Friendship Wallet Privacy Policy

Effective date: August 25, 2018

Friendship Wallet Company Limited ("us", "we", or "our") operates the “Friendship Wallet” mobile application (the "App") that allows businesses to deliver contents (“Contents”), ads, coupons, and deals (collectively, “Advertisements”) to a user’s smartphone lockscreen — and compensates users with reward points (“Reward Points”) that can be redeemed for cash, products and services from participating partners and / or making charitable contributions to participating non-profit organizations. 

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of data in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

1. Data We Collect
   • Your privacy is important to us and we have taken steps to ensure that we do not collect more data from you than is necessary for us to provide you with our services and to protect your account.
   • When you register your account on the App, we may require or otherwise collect data that identifies you as a specific individual and can be used to contact or identify you (“Personal Data”). The Personal Data shall mean and include name, email address, password, profile picture, cover picture, bio (profession),id card number (and photo), country, date of birth, gender, ethnicity, marital status, phone number, educational level, interests, hobbies, precise location-based information, mailing addresses, contacts, PayPal account information, Payoneer account information, Truemoney account details, Bank account details, and list of installed mobile applications and such other data as we may deem necessary for provision of Services.
   • When you want to redeem your Reward Points, we may collect information about your PayPal account, Payoneer account, Truemoney account, Bank account, or the products and services you are purchasing with the redeemed Rewards Points and / or the charitable organization to which you are making a donation.
   • We collect information about your interactions with the Services including, your engagement with particular Advertisements, the Reward Points you have accumulated through the Services, the products and services you have purchased and/or the charitable organizations to which you have made a donation.
   • In connection with an Advertisement intended to create marketing leads for the advertiser, we may allow you to disclose your Personal Data to an advertiser through the Advertisement, but only where it is clear that your Personal Data is being collected by the advertiser.
   • When you purchase products through the Services or make a charitable donation, we will collect all information necessary to complete the transaction, including your name and shipping information.
   • If the value of the Reward Points you redeem through the Services exceeds the amount under which we are required to report to any taxing authority, we will collect your social security number or other tax identification number.
   • We retain information on your behalf, such as files and messages that you store using your App account.
   • If you provide us feedback or contact us via e-mail, we will collect your name and email address, as well as any other content included in the e-mail, in order to send you a reply.
   • We may also collect data that your device sends whenever you launch our App ("Usage Data").
   • This Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), the type of mobile device you use, your mobile device unique ID, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
   • It is mandatory for you to provide Personal Data (as specified at the time of collection). In the event that you do not provide any or sufficient Personal Data marked as mandatory, we may not be able to complete the registration process.
   • We provide two options to you for registering an account in the App. You may register your account by using standard email or through Social Media account. We are proving secure social login feature for user to conveniently login the App. When you register your account using Social Media login, we only collect certain data from your social media account such as your Name, Email and Profile picture. We collect these details for basic unique user identification. We do not, in any way, collect any sensitive data from your social media account such as password etc.
   • We use Social media Product’s official API plugin for connecting social login with the App signup process. No other connection between the App and Social media user account is established.
   • If you are uncertain about which Personal Data is mandatory you are welcome to contact us at info@friendshipwallet.com.
2. Your Consent is Necessary
   • When you provide us with Personal Data to complete registration, we imply that you consent to our collecting it and using it for best App experience and App Improvement.
3. Disclosure of Your Personal Data
   • We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
   • Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our App; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.
   • Affiliates and Acquisitions. We may share some or all of your Personal Data with our ad agencies, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy
   • Social Networking Sites. The Services may automatically post, only with your consent, information on your Facebook wall and Twitter feed based on your most recent activities.
   • Third Party Websites and Applications. When you click on a link or swipe to connect to any other website or location, you will leave our Services and go to another site and another entity may collect Personal Data or Usage Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links or swipe left to connect to such outside websites
   • Our Relationship with Third Party Services
   • We offer you interfaces that allow you to connect with third party services and social networking services such as Facebook and Twitter (collectively, “SNS”) through our Services. We will work with the SNS’s application protocol interface (better known as their developer API) in a way that allows you to authorize us to access your account on that SNS on your behalf. In order to provide this authorization, you will not provide us with your user name or password to the SNS, but you will need to log-in to that SNS directly through our Site. Once authorized by you, the SNS will provide us a token that allows the SNS to recognize us when we ask, on your behalf, for access to your account information or to post information. You will be able to revoke our access to any SNS Site at any time by amending the appropriate settings from within your account settings on the applicable SNS, though such revocation may limit the Services we are able to provide you. In addition, when you engage in certain activities within the Services, those activities may be automatically posted to your Facebook and Twitter feeds. We allow you to disable this functionality at any time by logging into your profile and selecting the option to disable this feature.
4. How We Use the Data
   • The Data collected by us from you may be used to provide you with services and better understand your needs related services and programs, to correspond with you and reply to your questions with about our services.
   • We will not share, rent or sell your Personal Data to others except as provided herein. We may store Personal Data in locations outside the direct control of the Company (for instance, on servers or databases co-located with hosting providers).
   • If you provide any Personal Data to us, you are deemed to have authorized us to collect, retain and use that Personal Data for the following purposes:
5. verifying your identity;
6. verifying your eligibility to register as a user of the App;

• processing your registration as a user, providing you with a log-in ID for the App and maintaining and managing your registration;

1. providing you with customer service and responding to your queries, feedback, or disputes;
2. making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us;
3. provide and maintain the service and App;

• notify you about changes to our service and App;
• allow you to participate in interactive features of our App when you choose to do so;

1. provide customer care and support;
2. provide analysis or valuable information so that we can improve the service and App;
3. monitor the usage of the service and App; and

• detect, prevent and address technical issues.

5. Disclosure of Data
   • We shall not be able to keep your Personal Data private in response to legal process i.e., a court order or a subpoena, a law enforcement agency’s request. If, in our view, it is deemed appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law, we may be compelled to disclose your Personal Data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your data to new platform.
   • We may disclose your Personal Data in the good faith belief that such action is necessary to:
     • To comply with a legal obligation
     • To protect and defend the rights or property of App
     • To prevent or investigate possible wrongdoing in connection with the App
     • To protect the personal safety of users of the Service or the public
     • To protect against legal liability

6. Storage and Processing
   • Your data collected through the App may be stored and processed at the servers of the App in the United States, Europe, or any other country in which the App or its subsidiaries, affiliates or service providers maintain facilities.
   • The App may transfer Personal Data to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
   • App will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
7. Methods of processing Data
   • We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this App (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from us at any time.
8. The rights of Users
   • Users may exercise certain rights regarding their Data processed by us. In particular, Users have the right to do the following:
     • Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
     • Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
     • Access their Data.Users have the right to learn if Data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
     • Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
     • Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, we will not process their Data for any purpose other than storing it.
     • Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from us. Users may request us at info@friendshipwallet.com to get their Personal Data deleted.
     • Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.

9. How We Protect Your Data
   • We store the Personal Data to database directly with secure algorithm. Passwords are highly secured data and we do not access them.
   • The App is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any data you transmit to or guarantee that your data on the App may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive data (such as log in credentials) on our registration form, we encrypt that data using secure socket layer technology (SSL).
   • No method of transmission over the Internet or method of electronic Therefore, we cannot guarantee its absolute security. If you have any questions about security on our App, you can contact us at info@friendshipwallet.com
10. Compliance of EU’s GDPR
    • For users based in the European Union (EU), the App shall make all reasonable efforts to ensure that it complies with The General Data Protection Regulation(GDPR) (EU) 2016/679 as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. App shall make all reasonable efforts to adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
11. Cookies
    • This App may use cookies to better the users experience. Cookies are small files saved to the user's mobile devices’ hard drive or memory that track, save and store data about the user's interactions and usage of the App. This allows the App, through its server to provide the users with a tailored experience within this website.
12. How You can Access or Correct Data
    • Under the applicable laws, you have the right of access to Personal Data held by us and to request correction of the data.
    • If you have any questions regarding this Privacy Policy or its implementation or if you wish to access or correct your Personal Data, you may send your request in writing at info@friendshipwallet.com
    • We may verify your Personal Data before processing your request and in accordance with the applicable laws, we reserve the right to charge you a reasonable fee for the processing of any data access or correction request.
    • You may update or correct your Personal data and preferences at any time by accessing your Account settings page on the App. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all data you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
    • At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law
13. Children's Privacy
    • Our Service does not address anyone under the age of 13 ("Children").
    • We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
14. Changes to this Privacy Statement
    • We may modify these this Privacy Policy from time to time, and any such change shall be reflected on the App with the updated version of the Privacy Policy and you agree to be bound to any changes to the updated version of Privacy Policy when you use the App or its services.
    • Also, occasionally there may be data on the App that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability, and various other data, and the App reserves the right to correct any errors, inaccuracies or omissions and to change or update the data at any time, without prior notice.