Privacy Policy

Last updated: April, 2018

This Privacy Notice (the “Notice”) describes how KUBRA Data Transfer Ltd. (“KUBRA”, “we”, “our” or “us”) handles personal information in connection with the operation of the KUBRA EZ-PAY services offered to individuals through or through the KUBRA EZ-PAY mobile app (collectively, the “KUBRA EZ-PAY Services”).

This Notice applies only to information that KUBRA obtains through the KUBRA EZ-PAY Services and describes how we can use the information we obtain and with whom we may share it. This Notice does not describe the privacy practices of the utilities, insurance companies, government agencies and other service providers for which you use the KUBRA EZ-PAY Services as a payment platform (collectively, the “Service Providers”). We encourage you to review their privacy policies and other similar statements.

We obtain different types of information, including personal information, when you use the KUBRA EZ-PAY Services. This information may be provided by you, such as when you create an account, it may be automatically collected from your browser or mobile device using technologies such as cookies, or it may be obtained from other sources.

Information you provide:
We obtain information you provide in relation to your use of the KUBRA EZ-PAY Services, including when you make a one-time payment or create an account. This may include:
  • your contact information, including your name, email address and phone number;
  • your account numbers for the Service Providers with whom you engage; and
  • your bank account number or debit or credit card number information (including payment card number, expiry date, security code).

We may also obtain information you provide us about others, such as the phone number and email address of the recipients to whom you want to send a receipt of the bill payment, if you choose to share the receipt with others.

If you contact us with any questions or requests relating to the KUBRA EZ-PAY Services, we obtain the information you provide to us in connection with your inquiry or request.

Information automatically collected:
We may automatically obtain certain information when you access the KUBRA EZ-PAY Services from your web browser or mobile device, such as information about the number and frequency of visitors, technical information about browsers and devices used to access the KUBRA EZ-PAY Services, and information about crashes or other technical issues. In addition, we and third parties may automatically collect certain information through automated means about your activities over time across the browsers and devices you use to access the KUBRA EZ-PAY Services as well as across third-party sites, apps or other media. These technologies may assign or collect a unique identifier on your browser or device, and may reside, among other places, on your computer or device, within webpages or mobile apps. We may use these technologies to administer the KUBRA EZ-PAY Services, understand usage of the KUBRA EZ-PAY Services and improve the content and offerings of the KUBRA EZ-PAY Services.
For more information about the use of automated means in the context of interest-based advertising and how you can limit tracking on your browser or mobile device, see Interest-based advertising.

Information we obtain from other sources:
We may obtain information about you from third parties, including the Service Providers with whom you engage.

We may use the information we obtain through the KUBRA EZ-PAY Services for a number of purposes, including, but not limited to:
  • providing you with the KUBRA EZ-PAY Services, as well as information you may request;
  • marketing and advertising the KUBRA EZ-PAY Services and other products and services;
  • sending you communications, including informational and marketing communications;
  • improving the KUBRA EZ-PAY Services we provide and customizing the user experience;
  • generating and analyzing statistics about your use of the KUBRA EZ-PAY Services;
  • detecting, preventing, and responding to violations of this Notice or the Terms of Use, violations of law, or other misuse of the KUBRA EZ-PAY Services; and
  • supporting our business operations.

Interest-based advertising:

We and third parties may collect information about your online activities to provide you with advertising tailored to your interests. You may see certain ads on other websites because we or third parties participate in advertising networks. Ad networks track your online activities over time and across different browsers and devices you may use by collecting information through automated means, including through the use of cookies, web server logs and web beacons.

The information ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages, advertisements or videos you view and the actions you take on the websites. This data collection may take place both on our website and on third-party websites or apps that participate in ad networks. This process allows us and third parties to deliver more tailored advertising and helps us track the effectiveness of our marketing efforts.

To learn more about your rights in relation to this ad network interest-based advertising on your browser, including your choice to opt out, you can follow the instructions provided by the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”) to place an opt-out cookie on your browser. These opt-out cookies enable you to block participating companies from installing future cookies on your computer or browser. If you place opt-out cookies but subsequently clear or delete cookies on your computer or device browser, your opt-out cookies may be deleted and you may have to renew your opt-out choices for that specific browser.

To limit interest-based advertising on your mobile device, you can review and adjust the settings provided by your device manufacturer, such as “Limit Ad Tracking” for iOS or “Opt-out of interest-based ads” for Android.

These opt-out mechanisms are provided by third parties. KUBRA does not control or operate these mechanisms or the choices provided through these mechanisms.

We may share the information we obtain from you through the KUBRA EZ-PAY Services:
  • with the Service Providers with whom you engage;
  • with our affiliates and subsidiaries;
  • with third parties that provide services or handle transactions on our behalf;
  • as we believe is necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the KUBRA EZ-PAY Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, subpoenas and other requests from public and government authorities;
  • we reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation; and
  • we may share your information with third parties when you consent to or request such sharing.

We maintain reasonable administrative, technical, and physical safeguards to protect the personal information we obtain through the KUBRA EZ-PAY Services. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. If you create an account to use the KUBRA EZ-PAY Services, you are responsible for keeping your password secure.

The KUBRA EZ-PAY Services may contain links to third-party websites, mobile apps or features, including through social media features and widgets on our website. KUBRA is not responsible for the collection and use of your information by such third parties. We encourage you to review the privacy policies or other similar statements applicable to third-party websites, mobile apps or features.


Your California Privacy Rights

Residents of California may request a list of third parties to which certain personal information (as defined by applicable California law) obtained through the KUBRA EZ-PAY Services and disclosed by KUBRA during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please write to us at 40 E Rio Salado Pkwy, Suite 535, Tempe, AZ, 85281. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via other contact channels, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Do Not Track
KUBRA does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

The KUBRA EZ-PAY Services are intended for U.S. users. If you are located outside of the United States, please note that the personal information we collect in connection with your use of the KUBRA EZ-PAY Services will be transferred to the United States and other countries. ‘

The KUBRA EZ-PAY Services are not directed to, nor do we knowingly collect personal information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us as indicated below.

We may update this Notice from time to time to reflect changes in our privacy practices or applicable laws. We will notify you of these changes by publishing the updated version on our website and indicate at the top of the Notice when it was most recently updated. Your use of the KUBRA EZ-PAY Services will be governed by the current version of this Notice.

Any dispute you may have arising under this Notice will be resolved in accordance with the Terms of Use.

If you have any questions about this Notice or you would like to review or request changes to the information collected in connection with your use of the KUBRA EZ-PAY Services, please contact us at