Privacy Policy

Last Updated:Thursday, June 1st 2017

Privacy is of utmost importance at Moolre Limited (“Moolre”). We recognize the significance of protecting information which is stored on our computers or is intended to be stored on our computers and which relates to an individual. The data we protect are the “Personal Data” which is any information relating to an identified or identifiable natural person, sometimes called a data subject, and have made protecting privacy and the confidentiality of Personal Data a fundamental component of the way we do business. This Privacy Policy informs you of the ways we ensure privacy and the confidentiality of Personal Data. We are compliant with applicable privacy laws in the countries in which we operate. This policy describes the information we gather, how we may use those Personal Data and the circumstances under which we may disclose such information to third parties.

1. INFORMATION WE COLLECT

1.1. When you create a Moolre account, we'll collect some important details about you such as your name, address, phone number, email, birth date, password, etc.
1.2. If you want to link a debit card, credit card or bank account or other payment method, we'll need to collect the card number or account/routing numbers and related account information. As Moolre adds additional features, you may also be prompted to provide additional information.
1.3. Sometimes we need to request more information to verify your identity or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.
1.4. In the event that Moolre integrates with other platforms, you may be prompted from time to time to grant Moolre access to additional information from such platform (or grant such partner platform access to information you have provided to Moolre). For example, if Moolre implements an integration with a social media platform, you would have the option of linking your account on that platform to Moolre in order to streamline the signup process, populate your contact list or other specified purposes.
1.5. When you access or use the Moolre site or Services, we may collect some information, including:

  • Device Information. We collect information about your device, including the type of device (Computer vs. iPhone vs. Android), operating system, mobile phone number, browser type and language, and device identifiers (such as IMEI and MAC address).
  • Location Information. With your permission, we collect your device location so that we can offer you location-based features such as the ability to send funds to nearby Moolre users.
  • Contacts. To make it easier to send money to your contacts, we will - with your permission - collect information from your phone's address book or other contact lists that you grant us access to (for example, your Facebook friends list).
  • Photos, Videos & Other Media. If you want to attach photos, videos or other media to your payments, payment requests or other communication using Moolre, we require access to the photos on your phone. Any photos, videos or other media you attached will be stored and accessible to Moolre, but we will never download or store any photos, videos or other media from your phone that aren't attached to payments, payment requests or other communications using Moolre.
  • Message Content. If you include a message with your payments, the content of that message is stored and accessible to Moolre.
  • Transactions. We collect information about your payment activity such as the amount, date, time, recipient for each transaction.
  • Cookies: Like most mobile apps and websites, we use cookies . Cookies are small data files that we place on your device that allow us to identify you as a Moolre user and provide a customized Moolre experience. We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Longer lasting cookies, known as persistent cookies, remain on your browser until you erase them or they expire. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of Moolre. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.

2. PROTECTING YOUR INFORMATION

2.1. Throughout this policy, we use the term "personal information" to describe information that is associated with you or can be used to identify you. We do not consider personal information to include information that has been anonymized.
2.2. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Sometimes in order to better secure your information and use it for the purposes contemplated by this Privacy Policy, certain personal data may be stored with our third-party partners and service providers. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations.

3. HOW WE USE YOUR INFORMATION

3.1. We collect all of this information so that we can provide you with a safe and seamless way to make and receive payments. The information we collect allows us to:

  • Deliver the full range of payments and functionality of the Moolre product
  • Keep in touch with you - whether it be for providing customer service, notifying you of cool new features that have been added to the mobile apps, or providing security notices or information
  • Verify your identity so that we can prevent fraud or unauthorized activity
  • Improve Moolre or add new product features by analyzing usage trends
  • Personalize the Moolre experience by matching product features to things that we think you specifically might be interested in
  • Fulfill any other purpose for which the information was collected.
  • Deliver the full range of payments and functionality of the Moolre product
  • Keep in touch with you - whether it be for providing customer service, notifying you of cool new features that have been added to the mobile apps, or providing security notices or information
  • Verify your identity so that we can prevent fraud or unauthorized activity
  • Improve Moolre or add new product features by analyzing usage trends
  • Personalize the Moolre experience by matching product features to things that we think you specifically might be interested in
  • Fulfill any other purpose for which the information was collected.

    3.2. We will never sell or rent your personal information to third parties . We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

    4. HOW WE SHARE YOUR INFORMATION

    4.1. In order to provide you with the Moolre product and meet our legal and regulatory obligations, we may share the information we collect as detailed below:
    Sharing with Third Parties:

    • If you link a debit card, credit card, bank account other payment method, we will share your account information with our banking partners so that we can process payments.
    • In order to prevent fraud, we will sometimes need to share your information with third party identity verification services. This lets us make sure you are who you say you are, by comparing the information you provide us to public records and other third-party databases.
    • In order to improve Moolre's functionality, we will sometimes share information with service providers that help us analyze how people are using the app. This allows us to refine popular features and improve or eliminate features people don't use.
    • As a regulated financial institution, we may need to share your information with law enforcement or government officials. We will only do this when we are compelled to do so by a specific regulation, subpoena, court order or formal request, or we otherwise believe in good faith that we need to share such information to prevent physical harm, financial loss, or are obligated to report illegal activity.
    • From time to time Moolre may partner with other companies ("Partners") to allow you to send and receive money with individuals that are customers of such Partners and not Moolre. In order to complete these transactions, we will need to share information regarding your account (such as name, email address, phone number and date of birth) with the applicable Partner so they can meet their legal and regulatory obligations. Your information will only be shared with such Partners to the extent you actually transact or interact with customers of such Partner.
    • In order to complete third party financial, technical and legal audits of Moolre’s operations, we may need to share information about your wallet as part of such review.
    • If Moolre merges with or gets acquired by another Company, they will have access to the information you have provided to us. If this happens, we will require that the new entity follows this Privacy Policy and will notify you of any such change.
    • We will share your information with other third parties if you specifically authorize us to do so.
    Sharing with Third Parties:
    • Transaction Details. At the risk of stating the obvious, when you send someone a payment or payment request, they will be provided with the details of that transaction, including the payment amount, currency, date, time and a unique transaction ID number.
    • Messages & Photos. If you attach a message or photo, video or other media to a payment, payment request or other communication using Moolre, that information will be visible to the person(s) receiving the payment. You should know that the recipient of a message or photo (or other media) can always save them - so don't send anything you wouldn't want shared publicly.
    • Your Identity & Photo. In order for other Moolre users to transact with you (sending money, receiving money, requesting money, etc.) they will be able to see your full legal name. If you upload a profile photo or avatar to your account, this will also be visible to other Moolre users. If Moolre adds additional features that allow you to share more identity information, further information may be shared if you opt in to such features.
    • Location. If you have your location enabled in your settings, the location from which a payment was initiated may be visible to the recipient.
    • Status as a Moolre User. Other Moolre users may be able to see that you have a Moolre account. This lets them know they can send you a payment and you will receive it instantly without having to first set up a Moolre account.
    • Sharing of Transactions. In the future, Moolre may give users the ability to share certain payment information through group payments, a public feed, social media integration or other means. The information may include sender, recipient, date and time of transaction, avatars, location, media or other information regarding the transaction. If this feature is enabled, you will be able to determine how much information is shared in your account settings or opt out of sharing information by not using such features.
    • Other Information. As we add new product features, there may be additional information that is shared with other Moolre users. If those new features require sharing any personal information, we'll always get your permission first and will do our best to allow you to disable such features in your account settings. We'll also provide information to other Moolre users if you specifically request that we share such information.

    5. HOW TO CHANGE OR DELETE YOUR INFORMATION

    5.1. If you need to add or change any information, you can just log in to your Moolre account and make the change in your settings. If it doesn't look like you can make the change on your own, just reach out to us and we'll take care of it.
    5.2. If you want to know what information we're keeping on you, check out the categories listed above. We can also provide you with a copy of this information, but we won't include any sensitive financial information.
    5.3. If you want to close your Moolre account, know that as a regulated financial institution we are required to retain certain information you have provided for a number of years.

    6. QUESTIONS?

    6.1. If you have any questions about this Privacy Policy, feel free to reach out to Support.