functionality of the Service may not be available to you.
10.3. Further, if user provides Panax with details of any other individual, he/she must give a copy of this Policy to, and obtain consent from, that individual before disclosing their Personal Information to us.
10.4. Please note that according to the Israeli Privacy Protection Law, 1981 (the “PPA”),every individual is entitled to review information about themselves, either personally, or through a duly authorized legal representative, or through a guardian. If you submit such a request to access and/or review your Personal Information we keep about him/her (which may be a digital copy), Panax will not charge you with a fee for such request.
10.5. If, after examining your Personal Information, you find it to be incorrect, incomplete, unclear, or outdated, you may request that we correct or delete said information.
10.6. If we decline your request in accordance with the PPA, we shall notify you, in the manner and procedure prescribed by the PPA and the applicable regulations.
10.7. Pleasenotethat Panax may request you to provide certain credentials to verifyyouridentity as a condition for reviewing your application.
11. LINKS TO OTHER WEBSITES; THIRD PARTYSERVICES
11.1. This Privacy Policy applies only to the Service offered by Panax. Nonetheless, please note that the Service may contain links to other websites or applications not operated or controlled by Panax. We are not responsible for the content, accuracy or opinions expressed in such websites or applications, and such websites or applications are not investigated, monitored or checked for accuracy or completeness by Panax. Please note that when you use a link to go from Panax’s Service to another website or application, your access to and use of such websites or applications are governed by the websites or applications’ own rules and policies.
11.2. Panax may make available through the Service, third-party content, applications, products and services solely as a convenience (the "Third Party Services"). You acknowledge and agree that Panax is not, and shall not be, responsible for any Third Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Panax does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third Party Services accessed and/or consumed by you or any third parties, and if you or any third party choses to access and use them, you do so at your own risk and subject to the rules and policies of such Third Party Services.
12. COMPLIANCE
If you believe that we havenot adhered to our Policy asoutlined herein, please notify us by email to privacy@thepanax.com. Panaxwill examineany query and make commercially reasonable efforts to resolve anyexisting orpotential dispute. Note that when you send us a request to exerciseyour rights,we will need to reasonably authenticate your identity andlocation, andtherefore we may ask you to provide us credentials to make surethat you are whoyou claim to be and will further ask you questions tounderstand the nature andscope of your request.
13. CHANGES TO THIS POLICY
We reserve the right tochange this Policy from time to time,so please review it frequently. If wemake material changes to this Policy, andyou are a registered user of theService, we will notify you by email when wemake any changes.
14. GOVERNING LAW
This Policy shall be construed in accordance with and governed for all purposes by the substantive laws of the State of Israel without regard to conflicts of law provisions. You agree that any claim or dispute you may have against us and/or our affiliates, directors, officers, employees, and representatives will be resolved exclusively by the competent courts located in Tel Aviv – Jaffa, Israel, and waive any jurisdictional, venue or inconvenient forum objections to such courts.
15. CONTACT US
If you have any questions about this Policy, please contact us via privacy@thepanax.com or via post to 8 Shaul Hamelech St., Tel Aviv –Jaffa, Israel
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