This Privacy Notice explains how Smolleys (“Smolleys -Banking For Kids”) and its Parent company Tuzapay Limited (“Tuzapay Ltd”) collect, use and disclose personal data online and offline in connection with the services we provide to you and your family. The terms “Smolleys”, “we”, “our”, and “us” are used in this Privacy Notice to refer to Smolleys -Banking For Kids and Tuzapay Ltd collectively, and we have therefore specified where only one of them undertakes a specific activity. It applies to everyone who: visits our websites that link to this Privacy Statement (the “Site”); uses our mobile applications, financial accounts and cards (collectively, the “App”); uses our platforms – including touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control that link to this Privacy Statement (collectively, our “Platforms”) – or otherwise uses the services we provide (collectively, the “Service”). Key terms: In this Privacy Statement, we refer to “you” as a visitor to our Site, user of our Platforms, and/or the parent or guardian who is responsible for the account(s) you create using our Service (the “primary accountholder” as defined in our Terms). We use “your family” to refer to anyone affiliated with your account on the Service, such as any child or children you sign up for the Service. If you designate any other individual to be responsible for the Service, such as your spouse, or authorized user (as defined in the Terms) or other secondary approver (defined in the Terms), “your family” also includes the authorized user.
TYPES OF INFORMATION WE COLLECT AND HOW
We collect the following categories of personal information:
Identifiers and contact details: such as name, postal addresses, email addresses, social networking website user account names, telephone numbers, or other addresses at which you are able to receive communications.
Official identification information: such as Social Security number, government issued Driver’s License, State ID Card, passport and/or any related information that is necessary to comply with legal obligations.
Demographic information: such as age, date of birth, gender, and pronouns.
Transaction information: such as purchases made with the Service, transaction history, trading history, and account balances.
Financial information: such as transaction information and account numbers pertaining to financial accounts you choose to link to the Service.
Location information and motion detection: such as information related to your state, city, or neighborhood. For our safety features, including those offered under the Smolleys Universal Plan, only if you provide your consent within the App, we will also collect precise location data, such as GPS coordinates, and activity data through sensor and motion detectors on mobile devices used to access the Service, relating to you or your family members (according to your settings). To use safety features, you may be required to authorize the collection of location and activity data in the background, including when you and your family members are not using the App.
Internet and usage information: such as internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), clicked pages and any other information about how you and your family use the Service.
Communications with us and information you provide: such as any customer service requests you or your family initiate and other information you or your family choose to provide to us through the Service
Preferences: such as marketing preferences and inferences about any Service you may be interested in.
We collect personal information from a variety of sources, including:
From you and your family: including identifiers and contact details, demographic information, financial information, location information, communications with us, and preferences.
Automatically, from your and your family’s devices: including internet and usage information, some of which we collect via cookies and other similar technologies as described below, and other information about how you and your family use the Service.
Social media networks: including information you and your family provide to us and your communications with us on social media channels, such as Facebook, YouTube, TikTok, Twitter, and Instagram, and any demographic information such platforms provide to us, including the average age and most popular locations of individuals who interact with our social media channels.
Other third parties: including information we receive from:
- Financial institutions, including Equity Bank Rwanda (EBR), First I&M Bank (I&M) and other entities that operate any financial accounts or products that are related to the Service, such as DriveWealth if you use our Invest Account Services.
- Financial service providers, including Flutterwave, PayPack, MFS Africa and Plaid, which allow us to verify you own the bank account you elect to use as a funding source, verify the amount requested is available to fund your Smolleys account, and complete the transfer of funds to your Smolleys account.
- Business and advertising partners that provide us with information to allow us to better tailor the Service to you and your family.
- Safety partners including RapidSOS, ZenDrive and other entities that provide us with information to facilitate safety features you or your family members enable. For example, if you sign up for safety features, we may receive information to allow us to share your location with selected family members and emergency responders in an emergency situation.
Cookies and other similar technologies
Like many digital platforms, Smolleys and our third-party service providers may collect certain information automatically using cookies and other similar technologies to help us manage, improve and customize our features and functionality. We use the term “cookies and other similar technologies” to refer to small data files, including cookies, pixel tags, and/or other technologies provided by your browser or associated applications. You are free to decline optional cookies and similar technologies if permitted by your computer, browser, mobile phone, or other device, although doing so may affect your use of the Service.
HOW WE USE PERSONAL INFORMATION
We use personal information for the following purposes:
To create, fund, maintain, customize, improve, and secure the Service, or otherwise provide services you request. This includes:
- Processing and analyzing account transactions and payments, and notifying you and your family about them;
- Providing customer support and delivering Service update notices, answering questions and responding to requests, and otherwise communicating with you and your family;
- Testing, personalizing, developing and improving the Service, including for analytics and to create new algorithms or other tools, so we can better cater to your interests;
- Providing services or features you request, such as, if you choose to participate, enrolling you in Smolleys Trivia or our safety features, and making investment recommendations if you participate in Invest Account Services.
To market our products and services, including:
- Direct marketing, such as sending direct marketing communications as permitted by law, including by email or text messages;
- Referrals, such as facilitating, managing and confirming referrals from you, your family, and our business partners; and
- Interest-based advertising, such as engaging third-party advertising companies and social media companies to display ads promoting our and other services across the web. We do not use third-party advertising technologies within our App, including to target children under the age of 13 who are logged into our Service with interest based ads.
To maintain the security and integrity of the Service, our technology, assets and business, including:
- Detecting, preventing, and investigating fraud or other illegal activities;
- Evaluating, monitoring and auditing the security of the Service, and troubleshooting and debugging;
- Performing identity verification on our own behalf and on behalf of regulated business partners including I&M (issuer of Greenlight prepaid card), EBR (issuer of Greenlight Family Cash Card), and DriveWealth (broker dealer for the Invest Account); and
- Enforcing our Terms and the Cardholder Agreement, including to prevent potential breaches.
To comply with applicable laws, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
HOW WE SHARE PERSONAL INFORMATION
We do not sell personal information. We may share personal information as follows:
Within your family. Information you or your family provide may be accessible to other members of your family through the Service. For example, you and any authorized approver you authorize will be able to see the account activity of your child on the Service, and the authorized approver may be able to see certain information about you, such as your name and accounts. If you sign up for safety features, you will be able to share information such as your location with members of your family or other emergency contacts.
Processing transactions. To process payments and other transactions on the Service, we share information with the person you or a member of your family are paying or from whom you or a member of your family are receiving a payment.
Service Providers. We engage with select service providers who provide services to support our operations such as: open banking interface providers (like Plaid); payment processors (including merchant acquirers and automated clearinghouse (ACH) payment processors); broker dealers (like DriveWealth); insurance providers for mobile phone protection and purchase protection; identity verification services; cloud hosting providers (like Firebase); and other service providers pursuant to written agreement with us.
Business and Safety Partners. We may share your personal information with our business and safety partners, including partner financial institutions and emergency response partners (if you enable safety features), as well as with affiliates, to provide you with a product or service you request (such as to facilitate and fulfill an emergency request, third-party referral, offer or invitation to use the App and to confirm the same) and for our affiliates internal business purposes.
Other Parties. We share personal information when we have reason to believe that disclosing the information is necessary to prevent fraud, damage to person or property, protect and secure our business, assets, user accounts or enforce legal rights or comply with subpoena, court order, legal process or obligations, including as needed to support auditing, compliance, and corporate governance functions. We also share personal information as needed if that information is requested by law enforcement agencies or if we are required to do so by law or court order.
Advertising Networks and Analytics. We may allow advertising networks to collect information on our Site for the purposes of serving ads that are more relevant. We also work with partners that assist us with ad campaign measurement and analytics on our Site and App.
Successor Entities. We may disclose or transfer your personal information to a successor entity in the event of a corporate merger, divestiture, consolidation, reorganization, sale of assets or other corporate changes respecting Greenlight (including, in connection with a bankruptcy or similar proceedings), and in connection with due diligence and negotiations relating to any such transactions.
We may also share personal information if the information has been aggregated, de-identified, or otherwise does not identify you personally, and otherwise with your consent.
YOUR RIGHTS AND CHOICES
We provide you and your family with the following choices.
Marketing Preferences. Each recipient of our marketing emails may unsubscribe from the emails from within each marketing email, but please note that you may continue to receive transactional emails with Smolleys account-related information, even if you opt-out of marketing emails.
Update Your Information. You can edit or update personal information in your account by reviewing the account settings and profile across the family of accounts. It is your responsibility to make sure that personal information of everyone in your family is accurate. You should promptly update your and your family’s personal information if it changes or becomes inaccurate.
Change location and motion detection settings. You can change what location and/or motion detection information you share within the settings of your device. Please note that by changing these settings we may not be able to provide you with services or features you have requested, such as our safety features.
Closing Account(s) and Deletion of Personal Information. As the primary account holder, you can close your account and the account of any member of your family within the settings of the App or by emailing Smolleys Customer Service at smolleys@smolleys.com. If you close an account, the account will no longer be accessible, but we may retain personal information from the account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Cardholder Agreement and Terms, or take other actions as required or permitted by law.
Opt-Out Rights. There are a number of ways to limit online tracking on our Site, which we have summarized below:
Blocking cookies in your browser.Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org
Using privacy plug-ins or browsers.. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
Advertising industry opt-out tools.You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
Digital Advertising Alliance for Websites: outout.aboutads.info
Network Advertising Initiative: optout.networkadvertising.org
Currently, we do not alter our data collection and use practices in response to “Do Not Track” signals. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com
SECURITY
Our information security program is managed by dedicated information security personnel with commercially reasonable information security measures to protect personal information against loss, misuse, and unauthorized access. These measures include, but are not limited to, data encryption, cyber threat detection, and internal access controls. We regularly have our information security program assessed and validated by independent security audit experts. We use administrative, technical, and physical security measures designed to protect personal information we collect against loss, misuse, and unauthorized access. You and your family are responsible for maintaining the security of your usernames and passwords used to access the Service.
INFORMATION FROM CHILDREN
At Smolleys, our goal is to help parents raise financially-sane and smart kids, and we take our responsibility to your children seriously.
Registration
During the registration process, we ask for your mobile phone number and date of birth, which we use to determine your age and eligibility for the Service. Children under the age of 18 must register for our Service with their parent or guardian as follows:
Children under 13. Parents or guardians must initiate the registration process on behalf of children under the age of 13. We request, via digital consent during the registration process, that you represent that you are the parent or legal guardian of any child under the age of 13 for whom you register an account and that you consent to our collection and use of the child’s personal information in accordance with this Privacy Statement. If a child under 13 initiates the registration process without a parent or guardian the registration session will end and we will inform the child that the child will need a parent or guardian to create an account. In those cases, we do not retain the mobile phone number, birth date, or any other personal information from children under 13 until a parent or guardian initiates a new registration.
Children aged 13-17. For children 13 years or older but younger than 18, we request that the child provide a first and last name, an email address and password, and a parent’s mobile phone number so that we can provide the parent with information about how to download the App and finish registering an account.
Parental Choices and Controls
You can update or change the personal information of a child at any time through the account settings. At any time, you can refuse to permit us to collect further personal information of a child by closing that sub-account by emailing Smolleys Customer Service at smolleys@smolleys.com. If you close an account, we will mark the account in our database as “Closed,” but may retain personal information from the account to deactivate the account with our service providers, allow you to reactivate the Greenlight account for some period in the future, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Cardholder Agreement and Terms, or take other actions as required or permitted by law. If you request that we delete your child’s personal information, we will delete as much information as we are legally permitted. Due to regulatory recordkeeping obligations, we may be required by law to retain some information associated with a closed account.
Site and Advertising
While we provide a Service for families, our Site is for promotional purposes only and is not intended for children under the age of 13. We do not knowingly collect any information from children under the age of 13 on our Site. If we learn that we have collected personal information from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
LOCATION OF SERVICE
We are headquartered in the Republic Of Rwanda and currently our Service is only intended for residents of Rwanda, Uganda, Kenya, Tanzania, Dubai, Canada, South Africa, Nigeria and many others.
CHANGES TO PRIVACY STATEMENT
If we make any material changes to this Privacy Statement, we will change the Effective Date above. We encourage you to review this Privacy Statement to stay informed. If we make material changes and we need to provide additional notice, we will notify you via the email specified in your account or through the Service or Site.
CONTACT US
If you have questions about this Privacy Statement or our information practices, please contact us by email at smolleys@smolleys.com