At Sproutly, our guiding principle is to treat our customers with utmost care and respect. We respect your school, alumni, business and family’s privacy, and we are committed to protecting your information. This Privacy Policy describes the type of information we collect, how we use it, and the choices available to you regarding our use of your information.

By using any Sproutly Services, you accept this Privacy Policy and agree to the collection and use of your Personal Information in accordance with this Privacy Policy. We use the term “Personal Information” in this Privacy Policy to describe information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device. We do not consider Personal Information to include information that has been aggregated and/or otherwise de-identified such that it does not identify a specific individual, business, household or device.

Our Terms of Service

This Privacy Policy is limited to discussing such Sproutly Services to the extent they bear on our information collection and handling practices. This Privacy Policy describes privacy practices for users of the services described below who are 13 years or older. User accounts for minors under the age of 18 must be established by a parent or legal guardian we call Billing Mangers.

Personal Information We Collect And How

We generally collect Personal Information in three ways: (1) information a user provides to us, (2) information we collect automatically, as a digital platform, and (3) information we receive from third parties, as described further below.

Personal Information provided in connection with financing services:

When a user visits, uses or otherwise interacts with Sproutly Services, for example, by contacting customer service, you (the user) may sometimes give Personal Information directly to us or to our third-party service providers. In order to create an account to use the Sproutly Cowri, as part of Sproutly Services, you must be 18 years old or older (or a parent or legal guardian if creating an account for a user under 18). The account creator will provide the following Personal Information to us through a KYC process: account applicant’s full name, email address, street address, phone number, date of birth, and the applicant’s identification number/ BVN (or, in some cases, only the last 4 digits) and government issued ID in the cases of schools, alumni and businesses, we carry out KYB and as such, we might request business or association registration documents alongside account applicant’s full name, email address, street address, phone number, date of birth, and the applicant’s identification number/ BVN (or, in some cases, only the last 4 digits) and government issued ID . This Personal Information is used to verify the applicant’s (known as a “primary accountholder’s”) identity and set up the account. The full name, birth date, email address and (optionally) mobile phone number of individual sub-account users (typically children) or a designee (also known as “co-parent”) to help manage the account (often a spouse) is also requested from the applicant to establish such user rights ancillary to the applicant’s account. Designating a sub-account or co-parent is optional.

The primary accountholder and secondary approver may see all Personal Information of accountholders across the account family (including transaction history). When an individual requests that an account be created, we ask for the applicant’s date of birth in order to determine whether the applicant is a minor or is 18 years old or older and eligible to set up their own account. If the requestor is younger than 18, we require that the child’s parent or legal guardian complete the account creation process and disclose the minor’s Personal Information to us.

We may invite accountholders from time to time to participate in surveys, sweepstakes, contests and other promotional programs and participation will always be optional. If you decide to participate, you may be asked to provide certain information to enable us to communicate with you about the opportunity, which may include Personal Information. If we make a sweepstakes, contest or other promotional offer available to non-accountholders, we will disclose the Personal Information we collect and why (typically to communicate about the offer) in the offer terms.

To fund the Sproutly account, in order to use the Sproutly payment services, we request that the primary accountholder (all users and/or co-parent if one is designated) transfer funds from a bank account, debit card or any other source that may be approved in the future. The primary accountholder and co-parent may also permit the funding of a sub-account with a direct deposit of wages from an employer of the sub-account cardholder (e.g., participating child’s employer), and any primary accountholder can fund their Sproutly account by a transfer.

When the primary accountholder or secondary approver elect funding by a bank account, when the primary accountholder or co-parent elects funding by debit card, Sproutly uses a third-party merchant acquirer to process your debit card payments. The merchant acquirer will collect your debit card information including your full name appearing on the face of your debit card, card number, expiration date and CVV (collectively, “Cardholder Data”) through various types of software development kits (“SDK”) installed on the Website and Sproutly App, which allow the Cardholder Data to be collected by the merchant acquirer without being accessible to Sproutly. The merchant acquirer is expected to maintain such data in compliance with the card network rules and Payment Card Industry – Data Security Standards (“PCI-DSS”). We do not receive Personal Information back from the merchant acquirer about you.

Automatic Collection

Like many digital platforms, Sproutly collects certain information automatically to help us manage, improve and customize our features and functionality. When you use, visit, or otherwise interact with Sproutly Services, we and our third-party service providers may use technology that stores or collects information sent to us by your computer, browser, mobile phone, or other device. This information may include your IP address, unique device identifiers, or other unique identifier; your device functionality, such as the type of browser, operating system, or hardware used; your device location, which may include a street name and city or GPS-location; mobile network information; your activities within Sproutly Services, including the portions of the Website and Sproutly App you access; your email address and mobile phone number; and other information. When you use Sproutly Services, we also collect information about your transactions and your activities using the Sproutly card, including financial and payment information.

These technologies include “Cookies” (small data files, including cookies, pixel tags, and/or other local storage provided by your browser or associated applications) on your computer, browser, mobile phone, or other device. You are free to decline optional Cookies if permitted by your computer, browser, mobile phone, or other device, although doing so may affect your use of Sproutly Services. We use both session Cookies, which expire and no longer have any effect when you log out of your account or close your browser, and persistent Cookies, which remain on your device until you erase them or they expire. Information from Third Parties When you use the Sproutly App or Website, if you are the primary accountholder or co-parent, we will receive the following information from your wireless operator: your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber details.

How we use personal information

We may use your Personal Information for one or more of the following purposes:

• Create, fund, maintain, customize, and secure your Sproutly card account with us
• Process and analyze account transactions and payments, notify you about them, and audit them if needed.
• Provide Sproutly Services and customer support to you.
• Deliver service update notices and promotional offers, answer questions and respond to your requests, and otherwise to communicate with you.
• Maintain the security and integrity of Sproutly Services, our technology, assets and business.
• Engage in detection and prevention of fraud or other illegal activities and debugging.
• Enforce our Terms of Service and the Cardholder Agreement, including to prevent potential breaches.
• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• If required by applicable law, perform identity verification on our own behalf and on behalf of the bank that issues the Sproutly card.
• Test, personalize, develop and improve Sproutly Services, including to create new analytics, algorithms, or other tools, so we can better cater to your interests;
• Lock and unlock your Sproutly card
• Market our products and services to you, including by presenting tailored content, and features notices through our Website, third-party sites, in-App notifications, emails or text messages (with your consent, where required by law).
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users, online visitors, business contacts or employees is among the assets transferred.

How we share personal information

Sproutly may also share Personal Information with third parties, as follows:

• Service Providers. We engage with select service providers who provide services to support our operations such as: open banking interface providers; payment processors (including merchant acquirers and payment processors); identity verification services; web hosting providers (like AWS); marketing vendors such as email distribution providers, and other service providers. A number of these service providers are described in more detail above under “PERSONAL INFORMATION WE COLLECT AND HOW.”
• Certain Mobile Carriers. If you access Sproutly Services via a mobile device, your device may transmit your request via your mobile carrier’s network and your carrier may have access to any information that is transmitted. You should consult your carrier’s privacy policy for additional information.
• Other Parties. As further described above, we may share your 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. We reserve the right to disclose any 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.
• Successor Entities. We reserve the future right to disclose or transfer your Personal Information to a successor entity in the event of a corporate merger, consolidation, sale of assets or other corporate changes respecting Sproutly.

Please be aware that users of Sproutly Services may themselves disclose Personal Information to other members of their account family or to app stores in connection with downloads as follows:

• A sub-account cardholder’s Personal Information, including but not limited to, established spending parameters, pending transactions, approved purchases, and transaction history, will be shared with the linked primary accountholder and with their secondary approver to manage the account, if any, who can access the information from the sub-account dashboard in the Sproutly App.
• The first and last name, or any designated account name, of the primary accountholder and co-parent cardholders are known to one another and used to communicate between the accounts (e.g., sub-account cardholder sends request to primary accountholder to add more funds to the sub-account). In other words, individual users within an “account family” may also disclose their Personal Information to one another while using Sproutly Services.
• When a user of Sproutly Services downloads the Sproutly App from Apple®, Google® or any other third party platform from which it may become available, the user provides certain Personal Information to the third-party platform in order to complete the download, and as may be necessary to receive updates to the Application through the platform, according to the platform’s separate privacy policy and terms.

Links To Third Party Services

Sproutly Services may contain links to third party websites that may be of interest to our users. If you follow a link to any of these websites, please note that these third parties have their own privacy policies, and that Sproutly does not accept any responsibility or liability for such third-party privacy policies or practices. Please check the individual policies before you engage with any linked third-party website.

Your rights and choices

Sproutly maintains the preferences the primary accountholder has provided to us regarding the use, collection, and sharing of Personal Information, including how we may contact you.

• 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 emails with Sproutly account-related information, even if you opt-out of marketing emails.
• Account Information. The primary accountholder and any co-parent they designate to oversee the account and any sub-accounts linked to the primary account have access to information about sub-accounts unless and until a subaccount is closed. However, one sub-account cannot see information in another sub-account.
• Update Your Information. Personal Information of accountholders can be reviewed and edited at any time by logging in to the primary account and reviewing the account settings and profile across the family of accounts (meaning all accounts linked to the primary account). It is the primary accountholder’s responsibility to make sure that Personal Information of users in the account family is accurate across the primary account and linked sub-accounts. The primary accountholder should promptly update your account family’s Personal Information on the Sproutly App if your Personal Information changes or becomes inaccurate.
• Closing Account(s). The primary accountholder can close the primary account or any sub-account by calling Sproutly Customer Service If they close an account, the account will not longer be accessible to the accountholder and we will mark the account in our database as “Closed,” but may retain Personal Information from the account to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, or take other actions as required or permitted by law.
• Deletion of Personal Information. If you request us to delete your account information, we will delete as much information as we are legally permitted. Due to regulatory recordkeeping obligations, we may be unable to delete all information associated with a closed account and may be required to retain information related to each accountholder and their Sproutly card account and their Invest Account in order to comply with applicable law.

Security

Sproutly Information Security Program is managed by dedicated information security personnel with commercially reasonable information security measures to protect your 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 reasonable administrative, technical, and physical security measures to protect Personal Information we collect against loss, misuse, and unauthorized access. You and your linked sub-account cardholders are responsible for maintaining the security of your user names and passwords used to access Sproutly Services.

Changes to Privacy Policy

Sproutly reserves the right to modify this Privacy Policy at any time and may apply changes to previously collected information, as permitted by applicable law. From time to time, we may change or update this Privacy Policy and will give notice of material changes as required by applicable law. We encourage you to review this Privacy Policy from time to time for any updates. You acknowledge and agree that we may notify you about any material changes in the way we treat Personal Information by giving you notice through Sproutly Services, including by posting an updated version of this Privacy Policy on the Website. Your continued use of Sproutly Services after any such notice shall constitute your acceptance of such changes. If you do not agree with any such changes, please stop using Sproutly Services.

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