Fivvy Privacy Policy.

This Privacy Policy (“Policy”) describes how Fivvy Inc. (“Fivvy,” “we,” “our,” “us”) collects, uses, and discloses certain information obtained through your use of the FIVVY mobile application (“App”), which is available for download on iOS on the Apple App Store and through Android on the Google Play Store, and our website (the “Site”), which is located at Fivvy . By visiting our App, Site, and/or using the features made available to you on those platforms (collectively, the “Services”), you are agreeing to the terms of this Policy. This Policy only applies to information we collect from the App and Site and not information we collect in other contexts.

Information We Collect and Maintain About You

We collect information from you directly when you provide it to us through the Services. We may also automatically collect certain information about you and your smartphone or other device when you use, access, or interact with our Services. Personal information provided directly by you. As described below, we collect personal information in some instances from both website visitors and App users.

1.Website visitors.

You may navigate our website without submitting any personal information. However, if you use certain features on the Site, such as the “Contact Us” feature, you may be required to provide personal information. This information could include your name, email address, and any other information you choose to provide as part of your inquiry.

2.App users.

If you sign up for an account with us through the App, we will collect your personal information in order to:

Create an account with us and administer Your account.
Fulfill Your requests, respond to Your inquiries, provide the features You enroll for on the App, and/or complete transactions You have requested.
Send You requested product or service information or to inform You of products or services that we believe You may be interested in.
Display content based on Your interests.
Send You important information regarding the App or the Site changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, You may not opt out of receiving such communications.
For our internal business purposes, such as data analysis, audits, developing new products or services, enhancing and improving the Site and the App, identifying usage trends and determining the effectiveness of features, offers and promotional campaigns.

As we believe to be required, necessary or appropriate:

To comply with legal process.
To respond to lawful requests by public authorities (which includes public authorities outside Your country of residence), including to meet national security or law enforcement requirements.
To enforce our terms of service.
To protect our operations, business and systems.
To protect our rights, privacy, safety or property, and/or that of other users of the App and the Site, including You.
To allow us to pursue available remedies or limit the damages that we may sustain.

The information we collect may include:

Your name.
The username and password you use to create your account.
Contact information (such as your email address, phone number, and mailing address).
Information about your financial goals.
Your payment card information (that you choose to provide as part of setting up your account).
Your purchase history (i.e., we will note the situations where you use our Services by tracking what you were buying, how much it cost, how much money you saved, how many rewards points you earned, etc.)

With your permission, we may also access your bank account(s) as part of providing our Services to you.

Server logs.

Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Services on a particular time and day and collect information such as your device ID.

Cookies.

We also use cookies on the Services. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

Pixel tags.

A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement, or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our App, viewed a particular advertisement, or opened a specific email.

SDKs and mobile advertising IDs.

Our Services may include third-party software development kits (“SDKs”) that allow us and our service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google’s Advertising ID) that, like cookies and pixel tags, allow us and our service providers to identify your mobile device over time for advertising purposes.

Third-party plugins.

Our Services may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking.

We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels and mobile advertising IDs through the App. This information may be used for a variety of purposes, including analytics and interest-based advertising, as discussed below (see the section entitled “How we share your information”).

Aggregated or deidentified information.

We may also share aggregated or deidentified information about users of the Services, such as by publishing a report on trends in the usage of the App or Site. Such aggregated or deidentified information will not identify you personally.

How We Use and Process Your Information.

The primary purpose for which use the information you provide is to offer our Services to you. Other purposes for which we use your information include to:

Respond to your questions or requests concerning the Services.
Fulfill the terms of any agreement you have with us.
Fulfill your requests for our Services or otherwise complete a transaction that you initiate.
Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails.
Improve our artificial intelligence and machine learning.
Deliver confirmations, account information, notifications, and similar operational communications.
Improve your user experience and the quality of our products and Services.
Comply with legal and/or regulatory requirements.
Aggregate and deidentify information.
Serve advertisements.
Count and recognize visitors to the Services.
Analyze how visitors use the Services and their features.
Improve the Services and enhance users experiences with the Services.
Create new products and services or improving our existing Services.
Enable additional analytics and research concerning the Services
Manage our business

We may link information gathered through the Services with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.

With Whom and Why We Share Your Information.

We share your information with third parties for a variety of purposes, as described below.

1.Third-party service providers.

We use third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business. If fivvy, or substantially all of its assets were acquired, or in the unlikely event that fivvy goes bankrupt or goes bankrupt, the user’s information will be one of the assets that are transferred or acquired by a third party. You acknowledge that such transfer may occur, and that the acquirer of fivvy may continue to use your personal information as set forth in this policy.

2.Analytics.

We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use pixels or server logs, and they may set and access device IDs from your device.

3.Interest-based Advertising.

The Services also enable third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties, such as Facebook, may use the fact that you visited our Site to target online ads to you about our Services. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above. If you are using a mobile device, you can opt-out of interest-based advertisements by adjusting the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that participate in the Digital Advertising Alliance’s AppChoices tool by downloading it here and following the instructions in the app.

Data generated by Fivvy.

Fivvy generates different types of data and stores it differently.

On the one hand, all the data generated by user behavior and transactions is stored in unstructured databases managed by the Cloud provider.
On the other hand, Fivvy generates aggregated and structured information based on the behavior of users and external sources of information, it is stored in structured databases.
As for security, as we mentioned in the previous section, the databases are managed by the cloud provider and they store the data in an encrypted manner, they are also in an environment isolated from the public networks and are only accessed through of internal services through an API Gateway protected by AWAF rules inside a firewall.

Legal purposes.

We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

To comply with applicable law or a court order, subpoena, or other legal process.
To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party.
To establish, protect, or exercise our legal rights or defend against legal claims.
To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Your Choices.

If you wish to access, amend, or delete any information we have on file, please contact us at support@getfivvy.com. Similarly, if you wish to opt-out of marketing emails you receive from us, you may do so by contacting us at support@getfivvy.com or by opting out using the methods provided in those emails.

External Links.

This Services may contain links to third-party websites or services. If you use these links, you will leave the Services. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security.

We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website or mobile app is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

Data Retention.

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International Users.

The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services or by providing any information to us, you expressly consent to such transfer and processing.

Children.

Content on the Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

Changes to this Policy.

We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, so you should review this page periodically.

How to Contact Us.

Should you have any questions or concerns about this Policy, you can contact us at by email at legal@getfivvy.com.