Keeta respects your privacy and strives to collect only the personal information necessary to provide the function it was collected for. This Privacy Policy describes Keeta collects, uses, shares and otherwise processes personal information in connection with Keeta mobile applications and websites (collectively “Keeta App”) and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”).
If you have a financial product or service with us, we will use and share any nonpublic personal information that we collect from or about you in accordance with our GLBA Privacy Notice, which offers you certain choices with respect to the collection, use, sharing, and processing of your nonpublic personal information by financial institutions

1. INFORMATION WE COLLECT

We collect personal information to approve you for and service your Keeta account, to comply with laws and regulations, to prevent fraud, and in some instances to market to you. We may get that data directly from you, including when you submit an application or correspond with us. We may also get data from other parties, including credit reporting bureaus and your other bank institutions when you choose to link a bank account. We may link or combine your activities in the Keeta App with information from you or other parties to provide you with a personalized experience.

When we use the term “personal information” in this Privacy Policy, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data,” “personal information,” or “personally identifiable information.

We collect information about you in the following ways:

Information You Provide. This includes:

• Registering or applying for an account, such as identifying and contact information including name, email, address, phone number, password, date of birth, Social Security number, country of citizenship, and government issued ID; and financial information including bank account and routing, debit and credit cards details. We use this data to help us verify your identity and prevent someone else from attempting to open an account in your name.

• Other information you provide, including survey responses; participation in promotions; suggestions; referrals; employment application information; or any other actions performed on the Services.

Information We Get from Others. This includes: 

• Banks and Financial Institutions: You may choose to link a bank account to add money to an account, receive a direct deposit, or other related services. When you link a bank account we receive financial information related to that account, including your account balance, and may also receive transaction history and information about the account owner. The amount of information we receive depends on your financial institution's own privacy policy. We use third-party bank account verification, to connect your Keeta account with your bank account(s). Their use of your personal information is governed by their privacy policies, which may be found HERE. [links to be inserted on launch].

• Service providers and linked account data: we use third-party service providers to perform services for us, including to help us process and authorize your payments and to facilitate ownership of account transfers. By using our Services, you are authorizing us and our third-party service provider(s) to take actions on our behalf such as debiting your account using your selected payment method when you initiate such action.

• Credit reference agencies: which may provide information related to your credit file, such as your credit score, credit inquiries, and payment history.

• Social media: When you interact with our Services through social media networks, we may receive information about you that you permit the social media network to share. The data we receive is dependent upon your privacy settings with the social media network.

• Job applicant-related third parties: we may receive personal information from job applicant-related third parties, such as job application platforms, your current employer, references, background check providers and recruiters.

• Publicly available sources: We may also collect personal information from publicly available sources to, for example, contact you if we are otherwise unable to reach you, or, to send advertising or promotional materials or to personalize our Services.

Information Automatically Collected. This includes:

• Information about you and your computer or mobile device such as your hardware model, operating system info, unique device identifier, mobile network information, device performance information, and information about the device’s interaction with our Services. Note that the Keeta App may periodically recollect this information in order to stay up to date. You can review and change permissions for some information the Keeta App has access in your device privacy settings.

• Transaction data, when you use our Services, including if you give us access to collect your financial data from your other accounts, for example payments into and out of such accounts including the date, time, amount, merchant or beneficiary details, or ATMs associated with the transaction.

• Usage data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your activity information on our services.

• Location information. We use your information to protect against fraud. If you have location services in the Keeta App enabled, we may track your geolocation and your IP address. You can withdraw your consent at any time by disabling location permission for the Keeta App within your device settings. We may use third-party providers to help provide location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third-party providers may use the information only in accordance with this Privacy Policy.

2. OUR USE OF PERSONAL INFORMATION

We may use the personal and other information we collect from and about you as follows:

• To manage your account, including assessing your eligibility for an account, and to communicate with you regarding your account.

• To carry out our obligations arising from any transactions you enter into with us, for example top-ups, bank transfers, electronic money exchanges, ATM withdrawals, and card purchases.

• To operate and administer our rewards program and other promotions you participate in on our Services.

• To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services.

• To respond to your comments and questions and to provide customer service.

• To send information including technical notices, updates, security alerts, and support and administrative messages.

• To send you marketing communications, including through SMS text with your consent, and through emails, messages, and push notifications. You may unsubscribe from these emails at any time: just follow the unsubscribe instructions contained in any such marketing emails.

• To review and process your employment application including to communicate with you about your employment application, to verify your information and carry out reference checks and/or background checks (where applicable) if you are offered a job and to assist you with obtaining an immigration visa or work permit when requested by you.

• To comply with applicable laws and legal processes including to respond to requests from public and government authorities; to enforce our Privacy Policy; and to protect our, your or others’ rights, privacy, safety or property.

• To operate, maintain, and improve our Services, products, and services, including to research and develop new products and services; enhance, improve, debug and analyze our products and services; manage our business relationships; process transactions or payments; and perform accounting, auditing and other functions;

Where an individual chooses to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide additional privacy disclosures where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Policy.

3. SHARING PERSONAL INFORMATION

We may share personal information with our affiliates, subsidiaries, or entities that share a common ownership in Keeta, partners, other Keeta App customers designated by you for the purposes of customer referrals or managing shared pockets, and to third-party service providers for purposes such as risk detection and prevention, customer service, email delivery and other similar services.

We may also be required to share personal information in the event of a corporate restructuring (e.g., merger, sale, joint venture, or other disposition) or when we deem it necessary or appropriate to:

• Comply with applicable laws, including disclosing information to fraud prevention agencies;

• Comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements;

• Enforce our Privacy Policy; and

• Protect our, your and others’ rights, privacy, safety or property.

We may also share anonymized or de-identified aggregated information (this means information that is no longer personal information because it is no longer attributable to a specific individual) with third parties to help deliver products, services, and content that are tailored to the users of the Keeta App and for other purposes. We may also disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

4. THIRD-PARTY ONLINE ADVERTISING AND COOKIES

• Advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Keeta App, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

• Cookies. We and our third-party partners may also use cookies and tracking technologies for advertising purposes. Our use of cookies in accordance with our Cookie Policy [link to be inserted on launch].

• Social Media Widgets and Advertising. We may display targeted advertising to you through social media platforms. These companies have interest-based advertising programs that allow us to direct advertisements while those users are on the social media platform. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel. These activities are governed by the privacy policies of those social media companies that provide them.

• Third Party Partners. We may use third-party analytics on our Services. For example, we use Google Analytics to better understand how you interact with our Services. The information we obtain through our Services may be disclosed to or collected directly by these third parties. To learn more, see Google Analytics.

5. CONTROL OVER YOUR INFORMATION

• Updating Your Information. Once you have registered for an account, you may be able to update or correct your profile information details and preferences by accessing your account settings through the Keeta App, or by contacting us at [email protected]

• Deactivating Your Account. We do not delete information about you upon deactivation of your account. Although your deactivated status is reflected promptly in our user databases, we may retain the information you submit for a variety of purposes, including legal compliance, backups and archiving, prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from Keeta and links to third-party financial accounts and services will automatically terminate. If you have a money transfer transaction pending at the time you deactivate your account, your link to this service from Keeta will terminate but your pending transfer will continue to completion and your bank account will remain open.

• Correcting Credit Reports. Information related to your creditworthiness is maintained by the credit bureaus. If you find that there is an error or you want to dispute the information found in your credit report, please contact the credit reporting bureaus: Experian, Transunion, and Equifax. 

• Opting-Out of Certain Online Ads. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you can visit the Digital Advertising Alliance (DAA) and/or the Network Advertising Initiative’s (NAI) at www.aboutads.info/choices or http://www.networkadvertising .org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

When you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us. It means that the online ads that you see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

• GLBA-Covered Data. Our GLBA Privacy Notice provides information about how you can limit your sharing options for our financial services and GLBA-covered data.

6. CHILDREN'S PERSONAL INFORMATION

The Keeta App is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us.

7. UPDATES TO THIS PRIVACY POLICY

When we make changes to this policy, we will change the date at the beginning of this document. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on the Keeta App, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

8. CONTACT US

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, write to us at [email protected]
California Privacy Notice

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).  
Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.  

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

1. COLLECTION AND USE OF PERSONAL INFORMATION

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your first, middle and last name, email address, or other similar identifiers;

• Internet/Network Information, such as device information, logs and analytics data;

• Geolocation Data, such as approximate location data generated based on your IP address or other information;

• Sensory Information, such as recordings of any phone calls or video calls (with your permission, as applicable).

• Professional/Employment Information when you apply for employment, such as the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization, job application information and other details contained in your resume;

• Other Personal Information, including information you submit into the feedback form and any communications between you and Keeta, as well as information we receive from social networking sites.

We collect this information from the following sources: directly from you, from our business partners and affiliates, from your browser or device when you visit the Keeta App or use our Services, or from third parties that you permit to share information with us.

2. DISCLOSURE OF PERSONAL INFORMATION

In the previous 12 months, we have disclosed the categories of personal information described above with third parties for business purposes. The categories of third parties to whom we disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) analytics providers; (iv) marketing and strategic partners; and (v) social networks.

3. SALE OF PERSONAL INFORMATION

As further described in the Third-Party Data Online Advertising and Cookies section of our Privacy Policy, we may “sell” your personal information (as that term is defined by the CCPA) to third parties or we may share your personal information for targeted advertising, each subject to your right to opt out of those sales (see Exercise Your Right to Opt-Out below).

In the last 12 months, we have shared for targeted advertising or sold the following categories of personal information for the purposes described in our Privacy Policy, subject to your settings and preferences and your Right to Opt-Out: Identifiers, such as your name and email address, Internet/Network Information such as your IP address, and Commercial Information, such as records of services purchased, obtained or considered.

The categories of third parties to whom we may share or sell the personal information include: Business and Marketing Partners, Online Advertising Networks and Analytics Providers, and Social Networks.

4. YOUR CALIFORNIA PRIVACY RIGHTS

As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):

The Right to Access/Know: You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;

• The categories of personal information we have collected about you;

• The categories of sources of the personal information;

• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

• The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and

• The business or commercial purposes for collecting or, if applicable, selling the personal information.

The Right to Request Deletion: You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt-Out of Personal Information Sales: You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

The Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

“Shine the Light”: California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, or the right to opt out of such practices (Civ. Code §1798.83).

5. HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

Exercise Your Right to Access, Right to Know, and Right to Deletion

To exercise your Right to Access, Right to Know or your Right to Deletion, please submit a request by:

• Emailing us at [email protected]

Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email address and phone number.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Exercise Your Right to Opt-Out

As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including preferences, geolocation, commercial information and internet, network and device information) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes. By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. To learn more about how third parties collect information through tracking technologies and what other choices you may have in relation to those activities, please see the Information Automatically Collected and the Third-Party Online Advertising and Cookies sections of our Privacy Policy.

Authorized Agents

In certain circumstances, you may permit an authorized agent to submit requests to exercise your California Privacy Rights on your behalf. The authorized agent must provide a letter signed by you confirming the agent has permission to submit a request on your behalf or must provide sufficient evidence to show that the authorized agent has been lawfully vested with power of attorney.
For security purposes, we may need to verify your identity and confirm directly with you that you have provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. Please note that for privacy and security reasons, we will direct future communications to the data subject on whose behalf the request was made.

Minors

We do not sell the personal information and do not have actual knowledge that we sell the personal information of minors under 16 years of age. Please email us at [email protected] to inform us if you, or your minor child, are under the age of 16.
If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please email us at [email protected] We may not be able to modify or delete your information in all circumstances.