Privacy Statement

Effective Date: October 29, 2019

1. Overview

Vidiva has developed this Privacy Statement to explain how we may collect, retain, process, share and transfer your Personal Data when you visit our Sites, use our app or Services. This Privacy Statement applies to your Personal Data when you visit Sites, use app or Services, and does not apply to online websites, app or services that we do not own or control, including websites, app or services of other Vidiva Users.

This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites, app and Services. Please note that our Service offerings may vary by region.

We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalized term in the Definitions section.

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Statement.

2. What Personal Data Do We Collect?

We may collect information about you when you visit our Sites, use our app or Services, including the following:

3. Why Do We Retain Personal Data?

We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.

4. How Do We Process Personal Data?

We may Process your information for the following reasons:

5. Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement.

We may share your Personal Data or other information for the following reasons:

With other members of the Vidiva corporate family: We may share your Personal Data with members of the Vidiva family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of Vidiva products, Services, and communications.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.

With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product, such as with Synchrony Bank in connection with the Vidiva Extras credit card. These financial institutions may only use this information to market and offer Vidiva-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.

With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds frommerchants, and their service providers when you use the Services to pay for goods or services. The information includes:

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Vidiva’s business purposes or as permitted or required by law, including:

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.

In addition, Vidiva may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. How Do We Work with Other Services and Platforms?

A significant benefit and innovation of Vidiva’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection you authorize or enable between your Account and a non-Vidiva account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Vidiva and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection. For example, Personal Data that Vidiva shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

7. How Do We Use Cookies and Tracking Technologies?

When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies.

8. What Privacy Choices Are Available To You?

You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

9. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

10. Can Children Use Our Services?

The Sites and Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

11. What Else Should You Know?

Changes to This Privacy Statement.

We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.

If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.

Transfers of Your Personal Data to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Statement if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.

12. Definitions

Account means a Vidiva member account.

Device Information means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).

Geolocation Information means 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. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

Checkout without a Vidiva Account means a person’s use of the Services without logging into and/or establishing an Account.

Vidiva means Vidiva Pte. Ltd. and subsidiaries or affiliates. In this Privacy Statement, Vidiva is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID). Personal Data does not include information that does not identify a specific User.

Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Vidiva in connection with an Account or Checkout without a Vidiva Account.

Sites means the websites, mobile apps, official social media platforms, or other online properties through which Vidiva offers the Services and which has posted or linked to this Privacy Statement.

Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.

User means an individual who uses the Services or accesses the Sites and has established a relationship with Vidiva (for example, by opening an Account and agreeing to the Vidiva User Agreement) or otherwise uses the Services as a buyer, seller or other type of participant to a transaction, including a Checkout without a Vidiva Account.

13. Additional Information

The information provided in this section may be specific to customers depending on your region or is provided to Vidiva from third parties whom you may interact with when using the Services. You can contact us if you have any questions about the details in this section.

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