Data you provide to us. We collect information that you provide to us, including:

• Your name, email address, mobile phone number, tax identification number (such as U.S. social security number) or other government-issued ID number, date of birth, physical address, and currency preference, such as when you create an account, complete your profile or submit a request for support;
• The emails and phone numbers of your contacts, if you choose to invite third parties to use Qwil as part of any Qwil referral program; we allow your contacts to unsubscribe from the commercial messages they receive from us.
• Information about transactions you complete using our services, including the amount of funds associated with a transaction, the type of transaction executed, and other related information.
• If you use our mobile apps, we collect from your mobile device a unique ID (where your device is an iPhone, we also collect the Apple-recommended CFUUID (the Core Foundation Universally Unique Identifier)).
  

Other Data Collected. We may also automatically collect the following data:

• Cookies. We use cookies on our website to collect data about your visit and to allow you to navigate from page to page without having to re-login each time, count visits, and see which areas and features of our website are popular. We do not link the information we store in cookies to any information you submit while on our website. We may also use the data collected via cookies to tailor advertisements to you and to track the popularity of our website. They may also collect information about:
  

• Your Internet Protocol (IP) address. This is a number automatically assigned to your computer or device whenever you are connecting to the Internet. It allows web servers to locate and identify your device, this is a unique address assigned to your device by your Internet service provider or information systems department on a TCP/IP network.
  
• Clickstream behavior. For example, the pages you view and the links you click.
  

• Our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of our services.
  
• Analytics. When you visit our website, we use third party analysis tools to collect data about your computer and Internet connection. That information includes the IP address of your computer and/or Internet service provider, when you access our website, the Internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your movements and preferences on our website. All of this information is used internally for the purpose of understanding how our website is being used and improving our website. We also use third party analysis tools to collect data about your use of our mobile apps. The information collected identifies the types and timing of actions you take within our mobile, including installation, registration, uploading, and certain types of navigating. All of this information is used internally for the purpose of understanding how our mobile apps are being used and improving them.
  
• Action Tags. When you visit our website, we use action tags (also called pixel tags, clear GIF, or beacons) to identify some of the pages that you visit and how you use the content on those pages. Action tags may collect and transmit this data in a manner that identifies you if you have registered with our website, or are logged into our website. We also use action tags in our emails, to determine whether an email was opened or whether it was forwarded to someone else. When you use our mobile apps, we use action tags where you are accessing websites from links in our mobile apps. These may identify the pages that you visit and how you use the content on those pages.
  
• Site Management. We aggregate data that we collect about the use of our website for administering, protecting and improving our website and our systems, to better understand the preferences of our website visitors and optimize the content that we serve, to identify server problems, to compile aggregated statistics about our website usage, and to improve our marketing and research.
  
• Do Not Track. Our Service currently does not respond to “Do Not Track” signals and operates as described in this Privacy Policy whether or not a Do Not Track signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.
  

By voluntarily providing us with personal data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide personal data to us, you acknowledge and agree that such personal data may be transferred from your current location to the offices and servers of Qwil and the authorized third parties referred to in this policy, some of whom may be located in the United States.

We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Policy.

• We use reasonable physical, technical, and procedural safeguards to protect the personal information that we obtain from you from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please note that we are not responsible for the security of any data you are transmitting over the Internet, or any data you are storing, posting, or providing directly to a third party’s website, which is governed by that party’s policies. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure. If you have further questions about security, you can contact us at compliance@qwil.com.
  

If you wish to close your Qwil account altogether, please let us know by submitting a request to support@qwil.co.

• We may retain information about you in our databases for as long as your account is active or as needed to provide you services and in accordance with applicable laws. Our retention and use of your information will be as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain certain information to prevent fraudulent activity, protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain, or if we believe in good faith that a law, regulation, rule or guideline requires it.
  

We will respond to your request for access to information we collect about you within the time frame required by applicable law.

We may share your information as follows:

• You’ve consented or otherwise given us permission to share;
  
• We’ve aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
  
• With third party service providers who we use in delivering our service, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
  
• If required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process;
  
• To protect the rights, property and safety of Qwil, our users and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims; or
  
• In connection with selling, merging, transferring, or reorganizing all or parts of our business.

Qwil encourages parents and guardians to take an active role in their children's online activities. Qwil does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the applicable age of consent in your country without proper consent, please let us know by emailing compliance@qwil.com and we will take appropriate measures to investigate and address the issue promptly.

If you opted-in to receive information about our product, updates and offers, we will use your name and email address to send this information to you. If you no longer wish to receive these communications, you can unsubscribe by following the instructions contained in the emails you receive or on our website. Please note that we may send you transactional and relationship messages, even if you have unsubscribed from our marketing communications. For instance, if our service is going to be temporarily suspended for maintenance, we might send you an email to update you.

As part of our service, you may be able to use Facebook Connect or other social networking services (referred to in this policy as Social Networking Services) to authenticate your identity and to authorize a Social Networking Service to share certain information with us, such as your name and email address, which is associated with your Qwil account. A Social Networking Service may also let you post information about your activities on our website and in our mobile apps to your Social Networking Service profile page to share with others within your network. The information we obtain depends on your Social Networking Service settings and the Social Networking Service’s privacy policies, so be sure you know what those are. Qwil will have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within our services.

Our website may include links to other websites or online services, including Facebook, whose privacy practices may differ from those of Qwil. If you submit information to any of those websites or online services, your information is governed by their privacy policy. We encourage you to carefully read the privacy policy of any website you visit.

The following Qwil policies are also publicly available and may concern our use of your data:

• Qwil Data Request Policy
• Qwil Subprocessors
  

To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal data in our possession that you have previously submitted using our services. Please also feel free to contact us if you have any questions about our Privacy Policy or the information practices of Qwil’s services.

You may contact us as follows:

Qwil PBC
599 3rd Street, Suite 211
San Francisco, CA 94107
compliance@qwil.co

We may update this Privacy Policy from time to time. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. You agree to visit these pages every now and then to be aware of and review any such revisions. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.

This Privacy Policy was last updated on May 25, 2018.