Privacy Policy

Updated: May 8th, 2024

I. Who We Are is a company based in Delaware, U.S.A., that acts as a technology service provider for various institutions.

We welcome your questions, comments, and concerns about privacy. If you have any questions or comments about this Privacy Policy or our practices, or wish to make a request regarding your Personal Information, please contact us as follows:

II. Who and What is Covered by this Privacy Policy?

This Privacy Policy describes how (hereafter, “Company,” “we,” “us,” and/or “our”) uses and/or shares Personal Information. This Privacy Policy applies to the Company’s online and offline information gathering and dissemination practices in connection with this website (collectively, the “Site”) and also Personal Information we may receive through other means. We do not knowingly attempt to solicit or receive information from minors or from persons residing outside of the U.S.A.

If you have arrived at this Privacy Policy by “clicking” on an authorized link directing you to a Site operated by the Company, then this Privacy Policy applies to you and such Site. When you use the Site, you consent to the use of your information in the manner specified in this Privacy Policy. This Privacy Policy does not apply to any website owned and/or operated by or on behalf of any third party, even if we provide a link to such website on our own Site. We understand that you care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes the Company’s policies and practices regarding its use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies, so please check back from time to time for updates to the policy posted here. Updates become effective immediately upon posting unless otherwise stated. By your continued use of the Site, you consent to the terms of the most recently revised and posted policy. Use of our Site is strictly limited to persons who are of legal age in the jurisdictions in which they reside. You must be at least eighteen (18) years of age to use our Site. If you are not at least 18 years of age, please do not use or provide any information through this Site.

III. Personal Information We Collect

The following is a description of: (i) the categories of Personal Information we may have collected in the preceding 12 months; (ii) the sources from which we may have collected it; and (iii) the business purposes for which we may have collected it. We do not knowingly solicit, collect, or receive information from or about minors under the age of 18 or from persons residing outside of the U.S.A., through the Site or otherwise.

A. Information You Provide Directly.

If you voluntarily choose to submit or otherwise disclose Personal Information to us, including through the Site, or by regular mail, telephone, fax, e-mail or other electronic means of communication, that information is governed by this Privacy Policy.

The Personal Information we may collect directly from you from these sources includes your:

• First and last name

• Contact information

• Device contacts

• Contacts list

• Device telemetry

• User ID

• Profile Image, Contacts Images

• Photos & Videos

• Audio recordings

• Songs & Music

• Files on device

• E-mail Address

• Cell Phone Number

If you contact or correspond with us by phone or email, we may keep a record of your contact information and correspondence, and we reserve the right to use your contact information, and any other information that you provide to us in your message, to respond thereto. If you wish to change or correct any information you have voluntarily submitted to us, please do so by contacting us in the manner described, below.

C. Information Provided To Us By Others. acts as a Service Provider for various institutions. (“Clients”). In its role as a Service Provider, the Company receives Personal Information regarding customers of the Company’s Clients. The Personal Information received by may include:

• customer information, including User ID, IP address, mobile device identifier, and type of browser;

• customer account information, including account ID, account type, balance history, and transfer history;

• user information, including IP address, mobile device identifier, date/time of login, and type of browser;

• information regarding recipient information, including external financial institution ID, type of account, routing number, transfer balance, date/time of transfer, status of transfer, transfer ID, transfer method, direction of money movement, and balance history;

• customer service engagement, including date/time of customer service contact, means by which customer service was contacted, and customer satisfaction score; and

• collections engagement, including date/time of customer service contact and means by which customer service was contacted.

D. Information Automatically Collected by Your Use of This Site.

You may use this Site without disclosing to us any personally identifiable information. We do not automatically collect any personally identifiable information from you (e.g., name, address, telephone number, email address, social security number, account numbers, or financial information) when you use the Site. The Site can only collect such information if it is affirmatively provided by you.

Like most websites, however, the Site automatically collects certain non-personally identifiable information during a user’s visit. That information may include the internet protocol (IP) address of your device, the location where the device is accessing the internet, browser type and language, internet service provider, type of computer/operating system, date/time stamps, user interface interaction data (e.g., mouse clicks or navigation through the Site), and other information about the usage of the Site, including a history of pages viewed and or uniform resource locator (URL) information (showing where you came from or where you go to next). We use this information to improve the Site’s design, estimate user volume and usage patterns, speed up searches, and improve the user experience. We may also use this information to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

More specifically:

(i) IP Address

Each time a user visits the Site, we may automatically collect an internet protocol (IP) address and the web page from which the user was directed to the Site. In order to administer and optimize the Site and to diagnose and resolve potential issues or security threats to our Site or to the Company, we may use an IP address to help identify users and to gather broad demographic information about them.

(ii) Cookies, Pixel Tags, And Web Beacons

Cookies are small files that a site or its service provider transfers to a user’s device through the web browser (if you allow) that enables the site’s or service provider’s systems to recognize the browser and capture and remember certain information. We use cookies to optimize Site functionality and improve a user’s experience while navigating through the Site. Most or all browsers permit you to disable or reject cookies. You can do this by adjusting your preferences in the browser.

Our Site may incorporate “pixel tags,” “web beacons,” or similar tracking technologies (collectively, “pixel tags”) that track the actions of Site users. Pixel tags are used to collect information, such as the internet service provider, IP address, the type of browser software and operating system being used, the date and time the Site is accessed, the website address, if any, from which a user linked directly to the Site and/or the website address, if any, to which the user travels from the Site and other similar traffic-related information.

We may aggregate information collected from Site visits by various users to help us improve the Site and the services that we provide through the Site.

(iv) Analytics Information

Web servers for the Site may gather anonymous navigational information about where visitors go on our Site and information about the technical efficiencies of our Site and services. Anonymous information does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual. Examples of anonymous information may include certain information about the internet browser, domain type, service provider and IP address information collected through tracking technologies and aggregated or de-identified data. We use anonymous analytics information to operate, maintain, and provide to you the features and functionality of the Site, improve our services, analyze trends and administer our web applications.

IV. How We Use The Information We Collect or Receive
A. Information Received from the Company’s Clients

• To exercise or defend legal claims.

B. Device contacts, photos, and contact information

• To allow for easier sharing and improve the product features. This information is never sold or distributed to 3rd parties.

V. Who We Share Your Information With
A. No Sale of Personal Information to Third-Parties for their Own Use.

The term “Third-Parties” does not include our affiliates, website hosting partners, and other Service Providers who assist us in operating our Site, conducting our business, or providing services to you, so long as those parties agree to keep this information confidential and not use or further disclose it for their own purposes.

We do not sell, trade, or otherwise transfer to Third Parties for their own use any of your Personal Information. We also do not disclose to Third Parties any personally identifiable information about your visits to our Site.

Accordingly, there have been no sales of Personal Information to Third Parties for their own use or further disclosure in the past twelve (12) months. Likewise, the Company does not knowingly collect and does not, and will not, sell Personal Information of minors under 16 years of age without affirmative authorization.

B. Sharing Personal Information with Service Providers That Help Us Perform Our Business Purposes.

We may provide your Personal Information to our Service Providers who help us perform our business purposes, such as bank processing companies and technology companies, which assist us in maintaining, protecting, and enhancing our Site and our communication systems. Any Service Providers agree to keep this information confidential and not use or further disclose it for their own purposes.

C. Sharing Information with Third-Parties at Your Direction.

We may share your Personal Information with Third Parties to whom you or your agents authorize us in advance to intentionally disclose to or allow to use your Personal Information in connection with services that we provide.

D. Monitoring, Enforcement, and Legal Requests.

The Company may be required by law enforcement, federal or regulatory entities, or judicial authorities to provide your Personal Information, such as in response to an audit, investigation, or subpoena. The Company will only disclose information as legally required or necessary to demonstrate compliance with the law. The Company has no obligation to monitor the Site or the use of the Site or to retain the content of any user session. However, we reserve the right, at all times, to monitor, review, retain and/or disclose any information, including Personal Information, as may be necessary to satisfy any applicable law, regulation, legal process, or governmental request or to cooperate with law enforcement and other authorities.

We may also use IP addresses to identify a Site user when we feel it is necessary to protect the Site, our service, clients, potential clients or others.

E. Sale of the Company or Assets.

In the event of a sale, assignment or transfer of our assets or of any portion of our business, we reserve the right to transfer any and all information that we collect to unaffiliated third-party purchasers in connection with that event.

F. Internal Use and Research.

The Company reserves the full and unrestricted right to use and disclose de-identified information; anonymized information; aggregated information; or publicly available information that has not been combined with non-public Personal Information for purposes including, but not limited to, the Company’s own internal use, data mining, and research.

Similarly, aggregated, de-identified and non-personally identifiable Site visitor information may be provided to other parties for marketing, advertising, or other uses.

VI. Protection Of Your Personal Information

The Company is committed to protecting your privacy.Company takes reasonable security measures and seeks to implement the best practices and procedures in data collection, storage, processing and security, to protect personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction. We maintain physical, electronic and procedural safeguards designed to protect against the unauthorized disclosure of Personal Information, and Personal Information is disposed of properly and securely utilizing industry standards. Our data security policies and practices are periodically reviewed and modified as necessary,

VII. Other Sites/Third Party Links

In an attempt to provide you with increased value, we may include third party links on our Site. When you click on such links and visit such other websites, you need to be aware that we do not control such other websites or such other websites’ business practices, and that this Privacy Policy does not apply to such other websites. . This Privacy Policy does not apply to any website owned and/or operated by or on behalf of any other entity, even if our Site posts a link to those other websites and you click through from our Site. We do not control the content or links that appear on these third party sites, and are not responsible or liable for the practices employed by or activities of third party websites linked to or from our Site. Those websites have separate and independent privacy policies. If you visit and/or disclose information through other sites, you are subject to the privacy policies, customer service policies, and practices of those websites. Browsing and interaction on any other website is subject to that website’s own terms and policies.

VIII. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Site. By continuing to use our Site and services following such changes, you will be deemed to have agreed to such changes.