Effective August 1, 2021
Collection of Personal Information
If you do not agree to our collection of this information, you may not be able to use our Service. If you create a SoshWallet account, we may collect the following information from you:
- Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
- Identification Information - your name, street address, email address, date of birth, and tax identification number (e.g., social security number) or other governmental issued verification numbers).
- Device Information - information about you: (a) from your mobile device or computer such as your device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
- Geolocation Information - information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. We will collect this data for fraud and risk purposes. In addition, some of our Services may ask you for permission to share your current location within your device settings to enhance our Services. If you do not agree to our collection of Geolocation Information, our Services may not function properly when you try to use them. For information about your ability to restrict the collection and use of Geolocation Information to enhance our Services, please refer to the settings available in your device.
- Financial Information - bank account online login information, bank account and routing numbers and credit cards linked to your SoshWallet account. SoshWallet does not share financial information with third party social networking services such as those listed in the prior bullet.
We are committed to providing a safe, secure service. Therefore, before permitting you to use the Services, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.
When you are using the Services, we collect information about your account transactions and we may collect Geolocation Information and/or information about your computer or other access device for fraud prevention and other similar purposes.
Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.
Collection of Non-Personal Information
When you visit the App, our servers automatically record non-personally identifiable information that your mobile device sends. This data may include information such as your device's IP address, mobile device ID, operating system type and version, language preferences, sections of our App that you visit, the time spent on those sections, information you search for in our App, access times and dates, and other statistics.
Use and Processing of Collected Information
Any of the information we collect from you may be used to run and operate our App and Services; personalize your experience; improve our Services; improve customer service and respond to queries and emails of our Users. We primarily collect Personal Information for identification verification and fraud prevention purposes and we do not store such information, unless required by law. Non-personal information collected is only used to identify potential cases of abuse and establish statistical information regarding App usage. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the Services.
We may process Personal Information related to you if one of the following applies: (i) you have given your consent for one or more specific purposes (note that under some applicable laws we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below); (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary to comply with any applicable law and assist law enforcement agencies under any applicable law, when we have a good faith belief that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party; (vi) to detect abuse and illegal activity, fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services; (vii) to take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other Users or third parties with respect to, or in relation with the Services; and (viii) to help improve the safety and reliability of our Services, including detecting, preventing, and responding to security risks, and technical issues that could harm us, our users, or the public.
Sharing Information (Including Your Personal Information)
The Services are based on a community of users publicly sharing information with us and with other members of that community.
In particular, Users may choose to share Personal Information such as name, age, gender, picture and other information, including certain financial information. This information may be shared directly to the Services and to all Users. This information may also be shared via third party services (such as social networks) which interact with the Services upon such User’s choice.
You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload may be posted along with your User name and other information including Personal Information you attached to your publicly available User profile. At the very least you should demonstrate the same degree of caution as when publishing Personal Information by means other than the Internet and cellular services.
We take commercially reasonable measures to provide you with the best experience you can have while using the Services. However, we have no control over the conduct of any User and disclaim all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information, including Personal Information, and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.
Participating in any User’s activities as a result, directly or indirectly, from using the Services, is entirely at your own risk. We are not a party to any agreement entered into between the users in any circumstances. The User has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a User or a third party nor in connection to any agreement between the Users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.
Information Transfer and Storage
We will transfer or otherwise disclose the information we collect in the App to our employees, independent contractors, and third-party suppliers if (i) the disclosure will enable that party to perform a business, professional, or technical support function for us, (ii) the disclosure will enable us to prevent or mitigate fraud, or (iii) we are required to do so by law. We do not allow these employees, independent contractors or third-party suppliers to use this information or to share it for any purpose other than to provide services on our behalf. We will also transfer or otherwise disclose Personal Information in response to judicial process, to comply with legal requirements, and, as permitted under provisions of law, to provide information to law enforcement agencies or in connection with an investigation on a matter related to public safety. We may also use your Personal Information as permitted by law to protect our rights or property, the App, or its Users.
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. If any such transfer takes place, you can find out more by checking the relevant sections of this document or inquire with us using the information provided in the contact section.
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Unless necessary to comply with applicable law, Personal Information will not be stored or retained for longer than 12 months after you delete the App. If we anonymize your Personal Information (so that it can no longer be associated with you), we may use and retain this information indefinitely without further notice to you.
In some cases, we may choose to buy, sell or otherwise transfer assets. In these types of transactions, User Personal Information is typically one of the business assets that is transferred. Moreover, when all, or substantially all of our assets, are acquired or otherwise transferred, your Personal Information would be one of the assets that is reviewed and transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of or recipient of our assets, including, but not limited to our App, may continue to use your Personal Information for the purposes for which it was supplied by you.
The Rights of Users
You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
The Right To Object To Processing
Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. Should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this document.
How To Exercise These Rights
Any requests to exercise User rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month. In order to withdraw consent, you are required to uninstall the App.
Privacy of Children
We do not knowingly collect any Personal Information from children or anyone under the age of 18. We encourage parents and legal guardians to help enforce this Policy by instructing their children never to provide Personal Information through our App or Services without their permission. If you have reason to believe that a person under the age of 18 has provided Personal Information to us through our App or Services, please contact us. You must also be at least 18 years of age to consent to the processing of your Personal Information.
Links to Other Apps or Websites
Our Services contain links to other apps and websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other apps, websites or third-parties. We encourage you to be aware when you leave our App and to read the privacy statements of each and every website that may collect Personal Information.
We secure information you provide on our information systems in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet and mobile device networks which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and our App cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.
In the event we become aware that the security of the App has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the App.
We will disclose any information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Changes and Amendments
We reserve the right to modify this Policy relating to the App or Services at any time, effective upon posting of an updated version of this Policy within the App. When we make such updates or amendments, we will revise the effective date of this Policy. Continued use of the Services after any such changes shall constitute your consent to such changes.
Acceptance of This Policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By using the App or Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to use or access the App and Services.
If you have any questions about this Policy, or if you believe that your privacy has been compromised in the course of using the Services, please contact us at firstname.lastname@example.org.
CALIFORNIA PRIVACY NOTICE
Last updated: August, 2021
This California Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
Notice of Collection and Use of Personal Information. We may collect the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet protocol address, email address, account name, and other similar identifiers.
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, pet insurance policy number, credit card number, debit card number, and other financial information, pet medical information, and pet health insurance information.
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status.
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
- Geolocation Data
- Sensory Information: audio, electronic, visual, and similar information.
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Sharing of Personal Information. We may disclose the following categories of personal information about you for a business purpose to the following categories of third parties:
Category of Third Party
Category of Personal Information
Our Affiliates and Subsidiaries
Our Service Providers
Our Business Partners
Data Analytics Providers
We do not sell your personal information in exchange for monetary compensation or other valuable consideration. We do not have actual knowledge that we sell personal information of minors under 16 years of age.
California Consumer Privacy Rights. California residents may have certain rights pursuant to the CCPA, as described below.
- Right to Delete: You have the right to request that we delete certain personal information we collected from you. Please email us at email@example.com.
- Right to Know: You have the right to request, twice in a 12-month period, a report that details the categories of personal information collected about you, the categories of sources from which the personal information is collected, the purposes for collecting the personal information, the categories of third parties which whom we share the personal information and the specific pieces of personal information collected about you over the past 12 months. To exercise this right, please email us at firstname.lastname@example.org.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: name, phone Number, and email address. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes and to process transactions and facilitate customer requests. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us, though we may not be able to provide some services to you without such information. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
California Privacy Rights. If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:
- Exercising the Right to Know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
- Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
- Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
- Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
To submit a request to exercise any of the rights described above, you may contact SoshWallet either via email to email@example.com or contact us via postal mail, proper postage prepaid, at:
SoshWallet, Attn: Your California Privacy Rights
1701 Bagdad Rd, Cedar Park, TX 78613
Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail).
All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.