PRIVACY POLICY AND FINANCIAL PRIVACY NOTICE –MONZO INC.,LAST UPDATED: DECEMBER21, 2020,This Privacy Policy (“”) applies totheinformationthat Monzo Inc.and its U.S.
affiliates(collectively “”“,” ,PolicyMonzowe,“,” or “”)collectsand usesabout you when you access its website at www.monzo.com/usa(the “”), its mobile ,usourSite,applications (the “”), or otherwise interact with us, such as through in-person interactions (collectively, the ,App,“Services”).
This Policy does not apply to Monzo Bank Limited, our parent company in the U.K.Monzo Bank Limited’s ,Privacy Notice may be accessed at https://monzo.com/legal/privacy-notice/.
By accessingthe Services, you agree to ,the terms and conditions of this Privacy Policy.,The Policy describes the types of information we obtain about visitorsto the Services, how we use the information, and ,withwhom we share it.
We also describe the measures we take to protect the security of the information,and how you ,can contact us about our privacy practices.
The Servicesarefor a general audience, arenot targeted to children, and ,we do not knowingly collect personal information from children under 16years of age.,CATEGORIES OF PERSONAL INFORMATION WE COLLECT,Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about users.
,Under the California Consumer Privacy Act(“”), we are also required to provide you with the “categories” of ,CCPA,personal information we collect.
The categories we collect are: basic contact information(such as name, address, email ,address, and telephone number);personalidentifiers (such as driver’s license number, payment card number, ,username and password), device identifiers(such as IP address, web logs, MAC address, cookies, mobile UDID).
,geolocation information (such asGPS coordinates, zip code,your city and state based on IP address or precise ,location, with your consent).
telemetry data (such as information on the length of use of our App), and other information ,that identifies or can be reasonably associated with you.,Not all of these categories of information are subjectto the CCPA.,Information excluded from the CCPA’s scope ,includes personal information covered by certain sector-specific privacy laws, including the Gramm-Leach-Bliley Act ,(“”) or California Financial Information Privacy Act (“”).
Our Financial Privacy Notice applies to this excluded ,GLBAFIPA,data and may be accessed below.,WHAT INFORMATION WE COLLECT AND THE SOURCES OF SUCH INFORMATION,We collect information in multiple wayswhen you accessthe Services, including when you provide information directly ,to us,andwhen we passively collect information from or about you, such as from your browser or device.
We may ,combine all of the information we collect from or about you from these various sources.,Information You Provide Directly to Us.,We will collect any information that you provide to us.
Forexample, if you ,contact us, we may collect certain information, such as your name, phone number,information provided during calls, ,email address,the contents of any message you sendus, public details from your social media profile, any other ,information you provide in messages or posts to Monzo.
With your consent, we may also access your mobile contacts ,and photographs you take using your mobile device.,Information We Receive from Our Affiliates.,If you hold or previously held an account with Monzo Bank Limited, we may ,receive certain information about you and your account from Monzo Bank Limited in connection with assessing your ,eligibility for and providing you with products and services.
,Information We Collect Through Automated Means.,We also collect information through automated and technical ,means as you browse or otherwise use our Services.
,•Websiteand App Usage Information.As you browseor usethe Services, we and our service providers (which ,are third party companies that work on our behalf to provide and enhance the Services) use a variety of ,technologies, including cookies and similar tools, to assist in collecting information about how you use the ,Services.
For example, our servers automatically record certain information in server logs.
These server logs ,may include information such as your web request, IP address, browser type and settings, referring / exit ,pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing ,pages, pages viewed, mobile carrier, mobile device identifiers and information about the device you are using ,to access the Services, date and time stamp information and other such information.,•Location Information.With your consent, and consistent with the permissions you have enabled on your device, ,we collect and process informationabout the precise location of the device from which you are accessing the ,App (i.e.
GPS coordinates).
We also collect and process information about your general location (e.g., ,approximate geographic location inferred from an IP addressor ZIP code).,•Cookies and Other Tracking Technologies.We and our service providers may also collect data about your use ,of the Services automatically when you interact with the Site or the App.
To collect thisinformation, we and ,our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking ,technologies.
A web server log is a file where website activity is stored.
An SDK is a section of code that we ,embed in our applicationsand software to allow third parties to collect information about how users interact ,with the Services.
A cookie is a small text file that is placedon your computer or mobile device when you visit ,a site, that enables us to: (i) recognize your computer.
(ii) store your preferences and settings.
(iii) understand ,which web pages of the Siteyou have visited.
(iv)enhance your user experience by delivering and measuring ,the effectiveness of content and advertising tailored to your interests.
(v) perform analytics.
and (vi) assist with ,security and administrative functions.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) ,are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are ,designed toprovide usage information like ad impressions or clicks, email open rates, measure popularity of ,the Siteand associated advertising, and to access user cookies.
As we adopt additional technologies, we may ,also gather information through other methods.,Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting ,your browser’s the Help menu.
If you choose to decline cookies, please note that you may not be able to sign in, ,customize, or use some of theinteractive features of the Site.
Flash cookies operate differently than browser cookies, ,and cookie management tools available in a web browser will not remove flash cookies.
To learn more about how to ,manage flash cookies, you can visit theAdobewebsiteand make changes at theGlobalPrivacySettings Panel.,HOW WE USE THE INFORMATION COLLECTED,We and our service providers may use the information we collect from and about you for the following purposes:,•for the purposesfor which you provided it;,•to maintain, provide(or assess whether to provide), and improve the Services;,•to process transactions and send notices about your transactions;,•to resolve disputes, collect fees, and troubleshoot problems;,•to investigate and prevent potentially prohibited or illegal activities;,•to enforce our Terms of Service and the Sutton Cardholder Agreementwith you;,•to deliver targeted marketingof our services to you, service update notices, and promotional offers based on ,your communication preferences;,•to contact you via telephone, text (SMS) or email messaging, including as authorized by our Terms of Service ,and the Sutton Cardholder Agreement;,•to confirm your identity;,•to comply with anti-money laundering and counter-terrorism laws;,•to prevent or address technical or security issues;,•to send you informationor other communications, such as newsletters;,•to process and respondto your inquiries or to request your feedback;,•to identify you by yourdevice(s) and to match your device(s) with other browsers or devices you use for the ,purpose of providing relevant and easier access to content and other operational purposes;,•to engage in internal analytics, research, and reporting;,•to customize the advertisingand content you see;,•to comply with the law and protect the safety, rights, property, or security of Monzo, the Services, and the ,general public.
and,•for other purposes to whichyou have consented.,Please note that we may combine information that we collect from or about you (including automatically collected ,information) with information we obtain about you from our affiliates, and use such combined information in accordance ,with this Privacy Policy.,We may aggregate and/or de-identify information collected through the Services.
We may use aggregateor de-,identified Information for any purpose, including without limitation for research and analytics, and may also share such ,data with any third parties, including partners, affiliates, subsidiaries, services providers, and others.,HOW AND WHEN WE SHARE INFORMATION WITH THIRD PARTIES,We may disclose and/or share thecategories of personalinformation identified above, as well as the specific types of ,informationidentified aboveunder the following circumstances:,•Affiliates and Subsidiaries.We may share the information we collect withinthe Monzofamily of companies.,•Service Providers.We may provide access to or share your information with select entitiesthat use the ,information only to perform services on our behalf.
These service providersprovide a variety of services to us, ,including without limitation sales, marketing, provision of content and features, analytics, data storage, security, ,fraud prevention, and other services.
,•Third parties for legal purposes.We may disclose information that we collect and maintain about you if we are ,required to do so by law or in a good faith belief that such disclosure is reasonably necessary to comply with ,legal process, protect the rights, property, or safety of ourselves, our users, the public, or other third parties.,•Business Transactions.If we areinvolved in a merger, acquisition, transfer of control, bankruptcy, ,reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the ,information described in this Policy in connection withthat transaction.
Your information would remain subject ,to the promises and commitments contained in this Policy until such time as the acquiring party modifies it.
If ,such transfer is subject to additional mandatory restrictions under applicable laws, wewill comply with such ,restrictions.,WEBSITEANALYTICS AND DO-NOT-TRACK,•WebsiteAnalytics.We may use third-party web analytics services on our Servicesto collect and analyze usage ,information through cookies and similar tools.
engage in auditing, research, or reporting.
and provide certain ,features to you.
To prevent Google Analytics from using your information for analytics, you may install the ,Google Analytics Opt-out Browser Add-on byclicking here.
Facebook offers settings that may control what ,information Facebook uses about you or your device activity for advertising purposes.
Login to Facebook and ,go to Settings >.
Ads >.
Ad Settings (web) or Ad Preferences >.
Ad Settings (app) for more information.,•Notice Concerning Do Not Track.Do Not Track (“”) is a privacy preference that users can set in certain ,DNT,web browsers.
We do recognize andrespond to browser-initiated DNT signals.
To learn more about Do Not ,Track, you can do sohere.,MARKETING,We may send marketing materials from time to time to those who have provided us with Personal Information about ,products and services offered by Monzo.
If you signed up to receive newsletters or other marketing communications ,from us, you can opt-out at any time by clicking the unsubscribe link at the bottom of the message.
You can also log-,in to your account to opt-out and update your marketing preferences at any time.
,Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing ,preferences.
Unless otherwise required to process your requests earlier bylaw, it may take up to 5 days to process ,your opt out requests in relation to receipt of electronic marketing materials such as emails, and up to 30 days for all ,other marketing-related requests.
,Even after you opt-out of receiving marketing communications from us, we may still contact you for transactional or ,informational purposes.
These include, for example, customer service issues, returns or product-related inquiries, ,outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.
,You may also contact us on:,Monzo Customer Support Contact Information:,Mailing Address:Monzo Inc.,1370 North St Andrew’s Place,Los Angeles CA 90028,Website:www.monzo.com/usa,Email:usa-help@monzo.com,Phone Number:(415) 200 4074,DATA SECURITY,We use administrative, technical, and physical security measures to protect against the loss, misuse, and/or alteration ,of your information.
These safeguards vary based on the sensitivity of the information that we collect and store.
,However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, ,use, or disclose your information since despite our efforts, no Internet and/or other electronictransmissions can be ,completely secure.
,DATA TRANSFERS ,The Servicesareoperated in the United States.
If you are located in the European Union or elsewhere outside of the ,United States, please be aware that any information you provide to us will be transferred to the United States.
By using ,theServices, participating in anyof our Services and/or providing us with your information, you consent to this transfer.,DATA RETENTION,We keep most of your data as long as you’reusing Monzo, and for 6 years after that to comply with the law and if we ,face a legal challenge.
In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer ,if we need to and/or the law says we have to.,YOUR RIGHTS AND CHOICES ,Subject to applicable law, you may have certain rights with respect to your personal information, including the rights to ,access, review, update, delete, and correct inaccuracies in your personal information.
For instance:,ForCalifornia Residents:,•California Privacy Law.If you are a California resident, California law requires us to provide you with some ,information regarding your rights with respect to your “personal information” (as defined in the California ,Consumer Privacy Act (CCPA)).
In this Policy, we describe the categories of personal information we collect, ,the sources and uses of such information and the entities to which we share such information.,oCalifornia Data Access and Deletion Rights.If you are a California resident, the CCPA allows you to ,make certain requests about your personal information, such as to:,•inform you about the categories of personal information we collect or disclose about you.
the ,categories of sources of such information.
the business or commercial purpose for collecting ,your personal information.
and the categories of third parties with whom we share/disclose ,personal information;,•provide access to and/or a copy of certain personal information we hold about you;,•delete certain personal information we have about you.
and,•provide you with information about the financial incentives that we offer to you, if any.,Please note the CCPA’s scope excludes personal information covered by certain sector-specific ,privacy laws, including the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy ,Act (FIPA).
Our Financial Privacy Notice applies to this excluded data and may be accessed below.,Certain other information may be exempt from deletion requests under applicable law.
For example, ,we need certain types of information so that we can provide the Services to you and for compliance ,with applicable law.
In addition, if you ask us to delete certain information, you may no longer be able ,to access or use the Services.,Additionally, we will take reasonable steps to verify your identity before responding to a request.
You ,are also permitted to designate an authorized agent to submit certain requests on your behalf.
In order ,for an authorized agent to be verified, you mustprovide the authorized agent with signed, written ,permission to make such requests or a power of attorney.,If you would like further information regarding your legal rights under California law or would like to ,exercise any of them, pleasecontact us atusa-help@monzo.com.,oNotice of Right to Opt Out of Sale of Personal Information.
The CCPA sets forth certain obligations for ,businesses that “sell” personal information (as sell is defined under CCPA and under current guidance).
,We do not engage in such activity and have not engaged in such activity in the past twelve months.,The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) ,for exercising your access, deletion or sale opt out rights.,•Shine the Light Disclosure.The California “Shine the Light” law gives residents of California the right under ,certain circumstances to request information from us regarding the manner in which we share certain ,categories of personal information(as defined in the Shine the Light law) with third parties for their direct ,marketing purposes.
We do not share your personal information with third parties for their own direct marketing ,purposes.,For Nevada Residents.,•Nevada Privacy Law.
C ertain Nevada consumers may opt out of the sale of “personally identifiable information” ,for monetary consideration to a person for that person to license or sell such information to additionalpersons.
,“Personally identifiable information” includes first and last name, address, email address, phone number, Social ,Security Number, or an identifier that allows a specific person to be contacted either physically or online.
We ,do not engage in such activity.
however, if you are a Nevada resident who has purchased or leased goods or ,services from us, you may submit a request to opt out of any potential future sales under Nevada law by,emailing us at usa-help@monzo.com.
Please note we will take reasonable steps to verify your identity and the ,authenticity of the request.
Once verified, we will maintain your request in the event our practices change.,International Users.,Some internationalusers of our Websitehave certain legal rights to access certain information we hold about them and ,to request its deletion.
For example, your local laws may permit you to request that we:,•provide access to and/or a copy of certain information we have about you;,•prevent theprocessing of your information for direct-marketing purposes;,•update information which is out of date or incorrect;,•delete certain information which we have about you;,•restrict the way that we process and disclose certain of your information;,•transfer your information to a third party provider of services.
and,•revoke your consent for the processing of your information.,We will consider all requests and provide our response within the time period stated by applicable law.
Certain,information may be exempt from such requests in some circumstances, which may include if we need to keep ,processing your information for our legitimate interests or to comply with a legal obligation.
We may request you provide ,us with information necessary to confirm your identity before responding to your request.,If you would like further information in relation to your legal rights under applicable law or would like to exercise any of ,them, please contact us using the information in the “ContactUs” section below at any time.,LINKS TO AFFILIATES, SUBSIDIARIES,AND THIRD-PARTY SERVICESS, APPS, AND SERVICES ,For your convenience and information, the Servicesmay provide links to Monzo’saffiliates’and portfolio company’s,sites, as well as those of non-affiliated third parties.Those entities have their ownprivacy notices or policies.
We are ,not responsible for the privacy practices of any non-Monzosites, apps,or services.,You understand that your Monzo card is issued by Sutton Bank, member FDIC, and you confirm acceptance of Sutton ,Bank’s privacy policy.,CHANGES TO OUR PRIVACY POLICY,We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, ,the features of our Services, or advances in technology.
We will make the revised Policy accessible through the ,Services, so you should review the Policy periodically.
If we make a material change to the Policy, we will comply with ,applicable legal requirements regarding providing you with notice and/or consent.
,CONTACT US,If you have questions regarding this Privacy Policy, please contact us at usa-help@monzo.comand we will endeavor ,to respondto your request within a reasonable period of time.
You may also submit questions or comments using the ,postal address listed below:,Monzo Inc.,1370 North St Andrew’s Place,Los Angeles CA 90028,FINANCIAL PRIVACY NOTICE (Rev.
11/2020),FACTSWHAT DOES MONZO DO WITH YOUR PERSONAL INFORMATION?,Why?Financial companies choose how they share your personal information.
Federal law gives consumers ,the right to limit some, but not all, sharing.
Federal law also requires us to tell you how we collect, share, ,and protect your personal information.
Please read this notice carefully to understand what we do.,What?,The types of personal information we collect and share depends on the product or service you have ,with us.
This information can include:,•Social Security number and income;,•account balances and payment history.
and,•credit history and credit scores information on accounts linked to your Monzo account ,(account/routing numbers and balances).,When you are no longer our customer, we continue to share your information as described in this ,notice.,How?,All financial companies need to share customers’ personal information to run their everyday business.
,In the section below, we list the reasons financial companies can share their customers’ personal ,information.
the reasons Monzo chooses to share.
and whether you can limit this sharing.,Reasons we can share your personal informationDoes Monzo Can you limit this ,share?sharing?,For our everyday business purposes –such as to process your ,transactions, maintain your account(s), respond to court orders and legal YesNo,investigations, or report to credit bureaus,For our marketing purposes –to offer our products and services to youYesNo,For joint marketing with other financial companiesNoWe don’t share,For our affiliate’s everyday business purposes –information about your ,transactions and experiences,YesNo,For our affiliate’s everyday business purposes –information about your ,creditworthiness,NoWe don’t share,For our affiliates to market to youNoWe don’t share,Questions?,Contact us through the Monzo app, email us at usa-support@monzo.com, ,or call (415) 2004074.,Who we are,Who is providing this notice?Monzo Inc.
,What we do,How does Monzo protect my To protect your personal information from unauthorized access and use, we use ,personal informationsecurity measures that comply with federal law.
These measures include computer ,safeguards and secured files and buildings.
,How does Monzo collect my We collect your personal information when, for example, you:,personal information,•open an account or deposit money;,•pay your bills or use your debit card;,•give us your contact information.,We also collect your personal information from other companies.,Why can’t I limit all sharing?Federal law gives you the right to limit only:,•sharing for affiliates’ everyday business purposes –information about your ,creditworthiness;,•affiliates from using your information to market to you;,•sharing for nonaffiliates to market to you.,State laws and individual companies may give you additional rights to limit sharing.
,See below for more on your rights under state law.,Definitions,AffiliatesCompanies related by common ownership or control.
They can be financial and ,nonfinancial companies.,•Our affiliates include financial companies such as Monzo Bank Ltd.
and ,nonfinancial companies such as Monzo Support US Inc.,NonaffiliatesCompanies not related by common ownership or control.
They can be financialand ,nonfinancial companies.,•Monzo does not share with nonaffiliates so they can market to you.,Joint marketingA formal agreement between nonaffiliated financial companies that together market ,financial products or services to you.,•Monzo doesn’t jointly market.,Other Important Information,You may have other privacy protections under applicable state laws.
To the extent these state laws apply, we will ,comply with them when we share information about you.,California Residents:,In accordance with California law, we will not share information we collect about you with ,companies outside of Monzo or Sutton Bank, unless the law allows.
For example, we may share information with ,your consent, to service your accounts, or to provide rewards or benefits you are entitled to.
We will limit sharing ,among our companies and with Sutton Bank to the extent required by California law.,Vermont Residents:,In accordance with Vermont law, we will not disclose information about your creditworthiness ,to our affiliates and will not disclose your personal information, financial information, credit report, or health ,information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you ,authorize us to make those disclosures.,We will send you SMS messages when you open your account to verify your phone number and to authorize some ,transactions.