SIMON WALLET, INC. PRIVACY POLICY

Last Updated: December 22, 2020 

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This Privacy Policy explains how Simon Wallet Inc. doing business as Simba (“Simba,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team.

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We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

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CONTENTS

Collection of Information

Use of Information

Sharing of Information

Analytics 

Transfer of Information to the United States and Other Countries

Your Choices

Contact Us


COLLECTION OF INFORMATION

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Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, make transactions, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, postal address, phone number, source of funds,  identification documents (for example, government-issued identification information such as a passport or driver’s license) and other documents about citizenship or visa status, and images of identification documents, username, password, social security number, and any other information you choose to provide.

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All information supplied during registration is used in accordance of the USA Patriot Act CIP Notice here, to help the government fight the funding of terrorism and money laundering activities.

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We obtain certain financial information about you when you use our Services, including your bank account numbers, debit card and credit card numbers and other payment information, and transaction history. When you submit transactions through the Services, we collect information about the transaction, including deposits, withdrawals, transfers, and exchanges, as well as the sender and recipient, amount, and timing of the transaction. 


Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

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  • Transactional Information: When you make a transaction (amount of money transferred and received and any other transactions that you conduct or attempted to conduct through the Services), we collect information about the transaction, such as payment details including the recipient’s information, amount, date and location of the payment; and your Simba account details.
  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Location Information: In accordance with your device permissions, if you use our ATM map feature, we may collect information about the precise location of your device at the time you are using such feature. You may stop the collection of precise location information at any time (see the Your Choices section below for details).‍
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. We use first party cookies for several reasons. Some cookies are required for technical reasons in order for the Services to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience of our Services. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. These allow us, for example, to monitor the traffic patterns of users from one page to another, to deliver or communicate with cookies, to understand whether you have come to the Services from an online advertisement displayed on a third-party website, to improve Services performance, and to measure the success of e-mail marketing campaigns. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from identity, citizenship, and visa verification services; data analytics providers; marketing service providers; and banking service providers. 


Your use of our Services may require that we collect account numbers, balances, and other information about your external bank accounts from your bank or financial services provider or from our banking service provider that issued your account.  If you connect your Simba account to external financial accounts, directly or through a third-party entity, we may have access to information about that account, and we may receive information from such third-party about you and your use of the third-party’s service to facilitate applicable transactions and fund your Simba account. The information you provide to us through a third-party entity, or that such third-party entity provides to us about you, will be treated by the third-party entity in accordance with its privacy policy and by us according to this privacy policy. 


Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to purchase certain products and services based on your browsing behavior and past transactions. 


USE OF INFORMATION

We use the information we collect to administer your account and facilitate transactions. We also use the information we collect to:


  • Provide, maintain, and improve our products and services; 
  • Verify the user’s identity and citizenship; 
  • Conduct anti-fraud, identity verification, sanctions screening, and other screening procedures;
  • Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices;
  • Personalize and improve your experience on our Services;
  • Send you technical notices, security alerts, and support and administrative messages; 
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by Simba and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Services; 
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Simba and others;
  • Debug to identify and repair errors in our Services; 
  • Comply with our legal and financial obligations including Know Your Customer and Anti-Money Laundering obligations; and
  • Carry out any other purpose described to you at the time the information was collected.


SHARING OF INFORMATION


We share personal information in the following circumstances or as otherwise described in this policy: 

  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with identity and citizenship verification, sanctions and anti-money laundering screening, payment processing, card manufacturing, fraud management, customer service, website and app analytics services, and marketing and advertising. These service providers may create derivative data based on your personal information to conduct services on our behalf and may conduct their own searches of publicly available information about you in order to verify your identity or authenticate your information. You may in some cases provide information directly to those services providers acting on behalf of Simba, for example, to verify your identity before your Simba account can be fully enabled. 
  • We share information with third party entities or organizations, such as our banking service providers, with whom you choose to interact through the Services that need access to your information in order to provide services to you in connection with the Services, such as allowing you to deposit or withdraw funds or make transactions. 
  • To the extent required to complete transactions through your Simba account e.g. with other Simba users with whom you are sending funds or with a financial services provider that is sending or receiving funds to or from your Simba account on your behalf.
  • If you choose to use integrations we offer on our Services, such as sharing your location through our Google Maps integration, we may share certain information with the integration partners. 
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Simba, our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. 
  • Personal information is shared between and among Simba and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership. 
  • We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you. 


ANALYTICS 


We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Simba and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. 


TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES


Simba is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.


YOUR CHOICES

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Account Information

You may update and correct certain account information at any time by logging into your account, or by calling customer support at 866-674-9630 or emailing us at support@hellosimba.com.  If you wish to cancel your account, please call customer support at 866-674-9630 or send an email to support@hellosimba.com but note that we may retain certain information as required by law or for our legitimate business purposes.

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Location Information

When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device. If you stop our collection of this location information, our Services, including the ATM Finder feature, may no longer function properly.

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Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. 

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Communications Preferences

You may opt out of receiving text messages and promotional emails from Simba by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

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Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.


CONTACT US


If you have any questions about this Privacy Policy, please contact us at: 


Simon Wallet, Inc. d.b.a. Simba 

115 Broadway, 5th Floor 

New York, NY 10006

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support@hellosimba.com 

866-674-9630

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SIMBA PRIVACY NOTICE‍

Rev. December 22, 2020


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