SMSCash recognizes the importance of protecting privacy. Our Privacy Policy describes what personal information we may collect and how we may use and protect any personal information that is made available to us. Save where the context indicates otherwise our Privacy Policy applies to all registered or non-registered Users of our messaging or other Services as defined in our standard Terms and Conditions, including visitors to any of our websites. Where used in this policy, the term “personal information” means any information identifying or describing an identifiable individual, including, but not limited to information relating to their name, age, gender, reproductive status, marital status, national, ethnic or social origin, sexual orientation, physical or mental health, disability, conscience, belief, culture, language and birth of the individual; educational, criminal or employment history of the individual, financial status or information relating to financial transactions in which they have been involved and any identifying number, address or contact information of the individual. We are committed to maintaining the confidentiality, integrity, and security of personal information and we will take all appropriate technical and organizational security measures to ensure that where any personal information is provided to us it will be protected against loss, destruction, and damage, and against unauthorized or accidental access, processing, erasure, transfer, use, modification, disclosure or other misuses. We shall not disclose to any person any personal data of a data subject that is processed or hosted by us where any such disclosure would not comply in all respects with the provisions of any applicable data protection legislation or regulations relating to the data subject concerned. We will ensure that personal data shall be: Within the context of the Services that we provide, our commitment to the above principles means that we recognize that a User’s phonebook, message content and MSISDNs indicating to whom messages were sent to or received from belong exclusively to that User and will not be disclosed by us to any third parties without the user’s written permission or unless compelled to do so by a court of law. We also recognize that any recipient of any message has the right to know the identity of the sender, and this will be disclosed on request to the recipient where known to us. Where the personal data of any EU member state subject is transferred to SMSCash in a non-EU member state for processing, or where the personal data of a subject of any state or union of states whose laws prohibit the transfer of personal data for processing outside of such state or union of states unless minimum protection measures are in place as determined by the provisions of the relevant laws, is transferred to SMSCash for processing outside of such state or union of states SMSCash shall ensure that adequate technical and organizational security measures are in place so as to comply with such laws and so as to provide a level of protection appropriate to the risks represented by the processing of such data and in order to protect such data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access or any other unlawful form of processing. Our Users may be required to submit limited personal information when accessing the Services including a username, email address, and password for the purposes of protecting User accounts against unauthorized access. In addition, messages, files, or other data contained in the Services may contain the personal information of third parties. We may automatically record certain information about the use of our Services such as account activity (e.g. usage, log-ins, actions taken), data displayed or clicked on (e.g. GUI elements, links), and other log information (e.g. browser type, IP address, date and time of access). We may use this information to provide authorized persons with usage reports and internally to deliver the best possible service to our clients and Users, such as improving software user interfaces and maintaining a consistent, reliable, and secure user experience. We may also detect and log a User’s location and IP address in order to identify the User’s geographic region or time zone for routing traffic to geographically based servers or for managing time-sensitive tasks like the sending of notifications. Like many reputable online companies, our Services, including our website, other online services, applications, email messages, and advertisements, if any, may use “cookies” and other technologies such as pixel tags and web beacons to collect information. A cookie is a small data file stored on the web browser on your computer’s hard drive. Cookies and other technologies allow us to count how many Users visited certain web pages within our website, and their personal preferences, and to measure the effectiveness of our website and electronic advertisements for different computing devices and regions. We use this information to understand and analyze trends, administer our websites, and learn about user behaviors on our websites. If a User blocks cookies from being stored on a computer, the functionality of our Services may be negatively affected. We may carry out and perform functional, statistical, textual, semantic, and other forms of analysis of non-personally identifiable data that is hosted or processed by us in relation to our Services. We do this to improve the performance of our Services, to understand the way in which our Services are being utilized, to identify usage patterns, and market trends, to gain insights, and to formulate new products and service offerings. We may also process, aggregate, and anonymize personal data such that it does not reveal any confidential, personal or sensitive data or any features from which confidential, personal or sensitive data may be ascertained. We will never disclose confidential, personal or sensitive data without the direct or indirect consent of the party to whom we owe the duty of confidentiality and/or the data subject concerned. We may process and transfer anonymized data in our reasonable discretion including within the SMSCash group of companies. 2.4 INFORMATION AUTOMATICALLY COLLECTED When you visit the Site, use the Services, or open an email from NerdWallet, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including without limitation: When you use the Services, we may send one or more Cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both Session Cookies and Persistent Cookies. A Session Cookie disappears after you close your browser. A Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent Cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your Cookie settings. If you delete, or choose not to accept, Cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. We may implement third-party advertising or other content on the Site that may use clear GIFs or other forms of web beacons, which allow the third-party content provider to read and write Cookies to your web browser in connection with your viewing of the third-party content on the Site. Additionally, we may implement third-party buttons (such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser Cookies, even when you do not interact with the button. We also engage third-party partners and vendors like Google Analytics, Hotjar and others, who provide analytics and advertising services, to assist us in providing you the Site and our Services. We allow these third parties, including nonaffiliated business partners, advertising networks, analytics providers, and other advertising service providers, to automatically collect Clickstream Data and other information about your online activities on the Site and across your browsers and devices using cookies, web beacons, mobile advertising identifiers and other technologies. For example, we may use third-party analytics tools to help us understand and record the electronic path you take to our Site, through our Site and when exiting our Site, as well as your usage and activity on our Site, such as the links and objects you view, click or otherwise interact with. We use this data for our own analytics and advertising purposes, as well as to facilitate partner relationships and your interactions with other third parties. In addition, certain of our third-party partners may use this information to display online advertisements tailored to your interests and preferences across your browsers and devices, to conduct ad campaign measurement and website analytics, to detect, prevent and report fraud, or to carry out their own business and commercial purposes. Where information collected through web beacons, buttons, and similar technologies is collected directly by third parties, their collection and use of information is subject to that third party’s own privacy policies. Some of these third parties are members of the Network Advertising Initiative or the Digital Advertising Alliance and participate in the industry’s opt out, available at http://optout.aboutads.info/#!/ or at http://optout.networkadvertising.org/#!/. Additionally, you may opt out of the use of Google Analytics Cookies here: https://tools.google.com/dlpage/gaoptout. Due to differences between using websites and apps on mobile devices, you may need to take additional steps to opt out on both platforms. Many mobile devices allow you to opt out of interest-based advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our app using the standard uninstall process available on your mobile device or app marketplace. Please note that your opt-out choice will apply only to the browser and device you are using when you opt out. 2.5 INFORMATION FROM OTHER SOURCES We may also obtain information about you from third-party sources, such as our business partners, referral partners or advertisers. We may also, at your direction, receive credit reports or scores from consumer reporting agencies such as TransUnion or Equifax, or third-party services that provide a mechanism to share information you have provided to the third party through the use of an application program interface (API), such as Facebook Connect or the Twitter API. If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Policy, the Terms, and applicable law. Where, for the purpose of providing the Services to you, any SMSCash Service acts as an Application Programming Interface (“API”) for the purpose of specifying how different software systems should interact with each other, or where for that same purpose any SMSCash Service interacts with other API’s, including third-party API’s, we may pass and retrieve data, including personal information, between the different software systems and third parties that interact via those API’s. Where we make use of third-party service providers to help us provide the Services to you, including for the purposes of retrieving or delivering information, records, notifications, or other messages to you or any Users or for hosting or providing any component of our Services, we require such third parties to maintain the confidentiality of any personal information we provide to them for these purposes. Some of these third parties may be situated outside of your country and you consent to your personal data and that of any data subjects you provide to us being transferred cross-border so that we can provide the Services to you. In this regard, we engage only with reputed third-party service providers who have security and privacy policies and procedures providing at least the same level of protection as we do ourselves. You warrant that you have all necessary permissions to give us the above consent. We may share data, including Personal Data, collected from Users of our Services with third-party service providers or consultants who require access to that data to perform their work on our behalf for the purpose of helping us deliver our Services. These third-party service providers or consultants are limited to only accessing or using this data to provide the services to us and must provide reasonable assurances that they will appropriately safeguard the data. We may also share non-personal or non-identifiable information, including website visitor information and account usage data with third-party analytics service providers. We may communicate with Users, resellers, and other persons by email and other messaging applications. You may opt-out from promotional communications from us that are not strictly related to the provision of the Services to you. We do not intentionally collect personally identifiable information from anyone who is a minor. If it is discovered that we have unintentionally collected personally identifiable information from a minor other than for a legitimate purpose associated with the Services, we will delete that information immediately. Our Privacy Policy may be updated from time to time at our discretion and changes will become effective upon posting to the site. If the SMSCash merges with or is acquired by any other business, you acknowledge that your personal information may fall under the control of another person. If you terminate your relationship with SMSCash, portions of your personal information may be retained in back-ups and archives for as long as is reasonably necessary to assist us in meeting our legal compliance obligations. If you have questions, comments, concerns, or feedback regarding this Privacy Policy, please send an e-mail to [email protected]
1. Introduction
2. Commitment to Privacy
2.1 Data Privacy Principles
2.2 Application of the Principles
2.3 Personal Data we may Collect and Process
3. API’s and Third Party Processing
4. Communications with You
5. Personal Information of Minors
6. Revisions and Termination
7. Questions and Comments
