Bitmo terms, conditions and privacy policy

Last updated June 24, 2016

Bitmo is fully owned subsidiary of MobilePop Inc, and as such, respects your privacy. We are publishing this version of the Bitmo Privacy, Terms of Use, and Regulatory Disclosures Policy (the “Policy”) to clearly disclose our practices and approach to our policies, data privacy and data protection with respect to any of our Services created or distributed by Bitmo, including the BitmoTM mobile wallet app, and with respect to the Bitmo website.

This Policy describes how we collect, use, transfer, and safeguard information about you and your options regarding accessing or modifying such information. The Policy applies when you:

  • Agree to the Bitmo Terms and Conditions;
  • Visit or utilize a BitmoTM website on which this Policy is posted;
  • Download any Bitmo Service (such as the Bitmo Payment WalletTM) to your mobile device;
  • Create a BitmoTM Account through the BitmoTM mobile app, or any other account for a Bitmo Service;
  • Use any Bitmo Service to conduct a Payment Account transaction, carry out any Bitmo Merchant Loyalty/Rewards Account program function (such as point accrual or reward redemption) using a Bitmo Service, or to opt-in, review or redeem any advertisements or offers through a Bitmo Service

In this Policy we use the terms “personal information” and “personally identifiable information” or “PII” to describe information that can be associated with an individual and can be used to identify that individual. We do not consider personal information or PII to include information that has been anonymized or aggregated so that it does not identify an individual. You represent that if you give us PII on behalf of someone else, the person providing the PII to you gave you consent to provide their individual information to Bitmo. If someone else gives us PII on your behalf, you represent that you gave that person consent to provide your PII to Bitmo.

If you have any questions about this Policy, please submit questions by sending via mail to: privacy@Bitmo.com.

Or by writing to us directly at:

Privacy Officer
Bitmo, a MobilePop Inc. Company
5411 Avenida Encinas Suite 255
Carlsbad, CA 92008
USA

Definitions

In this Policy, the following definitions apply:

“BitmoTM” means the Bitmo standalone mobile wallet app or any payment functionality Bitmo provides in any separate Bitmo Merchant app.

“BitmoTM Account” means the account you create by registering your mobile device to use the Services through either the Bitmo standalone BitmoTM app or any separate Bitmo Merchant app using BitmoTM.

“Feedback” means all feedback, suggestions, and ideas you provide to Bitmo concerning improvements or enhancements to the Services. “Feedback” may also include your responses to surveys or reporting problems.

“Loyalty/Rewards Account” means a loyalty/rewards account you have with a participating Bitmo Merchant that you choose to load into your BitmoTM Account that will be used in conjunction with all of your purchase of goods and services at that participating Bitmo Merchant unless and until you remove that Bitmo Merchant’s Loyalty/Rewards Account from BitmoTM.

“Bitmo Merchant” means a merchant that participates in the Bitmo Network.

“Bitmo Network” means the mobile payments network developed and managed by Bitmo, which includes BitmoTM and any other product or Service created, developed or facilitated by Bitmo.

“Payment Account” means the payment type or account you load into your BitmoTM Account to pay for goods and services at participating Bitmo Merchants.

“Personal Information” or “Personally Identifiable Information” (or “PII”) means information that can be associated with an individual and can be used to identify that individual, and may include Feedback, User Generated Data or any other PII necessary to participate in the Services.

“Services” means the off-line, online or mobile products or services offered by Bitmo.

“Third-Party Provider” means a third-party service provider retained by Bitmo whose products, services or support may be used to provide the Services, including Payment Account issuers.

“User Generated Data” means any information generated by your use of the Services, including automatic reporting and other tools that give you the ability to create, post and distribute various forms of content for, and in connection with, the Services, including, but not limited to: payment transaction data; pictures; photographs; videos; and other information, including content generated by you. For pictures, photographs and videos, the User Generated Data includes only those pictures, photographs and videos that you take through BitmoTM, and does not include those pictures, photographs and videos you take via the standard functions on your mobile device, or that you take through any other app not related to Bitmo.

How We Collect Information

Bitmo collects information from you regarding your use of the Services in the following ways:

Bitmo will collect information from you, including PII, when you interact with the Services. For example, you provide information to Bitmo when you:

  • Register for BitmoTM, or update registration information or other of your BitmoTM information;
  • Add a Payment Account to BitmoTM;
  • Initiate or complete a Payment Account transaction, a Loyalty/Rewards Account transaction or redeem an offer using the Services (including the location information of the physical point-of-sale terminal where such Payment Account transaction or Loyalty/Rewards Account transaction occurs for Bitmo’s operational uses, such as transaction record information and fraud detection/prevention);
  • Opt-in to receive advertising or offers or other marketing communications as part of the Services;
  • Interact with any advertising or offers in the Services;
  • Request a coupon or other offer;
  • Complete a survey related to the Services; or
  • Receive customer support.In addition, Bitmo may collect other information through the Services. For example, Bitmo collects data through use of technologies such as:
  • If you opt-in to location-based services, location detection technology, such as GPS signals, sent by your mobile device (**Please note that failure to opt-in for location-based services using your mobile device may reduce or eliminate some of the BitmoTM features or other Services available to you);
  • Device identifiers (such as unique device identifiers or device fingerprint);
  • Data analytics (such as analyzing anonymized and aggregated data generated by the Services);
  • Services analytics (such as diagnostics to improve the functionality of the Services); or
  • Point-of-sale terminal physical location for advertising and marketing Services that you opt-in to receive.

Bitmo sometimes obtains PII from other sources, such as through mergers and acquisitions with other companies, as well as through commercial arrangements with Third-Party Providers, business partners, and other sources. Information Bitmo receives from a third party is subject to your separate agreement with such third party, unless you enter into a separate agreement with Bitmo or otherwise give Bitmo your permission to use such information. Bitmo may merge information Bitmo receives from third parties with information Bitmo has collected or will collect subject to such limitations.

Some elements of Bitmo’s Services such as events, websites, apps and offers may be co-branded and offered in conjunction with a Bitmo Merchant. For example, Bitmo may provide the Services through a Bitmo Merchant via the Merchant’s own branded app. If you provide information in these instances, both Bitmo and the Bitmo Merchant involved in the transaction may receive information from that transaction and may use the information according to each entity’s privacy policy and any other agreement each Bitmo Merchant may separately have with you.

Information We Collect

Information that Bitmo Actively Collects From You

You must provide Bitmo with the following information in order to use the Services if requested:

  • Your name, physical address, email address, and mobile device number;
  • Payment transaction data and details for payments made for goods and services at participating Bitmo Merchants;
  • Payment Account data you choose to enter into BitmoTM, as well as information needed to complete Payment Account transactions. Payment Account data may include your bank account information, credit or debit account or gift card or stored value account details, related security codes or other payment credentials;
  • Additional PII required for authentication of Payment Accounts you choose to enter into BitmoTM, such as driver’s license number, Social Security number, date of birth, or answers to challenge and response questions used to authenticate your identity. **Please note driver’s license number, Social Security number, date of birth and challenge and response question information is only used for authentication by Bitmo’s authentication Third-Party Provider or by a Payment Account issuer where you instruct Bitmo to load your Payment Account with the Issuer into your BitmoTM Account. Such information is not retained by Bitmo, is not used for marketing purposes by Bitmo or any of its Third-Party Providers, and is not shared with or disclosed to any other unaffiliated third parties. If you would like to access the privacy policy for Bitmo’s authentication Third-Party Provider, please contact Bitmo Customer Care at 1-866-866-1492, or by submitting an email to: info@Bitmo.com.
  • Loyalty/Rewards Account IDs or account numbers;
  • Interest in and use of advertising, marketing and offers in conjunction with use of BitmoTM;
  • Responses to survey questions regarding the Services (if you participate in surveys, Bitmo will collect the information you provide to Bitmo, which may include PII);
  • Your user preferences, product and Services interests, communication choices, and other user profile information, including Feedback and User Generated Data; and
  • Your protected health information, claims or other information used to measure your health or wellness if such information is included in your Payment Account transactions. **Please note that while direct protected health information is not normally required for a Payment Account transaction, some protected health information, such as the number of prescriptions you purchase each month, or the location of the pharmacy or store where you purchase prescriptions, may be included in information generated in conjunction with a Payment Account transaction.

General Information Automatically Collected by Bitmo When You Use the Services

Bitmo uses location detection technology to determine your approximate location, nearby Wi-Fi access points, and cell towers. When you use the Services, Bitmo automatically collects and stores certain information in activity logs such as details of how you used the Services.

Special information is automatically collected for certain of the Services. For example, if you use the Services in connection with a mobile device or mobile application, Bitmo will automatically collect additional information about you, your use of your device, and the Services on your device such as:

  • Mobile device settings and operating information (such as system and version; screen resolution; services version (e.g. 1.0, 2.0, etc.); and device type, identifiers or capabilities);
  • System activity;
  • Hardware settings;
  • Total amount of time spent in the Services;
  • User creation time; or
  • Length of Services session.Information That Is Unique Information Generated By Your Use Of The ServicesBitmo also collects certain types of unique information generated by your use of the Services such as:
  • Application identifiers;
  • Session ID and User ID in connection with use of BitmoTM Account;
  • Information, including usage information, such as frequency of use or average number of minutes for use, generated through use of the BitmoTM Account;
  • Date and time;
  • Location of purchases to complete a Payment Account transaction;
  • Internet Protocol (IP) address;
  • Other transaction data such as amount of purchase, store name or register number;
  • If you opt-in for certain location-based advertising and marketing Services, your location to provide location-based marketing, advertising or other Services (for example, such information will be used to “recognize” you within a store or specific geographic location to serve up relevant ads and offers, or in conjunction with a Bitmo Merchant’s loyalty/rewards program or customer appreciation activities);
  • If you opt-in for other location-based services, location information necessary to provide such Services (for example, store locators and directions);
  • If you opt-in for Services involving advertising or offers, transaction data for marketing purposes that is used to generate relevant advertising and offers, which may be used in conjunction with such advertising or offers; or
  • If you opt-in and register your Loyalty/Rewards Accounts with a participating Bitmo Merchant, information necessary for you to participate in such loyalty/rewards program. **Please note that Bitmo will automatically transmit information regarding any loyalty/rewards benefits based upon the rules of the specific Bitmo Merchant’s loyalty/rewards program. Information about these loyalty/rewards is shared only with the Bitmo Merchant or issuer owning or operating the loyalty/rewards program. Use of your information is governed by the Bitmo Merchant or issuer owning or operating the loyalty/rewards program; refer to their terms and conditions governing use of your information.

How We Use Information We Collect

We use information we collect to: conduct business and improve the effectiveness of Bitmo Services; develop new products and Services; provide information and support for the Services; conduct research and analysis, including focus groups and surveys; better understand your needs and interests; personalize communications and advertising/offers; promote a quality experience for users of Services; and to perform other business activities related to the Services as needed or as otherwise described in this Policy.

For example, we will use your information to:

  • Create and maintain your BitmoTM Account(s);
  • Communicate, interact and build the Bitmo relationship with you;
  • Gather transaction statistics relating to your use of BitmoTM in order to collect information to measure, analyze and improve the Services;
  • Manage dispute resolution and perform customer service activities;
  • Customize the content, products, and features (including marketing offers that you opt-in to receive) that are offered to you in the Services;
  • Process, fulfill, and follow up on transactions and requests for products, services, support, and information via the Services;
  • Engage in market research and analysis;
  • Comply with legal requirements;
  • Enforce our agreements; and
  • Deter, detect, and prevent fraud and other prohibited or illegal activities.

How We Share and Disclose Information

Bitmo may share or disclose your information as follows:

  • To Bitmo Merchants based on your purchase of goods and services from that Bitmo Merchant, or participation in that Bitmo Merchant’s loyalty/rewards program;
  • To Third-Party Providers involved in providing the Services;
  • To Third-Party Providers using your information on Bitmo’s behalf in connection with opening a BitmoTM Account;
  • To Third-Party Providers using your information on Bitmo’s behalf in connection with loading a Payment Account into BitmoTM;
  • To Third-Party Providers using your information on Bitmo’s behalf in connection with a potential or actual Payment Account transaction;
  • To Third-Party Providers or Bitmo Merchants using your information on Bitmo’s behalf in connection with loading of and use of a Loyalty/Rewards Account in BitmoTM;
  • To Third-Party Providers using your information to evaluate and enhance the performance of the Services;
  • Based on Bitmo’s sole discretion that such disclosure is necessary to protect the rights or safety of any person or entity; or
  • Based on Bitmo’s sole discretion that disclosure is necessary to detect or respond to instances of potential or actual fraud or other illegal activities, to respond to a law enforcement agency’s request for information or cooperation in an investigation, or to respond to judicial process or other valid government investigation or process.

Cookies and “Do Not Track”

Bitmo does not track your activities on other mobile apps. Bitmo does not allow Third-Party Providers or other third parties that we have agreements with to track your activities across different mobile apps when you use BitmoTM. Bitmo may share information with software companies that power your mobile device, app stores and companies that provide common tools and information for apps about consumers.

Bitmo Websites

When you use the Bitmo websites (Bitmo.com>, we will place a “cookie” on your web browser. A cookie is a very small text file that is sent to a customer’s browser from a web server and stored on the customer’s computer hard drive. It assigns the computer a unique identifier. The cookie stores information on your hard drive so we can communicate with you more efficiently, respond to you based on prior sessions at which you provided information about you or your preferences to us and understand what you prefer to view on our website. We do not use cookies to store passwords or Payment Account information. Cookies do not tell us your individual identity unless you have chosen to provide it to us.

Your browser may be set to allow you to be notified when a cookie is to be placed on your browser, decline the cookie or delete cookies that have been placed on your browser. For general information regarding opt-out, you can visit the Networking Advertising Initiative (NAI) at http://www.networkadvertising.org/. You can also find specific information regarding opting out of interest-based advertising that uses web browser and cookie information at this specific NAI webpage: http://www.networkadvertising.org/choices/. You may also check your web browser’s instructions. Some functions of our website may not work or may work slowly if a cookie is refused.

Our website uses third party service providers to serve and host our advertisements. These third parties may place cookies on your computer if you click on or access the advertising. The third party cookies are used to track whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain PII. We do not control these cookies and they may not follow the rules we have set for our own cookies.

We also use invisible pixels, sometimes called web beacons, on our website to count how many people visit certain web pages and to collect other website usage information. Information collected from invisible pixels is used and reported in the aggregate without the use of a customer’s Personally Identifiable Information.

Children’s Privacy

Use of our Services is only available to individuals who are of legal age to contract in their applicable state of residence. Bitmo’s Services are not directed to children under 13 years of age. If that policy changes, we will obtain consent from a parent or guardian before we knowingly collect data from anyone under the age of 13.

Enforcement of this Policy

Bitmo regularly reviews its compliance with this Policy. Please submit any questions or concerns regarding this Policy or Bitmo’s treatment of PII, by submitting via mail to: privacy@Bitmo.com.

Or by writing to us directly at:

Privacy Officer
Bitmo, a MobilePop Inc. Company
5411 Avenida Encinas Suite 255
Carlsbad, CA 92008
USA

Changes to this Policy

Please note that this Policy may change from time to time. We will post any Policy changes on this screen and, if the changes are significant or reduce your rights in any material manner, we will provide a more prominent notice.

Our Commitment to Security

We have put in place appropriate administrative, technical, and physical safeguards to help prevent unauthorized access, maintain data security and correctly use the information we collect. No system can be completely secure, however, and we do not guarantee that unauthorized disclosures and access will not happen.

If you have any additional questions about your information, you can contact us with your current contact information and questions by submitting via mail to: info@Bitmo.com.

Or by writing to us directly at:

Privacy Officer
Bitmo, a MobilePop Inc. Company
5411 Avenida Encinas Suite 255
Carlsbad, CA 92008
USA

We will provide you the personal information requested if reasonably available, or will describe the types of personal information we typically collect. We will make reasonable efforts to respond to your question as soon as possible.

Before we provide access to any data, including PII, or make any changes to it we will ask you to verify your identity or provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. We may keep a copy of information for our records. Your right to review, update, correct, and delete your PII may be limited, subject to the law of your jurisdiction of residence: (i) if your requests are abusive or unreasonably excessive, (ii) where the rights or safety of another person or persons would be encroached upon, or (iii) if the information or material you request relates to existing or anticipated legal proceedings between you and us, or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity. Your right to review, update, correct and delete your information is also subject to our records retention policies and applicable law, including any statutory retention requirements.

Additional Financial Disclosures

All funds held within Bitmo in coordination with SynapsePay partner Triumph Bank. Each depositor is FDIC insured up to at least $250,000.

Financial Services are provided by Triumph Bank, SynapsePay’s Bank Partner. To report complaints email issues@synapsepay.com.

By entering into this agreement, you agree to the Terms of Service of SynapsePay (our banking software provider) which are incorporated herein by reference.