1. Introduction

PythiaPlus Ltd., including its subsidiaries and affiliates ("Company", "Morgi", "us", "we", "our"), is committed to protecting the privacy of anyone who access, uses, or registers to our Services (defined below). We have published this Privacy Policy ("Policy") to outline our practices with respect to collecting, using, and disclosing your information when you use our Services. We encourage you to read this Policy carefully and use it to make informed decisions. Our Services may be connected by “hyperlinks” to other third-party’s sites. We are not responsible in any way for the privacy practices on other third-party’s sites and advise you to review the privacy policies on those linked sites before using them.

2. Our Services

To get a better sense on how and from whom we collect data, it is useful to start with a brief overview of our Services. Morgi operates a website www.morgi.org ("Website"), on which individuals ("Friends") can receive gifts ("Gifts") from other individuals ("Leaders") for gifting purposes (together, "Services"). This Policy applies to the information we collect from any person using or interacting with our Services, including Friends and Leaders, as well as any person visiting our Website (collectively: “Users”).

3. What types of data we collect?

We collect two types of data from you: Personal Data ("Personal Data") and non-Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (for example, the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you.

3.1. All Users

• When you register with us: when you set up an account on our Website, we collect the Personal Data you provided with us. This includes, for example, your name, email address, photo, and country of origin.
• When you visit or use our Website: we may use tracking technologies—such as cookies, JavaScript, beacons, and Local Storage—to temporarily store data about your use of our Services. This includes, for example, geo-location data, length of time spent on the Website, pages clicked on etc. This allows us to recognize you when you visit our Services and offer you, for example, tailored content and advertisements that better correspond with your interests. Our Cookies Policy discusses our use of tracking technologies in greater details.

3.2. Friends

• When you create a fundraising campaign ("Campaign"): Friends can open a Campaign with the goal of raising Gifts for a specific purpose (for example, purchasing a violin). When you, as a Friend, open such a Campaign, we collect and process the information you provided in relation to that Campaign (for example, the Campaign's title and description, the fundraising cause, and any photo you uploaded). We will also use your image information (e.g. likeness and physical attributes, such as user hair color or eye color) for face analysis, as described below.
• When you withdraw your funds: in order to withdraw funds from the Website into your bank account, you will be requested to provide your banking information and a document verifying your identity (for example, ID, Passport, or a driver's license). This information is collected by our third-party Payment Processors (defined below), with whom we have a direct contractual relationship, and for the purpose of ensuring that the funds will be transferred to the intended recipients. Our third-party Payment Processors currently is PayPal and CCBill (Collectively: "Payment Processors"). You can learn more about their practices with respect to collecting, using, and disclosing information at PayPal's privacy policy and CCBill’s Privacy Policy.

3.3. Leaders

• When you make a Gift: in order to make a Gift over the Website, you will be required to provide certain personal information – such as your name, email, and country of origin – as well as information about your payment instrument (for example, credit card). This information will be collected by our third-party Payment Processors for the purpose of processing the Gifts. The Payment Processors will provide us with information on the data which you made the payment, a generic number which is linked to your email address or account (order number), and information about the instrument used (e.g., credit card, debit card, or bank account).

4. Our use of cookies and tracking technologies

When you visit or access our Services, we use (and authorize third parties to use) pixels, cookies, beacons and other technologies. Those allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services’ performance, perform analytics, and customize your experience. To get a better sense on our use of cookies and tracking technologies, please visit our Cookies Policy.

5. Why we collect your Personal Data?

Privacy laws require us to have a valid lawful basis in order to process your Personal Data. The lawful basis for processing are set out in Article 6 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). This section explains for what purposes we may use your personal data and outlines the legal bases that underlie our usage.

6. MARKETING

6.1 The Company may use your Personal Data, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) affiliated companies or Company's business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.

6.2 We may also share and disclose Personal Data with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Data for different marketing techniques, such as, but not limited to, direct email, post and SMS.

6.3 You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to DPO@morgi.org.

6.4 Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

7. With whom we share your data?

We share your Personal Data as descried below –

• Service providers: we share your information with service providers, such as analytics providers, payment processors, and advertisers, who help us provide you with our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose.
• Advertising and marketing: we may share your information with our trusted partners to either provide you with tailored ads on our Services or on other third party websites or apps; or for the purpose of providing you with promotional materials we, or our trusted partner, believe may be of interest to you.
• Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
• Merger and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.

8. Data protection rights

This section addresses the specific rights applying to residents of the EU or residents in other jurisdiction that afford the below rights.

8.1. Your rights

You may request to:

1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your Personal Data that is in our control.
4. Request erasure of your Personal Data.
5. Object to the processing of Personal Data by us.
6. Request to restrict processing of your Personal Data by us.
7. Lodge a complaint with a supervisory authority.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.

8.2. Transfer of data outside the EU

Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Privacy Policy. However, we will only transfer your data-to-data recipients (i) located in the European Economic Area (the “EEA”), (ii) non-EEA countries which have been approved by the European Commission as providing adequate level of data protection, or (iii) countries entered into legal agreements ensuring an adequate level of data protection.

9. How we protect your data?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via DPO@morgi.org.

10. Minors

We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

11. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted on our Website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

12. Data Protection Officer

The Company has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address: DPO@morgi.org

13. Further Information

If you have any further questions regarding the data collects, or how we use it, please contact us via the available chat option.