Privacy Policy

Privacy Statement (Last updated: Mar. 22, 2021)

This Privacy Policy applies when you use Sociale Digital’s Services, including the Sociale True Wallet™ and is brought to you by Sociale Digital (Cyprus), Ltd. on behalf of itself, its affiliates and “Sociale True Wallet” (hereinafter, “Sociale”, “True Wallet”, “Wallet”, or “we”, “us” and “our”). For purposes of this Privacy Policy, “You” or “your” means those with whom we interact, including customers, visitors to our Site, and other users of our services.

You must agree to allow Sociale to collect, store, use, or share your data in the ways described in this Privacy Policy, or you may not use Sociale’s Services. Use of the Services is your indication to Sociale that you approve of the terms of this Privacy Policy. If you have any questions about this Privacy Policy, please contact us Support@Sociale.com.

We have designed this Privacy Policy to let you know a) What data we collect from you; b) How we collect and store your Personal Data; b) How we use and disclose your Personal Data, and c) what choices you can make about your Personal Data.

In the event that you fail to provide us with your Personal Data when we ask it of you, we may not be able to perform the service, enter or fulfil our contract to you.

1. THE DATA WE COLLECT ABOUT YOU

Personal information, or Personal Data, means any information about an individual by which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

a) Identity Data, including first name, maiden name, last name, username or such, title, and gender.

b) Contact Data, including your addresses, email addresses and telephone numbers.

c) Financial Data, including bank account details.

d) Transaction Data, including with us.

e) Technical Data, including internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our applications and website(s).

f) Profile Data, including your resume´, professional background and career history.

g) Usage Data, including information about how you use our website, products and services.

h) Communications and Marketing data, including your communication preferences and any preferences in receiving marketing from us and third parties.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We do not intend to collect the following special categories of Personal Data about you: your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Some examples of the types of Personal Data Sociale may collect and how we may use it:

When you create an account or use Sociale Services, we may collect the following types of data to meet our legal obligations: your name, date of birth, social security number, driver number ID, personal ID, address, phone, email, full bank account details and/or credit card numbers that you link to your Sociale account or input when you use Sociale Services. Sociale will use this information to fulfill your requests and provide the relevant Services.

You may choose to provide us with access to certain Personal Data stored by third parties such as social media sites. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization.

2. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our Application, by email or otherwise.

b) Automated technologies. As you interact with our Application, we may automatically collect Technical Data about your equipment, browsing actions and patterns. email or otherwise.

c) Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources such as Technical Data from analytics, technology and hosting providers, aggregators and from publicly availably sources.

d) Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you).

e) Credit Bureaus, Public Databases & ID Verification Partners: We may obtain Personal Data about you from public databases and ID verification partners for purposes of verifying your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We may obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you based on public interest grounds to ensure our Services are not used fraudulently or for other illicit activities.

f) Resellers, Channel Partners, Joint Marketing Partners, and Social Media Platforms: We may collect Personal Data about your publicly available social media profile, interests or preferences, and page-view information from some business partners with which we operate co-branded services or joint offerings. Once we obtain such information from third parties, we do not subsequently share it with any other third parties except as described in this Policy. This information is shared with Sociale's processors and corporate group as necessary to perform the Services.

3. HOW WE USE YOUR PERSONAL DATA

We only use your Personal Data when the law allows us to. Generally, we will use your Personal Data in the following circumstances:

a) Where we need to perform on a contract we are about to enter into or have entered into with you.

b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

c) Where we need to comply with a legal or regulatory obligation.

d) When you have expressly consented to us processing your Personal Data.

e) Where consent is relied on, you have the right to withdraw it at any time by contacting us.

f) Where the processing is necessary to protect the vital interests of any individual; or

g) Where we have a legitimate interest in the processing of your Personal Data.

The balancing test we have conducted in each case is as follows: (a) we have ensured that the Processing is lawful, proportionate, and conducted in accordance with the terms of this Policy; (b) we have ensured that we have a legitimate business need to perform the Processing; and (c) we have ensured that there is no material likelihood of any adverse impact on your interests, fundamental rights, or freedoms, as a result of the Processing.

4. PURPOSES FOR WHICH WE MAY PROCESS YOUR PERSONAL DATA

We may process your Personal Data for the following purposes, subject to applicable law:

a) Our Application and Site: operating and managing the App and our website; providing content to you; displaying advertising and other information to you; communicating and interacting with you; and notifying you of changes to any of our Services.

b) Members: communicating with you regarding your Membership (or prospective Membership), where applicable, and to keep you up to date with new developments at Sociale.

c) Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) information in which you may be interested (e.g., new product offerings, information relevant to you as a Sociale client), subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

d) Communications and IT operations: management of our communications systems; operation of IT security systems; and IT security audits.

e) Financial management: sales; finance; corporate audit; and vendor management

f) Surveys: engaging with you for the purposes of obtaining your views on our Services.

g) Security: electronic security (including login records and access details).

h) Investigations: detecting, investigating and preventing breaches of policy, fraud, and violations of law, in accordance with applicable law.

i) Legal proceedings: establishing, exercising and defending legal rights belonging to you or us.

j) Legal compliance: compliance with our legal and regulatory obligations under applicable law.

k) Improving our App, website and Services: identifying issues we may have with our Services; planning improvements to our Services; and creating new Apps, websites, or Services.

l) Aggregate your information on an anonymous basis with other data for data analytical and reporting purposes.

m) Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

5. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We may share your Personal Data to other entities for legitimate business purposes (including providing services to you and maintaining our App and website), in accordance with applicable law. In addition, we may disclose your Personal Data to:

a) you and, where appropriate, your appointed representatives;

b) legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

c) accountants, auditors, lawyers and other outside professional advisors to Sociale, subject to binding contractual obligations of confidentiality;

d) third party Processors (such as payment services providers; survey partners, marketing outreach providers, cloud service providers, etc.), located anywhere in the world;

e) any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;

f) any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

g) any relevant party if we believe disclosure is necessary and appropriate to prevent physical, financial, or other harm, injury, or loss;

h) any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);

i) any relevant third-party provider, where our Application or sites uses third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with that third-party provider. You should review that third party’s privacy policy before interacting with its advertising, plugins or content;

j) business partners, third party suppliers and our subcontractors (including delivery companies, payment providers and fraud prevention providers) to enable us to provide our Services, operate our websites and app and to detect and prevent fraudulent transactions;

k) analytics and search engine providers that assist us in the improvement and optimization of our website;

l) to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and reducing credit risk;

m) If we engage a third-party Processor to process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law; and

n) Sociale may use Blenet, Ltd dba “Directa24”, ("Directa") to provide certain payment services and to verify your account balance prior to approving a transaction or transfer of funds. Sociale only shares your information with Directa in accordance with this Privacy Policy. Information shared with Directa is treated by Directa in accordance with its Terms and Conditions, https://www.directa24.com/terms.

6. PERSONAL DATA SHARING WITH OTHER SITES AND SERVICES

Merchants you interact with may have their own privacy policies, and Sociale is not responsible for how they conduct their businesses, including, their data privacy practices. Please research and learn about the privacy practices of the third parties you choose to use.

If you authorize others to access your Sociale Account, the information you have provided to Sociale may be shared with them. Unless you provide further authorization, these parties are not allowed to use your information for any reason other than to facilitate your transactions using Sociale Services.

7. OPTING OUT

We will normally send you direct marketing by email if we have your email address, but may choose to contact you via other methods, if you have provided your consent for us to market to you using these methods. If you have provided us with this permission, you can change your mind and tell us not to send any more at any time by changing your account preferences or by selecting the ‘unsubscribe’ option in one of our marketing communications to you.

8. COOKIES

When you visit a Site we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies.

9. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Sociale may store, transfer, and otherwise process your Personal Data in countries outside of the country of your residence, including the United States and possibly other countries.

Sociale is responsible for the processing of Personal Data it receives and subsequently transfers to a third party acting as an agent on its behalf. We will take all reasonable steps to ensure that Personal Data we process is limited to only what is relevant to the purposes for which it was collected and that it is accurate, complete, and up-to-date.

Before Sociale shares your information with any third party, Sociale will enter into a written agreement that the third party provides at least the same level of privacy protection for the Personal Data as required under applicable data protection laws.

10. HOW WE PROTECT AND STORE PERSONAL DATA

Sociale maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of your Personal Data.

Sociale utilizes the highest level of security standards, from HTTPS SSL, encryption-at-rest to password encryption. These measures are intended to prevent the loss, misuse, and alteration of the information that we obtain from you.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, anywhere in the world where our facilities or our service providers are located. We protect your Personal Data by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

You play an important role in protecting your own Personal Data. When registering with our Services, it is important that you not reveal your password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Sociale cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur and we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

11. DATA ACCURACY

We take every reasonable step to ensure that:

a) the Personal Data that we process are accurate and, where necessary, kept up to date; and

b) any of your Personal Data that we process that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

12. DATA RETENTION

We will only retain your Personal Data for as long as we believe necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or audit requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your Personal Data are available by contacting us Support@Sociale.com.

13. YOUR LEGAL RIGHTS

a) a) “Data subject access request”. This enables you to ask for and receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

b) “Corrections”. You may as us to correct any of your Personal Data we hold. We may need to verify the accuracy of the new data you provide to us.

c) “Erasure”. You may ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. If we are unable to erase your data, for some legal reason, we will so notify you.

d) “Objection to processing”. If we process your information based on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you think processing your information impacts on your fundamental rights and freedoms, you may object. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e) “Restrict processing of your Personal Data”. You may ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

f) “Transfer of Personal Data”. At your request, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

g) “Withdrawal of consent”. Where we have relied on your consent to process your Personal Data, you may withdraw that consent, but your withdrawal of consent will not affect the lawfulness of any processing carried out before you withdraw your consent. Obviously, If you withdraw your consent, we may not be able to provide certain products or services to you and we will let you know if that is the case.

If you wish to exercise any of the rights set out above, please contact us at Support@Sociale.com.

14. TERMS OF USE

All use of our mobile Applications, Services or sites is subject to our Terms. Please review our Terms frequently in case they have changed.

15. NOTE REGARDING CHILDREN (UNDER 18 YEARS OF AGE)

Sociale does not knowingly solicit information from individuals under eighteen (18) years of age. We do not knowingly market our products or Services to individuals under eighteen (18) years of age.

16. DIRECT MARKETING

We reserve the right to process your Personal Data so that we may contact you to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

17. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your Personal Data with third parties for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by emailing Support@Sociale.com.

18. ADDITIONAL INFORMATION FOR RESIDENTS OF BRAZIL

Sociale is compliant with Federal Law No. 13,709/2018 - General Data Protection Law of Brazil ("LGPD"). This section provides additional information required by LGPD and is applicable to residents of Brazil. Sociale posts this Brazil-specific addition to its GDPR compliant Privacy Policy and will update it as necessary.

When Sociale acts as data controller with respect to collecting and processing personal data under LGPD, you have the right to make the following requests:

a) The right to confirmation of the existence of processing;

b) the right to access the data;

c) the right to correct incomplete, inaccurate or out-of-date data;

d) the right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD;

e) the right to the portability of data to another service or product provider, by means of an express request;

f) the right to delete personal data processed with the consent of the data subject;

g) the right to information about public and private entities with which the controller has shared data;

h) the right to information about the possibility of denying consent and the consequences of such denial;

i) the right to revoke consent;

To exercise any of these rights, please contact us at Support@Sociale.com. You will need to provide your first name, last name, email address, and country of residence to submit a request. You will also be required to verify your identity before we are able to fulfill your request.

If you are located in Brazil when you visit the Cam4 website or platform, we may transfer your personal data outside of Brazil. When we do, we will ensure that an adequate level of protection is provided for the transfer.

19. CONTACT DETAILS

Sociale is the Controller, for purposes of this Privacy Policy.

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact us at Support@Sociale.com.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and when required by law, we will notify you of changes to this Privacy Policy. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Services prior to the change becoming effective.