This Privacy Policy (the “Policy”) explains how PennyChats (“we” or “us”) collects, uses and discloses personal information through its mobile applications (the “Services” or “App”) or when you otherwise interact with us.

We encourage you to read the Policy carefully as it forms part of PennyChats’s terms and conditions.

Application of this Policy

For applicable international data protection laws, PennyChats with whom you have registered is the “controller” of personal information collected through the PennyChats mobile applications (the “App”) and is the organization to contact if you have questions about the use of your personal information (see the “Contact Us” section below). This policy also applies to personal data about each authorized representative of a client and about other persons or entities collected in the course of providing our services (such as directors of corporate clients).

Collection of Information

When You Sign Up or Register for a PennyChats Account or Services

If you sign up for a PennyChats account or Services, we will collect basic information about you including your social media account or your name and email address. You may provide this information to us directly, or by signing in to your account/service with a third party, including without limitation, Facebook or Google (see “Information We Collect from Other Sources” below). We will use the information that we collect about you to:

• Create and maintain your account;
• Allow you to log in to PennyChats;
• Contact you about your account and/or the services that PennyChats offers.

When a User Invites You to Use PennyChats

Users of PennyChats can invite their contacts to sign up for an account with us. We only collect the email addresses of individuals that users choose to invite to join PennyChats, PennyChats only uses the email addresses for sending an invitation to the individual at the request of the existing PennyChats user.

Information About Your Use of the PennyChats Services

Usage Information

We collect information about your use of the Services, such as email, photograph, and geo-location.

Automatically Collected Information

When you access or use our Services, we automatically collect information about you, including:

• Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Activities on the App: We collect records of activities on the App, including, any content you post, your account details, the time, value and currency of any deposit, withdrawal, or transaction made and the payment method.
• Location Information: Following your device permissions, we may collect information about the precise location of your device.
• Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. 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. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. You can find out more about PennyChats’s use of cookies in our Cookie Policy.

Use of Information

We use the information we collect to provide, maintain, and improve our services, such as administering and verifying your account, to provide the services you request and customize your experience with us. We also use the information we collect to:

• carry out our obligations owed to you;
• comply with our regulatory and other legal obligations;
• monitor any content, you post;
• compile statistical analysis of the pages of our App;
• monitor and analyze our business;
• investigate and manage enquiries, disputes and legal proceedings and comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions; and
• develop and market other products and services;

Sharing of Information

We will not share the personal information we hold about you except in the following circumstances:

• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of PennyChats by another company;
• in response to a request for information if we believe disclosure is legal or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of PennyChats or others.
• we have your consent. For example, if you use the “PennyChats connect” feature, we will get your permission before sharing your personal information with a third party. We will ask for your explicit consent to share any sensitive personal information.

Social Sharing Features

If you have elected to use one of our applications provided via social networks (such as Facebook, Twitter etc.), our application will access your social network account general information which includes your name and username in the social network, profile picture, gender, networks, user ID, list of friends, and any other information you have shared depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other App and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by PennyChats and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other apps, and better understand your online activity. For more information about interest-based ads, or to opt-out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices if you are in the United States and if you are in the EU, please visit www.youronlinechoices.eu/.

Your Choices

Depending on where you or your data reside you may have certain rights and protections under the law regarding the processing of your data. For example, you may also have the right to object to, or request that we restrict, certain processing and in some circumstances to obtain a copy of the personal information in a machine-readable format.

Legal Basis for Processing: When we process your data we will only do so in the following situations:

• Entering into and performing the Contract with You: If you have aPennyChats account or have registered on the App or for the Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant PennyChats Entity’s terms and conditions and to provide a service to you.
• For other Justifiable Grounds, including Legal Obligation and Legitimate Interests: We process your personal information where necessary for PennyChats to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests we have in conducting our business. These include without limitation:

• Learning about your interests and preferences to contact you with information that is relevant to you and helping us target marketing communication and advertisements so that they are more relevant to you.
• Using your pseudonymized details to show you advertising on social media platforms, such as Facebook or via other third-party advertising that may appear on other appsyou use. The information shared with these platforms is pseudonymized to protect your data.
• Analyzing and continually improving the App and our services and helping us pilot test versions of the App internally to develop new features and ensure the efficient running of PennyChats’s services.
• Detecting and reducing fraud and credit risk.

Data Subject Requests: You have the right to access personal data we hold about you and to ask that your data be updated, corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account or email us at support@pennychats.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

Questions or Complaints: If you would like to exercise any of these rights, you can log into your account or contact us. Any such request should be submitted in writing to support@pennychats.com.

Cookies

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

Promotional Communications

You may opt-out of receiving promotional emails or text messages from PennyChats by following the instructions in those emails or text messages or by visiting the “Notifications” tab in the “Settings” menu on our platform. If you opt-out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

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

Automated Analysis of Your Personal Information

We use the personal information you provide to us, or that we gather when you use our services, to tailor PennyChats to your Profile and to assign you a risk score. PennyChats will carry out this analysis automatically, and in most cases without human intervention. You can update the information in your Profile at any time by visiting the “Account” page in the Settings menu. We recommend that you update your Profile regularly, to ensure that the PennyChats functions offered to you are appropriate for your circumstances. If you have any questions about the automated analysis of your personal information, please contact us (see “Contact Us” below).

Your Rights

Under the GDPR, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your data.
2. The right to access the personal data we hold about you.
3. The right to have your data rectified if any of your data held by us is inaccurate or incomplete.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your data that we have.
5. The right to restrict (i.e. prevent) the processing of your data.
6. The right to object to us using your data for a particular purpose or purposes.
7. The right to data portability. This means that, if you have provided personal data to us directly, we using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
8. Rights relating to automated decision-making and profiling. We do not use your data in this way.

For more information about our use of your data or exercising your rights as outlined above, please contact us via support@pennychats.com.

Your Rights Under California Privacy Statutes

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@pennychats.com.

Notice to California Residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014), entitles California residents to know how PennyChats responds to “Do Not Track” browser settings. PennyChats does not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

Transfer of Information to Other Countries

When using our services, your data is processed and stored in the EU and other countries. We and our service providers may transfer your information to or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your data receives an adequate level of protection in the jurisdictions in which we process it.

We provide adequate protection for the transfer of personal data to countries outside of the EEA through a series of intercompany agreements based on the Standard Contractual Clauses authorized under EU law. You are entitled to obtain a copy of these agreements by contacting us using the contact information below.

Retention of Personal Information

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you are invited to use PennyChats by another user, we will store your personal information for six months to send an invitation to you by email.

If you have an account with PennyChats, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that apply to us.

Security and Integrity of Information

We protect your personal information by using data security technology and using tools such as firewalls and data encryption. We also require that you use a personal username and password every time you access your account online. As set out in the relevant PennyChats Entity’s terms and conditions, terms of business and/or terms of use, you must not share your password with anyone else. We restrict access to personal information at our offices so that only officers and/or employees with a legitimate business purpose can access it.

Minors

PennyChats is not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a “Minor”). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us.

 If we become aware that a minor has shared any information with us, we will delete such information. If you have any reason to believe that a minor has shared any information with us, please contact us at support@pennychats.com.

Changes to this Privacy Policy

The Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy.

Links

The App may include links to other apps on the internet. We are not responsible for the content of these apps or any other privacy practices on these apps. You should read the terms of use and the privacy statements of any such App. Our terms of use and our Privacy Policy apply only to information collected by us following this Policy.

Contact Us

Should you have any questions regarding the Policy, please contact us at support@pennychats.com. Please include your name, and mailing or email address. We may require that you provide additional information to verify your identity before allowing you to exercise certain rights outlined above.