This Privacy Policy (the “Policy”) explains how information that directly identifies you (“Personal Information”) is collected and used by Mezu (NA), Inc. (“Mezu”, “Company,” “we” or “us”) in connection with the services provided to you (the “Services”) through the Mezu mobile application (the “App”). The Policy also may describe some of our practices regarding information we collect or obtain that does not directly identify you or your identity. By downloading, using, or accessing the App, you indicate that you have read, understood and agree to our collection, storage, use and disclosure of your information as described in this Policy and our other Terms and Conditions. If you do not agree, you should notify us and discontinue your use of the App.
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Information We Collect, and How We Collect It.
In order to provide you the best possible experience and in order to comply with legal requirements that apply to us, we must collect certain information, including, but not limited to Personal Information, when you download and use the App. When you visit our website, we may also collect information that does not directly identify you. This collection includes information that you provide in connection with the App, information we may receive about you from third parties, and information that is collected automatically through the use of cookies and other technologies. The categories of information we collect can include:
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Information That You Provide Directly
Registration Information. We collect Personal Information that you provide when you sign up for an account with the App (the “Mezu Account”) or at any other point, during your relationship with us in order to verify and protect your identity, your Financial Information and the privacy of your financial transactions. This information may include your full name, email, mobile phone number, date of birth, physical address, social security number and a government issued photo ID. Mezu will not sell, trade, share nor provide access to any of your Registration Information or any other personal or Financial Information collected by Mezu, for any purpose whatsoever, except as required by Applicable Law or as required for the normal operation of the App and to manage and mitigate risk to protect the Mezu User Community.
Financial Information. In order to provide you the Services, we collect information about your external financial accounts that you choose to enable with the App, which may include debit or credit card accounts or bank accounts (“External Financial Accounts”). This information may include, but not be limited to, financial institution names, account numbers, routing numbers, and debit or credit card information. We will not share your Financial Information with third parties for marketing purposes for any reason.
Inquiries and Feedback. If you contact us, we will collect the information that you provide us, such as your contact information and the contents of your communication with us.
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Information That You Permit Us To Collect
Address Book Information. With your permission, Mezu may access the contact list available on your mobile device in order to enable you to invite your friends to use the Mezu App and/or to enable you to send money to or request money from people in your device-based contact list.
Mezu will send an invitation to your contacts to join the App only at your request, at which point we may include some limited Personal Information to let them know that you are extending the invitation to join Mezu, not us. Once you have sent these invitations, Mezu may send occasional reminder emails to your invitees on your behalf, which may also include your name. We may also show other users already using the Mezu app, and limited to them only, that you are also a Mezu user. We will not use the information contained in your address book for any purpose other than to enable you to invite your contacts, or send and request funds from your friends and contacts or for the purposes described in this section of this Policy.
Mezu will not sell, trade, share nor provide access to any of your Address Book Information or any other personal or Financial Information collected by Mezu, for any purpose whatsoever, except as required by applicable law or as required for the normal operation of the App and to manage and mitigate risk to protect the Mezu User Community.
Location Information. In order to enable and provide the basic services of the Mezu app, Mezu must obtain your location through GPS, WiFi, or wireless network triangulation. Mezu maintains location information as long as is reasonable to enable the basic service of the App and in order to protect you from any outside risk. Mezu will delete this data in accordance with applicable law. Please see “Data Retention” below to learn more.
Mezu will not sell, trade, share nor provide access to any of your Location Information or any other personal or Financial Information collected by Mezu, for any purpose whatsoever, except as required by applicable law or as required for the normal operation of the App and to manage and mitigate risk to protect Mezu users (collectively, the “Mezu User Community”).
If you would like to opt-out of the collection of your location data, you can do so by adjusting your settings through your device to limit the Apps’ access to your location data, however, this may affect your use of certain features and limit the functionality available through the App. Please see “Control Over Your Information” below to learn more.
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Information from Third Parties
We also collect and receive information about you from third parties, such as companies providing identity verification, fraud prevention and similar services, and combine that with information we collect through the App. This information may include information from financial institutions to verify your External Financial Account, to verify availability of funds in your External Financial Account, or information related to the financial transaction you request or initiate in connection with the App. We may also collect information about you from public records or that is otherwise publicly available. The data we receive from these third party services is dependent upon that third party’s policies and your privacy settings on that third party services.
We use Plaid Technologies (“Plaid”) to gather certain information from financial institutions for identity verification purposes, as well as to manage and mitigate risk to protect the Mezu User Community and to comply with legal requirements that apply to your use of the App. By using our service, you grant us and Plaid the right, power, and authority to act on your behalf to collect your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with its Privacy Policy located here. Mezu will not sell, trade, share nor provide access to any Information from Third Parties or any other personal or Financial Information collected by Mezu, for any purpose whatsoever, except as required by applicable law or as required for the normal operation of the App and to manage and mitigate risk to protect the Mezu User Community.
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Information That Is Automatically Collected (Cookies and Other Tracking Technologies)
Like most websites and online services, we and our third party partners automatically collect certain types of usage information when you visit our website, our App, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). Information that is automatically collected through tracking technologies as covered in this section does not directly identify you. These tracking technologies only collect anonymized information about how you use the App (e.g., the pages you view, the links you click, and other actions you take on the App), information about your browser and online usage patterns (e.g., IP address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email , links clicked), and information about the device(s) you use to access the App (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and depending on your mobile device settings, your geographical location data (which could include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may also collect analytics data, or use third party analytics tools, to help us measure traffic and usage trends for the App. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) recognize and/or contact you across multiple devices; (d) provide and monitor the effectiveness of our App; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; (g) manage and mitigate risk to protect the Mezu User Community; and (h) otherwise to plan for and enhance our App.
If you would prefer not to accept cookies when visiting our Website, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Website. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.
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How We Use Your Personal Information.
We collect, use, process, combine, retain and store personal information that we collect or receive for a variety of purposes, including the following:
- To verify your identity and age, as well as to guard against potential fraud;
- To provide you with the features and functionalities of the App;
- To process your transaction requests initiated through the App;
- To provide customer service and to send regular communications regarding your Mezu Account;
- To market additional products and services to you;
- To track App performance and use, and to improve the App;
- To enforce agreements with you;
- To comply with a court order, legal process, or applicable law, including retaining personal data or responding to governmental or regulatory requests; and
- For any other lawful purpose, or other purpose for which you provide your consent.
We also may use information that does not directly identify you, or aggregate information, for the purposes noted in this Policy.
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Sharing of Personal Information.
We may also share Personal Information with third parties for everyday business purposes, including:
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Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include fraud detection, identity verification, identifying and serving targeted advertisements, payment processing, and providing analytics services. For example, we may provide your Personal Information to financial institutions to process fund transfers and store funds that are associated with your Mezu Account, provide the App features and functionality, and review suspicious activity on the App; and
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Government officials, including law enforcement, when we subject to subpoena, court order or similar legal procedure or we need to do so to comply with law.
We will not sell or license any of your Personal Information to third parties for their marketing purposes and will only share your personal information with third parties as described above.
We will limit sharing of your information in accordance with the choices you have provided us in response to our Privacy Notice.
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Control Over Your Personal Information
Modifying or deleting your information. If you have registered for a Mezu Account, we may provide you with the ability to access, review and change certain information by logging into the App, visiting your Mezu Account, and using the features and functionalities available there. You are responsible for keeping your contact information and External Financial Account information up to date. Modifications to your information may require further validation before being accepted.
If you would like to request access to, or request correction or deletion of Personal Information, or if you want to remove your name or comments from publicly displayed content (such as a consumer review or comment that you left in our social media accounts or product ratings pages), you may send your request to us at [email protected] We may not be able to modify or delete your information in all circumstances. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from publicly displayed content, you can contact us directly at [email protected].
Access to your Device Information. You may control the App’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the App to access your address book and location. Please note that if you want to disable access to your device information, this may affect your use of certain features and limit the functionality available through the App.
How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the App, technical and security notices).
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Social Media Marketing and Third Party Tracking
We do not share, nor do we permit third party online advertising networks, social media companies and other third party services that we partner with, to collect information about your use of our website or our App. We do not share your information with third parties for their marketing purposes or for the marketing purposes of others.
We may share information collected through tracking technologies as defined above in section 1.D of this Policy. However, this information is shared only for purposes of Mezu’s own analytics and related marketing initiatives, and is not to be used by third parties in furtherance of any separate marketing. As noted above, depending on your browser or mobile device, you may be able to manage your settings to delete or notify you of cookies and other tracking technology.
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How We Store and Protect Your Information
Data storage and transfer. Your information collected through the App may be stored and processed in the United States or any other country in which our Company or service providers maintain facilities.
Keeping your information safe. We are committed to maintaining your information secure and private. We will employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our App and our website. In the event that any information entrusted to us is compromised as a result of a breach of security, we will take reasonable steps to investigate the incident and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with applicable law.
You should also use reasonable efforts to help maintain the safety and security of your Personal Information. For example, you may be required to set up a security pin through the App, and you must keep it confidential, and must not share it with other people. You should also secure your mobile device, including with a password or other technological lock, when you are not using it. If you believe that any account credentials for the App have been compromised, please contact us immediately at [email protected].
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Data Retention
We intend to only keep personal and transactional information for as long as we deem it necessary for our own business purposes, or as otherwise required to operate the App, comply with your requests, or to otherwise comply with applicable law.
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Information from Children
The App does not allow users under the age of 18. As such, the App is not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13. In the event that we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under the age of 13, please contact us immediately at [email protected].
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Third Party Websites
The App or our Website may contain links to and from third party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.
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Updates to This Policy
We may modify or update this Policy from time to time as we deem necessary in our sole discretion. If there are material changes to this Privacy Policy, we will provide notice where, and in the manner required by applicable law, including but not limited to, through the App. Your continued use of the App after an updated Policy is posted constitutes your consent to be bound by any such changes. We will, however, seek your consent to future modifications to the extent we are required by applicable law. If you object to any changes, you may request to close your Mezu Account.
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Contacting Us
If you have questions about this Policy or our privacy practices, please contact us at [email protected] or by telephone at 1-844-573-3265.
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Your California Privacy Rights
While Mezu does not share your information with third parties for their own direct marketing purposes, if you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at [email protected] or by writing to us at 101 Avenue of the Americas, 9th Floor, New York, NY 10013.
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Last Revision Date.
This Policy was last revised on February 26, 2019.