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Privacy Policy

Updated: 10 July 2024

OUR COMMITMENT TO PRIVACY

Puplar, a service provided by Akawo.me Synergy Limited, values your privacy and is committed to protecting your personal information. We understand that you may have questions or concerns about how your information is used and shared, and we want to assure you that we take your privacy seriously. This Privacy Policy is designed to provide you with clear information about how we collect, use, and protect your personal information. If you have any privacy-related questions, please feel free to contact us at support@puplar.com

PRIVACY POLICY APPLICABILITY

This Privacy Policy applies to all information collected through our Services from both current and former users of Puplar, including yourself. The term "Services'' encompasses all products, services, content, features, technologies, or functions provided by Akawo.me Synergy Limited, as well as any associated websites, applications, and services offered to you in connection with your Puplar account. Please note that even if you are no longer our customer, we will continue to share your information as outlined in this policy. It is important to understand that this policy specifically pertains to the Services and does not govern the practices of any other Akawo.me Synergy Limited entities. For the purpose of this policy, "personal information" refers to information that can be linked to a specific individual and used to identify that person. It is worth noting that we do not consider personal information to include data that has been aggregated or anonymized in such a way that it no longer identifies a particular user.

THE INFORMATION WE COLLECT

When you visit our website, use our mobile applications, or access our other Services, we may collect the following information:

  • Standard Web Log Information: This includes your IP address, browser type, and pages accessed on our website.
  • Puplar Account Information: If you open a Puplar account, we may collect the following information from you:
    • Account Information: This includes your text-enabled cellular/wireless telephone number, machine or mobile device ID, and similar information.
    • Identification Information: This includes your name, street address, email address, date of birth, social security number, or other government-issued verification numbers.
    • Device Information: This refers to information about your device, such as device type, machine or mobile device identification number, Geolocation Information, time zone, language setting, browser type, IP address, and information obtained from third parties for transaction processing, identity verification, fraud detection or prevention, and similar purposes. To prevent fraud, we may link your machine ID with others who use the same payment cards.

We are dedicated to providing a safe, secure, and excellent service. Therefore, before granting access to the Services, we may require additional information to verify your identity, address, or other details, or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties, such as identity verification and fraud prevention services. During your use of the Services, we collect information related to your account transactions, as well as Geolocation Information and/or information about your computer or other access device for fraud prevention and similar purposes. Finally, we may collect additional information from or about you through other means not explicitly described here.

PROTECTION AND STORAGE OF PERSONAL INFORMATION

We prioritize the security and storage of your personal information and employ measures to safeguard it. Your information is stored and processed on third-party servers, adhering to applicable US federal and state regulations. We implement a combination of physical, electronic, and procedural safeguards to protect your data. These measures include firewalls, data encryption, physical access controls to our premises and files, and limiting access to personal information to authorized employees with job-related responsibilities. While we strive to maintain the security of our systems, it is important to note that no method of transmission or storage can guarantee absolute security. Despite our best efforts, there is a possibility of unauthorized access, disclosure, alteration, or destruction of personal information.

Therefore, we strongly advise you to take your own precautions to protect your personal data, including keeping your Puplar password confidential and not sharing it with anyone. In the event of a security breach, where we become aware of unauthorized access to personal information, we will make reasonable efforts to notify you electronically so that you can take necessary protective measures. By using our Services, you consent to receive electronic communications from Puplar. If a security breach occurs, we may provide a notice on our website or mobile application. Additionally, we may send an email to the address you have provided us. Depending on your jurisdiction, you may have the right to receive written notice of a security breach. To receive written notice (or to withdraw your consent for electronic notice), please contact us at support@puplar.com

PERSONAL INFORMATION USAGE

At Puplar, we collect personal information to ensure your experience is safe, seamless, efficient, enjoyable, and tailored to your preferences. We may utilize your personal information for the following purposes:

  • Providing the services you request and offering customer support.
  • Processing transactions and delivering transaction-related notifications.
  • Resolving disputes, collecting fees, and troubleshooting issues.
  • Preventing potentially fraudulent, prohibited, or illegal activities by utilizing risk and fraud tools that analyze various types of information such as Account Information, Identification Information, Financial Information, Device Information, Social Web Information, and Geolocation Information.
  • Establishing a connection between your Puplar account and a third-party account or platform.
  • Customizing, personalizing, measuring, and enhancing our services, as well as improving the content and layout of our website.
  • Keeping you informed about new products and services we offer.
  • Verifying information for accuracy by cross-referencing with third parties.
  • Fulfilling other legal obligations and responsibilities.

SHARING PERSONAL INFORMATION WITHIN THE PUPLAR NETWORK

To facilitate payments on Puplar, it may be necessary to share certain personal information with the individual or company involved in the transaction. This information may include your contact details, sign-up date, number of payments received, and verification metrics like social graph activity. Such sharing occurs when transacting with, on, or through Puplar.

We collaborate with vendors to enable them to accept payments via Puplar. In this process, vendors may share information about you with us, such as your mobile phone number or Puplar username, to confirm your status as a Puplar customer and authorize Puplar as a payment method for your purchases.

It's important to note that we do not disclose your credit card number or bank account number to any party you transact with through Puplar, unless explicitly permitted by you or if legally required in response to a legal process.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

At Puplar, we value your privacy and ensure that your personal information is not shared with third parties for their promotional or marketing purposes. However, please note that certain personal information may be considered public and visible to anyone on the internet, regardless of whether they have a Puplar account. This includes details such as your Puplar username, profile photo, name, month and year of account creation, and public transactions you've been involved in. For business profiles, information such as username, photos, business name, description, and QR code may also be indexed by search engines and made searchable. There are specific entities with which we may share your personal information:

  • Our parent company, Akawo.me Synergy Limited., and its controlled affiliates and subsidiaries, in accordance with this privacy policy.
  • Companies intending to merge with or acquire Akawo.me Synergy Limited., or in the case of bankruptcy, a bankruptcy estate. In such cases, we ensure that the new entity adheres to this privacy policy, and you will be notified in advance to express any preferences.
  • Law enforcement agencies, government officials, or other third parties if required by a subpoena, court order, or similar legal procedure, to comply with the law, prevent harm or financial loss, report suspected illegal activity, investigate violations of the Puplar User Agreement, or as mandated by law.
  • Third-party service providers who assist us in delivering services to you, including fraud detection or similar services on our behalf or any vendor's behalf.

HOW TO ACCESS OR MODIFY YOUR PERSONAL INFORMATION

You can easily review and update your personal information at any time by logging into your account and accessing the account settings.

LINKS TO OTHER SERVICES OR SITES

Puplar may provide links to third-party services or websites, but please note that we do not have control over the information collection practices of these third-party services or websites. We encourage you to review the privacy statements of any third-party service or website that collects personally identifiable information when you visit them via our links.

CARD TERMINATION POLICY

Termination After Insufficient Funds: Virtual Dollar Cards will be terminated after three consecutive insufficient funds attempts. This measure is designed to reduce the number of forced debit attempts by merchants and to manage the costs associated with unsuccessful authorization attempts.

Charges on Cross-Border Transactions: Cross-border charges are now immediately charged on Transactions and might result in a negative balance on the card. 

Below are ways these charges can affect your cards or card transactions: 

  • Additional transaction Charge: Every foreign transaction, i.e., transactions occuring on non-USD denominated sites, or sites where the merchant will eventually be settled in a currency other than the USD, will include an additional fee.
  • Additional Transaction Charge: Negative Balances: These charges can sometimes lead to negative balances on your virtual card. For instance, If you are close to your limit or the transaction is processed with a delay, these fluctuations and fees can lead to a situation where the charged amount is more than what you anticipated, resulting in a negative balance. This is more likely to happen if the currency in question is particularly volatile or if the transaction occurs over a period (like a hotel stay) where the exchange rate changes between the time of authorization and the time of final charge. Cards with negative balances cannot be terminated, however, a force termination route has been introduced, and if force termination is done, the outstanding balance is passed to the merchant and the card is terminated. 

CARDS TRANSACTION HISTORY

Transaction Legs: Each transaction involves at least two stages: authorization and settlement. The authorization holds the transaction amount while settlement clears the transaction and the merchant is paid. If you see a transaction appear twice, this is normal.

CARD PREFUNDING

Prefunding Requirement: Newly created cards must be funded with at least $1 to become active. This $1 is prefunded by us and will be debited upon termination of the card. We appreciate your understanding and cooperation as we implement these updates. If you have any questions or need further assistance, please do not hesitate to contact our customer support team at support@puplar.com

CHANGES TO OUR PRIVACY POLICY

As Puplar continues to evolve and improve its services, we may occasionally update this privacy policy. In the event of any modifications, we will post the revised privacy policy on our website and indicate the "last updated date" above. If there are significant changes in how we use personal information, we will notify you through announcements on our mobile application or website, or via email. It is your responsibility to periodically review this privacy policy, as your continued use of the Services after any changes implies your acceptance of the updated policy.

Usepuplar Anti-Money Laundering (AML) Policy

Updated: 16 January 2024

PURPOSE AND SCOPE

The purpose of this Anti-Money Laundering (AML) policy is to outline the measures Usepuplar takes to prevent and detect money laundering activities. This policy applies to all employees, contractors, and third parties associated with Usepuplar.

COMPLIANCE WITH REGULATIONS

Usepuplar is committed to complying with all applicable AML laws, regulations, and guidelines. This includes, but is not limited to:

  • Anti-Money Laundering (AML) and Know Your Customer (KYC)
  • Data Protection and Privacy
  • Payment Services
  • Consumer Protection
  • Securities Regulation
  • Crowdfunding Regulations

CUSTOMER DUE DILIGENCE (CDD)

  • Customer Identification: Usepuplar will establish and verify the identity of all customers before providing services.
  • Enhanced Due Diligence (EDD): Enhanced due diligence measures will be applied to higher-risk customers, transactions, or relationships.
  • Ongoing Monitoring: Continuous monitoring of customer transactions and activities will be conducted to identify any unusual or suspicious behavior.

REPORTING OF SUSPICIOUS ACTIVITIES

  • Internal Reporting: Employees must report any suspicions of money laundering to the designated AML officer or compliance team.
  • External Reporting: Usepuplar will report suspicious transactions to the relevant authorities as required by law.

RECORD-KEEPING

  • Transaction Records: All relevant customer and transaction records will be maintained for a minimum period as required by law.

AML TRAINING

  • Employee Training: Regular training sessions will be conducted to ensure employees are aware of AML laws, regulations, and their responsibilities.

RISK ASSESSMENT

  • Risk Assessment: Periodic risk assessments will be conducted to identify and assess potential money laundering risks associated with Usepuplar's services and operations.

INTERNAL CONTROLS

  • Internal Controls: Usepuplar will establish and maintain internal controls to prevent and mitigate money laundering risks.

AML OFFICER

  • Designation: Usepuplar will designate an AML officer responsible for overseeing the implementation of this AML policy.

REVIEW AND UPDATE

  • Regular Review: This AML policy will be reviewed periodically to ensure its effectiveness and relevance to evolving regulations and risks.

NON-COMPLIANCE

  • Consequences: Non-compliance with this AML policy may result in disciplinary action, including termination of employment or contractual relationship.
  • This AML policy is subject to change and will be reviewed and updated as necessary.

Usepuplar Compliance Team

CONTACT US

If you have any questions, concerns, or feedback regarding this privacy policy or your privacy and the Services, please reach out to us at support@puplar.com. We are here to assist you.

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