(“Bankify”) respects the privacy of those using Bankify’s finance application products that helps you to manage finance more Social, Simple and Fun within your social network, including the Bankify website at www.bankify.io& www.blinky.appas well as the associated Bankify mobile application, and any other services provided by Bankify related to it (together “Services”). This Privacy Policy helps you understand what personal data (“Personal Data”) and non-personal data Bankify collects, and how suchdata is used.

Bankify’s Services are intended for people who are at least 16 years old. If you are a minor in your country of residence, please seek parental consent before using the Services. If You are under 13, please do not attempt to access or take in useour Services (if not explicitly otherwise stated in the relevant service) or send any information about yourself to us. We will not knowingly collect Personal Data from anyone under the age of 16 without such consent. If You believe that we might have any information from or about a child under the age of 16, please contact us at support@bankify.io.

If you do not agree to the terms of this Privacy Policy, do not use the Services.

1. General

“Personal Data” refers to data which allows the identification of an individual person (as defined and in compliance with the European Union’s General Data Protection Regulation 2016/679 (“GDPR”)). This is opposite to “non-personal data” meaning data that cannot be used to specifically identify any person.

We commit to adhereto the provisions of the aforementioned legislation and other such applicable laws and regulations pertaining to processingof Personal Data, as well as to process Personal Data in compliance with good data processing practice. All personnel processing Personal Data are obliged to keep such data strictly confidential.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make significant changes to this Privacy Policy, we will post a notice in the Services along with the updated Privacy Policy or contact you by email (using the address you have provided in the Services). Your continued use of our Services will signify your acceptance of the changes to this Privacy Policy

2. Legalbasis for the processing

The legal basis for the processing of your Personal Data is, where not stated otherwise or another legal basis is otherwise applicable, the performance of the contract for providing Bankify’s Services to you, as permitted by GDPR article 6(1)(b).

Bankifycan also process your Personal Data where we have a legitimate interest to do so, as permitted by GDPR article 6(1)(f), such as for marketing purposes.

Where the processing is such that your consent is required by the applicable legislation, we will state so and obtain your consent, and this will be the legal basis for the processing of your Personal Data, as permitted by GDPR article 6(1)(a). However, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If such withdrawal means that we are no longer able to provide the Services to you, we may cease providing the Services.

3. Types of Data and Sources of Personal Data

Bankifywill only collect such Personal Data that is relevant for the purposes described in this Privacy Policy, including information users give to us, and technically gathered information when users use our Services.

Personal and non-personal data is collected directly from the users of our Services, such as through registration or by logging the activities in the Services.

Personal data may include:

  1. Information provided by Customer and required for the provision of our products and services, including a) your name, email address, Google ID/Facebook ID, user nameand other registration information; (b) transaction-related information, such as your bank account number and when you make purchases, respond to any offers, or use the Services; (c) information you provide us when you contact us for help; and (d) information you enter into our system when using the Services.

  2. Technically gathered online data, such as unique device identifiers, IP addresses, device software version numbers and identifiers, and rough location information via GPS, IP address or mobile networks.

If you do not provide Bankify the required information, this may mean that we are not able to provide the Services to you.

In addition to Personal Data, Bankify will collect non-personal data relating to the users of our Services. This information includes either anonymous or anonymized data that is generated during the use of the Services, such as actions in the Services, and access times.

Some features of the Services may enable you to permit Bankify makecertain information, including your actions in the Services, available to other users of our Services (as specified in more detail in the Services).

The Services may be able to connect to your social networking sites and profiles to obtain information about you when you consent to allow your social networking site to make that information available to Bankify, and, consequently Bankify will be able to collect certain information from your social networking profile when your social networking site permits to make that information available.

Bankifyretains the Personal Data collected pursuant to this Privacy Policy for the period necessary to fulfilthe purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter, if the collected Personal Data is no longer needed for purposes specified in this Privacy Policy, Bankify will delete all aforementioned Personal Data in its possession within a reasonable timeframe or render it anonymous, meaning “non-personal data”. Further,  Bankify will store the following categories of your Personal Data for the retention periods outlinesbelow:

Information required for registration to our Services: During your subscription term in our Services

Technically gathered data: During your subscription term in our Services

4. How the Personal Data is Used

Users’ Personal Data may be used in order to:

  1. Provide users with the Services as requested by the users;

  2. Improve and personalize the Services, as well as to develop new products and services;

  3. Correspond with users regarding customer service issues;

  4. To enforce the Terms of Use;

  5. Ensure the functioning and maintenance of the Services; and

  6. Ensure users’ compliance with the Terms and this Privacy policy.

Bankifydoes not use automatic decision-making. However, we use profiling to provide you with individualized offers regarding the Services.

5. Third Party Analytics Tools and Disclosing Information

In order to analyze and improve the ServicesBankify uses tools provided by third party service providers to collect and use non-personal data. Users can decline the collection and storage of such data from their devices’ settings.

Bankifywill not disclose your stored Personal Data to third parties for direct marketing, market research, polls or public registers without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. Bankifyhas the right to share non-personal data (such as anonymous usage data, platform types, asset views, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality of the Services.

Bankifywill use your Personal Data for targeted in-service marketing and other similar purposes, and upon Your consent, to email marketing by Bankify. You can opt-out of receiving promotional emails by following the instructions in those emails. If You opt-out, Bankify can still send you non-promotional customer information, such as emails about your account, providing the Services or our ongoing business relations.

Bankifycan host the Services in and transfer Personal Data for this purpose to countries outside the European Union or the European Economic Area in accordance with mandatory legislation and this Privacy Policy.

6. Security

Bankifytakes reasonable measures to protect Personal Data as the data is transferred from users’ devices to Bankify and to protect the data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, Service’s users should always keep in mind that no Internet transmission is 100% secure or free from errors. For the avoidance of doubt, the safeguarding of all account registration information and credentials are at the Services’ user’s responsibility.

The register will be maintained on external service providers’ servers with appropriate safeguards. The register is protected by appropriate industry standard, technical and organizational safety measures. Although Bankify makes good faith efforts to store the data collected from the Services in a secure operating environment that is not available to the public, Bankify cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Bankifywill post a notice in the Services in case material security breach that endangers your privacy or Personal Data, and if necessary, will contact affected users directly. Bankifymay also temporarily shut down the Services to protect the Personal Data.

7. Cookies and Other Tracking Technologies

A cookie is a string of information or a small text file that a website stores on a visitor’s device, and that the visitor’s browser provides to the website each time the visitor returns. Bankifymay utilize cookies to help it identify and track visitors, their usage of the Services’ website access preferences, improving quality, tailoring recommendations, and developing the Services. Users who do not wish to have cookies placed on their computers can set their browsers to refuse cookies before using the Bankify websites, with the drawback that certain features of the website may not function properly without the aid of cookies.

If Bankifywill use other tracking technologies in addition to cookies, Bankify will notify users of use of such tracking technologies.

Bankifydoes not enable third parties to collect any Personal Data on the Services’ users. However, Bankify uses the following third-party data analytics platforms:

  • Google Analytics, a web analytics service provided by Google, Inc. You may decline the collection and storage of your data in the future and opt outat:https://tools.google.com/dlpage/gaoptout?hl=en

  • Crashlytics

  • Sentry

  • Expo

  • Firebase

  • Facebook

  • Google AdWords

  • Mailchimp

The Services may feature advertisements served by third parties that deliver cookies to your device so the content you access and advertisements you see can be tracked. You may click on the following link:http://www.networkadvertising.org(or such other URL as may be specified by us from time to time) for information on how to opt-out of the use of cookies for the delivery of more relevant advertising

8. Rights of the Data Subjects and Contact Information

Right to access, correct and object

You may contact us and we will inform what personal data we have collected and processed regarding you and the purposes such data are used for. You have the right to have corrected any incorrect, incomplete, outdated, or unnecessary personal data stored about you by contacting us.

You may object to certainuse of Personal Data when such processing is based on legitimate interest, including direct marketing or profiling. You may opt-out of receiving promotional emails by following the instructions in those emails. If You opt-out, we may still send you non-promotional customer information, such as emails about your account, providing our services and products or Bankify’s ongoing relationship with You.

Right to deletion and restriction of processing

You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.

You may request Bankify to restrict processing of certain Personal Data. Your Personal Data will then only be stored and not processed otherwise, this may howeverlead to fewer possibilities to use the Services. If such restriction means that we are no longer able to provide the Services to you, we shall be entitled to stop providing the Services.

Right to data portability

You have the right to receive personal data provided by you to us in a structured, commonly used format.

Bankifyprovides no guarantee that this information will be compatible, relevant or useful to any other service.

How to use the rights

These rights may be used by sending a letter or e-mail to us on the addresses set out below, including the following information: user nameused for login purposes (no password), name, phone number..We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

Complaints

In case you consider our processing activities of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with a supervisory authority for data protection.

Contact info:

BankifyLtd

Business ID: 2767166-4

Address: Hietaniemenkatu 7 A

00100 HELSINKI

Email:support@bankify.io

www.bankify.io, www.blinky.app

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