DOLLARIZE
PRIVACY
POLICY
Last
updated: March 25, 2025
Dollarize
Financial, Inc., (“Dollarize,” “we,” “us,” or “our”),
know that privacy is very important to you. We have created this privacy policy
(the “Privacy Policy”) to describe what kinds of personal information we
may obtain through:
· Our website, located at www.dollarize.me (the “Site”);
· Our mobile application,
available at app.dollarize.me and in app stores (the “App”); and
· When you interact with us
in any other way.
By
using the Site or the App, you can access our interactive platform (the “Platform”)
and apply to obtain various financial and other services (the “Services”).
Our Services are only available to individuals aged 18 or older.
By accepting this
Privacy Policy, accessing or using the Services, or otherwise manifesting your
assent to this Privacy Policy, you agree to be bound by this Privacy Policy and
the accompanying Terms of Service, which together make up
the Agreement. If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy or any other terms
of the Agreement, you may not access or use the Services. Capitalized terms not
defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.
This Privacy Policy will help you understand the following:
I.
The Information We Collect
II.
Information Use and Sharing
III.
User Access and Choice
IV.
External Websites and Services
V.
Security
VI.
Children’s Privacy
VII.
Do Not Track
VIII.
Notice to California Residents
IX.
Notice to Nevada Residents
X.
Important Notice to Non-US Residents
XI.
Changes to this Privacy Policy
XII.
Contacting Us
I.
The Information We Collect
In the course of providing the Services,
we may collect or receive the following types of information about you, which
may include personal information.
1. Contact Information
We collect contact information through our Services, which
typically includes your name, email address, phone number, and any information
you provide in messages to us (“Contact Information”). We use Contact
Information for purposes such as starting your application for a Dollarize
Account, providing you with information about the Services, responding to your
inquiries, sending you email alerts (including marketing emails), or providing
you with the Services.
2. Dollarize Account Information
Dollarize
provides a Platform for you to gain access to certain financial and other
services. When you open a Dollarize Account, you are also required to open one
or more accounts with certain third-party financial institutions and other services
companies (“Third-Party Service Providers”), including but not limited
to, banks, trust companies, money transmitters, and technology service
providers. Opening your Dollarize Account, and your other accounts, require you
to provide information in addition to Contact Information, including but not
limited to: date of birth, country of birth, nationality, social security
number or other tax identification number, passport number (or numbers
associated with other government issued identification), a selfie, financial
information, bank account and payment card details, account balance, and
payments and similar information.
If your
application is approved, you will be required to enter into a Customer
Agreement with Dollarize for your Dollarize Account. We reserve the right to accept or decline any
application(s) for Dollarize Accounts in our sole and absolute discretion. If you have a Dollarize Account, or have taken steps to apply for one, you may
review our Regulation
SP Privacy Notice for a description of our processing and
disclosure activities regarding the non-public personal information that we
collect from and about you in connection with opening and servicing Dollarize
Accounts.
3.
Information obtained
automatically from your online activity
When
you visit the Platform or use our Services, we may automatically collect
certain information sent to us by your computer, mobile device, or any other
device. This information may include the following:
Like
most online services, we automatically receive standard technical information
when you connect with the Services. We collect this information through browser
cookies, pixels, web server logs, web beacons, and similar technologies. These
features enable us to personalize your experience with the Services, understand
how you use them, maintain a persistent session, and improve and further
develop the Services.
Cookies
are small packets of data that a website stores on your computer’s hard drive
so that your computer will “remember” information about your visit. We use
cookies to help us collect information and to enhance your experience using the
Services. Specifically, we use cookies to authenticate users, personalize your
experience when using the Services, analyze which features of the Services you
use most frequently, and measure and optimize advertising and promotional
effectiveness. To do this, we may use both session cookies, which expire once
you close your web browser, and persistent cookies, which stay on your computer
until you delete them. If you do not want the Services to place a cookie on
your hard drive, you may be able to turn that feature off on your computer or
mobile device. Please consult your internet browser’s documentation for
information on how to do this. However, if you decide not to accept cookies
from us, the Services may not function properly. When the Services are made
available to you through third-party sites, please be aware that these other
sites maintain their own policies regarding cookies and the collection and use
of information. You are responsible for reviewing those policies.
We also automatically collect other information when
you use the Services, such as (i) information about
the device from which you access the Services (i.e., the type of device, the
advertising identifier (“IDFA” or “AdID”), the
operating system and version (for example iOS, Android or Windows), your
carrier and network type (WiFi, 3G, 4G, LTE); (ii)
your IP addresses (which may consist of a static or dynamic IP address and will
sometimes point to a specific identifiable computer or device); (iii) browser type
and language; (iv) referring and exit pages and URLs; (v) date and time of
access; (iv) the
content you viewed; (v) the amount of
time spent on particular pages; (vi) what features of the Services you use or
visit; (vii) details of your purchases; (viii) click stream information; and (ix) precise geolocation.
We
may also evaluate your computer, mobile phone, or other access device to
identify any malicious software or activity that may affect the availability of
the Services.
4.
Geolocation information
To
provide access to the Services while you are using an electronic device, we
automatically collect geolocation information from your mobile device, your
wireless carrier, or certain third-party service providers (“Geolocation
Information”). Collection of such Geolocation Information occurs only when
the Services are running on your mobile device. You may control the collection
of Geolocation Information through the user settings on your device. You may
decline to allow us to collect such Geolocation Information, in which case we
may not be able to provide certain Services to you. Please be sure to manage
your mobile device and privacy preferences on the Platform on an ongoing basis.
5. Information obtained from
other sources, including our social media pages
We may collect Personal Information from the
Owners of Dollarize Accounts and visitors to our Platform. We may also collect
your Personal Information when you visit, use, or access the Services from
third-party websites or apps. We will do so in accordance with the terms of use
and privacy policies of the third-party websites and apps, and applicable law.
This includes our social media pages on third-party services such as Facebook,
Instagram, Twitter, and LinkedIn. For example, we may collect the information
you shared on our social media pages through an application or form, which will
have a link to this Privacy Policy. Personal Information may also be collected
by the third-party social media sites that host our social media pages. These
sites may provide aggregate information and analysis to us about their
visitors’ use of our social media pages. This allows us to better understand
and analyze our user growth, general demographic information about the users of
these pages, and interaction with the content that we post. This Privacy Policy
does not cover Personal Information collected by such third-party social media
sites. For more information on their privacy and security practices please
review the privacy policies and terms of use on their respective websites.
6. Information obtained from
third-party analytics services
We use third-party analytics services (such as
Google Analytics and Smartlook) to evaluate your use
of the Services, compile reports on activity, collect demographic data, analyze
performance metrics, collect and evaluate other information relating to the
Services and mobile and internet usage. These third parties use cookies and
other technologies to help analyze and provide us the data. By accessing and
using the Services, you consent to the processing of data about you by these
analytics providers in the manner and for the purposes set out in this Privacy
Policy. The information used by such analytics services is generally at the
aggregate level. Google may associate such data with visitation information
collected from the Platform. Smartlook’s qualitative
website and mobile app analytics also include, but are not limited to, visitor
recordings (user replay), automatic event tracking, conversion funnels, and
heatmaps for websites.
For more information on these third parties,
including how to opt out from certain data collection, please visit the sites
below. Please be advised that if you opt out of any service, you may not be
able to use the full functionality of the Services.
·
For Google Analytics, please visit:
https://support.google.com/analytics/answer/6004245?hl=en
and
https://tools.google.com/dlpage/gaoptout
·
For Smartlook, please
visit: https://www.smartlook.com/opt-out/
II.
Information
Use and Sharing
We
use and share your Personal Information as set forth below:
· To analyze Platform usage and improve the Services;
· To deliver to you any
administrative notices, money alerts, and communications relevant to your use
of the Services;
· To fulfill your requests
for certain products and services;
· For market research,
project planning, troubleshooting problems, and detecting and protecting
against error, fraud, or other criminal activity;
· To Third-Party Service
Providers that provide services to you and us in the operation of our business
including servicing Dollarize Accounts and providing the Services such as
custodial services, banks, administrators, payment processors, technology
providers, customer service organizations, IT and cloud service providers,
among others;
· To enforce our Terms of Service;
· To disclose aggregated,
anonymous, user statistics and other information to (i)
affiliates, agents, business partners, and other third parties; (ii) describe
the Services to current and prospective business partners; and (iii) other
third parties for lawful purposes;
· To receive assistance from
third-party advertisers and remarketers for the purpose of tailoring,
analyzing, managing, reporting, and optimizing advertising you see on the Platform and elsewhere;
· To share some or all of
your information with our parent company and affiliates;
· As required by law, such as
to comply with a subpoena, or similar legal process, and when we believe in
good faith that disclosure is necessary to protect our rights, protect your
safety or the safety of others, investigate fraud, or respond to a government request;
· As we develop our
businesses, we may be involved in a corporate sale, merger, reorganization,
sale of assets, dissolution, investment, or similar corporate event and we
expect that your Personal Information will be part of the transferred assets;
and
· Otherwise, with your
consent.
We will
take reasonable measures to require that any party receiving any of your
Personal Information from us undertakes to: (i)
retain and use such information only for the purposes set out in this Privacy
Policy; (ii) not disclose your personal information except with your consent,
as permitted by law, or as permitted by this Privacy Policy; and (iii)
generally protect the privacy of your Personal Information.
III.
User
Access and Choice
If
the Personal Information on file for you changes, or
if you no longer desire our Services, you may correct or update it by making
the change in your Dollarize Account, or by contacting us as set forth in
Section XII of this Privacy Policy.
You
may manage your receipt of marketing and non-transactional communications by
clicking on the “unsubscribe” link located on the bottom of any of our
marketing emails. Please note that Dollarize Account Owners cannot opt out of
receiving transactional e-mails related to their Dollarize Accounts. If you are
part of our text messaging program, you can opt out of receiving marketing and
non-transactional messages by texting “STOP” in response.
We
will use commercially reasonable efforts to process such requests in a timely
manner. You should be aware, however, that it is not always possible to
completely remove or modify information in our databases. We will retain and
use your information as necessary to comply with our legal and/or regulatory
obligations, resolve disputes, and enforce our agreements.
IV.
External Websites and Third
Parties
Certain
Services offered through the Platform are provided by independent third
parties, including Sila, Inc. (“Sila”), Fortress Trust (“Fortress”),
and Cross River Bank (“CRB”).
Certain
technology services are provided by Sila. Certain custodial and technology
services are provided by Fortress. Dollarize, Sila, and Fortress are not banks.
Banking services are provided by CRB. Third-Party Service Providers are not
affiliated with Dollarize or Dollarize Financial.
Unless
explicitly stated otherwise, our Privacy Policy addresses only our use and
disclosure of information we collect from and/or about you in your interactions
with Dollarize. If you disclose information to third parties, the use and
disclosure restrictions contained in this Privacy Policy will not apply, as we
do not control the privacy policies of such third parties, nor are we subject
to them.
The
Platform may also contain links
to other third-party websites (“Linked Sites”). We have no control over
the privacy practices or the content of any of our business partners,
advertisers, sponsors, or other websites to which we provide links. As such, we
are not responsible for the content or the privacy policies of those Linked
Sites. You should check the applicable third-party privacy policy and terms of
use when visiting any other websites.
V.
Security
We
follow commercially reasonable and generally accepted standards to protect the
Personal Information submitted to us, both during transmission and once we
receive it. Please understand, however, that no method of transmission over the
internet, or method of electronic storage, is 100% secure. Therefore, we cannot
guarantee its absolute security. If you have any questions about security
regarding our Services, please contact us.
VI.
Children’s Privacy
Our
Services are only available to individuals aged 18 or older, and we do not
knowingly collect Personal Information from any person under the age of 18. If
an individual under the age of 18 has provided us with Personal Information, a
parent or guardian of that child may contact us and request that such
information be deleted, and we will endeavor to delete that information from
our databases.
VII.
Do Not Track
As
discussed above, third parties such as advertising networks and analytics
providers may collect information about your online activities over time and
across different websites when you access or use the Services. Currently,
various browsers offer a “Do Not Track” option, but there is no standard for
commercial websites. At this time, we do not monitor,
recognize, or honor any opt-out or do not track mechanisms, including general
web browser “Do Not Track” settings and/or signals.
VIII. Notice to California
Residents
Pursuant
to Section 1798.83 of the California Civil Code, residents of California have
the right to obtain certain information about the types of personal information
that companies with whom they have an established business relationship (and
that are not otherwise exempt) have shared with third parties for direct
marketing purposes during the preceding calendar year, including the names and
addresses of those third parties, and examples of the types of services or
products marketed by those third parties. If you wish to submit a request
pursuant to Section 1798.83, please contact us via email at legal@dollarize.me. Please note, however,
that we have not shared your Personal Information with third parties for this
purpose.
IX.
Notice to Nevada Residents
We
do not sell your personal information as defined under Nevada law. Nonetheless,
if you are a resident of Nevada, you have the right to opt-out of the sale of
certain Personal Information to third parties. You can exercise this right by
contacting us at legal@dollarize.me with the subject line “Nevada
Do Not Sell Request” and providing us with your name and the email address
associated with your Dollarize Account.
X.
Important Notice to Non-U.S.
Residents
The
Services are operated in the United States. If you are located outside of the
United States, please be aware that any information you provide to us maybe
transferred to, processed, maintained, and used on computers, servers, and
systems located outside of your state, province, country, or other governmental
jurisdiction where the privacy laws may not be as protective as those in your
jurisdiction. If you are located outside the United States and choose to use
the Services, you consent to any transfer and processing of your Personal
Information in accordance with this Privacy Policy, and you do so at your own
risk.
XI.
Changes
to this Privacy Policy
This
Privacy Policy is effective as of the date stated at the top of this Privacy
Policy. We may update this Privacy Policy from time to time without notice to
you. We will indicate at the top of this Privacy Policy when it was most
recently updated, and we encourage you to revisit this page periodically to
stay aware of any changes. By accessing the Services after we change this
Privacy Policy, you are deemed to have accepted such changes.
XII.
Contacting
Us
If
you have any questions about our Privacy Policy, our privacy practices, or if
you would like to exercise your rights and choices, please contact our Customer
Service at: legal@dollarize.me, by phone at +1 (212) 904-0003, or write to us at:
Dollarize
222 Pacific Coast Highway, 10th Floor
El Segundo, CA 90245