Last updated: May 02, 2023
This Privacy Policy ("Policy") applies to the websites located at Nilfee.com, the Nilfee mobile applications, and through any other programs (including Nilfee Research programs), websites, or applications owned and operated by Nilfee that direct you to this Policy.
This Policy, together with our User Agreement (and any additional terms of use mentioned in our User Agreement) applies to your use of our Services.
Where we use other capitalized words and phrases in this Policy (such as Agreement, Profile, Services, and Transaction), these have the same meaning as given to them in our User Agreement, unless we have defined them differently in this Policy.
NOTICE TO CALIFORNIA RESIDENTS
Notice at Collection of personal information: We list the categories of personal information we collect below under "What Personal Data Do We Collect." We collect personal information about you for business and commercial purposes as described below under "How Do We Use or Process Your Personal Data." For more information, including on how to opt-out of the sale or sharing of personal information, please see "US State Privacy Rights" section below.
Any personal data provided to or gathered by our Services is controlled by Nilfee, Inc. located at 447 Broadway, 2nd Floor Suite #466, New York, New York 10013, United States.
The personal data that we collect from you depends on how you interact with us and our products and services. When we say "personal data" or "personal information" we mean any information related to an identified or identifiable natural person. The following are the categories and specific types of personal data or information we may collect:
Basic Identifying Information: Including your full name, postal address, e-mail address, phone number, date of birth, occupation and employer, username or social media handle, or other similar identifiers.
Payment Information: Including your financial instrument details (either debit/credit card) or bank account details.
Government Issued Identification or Records: Including your driver's license, state or country issued identification card, passport (as well as a picture of yourself with your identification documentation), social security number (SSN), records of proof of address, or evidence of how you will fund your Transaction (e.g., bank statement or pay slip).
Device Or Other Unique Identifier Information: Including your device identifier, internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers. See our Cookie Policy for additional information on our use of Cookies.
Geolocation Data: Including information about the location of your device, such as information derived from your device (e.g., based on a browser or device's IP address).
Transaction Information: Including your transaction history/logs (including a unique Transaction reference number), purpose of transfers, relationship with the recipient, and referral rewards.
Recipient Information: Including your recipient's full name, address, phone number, or depending on the disbursement method selected certain financial institution or financial account details such as bank account or mobile wallet account.
Referral Information: Including your contact's name and email address.
User Generated Information or Content: Including your communications with us and any other content you provide us with such as social media profiles, photographs, images, videos, survey responses, comments, product reviews, testimonials, information you provide us for customer service (including chat) and other content.
Technical Information: Including the hardware and software you use to access our Services, network information, internet service provider, operating system, or the type of browser you use.
Internet or Network Activity Information: Including information on your interactions with our Services or Sites or browsing or search activity.
Audio and Visual Information: Including photographs, images, videos, and recordings of your voice (such as when we record customer service calls for quality assurance).
Inferences: Including information we may infer from other information described above.
For California residents, please note that we may collect Sensitive Personal Information including social security number, driver's license, state identification card, or passport number and Protected Classifications under California and federal law, including gender and age.
We collect personal data about you from various sources. For example, we collect and obtain information:
Directly from you
We collect personal data you provide, such as when you use our Service, create a profile, contact us (including via chat), respond to a survey, interact with us at events, participate in a sweepstakes, contest, or other similar campaign or promotion (including #payvianilfee), respond to a survey, post a review, or sign up to receive emails, text messages, and/or postal mailings.
Using cookies and other automatic data collection technologies
When you visit our websites, use our app, open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see our Cookie Policy.
From Other Sources
We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, social media platforms or networks, fraud prevention or identity verification service providers, electronic databases, credit reporting agencies, vendors that provide services on our behalf, or publicly available sources.
COMPLY WITH LEGAL OBLIGATIONS
We use personal data to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
Security and Fraud Prevention
We use personal data to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and harm to the rights, property, or safety of Nilfee and our users, customers, employees, or others.
Comply with Applicable Laws
We use your personal data to comply with applicable laws and regulations, such as those relating to "know-your-customer," anti-money laundering requirements, sanctions legislation, and the various associated regulatory rules and guidance in relation to risk investigation, risk scoring, fraud, counter-terrorist financing, anti-money laundering, consumer protection, and complaint handling.
To Provide Our Services
We use your personal data when you access or use our Services, including to process your Transaction(s), maintain and manage your account, deliver/fulfill promotional offers or rewards (including our referral program), process payments.
Communicating With You
We use your personal data to communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues or feedback, and to provide customer service.
Marketing and Promotional Purposes
We use personal data for marketing and promotional purposes, such as to send marketing, advertising, and promotional communications by email, text message or postal mail; to show you advertisements for products and/or services tailored to your interests on social media and other websites; and to administer our new customer promotions, sweepstakes, contests, and other similar promotions.
Analytics and Personalization
We use personal data to conduct research and analytics, including to improve our services and product offerings; to understand how you interact with our websites, mobile apps, advertisements, and communications with you to improve our websites, app, and marketing campaigns (business and marketing analytics); to personalize your experience, to save you time when you visit our websites and app, and to customize the marketing and advertising that we show you; to understand how you use our app and website.
Other Business or Commercial Purposes
At your direction or with your consent, we may process certain personal data to fulfill any other business or commercial purposes.
In addition to the specific situations discussed elsewhere in this privacy policy, we disclose personal data in the following circumstances:
Corporate Affiliates
We may share personal data with our corporate affiliates, including our parent company, affiliates and subsidiaries. Such corporate affiliates process personal data on our behalf to provide services or in other circumstances with your consent or as permitted or required by law.
Service Providers
We share certain personal data with third parties that perform services to support our core business functions and internal operations. This includes banks, disbursement providers, or other financial institutions completing your transfer or other financial service request (including payment processors), identity verification or KYC service providers, third parties that provide software and tools to send postal mail, e-mails and text messages, or analyze customer data, provide marketing assistance, administer our reviews, investigating fraudulent activity, conducting customer surveys, and outsourced customer service providers.
Third Party Partners
We may share your personal data with third parties that we have partnered with to jointly create and offer a product, service, or joint promotion. We may also share your personal data with our banking or distribution partners in the event we suspect you are violating our terms or engaging in fraudulent behavior as it relates to our business. Their use of your information is not governed by this privacy policy, but by their own respective privacy policies.
Social Media Platforms and Networks
Some of our websites have features such as, plugins, widgets, or other tools made available by third parties that may result in information being collected or shared between us and the third party. For example, if you use our referral feature to refer persons via WhatsApp, Facebook, email, or SMS. Their use of your information is not governed by this privacy policy.
Business Transactions
If we become involved with a merger, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
Legal Process
We may disclose personal data in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect our rights or the rights of others; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
Other Instances
We may ask if you would like us to share your information with other third parties who are not described elsewhere in this Policy.
Our customers in certain regions of the world have specific data privacy rights based upon the applicable privacy legislation (including but not limited to the laws of Europe or California). We try our best to implement the best privacy practices as a standard for all our customers.
Access Your Data & Data Portability
You may request that we provide you a copy of your personal data held by us. This information will be provided without undue delay subject to certain exceptions or limitations, including if such provision adversely affects the rights and freedoms of others.
Correct Your Data / Data Rectification
You have the right to request that we update and correct inaccuracies to your personal data. You can update certain information related to your account by logging into your account on our site or app, as applicable or otherwise contacting us as described in the Exercising Your Privacy Rights section below.
Data Deletion/Erasure
You may request to erase your personal data, subject to applicable law. If you close your account, we will mark your account in our database as "Closed," but will keep certain account information for a period of time as described below. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with our legal obligations. However, if you close your account, your personal data will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Policy.
Restrict Processing of Data Requests
You have the right to request to restrict or object to us processing or transferring your personal data under certain circumstances.
Unsubscribe from Direct Marketing
You have the right to ask us not to process your personal information for marketing purposes. You can exercise this right simply at any time by carrying out ‘unsubscribe’ actions which are made available to you (such as clicking on the ‘unsubscribe’ link in each promotional email we send you). We will honor your choice and refrain from sending you such communications. Please note that if you ask us not to contact you by email at a certain email address, we will retain a copy of that email address on a “suppression list” in order to comply with your no-contact request. You are free to change your marketing choices at any time.
You may also control how we use some of your personal data as part of our Services (such as how we may communicate with you) by confirming your preferences in your Profile. Please note that not all communications can be switched off – for example, we may be required to send you email notices about our Services to comply with our legal obligations under the national laws and regulatory guidance.
Automated Individual Decision-Making, Including Profiling.
In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
Exercising Your Privacy Rights
To exercise any of the above privacy rights, please submit a request through one of the following methods:
Identity Verification
For us to process some requests, we will need to verify your identity to confirm that the request came from you. We may contact you by phone or e-mail to verify your request.
We employ industry-accepted standards in protecting the information you submit to us. We have put in place SSL (Secure Socket Layer) encryption technology to protect your sensitive information such as bank account number, credit card number, date of birth and government identification number, transmitted through our Site and/or our App. We also require the use of security credentials (which may, for example, include a username and password) from each user who wants to access their information on our Site and/or our App.
Where we have given you (or you have chosen) security credentials (such as a password) that enable you to access certain parts of our Service, you are responsible for keeping these details confidential and secure. Moreover, if you allow access to our Services via using your fingerprint on your Device (for example, via Apple Touch ID), then you should not allow any other person to register their fingerprint on that Device as it may allow them access to our Services and you could be held responsible for their actions. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security and any transmission of personal information is at your own risk. If you have any questions about security, you can contact us at privacy@nilfee.com
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the following based upon your country of residence (amongst other things):
Please note that by using our Services you expressly agree to us retaining your personal data (including data related to your Transactions and our collection and verification of your identity) for longer than 5 years following the end of your legal relationship with us. This is to allow us to detect and prevent fraud and/or other illegitimate uses of our Service.
We may amend this Policy at any time, and whenever we do so we will notify you by posting a revised version on our Site and App. Please review this Policy each time you make a Transaction as it may have been updated since you initially registered for our Services, or since your last Transaction.
If you do not agree with any of this Policy, or any change, you can end your Agreement with us and close your Profile by emailing us at privacy@nilfee.com
Parts of our Service use Google Maps services, including the Google Maps API(s). Use of these features is subject to the Google Maps Additional Terms of Use and the Google Privacy Policy. By using this Site and the Service you also agree to the Google Terms (as amended from time to time).
Our Site and App includes links to other websites whose privacy practices may differ from those of Nilfee. We also create information based on our analysis of the information we have collected from you.
If you submit personal information to any of those websites, your information is governed by their privacy policies and we do not accept any responsibility or liability for these policies or for any personal information which may be collected and processed via those websites or services (such as contact and location data). We encourage you to carefully read the privacy policy of any website or software application you use or visit.
This Policy does not cover the practices of third parties that you may engage with when using the Services, such as your mobile network operator or other users of our Services. You should contact them about their privacy policy before providing them with any personal information.
Using our referral service via e-mail to tell a friend about our Services, you will need to provide your friend's name and email address. Before providing us access to any other person's details, you must obtain their prior consent to you sharing their personal data with us and we will let them know that you have supplied their details to us.
Where you have:
In both cases, your contact/friend may at any time request to remove this information from our database and we will honour such request. We will retain a copy of that email address on a "suppression list" in order to comply with their no-contact request. They are free to change their marketing choices at any time.
We ask that persons under the age of 18 (which we treat as children and minors) refrain from using our Services or submitting any personal information to us. Persons under the age of 18 years are not eligible to use our Services and if we discover that someone under the age of 18 has registered a Profile with us, we will close it.
This Policy is drafted in the English language and translations may be provided in other languages. You agree that the English version of the Policy will control in the event of any inconsistency between the English and translated versions in any dispute related to this Policy.
If you have a complaint regarding our handling of your personal information, email privacy@nilfee.com
If you have any questions, comments, or requests regarding our privacy policy, you may reach out to privacy@nilfee.com
We do our best to implement the best privacy practices from each region for all of our customers, but if you are in a certain region, here are some specific requirements that may apply to you.
US STATE PRIVACY RIGHTS:
Explanation of Applicable Privacy Rights
If you are a California resident, you may take advantage of the following privacy rights:
If you are a resident of Virginia, you may take advantage of certain privacy rights, such as to request access, correction, deletion, or a copy of your personal information. We do not "sell" personal information but may engage in "targeted advertising" as these terms are defined under Virginia law, you may also exercise your right to opt-out of such sales or targeted advertising. You have the right to appeal a denial of your privacy rights.
How to Submit a Request
To take advantage of your right to know, delete, correct, or portability under California or Virginia law, or to submit an appeal of a denial of your privacy rights, please contact us by email at privacy@nilfee.com We may request certain information to verify your identity before we can respond to your access, deletion, correction, or portability requests. We will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days, after proper verification, unless we need additional time, in which case we will let you know.
We value your privacy and will not discriminate against you in response to the exercise of your privacy rights.
What categories of Personal Information do we collect and what is the purpose?
You can find a list of the categories of personal information that we collect in the "What Personal Data Do We Collect" section above. For details regarding the sources from which we obtain personal information, please see the "How Do We Collect Your Personal Data" section above. We collect and use personal information for the business or commercial purposes described in the "How Do We Use Or Process Your Personal Data" section above.
Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
For more information on how your information is shared, please see the "Who Do We Share Your Personal Data With?" section. We may also need to share any of the above categories of information pursuant to Legal Process.
Our use of cookies or other tracking technologies may be considered a "sale"/ "sharing" under applicable law. You may have the right to opt-out of having your personal data shared for purposes of targeted advertising. We do not knowingly sell the personal data of consumers under 16 years of age.
Categories of Personal Information that may be considered a Sale or Sharing under California law: Basic Identifying Information, Device or Other Unique Identifier, Geolocation Data, Technical Information, and Internet or Network Activity Information.
Categories of third parties to whom the personal information was disclosed that may be considered a "sale" or "sharing" under California law: certain Service Providers including advertisers and marketing partners, data analytics providers, and social media networks.
For more information on how your information is shared, please see the "Who Do We Share Your Personal Data With?" section, which provides more detail on our Service Providers and Third Party Partners. We may also need to share any of the above categories of information pursuant to the Legal Process.