Privacy Policy

Last Updated: March 2019

This Privacy Policy describes how we collect, use, process and disclose your information, including personal information, in conjunction with your access to and use of our Community Platform.

This Privacy Policy applies to Members and Guests who use our Community Platform.

If you see an undefined term in this Privacy Policy (such as “Community Platform”), it has the same definition as in our Community Rules (available on our website www.hellotig.com).

When this policy mentions “Community”, “we”, “us”, or “our”, it refers to our Community or the Member or Guest with whom you are Interacting.

When you use our Community Platform, you may provide information to a Community Partner. If so, that Community Partner is the “Data Controller” of your information in that instance.

When you use our Community Platform, you may Interact with another Member or a Guest, and you may provide information to that Member or Guest. If so, the Member or Guest with whom you Interact at that time is your Data Controller for the purposes of this Privacy Policy.

This Privacy Policy also applies to the contract between Members using the TIG Cash App, which is the Standard Terms (“Standard Terms”). You may be providing information, including personal information, to another Member, and that other Member is the Data Controller of your information in that instance.

If you change your country of residence, your personal information may need to transfer to a Data Controller in your new country of residence. There are three general categories of information we collect. 1 INFORMATION YOU GIVE TO US

1.1 Information that is Necessary for Your Use of Our Community Platform

We may ask for and collect the following personal information about you when you use our Community Platform. This information is necessary under our Community Rules and allows us to comply with our legal obligations. Without it, we may not be able to allow you to access and use our Community Platform.

  • Account Information When you Join our Community, we require certain information such as your country of residence, first name, last name, email address or mobile number, and date of birth.

  • Identity Verification Information To help create and maintain a trusted environment, we may collect identity-verification information (such as images of your government-issued ID, passport, national ID card or driving licence, as permitted by applicable laws) or other authentication information.

  • Communications with Community and Other Members When you use our Community Platform to communicate with other Members, we may collect information about your communication and any information you choose to provide.

1.2 Information You Choose to Give Us

You may choose to provide us with additional personal information in order to obtain a better user experience when using our Community Platform. This additional information will be processed based on your consent.

  • Additional Profile Information You may choose to provide additional information as part of your Community Profile (such as gender, preferred language(s), location and a personal description). Some of this information, as indicated in your profile settings, is part of your public profile page, and will be publicly visible to others.

  • Payment Information To use certain features of the Community Platform you may choose to provide financial information (like your bank account or credit card information) in order to facilitate the processing of payments.

  • Other Information You may otherwise choose to provide us with information when you fill in a form, conduct a search, update or add information to your Community Profile, respond to surveys, post to community forums, participate in promotions, or use other features of our Community Platform.

1.3 Information that is Necessary for Payments

We may need to collect the following information as it is necessary for the adequate performance of our Community Platform and to comply with applicable laws (such as anti money-laundering regulations). Without it, you may not be able to use our Community Platform.

  • Payment Information We may require certain financial information (like your bank account or credit card information) in order for Community Partners to process payments and comply with applicable laws.

  • Identity Verification and Other Information We may require identity verification information (such as images of your government-issued ID, passport, national ID card, driving licence or other authentication information), date of birth, address, email address, phone number and other information in order to verify your identity before we can process payments to comply with applicable laws.

1.4 Information We Automatically Collect from Your Use of Our Community Platform

When you use our Community Platform we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of our Community Rules, and to enable us to comply with legal obligations, and, given our legitimate interest, in being able to provide and improve the functionalities of our Community Platform.

  • Geo-location Information When you use certain features of our Community Platform, we may collect information about your precise or approximate location, as determined through data such as your IP address or your mobile device’s GPS, to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using our Community Platform if this connection is enabled through your settings or device permissions.

  • Usage Information We collect information about your interactions with our Community Platform, such as the pages or content you view, your searches, and other actions on the Community Platform.

  • Log Data and Device Information We automatically collect log data and device information when you access and use our Community Platform. This information includes, amongst other things: details about how you’ve used our Community Platform (including if you’ve clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Community Platform.

  • Cookies and Similar Technologies We use cookies and other similar technologies, such as web beacons, pixels and mobile identifiers. We may also allow our Community Partners to use these tracking technologies on our Community Platform, or engage others to track your behaviour on our behalf. While you may disable the usage of cookies through your browser settings, our Community Platform currently may not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application, due to a lack of standardisation regarding how that signal should be interpreted.

  • Payment Transaction Information We collect information related to your payment transactions through the Community Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of our Community Rules.

1.5 Information We Collect from Third Parties

We may collect information, including personal information that others provide about you when they use our Community Platform, or obtain information from other sources and combine that with information we collect through our Community Platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • Third-Party Services If you link, connect or login to our Community Platform with a third-party service (e.g., Google, Facebook, WeChat), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.

  • Background Information To the extent permitted by applicable laws, and with your consent where required, we may obtain the local version of police checks, background checks, registered sex-offender checks, sanctions and politically-exposed person checks. We may use your information, including your full name and date of birth, to obtain such reports.

  • Other Sources To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers (like identity verification services) for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off our Community Platform through partnerships, or about your experiences and interactions from our partner ad networks.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, improve and develop our Community Platform, to create and maintain a trusted and safer environment on our Community Platform, and to provide, personalise, measure and improve our advertising and marketing and to comply with our legal obligations.

2.1 Provide, Improve and Develop Our Community Platform

1. We use, store, and process information, including personal information, about you to provide, improve, and develop our Community Platform, to: 2.

  • Enable you to access and use our Community Platform.

  • Enable you to communicate with other Members and Guests.

  • Enable you to Interact with Community Partners.

  • Enable you to see the number of Digital Currencies you have in a digital wallet on the blockchain.

  • Enable you to send or receive Digital Currencies using a Transfer.

  • Operate, protect, improve, and optimise our Community Platform and experience such as by performing analytics and conducting research.

  • Provide customer service.

  • Send you service or support messages, updates, security alerts, and account notifications.

  • Operate, protect, improve, and optimise our Community Platform and experience, and personalise and customise your experience. To do this we conduct profiling based on your interactions with our Community Platform, your search and booking history, your profile information and preferences, and other content you submit to our Community Platform.

We process this information, given our legitimate interest in improving our Community Platform and our Members’ experience with it, where necessary for the adequate performance of our Community Rules.

2.2 Create and Maintain a Trusted and Safer Environment on Our Community Platform

To create and maintain a trusted and safer environment on our Community Platform, we take the following actions:

  • Detect and prevent spam, abuse, security incidents, and other harmful activity.

  • Detect suspicious transactions which may be fraud, money-laundering, and terrorist financing.

  • Conduct security investigations and risk assessments.

  • Verify or authenticate information or identifications provided by you.

  • Conduct checks against databases and other information sources, including background checks, police checks, sanctions, and politically-exposed person checks, to the extent permitted by applicable laws and with your consent where required.

  • Comply with our legal obligations.

  • Resolve disputes between Members and Guests and enforce our agreements with third parties.

  • Enforce our Community Rules and Policies. In connection with the activities above, we may conduct profiling based on your interactions with our Community Platform, your profile information and other content you submit to our Community Platform, and information obtained from third parties.

In limited cases, automated processes may restrict or suspend access to our Community Platform if such processes detect a Member or Guest or activity that we think poses a safety, or other, risk to the Community Platform, other Members, or Guests, or third parties.

We process this information, given our legitimate interest in protecting our Community Platform, to measure the adequate performance of our Community Rules, and to comply with applicable laws.

2.3 Provide, Personalise, Measure and Improve our Advertising and Marketing

To provide, personalise, measure, and improve our advertising and marketing, we will:

  • Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Community or Community Partner campaigns and services), and social media advertising through social media platforms such as Facebook or Google.

  • Personalise, measure, and improve our advertising.

  • Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our Community Platform, information obtained from third parties, and your search and interaction history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your personal information for the purposes listed in this section, given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest. You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Community Profile.

2.4 How we use Payment Information we Collect

We use the payment information we collect to:

  • Enable you to make and receive payments.

  • Detect and prevent abuse, security incidents and other harmful activity.

  • Detect suspicious transactions which may be fraud, money-laundering and terrorist financing.

  • Conduct security investigations and risk assessments.

  • Conduct checks against databases and other information sources.

  • Comply with legal obligations (such as anti money-laundering and counter-terrorist financing regulations).

  • Enforce our Community Rules.

  • Send you, with your consent, promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences.

We don’t share your billing and payment information with other Community Members. Local Partners and Corporate Partners will see your billing and payment information, but only to the extent necessary for them to perform the services, you ask of them.

We process this information, given our legitimate interest in improving our services and your experience, where necessary for the adequate performance of our Community Rules and to comply with applicable laws. 3. SHARING AND DISCLOSURE

3.1 With Your Consent

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorise a Community Partner to access your Community information, including when you participate in promotional activities conducted by a Community Partner or third parties.

3.2 Sharing Between Members

To help facilitate interactions between Members, we may need to share certain information, including personal information, with other Members as it is necessary for the operation of our Community Platform and the adequate performance of our Community Rules.

3.3 Profiles, Listings, and other Public Information

The Community Platform lets you publish information, including personal information, which is visible to the general public. For example:

  • Parts of your public profile page, such as your first name, description, and city, which are publicly visible to others.

  • Community Partner information is publicly visible and includes information such as their approximate location (country, neighbourhood or city) or precise location (where you have provided your consent),

  • Content in a community or discussion forum, blog or social media post, or similar features on our Community Platform – this content is publicly visible.

Based on our legitimate interest to promote our Community Platform we may display parts of our Community Platform on sites operated by Community Partners using technologies such as widgets or APIs. If you are featured on a Community Partner’s site, only information from your public profile page may be displayed.

Information you share publicly on our Community Platform may be indexed through third-party search engines. In some cases, you may opt out of this feature in your profile settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practises of third-party search engines, and they may use caches containing your outdated information.

3.4 Additional Services used by Community Partners

Community Partners may need to use third-party services to assist with managing their Interactions with Members or providing additional services requested by you.

3.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights

We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorised third parties, if, and to the extent we are required or permitted to do so by law, such disclosure is reasonably necessary to: (i) comply with our legal obligations; (ii) comply with legal process and respond to claims asserted against our Community; (iii) respond to verified requests relating to a criminal investigation, or alleged or suspected illegal activity, or any other activity that may expose us, Members, Guests, Community Partners or any other of our users to legal liability; (iv) enforce and administer our Community Rules, or the Standard Terms; or (v) protect the rights, property or personal safety of our Community, its Members, Guests, Community Partners or members of the public.

Where appropriate, we may notify Members or Guests about legal requests unless: (i) providing notice is prohibited by the legal process itself, by the court order we receive, or by applicable law; or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud against our Community, Members, Guests, Community Partners or our Community Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member or Guest about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.6 Community Partners and Third-Party Service Providers

Our Community relies on Community Partners and third-party service providers to provide services related to our Community Platform. Service providers may be located in your country of residence, and they may not be. They may be inside or outside of the European Economic Area (“EEA”).

For example, Community Partners and third-party service providers may: (i) verify your identity or authenticate your identification documents; (ii) check information against public databases; (iii) conduct background or police checks, fraud prevention and risk assessment; (iv) perform product development, maintenance and debugging; (v) allow the provision of our Community Platform through third-party platforms and software tools (e.g., through the integration with our APIs); or (vi) provide customer service, advertising or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed, and consistent with this Privacy Policy.

We will need to share your information, including personal information, in order to ensure the adequate performance of our Community Rules.

3.7 Social Media Platforms

Where permissible, according to applicable law, we may use certain limited personal information about you, such as your email address or mobile number, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our Community. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be in your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time, ask the Community to cease processing your data for these direct marketing purposes by contacting us directly.

3.8 Collection and Remittance of Taxes

In jurisdictions where we facilitate the collection and remittance of Taxes, as described in the “Taxes” section of our Community Rules, where legally permissible according to applicable law, you expressly grant us permission, without further notice, to provide your data and other information to the relevant tax authority, including, but not limited to, your name, addresses, transaction dates and amounts.

3.9 Government Registration

In jurisdictions where we facilitate an application for a registration, notification, permit, or licence of a Community Partner with a local governmental authority through our Community Platform, in the event that one is required in accordance with local law, we may share information of Members and Guests with the relevant authority, both during the application process and, if applicable, periodically thereafter, such as the Members and Guests full name and contact details, address, tax identification number, transaction details, and interactions with our Community Platform.

3.10 Business Transfers

If our Community undertakes or is involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our Community’s assets, including your information, in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.11 Aggregated Data

We may also share aggregated information about our Community and its Membership overall (that is, information about our Members and Guests that we combine together so that it no longer identifies or references an individual Member or Guest) and other anonymised information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes. 4. OTHER IMPORTANT INFORMATION

4.1 Analysing your Interactions

We may review, scan, or analyse your interactions on our Community Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. In some cases, we may also scan, review, or analyse your interactions to debug, improve, and expand product offerings of our Community. We use automated methods where reasonably possible, however, occasionally we may need to manually review some interactions, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan or analyse your interactions to send third-party marketing messages to you, and we will not sell reviews or analyses of these interactions.

These activities are carried out based on our Community's legitimate interest in ensuring compliance with applicable laws and our Community Rules, preventing fraud, promoting safety and improving and ensuring the adequate performance of our Community Platform.

4.2 Google Maps and Google Earth

Parts of the Community Platform use Google Maps and Google Earth services, including the Google Maps API(s). Use of Google Maps and Google Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy. 5. THIRD-PARTY PARTNERS AND INTEGRATIONS

Our Community Platform may contain links to third-party websites or services, such as third-party integrations, co-branded services, or third party-branded services of our Community Partners or other third parties (“Third-Party Partners”). Our Community doesn’t own or control these Third-Party Partners, and when you interact with them you may be providing information directly to the Third-Party Partner. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit. 6. YOUR RIGHTS

You may exercise any of the rights described in this section by contacting us directly. Please note that we may ask you to verify your identity before taking further action on your request.

6.1 Managing Your Information

You may access and update some of your information through your Community Profile settings. If you have chosen to connect your Community Profile to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Community Profile).

6.3 Data Access and Portability

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly-used, and machine-readable format, and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure

We generally retain your personal information for as long as is necessary for the performance of our Community Rules, and to comply with our legal obligations. If you no longer want us to use your information to provide our Community Platform to you, you can request that we erase your personal information and cease to be a Member. Please note that if you request the erasure of your personal information, we may:

  • Retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention, and enhancing safety.

  • Retain and use your personal information to the extent necessary to comply with our legal obligations.

  • Because we maintain our Community Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing

Where you have provided your consent to the processing of your personal information by us, you may withdraw your consent at any time by changing your Profile settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where: (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and, pending the verification, whether the legitimate grounds of our Community override your own.

6.6 Objection to Processing

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time, ask the Community to cease processing your data for these direct marketing purposes by contacting us directly.

6.7 Lodging Complaints

You have the right to lodge complaints about the data-processing activities carried out by us before the competent data-protection authorities in your jurisdiction. 7. GLOBAL COMMUNITY

To facilitate a global Community we may transfer, store and process your information within our Community Partners or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the EEA may be transferred, stored and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer, store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

7.1 EU-US and Swiss-US Privacy Shield

We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

Under the Privacy Shield Framework, certain data may become subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to the EU-US Privacy Shield certification, contact us directly. If we are not able to resolve your concern, you may also contact or seek assistance from the designated Privacy Shield independent recourse mechanism, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third-party service provider for processing as described in this Privacy Policy, we will remain responsible if these providers process your personal information in a manner inconsistent with the Privacy Shield Principles, except where we can establish that we were not responsible for the violation.

7.2 Other Means to Ensure an Adequate Level of Data Protection

If your Data Controller is in the EEA and your information is shared with Community Partners, corporate affiliates or third-party service providers outside the EEA, we have (prior to sharing your information with such corporate affiliate or third-party service provider) established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country, or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection on request.

7.3 California and Vermont Residents

We will not share information we collect about you with Community Partners, corporate affiliates, or third parties (both financial and non-financial) except as required or permitted by law in the States of California or Vermont in the United States.

7.4 California Privacy Rights

California law may permit Members and Guests who are Californian residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. Please contact us directly with any such requests. We do not share personal information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal information to third parties for their direct marketing purposes by withholding consent.8. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your personal information has been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorised use of your Membership, please contact us immediately.9. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Community Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Membership. If you do not cancel your Membership before the date the revised Privacy Policy becomes effective, your continued access to or use of our Community Platform will be subject to the revised Privacy Policy.10. CONTACT US

If you wish to contact us directly, or you have any questions or complaints about this Privacy Policy or our information-handling practices, please use any of the contact details which are provided on our website.