Privacy Policy

1. Introduction

 

As part of our mission to help make Finance more accessible for everyone, Monkiri Inc. collects and processes a lot of information. This Privacy Policy is intended to help you better understand how we collect, use and store your personal information—whether you are a financial service provider or end user that uses Monkiri’s products, applications or services (together, the “Services”), a customer that uses our partners services, using the Monkiri Application, Chatbot or whether you’re simply visiting this website. By using any of Monkiri’s Services, or by dealing with a financial service provider using Monkiri’s Services, you are agreeing to the terms of this Privacy Policy and, as applicable, the Monkiri Terms of Service.

 

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will give you notice of such changes by posting the revised policy on this Website, and where appropriate, by other means. By continuing to use this Website or the Support Service after these changes are posted, you agree to the revised policy.

 

2. Information from financial service provider

Privacy matters! If you are a financial service provider, your customers need to understand how you (and how Monkiri) collects and processes their personal information as the data controller. Accordingly, if you use the Services, you agree to post an up-to-date and accurate privacy policy on your storefront that complies with the laws applicable to your business. You also agree to obtain consent from your customers for the use and access of their personal information by Monkiri and other third parties. In addition, if you are collecting any sensitive personal information from your customers (including information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, financials, trade union membership or sexuality), you agree to obtain affirmative, express consent from your customers for the use and access of sensitive personal information by Monkiri and other third parties.

 

What information do we collect from financial service providers and why?

We collect your name, company name, address, email address, phone number(s), education history, demographic information, financial history, payment details (for example, your credit card information) and any other information you may have provided with our financial service provider partners.

 

We use this information to provide you with our Services; for example, to confirm your identity, contact you, provide you with advertising and marketing, tailor content, make useful recommendations, build better content and invoice you. We also use this information to make sure that we comply with legal requirements.

We collect data about the Monkiri websites that you visit. We also collect data about how and when you access your account and the Monkiri platform, including information about the device and browser you use, your network connection, your IP address, and information about how you browse through the Monkiri interface.

 

We use this information to give you access to and improve our Services; for example, to make our platform interface easier to use. We also use this information to personalize the Services for you; for example, by shifting the order of lessons in the Monkiri app to show you lessons we believe may be of interest to you. Finally, we may use this information to provide you with advertising or marketing.

 

Where we need to verify your identity (for example, if there are concerns around identity theft, or if you call into support and we need to authenticate your account), we may request that you provide us with government-issued identification information.

 

We use some of the personal information you provide us to conduct some level of automated decision-making -- for example, we use certain personal information to help us screen accounts for risk or fraud concerns.

 

We will also use personal information in other cases where you have given us your express permission.

 

When do we collect this information?

We collect personal information when you sign up for our Services, when you access our Services or otherwise provide us with the information.

 

We also partner with third parties who provide us information about financial service providers or prospective financial service providers, for example to help us screen out financial service providers associated with fraud.

 

When and why do we share this information with third parties?

Monkiri works with a variety of third parties and service providers to help provide you with our Services and we may share personal information with them to support these efforts.

 

We may also share your information in the following circumstances:

 

to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.

to help us conduct marketing and/or advertising campaigns.

to provide verification to financial service providers

to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).

Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

 

Monkiri will always ask for your consent before sharing your personal information with third parties for purposes other than those described in this Section 2.

 

3. Information from customers

What information do we collect from our financial service providers’ customers and why?

We collect our financial service providers’ customers’ name, email, shipping and billing address, payment details, company name, phone number, IP address, information about orders you initiate, information about the Monkiri-supported financial service provider stores that you visit, information about the device and browser you use and other information that the financial service provider tracks that might be helpful for you to find, receive, be approved or be curated for different financial services or lessons.

 

We use this information to provide our financial service providers with the Services, including supporting and processing orders, risk and fraud screening, authentication, verification and payments. We also use this information to improve our Services.

We use some of the personal information you provide us to conduct some level of automated decision-making -- for example, we use certain personal information (for example, IP addresses or payment information) to automatically block certain potentially fraudulent transactions for a short period of time.

 

When do we collect this information?

We collect this information when you use or access a financial service provider that uses our Services, such as when you visit a financial service provider’s site, place an order or sign up for an account on a financial service provider’s site.

 

Additionally, we partner with third parties who provide us information about our financial service providers’ customers, for example to help us screen out financial service providers associated with fraud.

 

When and why do we share this information with third parties?

Monkiri works with a variety of third parties and service providers to help provide our financial service provider s with the Services and we may share personal information with them to support these efforts.

 

We may also share your information in the following circumstances:

 

to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.

If the financial service provider whose store you visit or access directs us to transfer this information (for example, if they enable a third party app that accesses customer personal information).

to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).

Personal information may also be shared with a company that acquires our business or the business of a financial service provider  whose store you visit or access, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding.

 

4. Information from partners

Partners are individuals or businesses that have agreed to the terms of the Monkiri Partner Program to work with Monkiri to promote the Services by (a) referring clients to Monkiri; (b)developing Monkiri lesson content; or (c) developing content using the Monkiri Application Interface (API) for financial service provider use.

 

What information do we collect from partners and why?

We collect your name, company name, website, twitter or other social media handles, phone number(s), address, business type, email address, and other relevant information they track.

 

We use this information to work with you, confirm your identity, contact you, pay you and to screen for risk, fraud, or other similar types of issues.

We collect data about the Monkiri websites that you visit. We also collect data about how and when you access your account and the Monkiri platform, including information about the device and browser you use, your network connection, your IP address, and information about how you browse through the Monkiri interface.

 

We use this information to give you access to and improve our Services; for example, to make our platform interface easier to use. We also use this information to personalize the Services for you; for example, by shifting the order of lessons in the Monkiri app store to show you lessons we believe may be of interest to you.

 

We will also use personal information in other cases where you have given us express permission.

 

When do we collect this information?

We collect this information when you sign up for a partner account, when you sign up one of your customers for our Services, or when your customers sign up themselves. We also collect any additional information that you might provide to us.

When and why do we share this information with third parties?

Monkiri works with a variety of third parties and service providers to help provide you with our Services and we may share personal information with them to support these efforts.

 

We may also share your information in the following circumstances:

 

to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.

to help us conduct marketing and/or advertising campaigns.

to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities (including to meet national security or law enforcement requirements).

Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.

 

Monkiri will always ask for your consent before sharing your personal information with third parties for purposes other than those described in this Section 4.

 

5. Information from Monkiri website visitors and support users

What information do we collect and why?

As you visit or browse the Monkiri websites, we collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device. We also collect personal information submitted by you via any messaging feature available from any of our websites (“Messaging Feature”).

 

From telephone support users, we collect your phone number, call audio, and other personal information you provide us during our call. Pursuant to our Terms of Service, we may request additional documentation from you during our call to verify your identity.

 

From chat support users, we collect your name, email address, information about the device and browser you use, your network connection, your IP address, chat transcript, and other personal information you provide us during our chat. Pursuant to our Terms of Service, we may request additional documentation from you during our chat to verify your identity.

 

From forum users, we collect your name, email address, website URL, and other personal information you may post.

 

We use this information to verify your account, to provide and enhance our Services (including supporting or servicing your account, if applicable), and answer any questions you may have.

 

When do we collect this information?

We collect this information when you visit the Monkiri websites, use Services offered on our websites or engage with us either by email, web form, instant message, phone, or post content on or through our websites (including forums, blogs and via any Messaging Feature). We also collect any additional information that you might provide to us.

6. Information from cookies and similar tracking technologies

What is a cookie? A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our website.

 

Why does Monkiri use cookies and similar tracking technology?

We use cookies to recognize your device and provide you with a personalized experience on our websites, or otherwise through the Services. We also use cookies as part of the Services, for example to operate the shopping cart for our financial service provider s’ stores. Read more about how we use cookies on our sites and our financial service provider s’ sites in our Cookie Policy.

 

We use cookies to serve targeted ads from Google, Facebook, Bing, SourceKnowledge, and other third-party vendors. We also use cookies, and other information from your browser and/or device to provide you with personalized advertising, ad delivery, and reporting across multiple sessions and devices.

 

Our third-party advertising partners use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioral advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.

 

Opting out: You can opt out of targeted ads served via specific third party vendors by visiting the Digital Advertising Alliance’s Opt-Out page or the Network Advertising Initiative’s Opt-Out page.

 

We may also use web beacons, software development kits, and other automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.

 

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

 

7. Third party apps

Monkiri’s platform currently does not allow financial service providers that are connected to Monkiri’s services to directly collect information while you are using the Monkiri services.  

8. For how long do we retain your personal information?

In general, we keep your personal information throughout your relationship with us. For financial service providers, this means we will keep your information as long as you maintain associated on our platform. For partners, this means we will keep your information until you inform us that you wish to terminate your partner relationship with us. For our financial service providers’ customers, we generally process your information solely as a data processor on behalf of our financial service providers, and it is up to the financial service providers to determine how long they will store your information in our systems. For users we keep your information for as long as you have an active account with us.

 

Monkiri acts as a data processor on behalf of our financial service providers, except where personal data of financial service providers’ customers is used for the purposes specified for us in Section 3 ‘What do we use this data for?’ Purposes include for risk and fraud screening.

 

Once you terminate your relationship with us, we generally will continue to store archived copies of your personal information for legitimate business purposes such as to defend a contractual claim or for audit purposes and to comply with the law, except when we receive a valid erasure request.

 

We will continue to store anonymous or anonymized information, such as website visits, without identifiers, in order to improve our Services.

 

9. What we don’t do with your personal information

We do not and will never share, disclose, sell, rent, or otherwise provide personal information to other companies (other than to specific Monkiri financial service providers you are interacting with, or to third party apps or service providers being used by those financial service providers if you are a consumer, or Partners that you hire if you are a financial service provider) for the marketing of their own products or services.

 

If you are a financial service provider using Monkiri’s Services, we do not use the personal information we collect from you or your customers to independently contact or market to your customers. However, Monkiri may contact or market to your customers if we obtain their information from another source, such as from the customers themselves.

 

10. How do we keep your personal information secure?

We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other personal information entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

 

11. Residents of the European Economic Area (“EEA”)

We currently do not operate in this area.

12. How do we protect your personal information across borders?

While Monkiri Inc. is a Canadian company, we provide services to individuals and our technology processes data from users around the world. Accordingly, Monkiri may transmit your personal information outside of the country, state, or province in which you are located.

 

13. Automated Decision-Making

In the course of offering our services, Monkiri uses a number of machine learning algorithms and forms of automated decision-making. For example, we use automated decision-making: to prevent risk and fraud by financial service providers; to help financial service providers avoid fraudulent transactions from their customers; to personalize users’ experience; and to determine eligibility for certain services.

 

Most of these algorithms are not fully automated and include some human.

 

14. Control over and access to your personal information

Monkiri understands that you have rights over your personal information, and takes reasonable steps to allow you to access, correct, amend, delete, port, or limit the use of your personal information. If you are a financial service provider or a partner, you can update many types of personal information. If you are unable to change your personal information within your account settings, or if you are concerned about data collected as you visit Monkiri’s websites or use our support services, please contact us to make the required changes. If you are a financial service provider’s customer and wish to exercise these rights, please contact the financial service providers you interacted with directly -- we serve as a processor on their behalf, and can only forward your request to them to allow them to respond. It’s important to remember that if you delete or limit the use of your personal information, the Services may not function properly.

 

If you have any questions about your personal information or this policy, or if you would like to make a complaint about how Monkiri processes your personal data, please contact Monkiri by email at trevor@Monkiri.co, or by using the contact details below.

 

15. How to contact Monkiri

 

Monkiri Inc.

Attn: Chief Privacy Officer

128 W Hastings Street,  

Vancouver, BC V6B 1G8

Canada

 

Last updated: April 23, 2019

© 2019 Monkiri Inc.