We may collect, store and use the following kinds of personal information:

We may collect, store and use information obtained by automated means through the Service such as, cookies, web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your use of the Service:

We may collect, store and use information obtained by automated means through the Service such as, cookies, web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your use of the Service.

We collect and use personal data only where we have one or more lawful grounds or basis for doing so under applicable privacy laws. Such grounds may vary depending on where our Users are located, but generally include processing personal data:

If you submit personal information, including User Content, for publication on the Service, we will publish and otherwise use that information in accordance with the license you grant to us, and by submitting such information to us, you hereby grant us a worldwide, revocable, sublicensable and royalty-free license to use such personal information for our business purposes. You shall be solely responsible for your own User Content and the consequences of submitting and publishing your User Content on the Service. You further agree that you will not submit to the Service any User Content or other material that is contrary to this Privacy Policy or contrary to applicable local, national, and international laws and regulations. We do not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

The security of your personal data is very important to us. We will take reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your personal information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, when processing sensitive personal data (such as data about ethnic or racial origin, political opinions/union membership, data concerning health, sex life or sexual orientation, genetic data, or biometric data) or data that reveals sensitive personal data, especially when using data profiling extra safeguards will be added.

You acknowledge that the transmission of information over the internet is inherently insecure, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

You are responsible for keeping the password you use for accessing the Service confidential; we will not ask you for your password (except when you log in to our Service). Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Policy. We are not responsible for circumvention of any privacy settings or security measures contained on the Service. Any transmission of personal data is at each User’s own risk.

We may process, store, and transfer Users' personal data in and to a foreign country, with different privacy laws that may or may not be as comprehensive as the data privacy laws applicable to a particular User. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to a User's personal data through the laws of the foreign country.

With your express permission, we may access your contact list on your mobile device so that you can identify your contacts on the Platform to allow you to send money to friends and family on the 5 Platform by searching for their phone number, email address or username. We transmit and use this information to help you easily filter your friends on the Platform and to help you transact with your friends and contacts if you choose to connect your contact list information with your Account. We only access your contact list information with your explicit permission. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services so you can send money to them for free and quicker. We will not send messages to your contacts or make use of the data for any other purpose.

We retain user profiles, transactions, and other personal data for as long as a user maintains their account and except as otherwise permitted or required by applicable law or regulation, only for as long as necessary to fulfill the purposes the Company collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may also retain certain information, if necessary, for purposes of safety, security, and fraud prevention. For example, if we deactivate a User’s account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that User from opening a new account in the future.

Users may request deletion of their account at any time. Following such requests, the Company deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retain location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.

Under some circumstances the Company may anonymize Users' personal information so that it can no longer be associated with a particular User. The Company reserves the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to the relevant User or its consent.

Some of the Company’s products, Services, and features require that we share data with other parties. As such, we may share the data, which may include personal data, we collect, or a User provides as follows:

Service Providers - we engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, including those of our contractors, service providers, subsidiaries and affiliates, may have access to user information as necessary in the normal course of our business.

Business Transfers. In some cases, we may choose to buy or sell assets, or have engaged in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Service users is among the assets transferred. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service, the Company, or substantially all of its assets, were acquired, liquidated, or dissolved, personal information would be one of the assets that is transferred.

Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of the Company and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order

Social Media Networks.S We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

With Other Users. This includes sharing User’s personally identifying information shared on the Application, including to such User’s Profile on the Application.

It is important that the personal data that we hold about each User is accurate and current. Each User should keep the Company informed if its personal data changes. By law, each User may have certain rights regarding the personal data that the Company holds about such User and may be entitled to the following:

Users who voluntarily provide their personal data in order for the Company to provide Services do so pursuant to the Company’s Terms of Service. The retention, return, transfer, and destruction of personal data provided for such purposes is subject to this Policy and Terms of Service. If you make a request, the Company will respond to you within the period prescribed by applicable privacy law. If you would like to exercise any of these rights, please contact us at the information provided below.

Opt-out. We have created the following mechanisms to provide you with control over certain uses and disclosures of your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly

Location Information.You can choose whether or not to allow the Service to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may then be inaccessible or not function properly.

Promotion by the Company. If you do not wish to have your email address or contact information used by the Company to promote our own or third parties' products or services, you can opt-out by following the unsubscribe instructions provided in the email you receive or contacting us directly at [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Disclosure of Your Information for Third-Party Advertising and Marketing.If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by following the unsubscribe instructions provided in the email you receive or contacting us directly at [email protected]You can also always opt-out by logging into the Service and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]

Targeted Advertising.If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by following the unsubscribe instructions provided in the email you receive or contacting us directly at [email protected]. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by providing us notice at [email protected]

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (the “NAI”) by visiting http://www.networkadvertising.org/index.asp.

Our Service is not intended for persons under 18 years of age. No one under age 18 may provide any information to or on the Service. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this Service or through any of its features, register on the Service make any purchases through the Service, use any of the interactive or public comment features of this Service, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 18, we will reject the application or close the account and delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]

The Site may contain links to other websites. This Policy applies only to the Site. If you navigate to any other website from a link on the Site, you should review the privacy policy of such website.

Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and at our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Service after any change in this Privacy Policy will constitute your acceptance of the changes. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

If you have any questions about this Policy, the data we hold on to you, or you would like to exercise one of your data protection rights provided for under applicable privacy laws, please do not hesitate to contact our Data Privacy Officer at [email protected]

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authority.

In Canada:
Office of the Privacy Commissioner of Canada 30, Victoria Street Gatineau, QC K1A 1H3, Canada.www.priv.gc.ca/en/