Privacy Policy

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, payment information, and social media login data.

Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user. 

We collect personal information that you voluntarily provide to us when registering at the Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps (such as uploading profile photo, updating account profile, creating and joining groups, balance withdrawal, and other activities) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. If you open a Joola account, the personal information we collect can include the following:

• Name and Contact Data. We collect your first and last name, email address, date of birth, social security number, postal address, phone number, and other similar contact data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
• Payment Data. We collect data necessary to process your payment when you create a Joola account, such as your payment instrument number (such as a bank account number), and the security code associated with your payment instrument. All payment data is stored by our payment processor, Dwolla, and you should review its privacy policies. We may request additional documents to verify your identity. 

• Third-party login data. If you register using a third-party account such as Apple or Google, we collect the profile information described in the “How do we handle your social logins” section below.

   

  All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.

We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Information collected through our Apps 

In Short: We may collect information regarding your mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

SMS communications. We may send you transactional SMS messages related to your account, group activity, and payment notifications. You can opt out of non-essential SMS communications by contacting us at [email protected] or texting STOP in response to any message.

Information collected from other sources 

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain limited information about you from public databases, marketing partners, and analytics providers to help improve our services and reach people who may benefit from Joola. We do not purchase or use data from third-party sources for advertising targeting purposes.

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive to:

• provide the services and customer support you request;
• enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent;
• enforce our terms, conditions and policies;
• respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond;
• facilitate account creation and logon process. If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed ” HOW DO WE HANDLE YOUR SOCIAL LOGINS ” for further information;
• create an account connection between your Joola account and a third-party account or platform; 
• process transactions and send notices about your transactions or your group activity;
• resolve disputes, collect fees, and troubleshoot problems; 
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our Terms of Services through the use of our risk and fraud tools which may include use of Account Information, Identification Information, Financial Information, Device Information, Social Web Information and Geolocation Information; 
• customize, personalize, measure, and improve our services and the content and layout of our app; 
• send you updates about services or products that we are offering to customers;
• compare information for accuracy and verify it with third parties; and
• perform other duties as required by law.

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• To process payments on Joola, we need to share some of your personal information with the person or company involved for payment processing purposes. We work with a third party payment processor for payment processing and we share information to enable them to accept and make payments from and to you using Joola.  
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Apps) or otherwise interact with public areas of the Apps, such personal information may be viewed by all users and may be publicly distributed outside the Apps in perpetuity. If you interact with other users of our Apps and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Apps, and view your profile.

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have categorized each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

• Allow Users to Connect to their Third-Party Accounts
  Facebook account and Google account
• Functionality and Infrastructure Optimization – Firebase
• Web and Mobile Analytics – Google Analytics for Firebase
• Website Testing – Google Play Console
• Financial Information – Joola’s third party payment processor – Bank account online login information and bank account and routing numbers. Joola does not share financial information with third party social networking services such as those listed in the prior bullet.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than seven years past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption and authorize access to personal information only for those employees who require it to fulfill their job responsibilities. 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Joola login information with anyone.

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

In Short: You may access, review, change, or delete your personal information, or terminate your account at any time.

Account Information  

If you would at any time like to review, update, or change the information in your account or terminate your account, you can:

■  Log into your account settings and update your user account.

■  Contact us using the contact information provided.

To terminate your account, you must not have any future or pending payments and your account must be in good standing. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

To get in touch with us about any privacy requests, you may contact us at [email protected]

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

■  Note your preferences when you register an account with the site.

■  Access your account settings and update preferences.

■  Contact us using the contact information provided.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), in addition to those provided by the “Shine The Light” law (California Civil Code Section 1798.83).

These rights include:

• The right to know what personal information we collect, use, disclose, and sell
• The right to request deletion of your personal information
• The right to opt out of the sale or sharing of your personal information
• The right to correct inaccurate personal information
• The right to non-discrimination for exercising your privacy rights

Joola does not sell your personal information to third parties.
To submit a California privacy request, contact us at [email protected].

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

Yes. We may update this policy from time to time to reflect changes in our practices or applicable law. The “Last updated” date at the top of this page will reflect the most recent revision. If we make material changes, we will notify you by email or through a notice in the app.

If you have questions or comments about this policy, you may email us at [email protected].