Privacy Policy

LAST UPDATED January 24, 2019
OUR COMMITMENT TO PRIVACY

RALY, a TNX Inc. service (the "RALY Services"), knows that you care about how your personal information is used and shared, and we take your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from home page of the RALY website at RALY.com (the "website") and through our mobile applications. You may also email us at [email protected] with any privacy-related questions you have.

APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all information we collect through our web and mobile applications from current and former RALY users, including you. When you are no longer our customer, we continue to share your information as described in this policy. This policy only applies to the RALY Services and does not apply to the practices of any other service.

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.

THE INFORMATION WE COLLECT

When you visit the website or use one of our mobile applications, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use our Service.
If you open a RALY account, we collect the following information from you:

• Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
• Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
• Device Information - information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, geo-location, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
• Social Web Information - including but not limited to your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve the Services and fight fraud). Additionally, another RALY user may mention you in a transaction to which you are not a party by “tagging” your username in a transaction note or comment. When you are mentioned in a transaction note or comment into which you have visibility (e.g., a public transaction, a “friends only” transaction by one of your RALY friends, or a comment on either such transaction), a link to your RALY profile will appear in the transaction note or comment and, if your push notifications are turned on, you will receive a push notification about the mentions. You may manage certain contact preferences and notifications in your account settings.
• Financial Information - bank account online login information, bank account and routing numbers and credit cards linked to your RALY account. RALY does not share financial information with third party social networking services such as those listed in the prior bullet.

We are committed to providing a safe, secure and all around great Service. Therefore, before permitting you to use our Service, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

When you are using the RALY Services, we collect information about your account transactions and we may collect information about your computer or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey.

INFORMATION FROM CHILDREN

The website and the RALY Services are not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

HOW WE USE COOKIES

When you visit our website, use our mobile application or the RALY Services, or visit a third-party website for which we provide online services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a customer; customize RALY Services, other content and advertising; measure the effectiveness of promotions; perform a wide range of analytics; mitigate risk and prevent potential fraud; and to promote trust and safety across our sites and RALY Services.

Certain aspects and features of the RALY Services and our website are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the websites and RALY Services may be limited or not possible.

Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your RALY password with anyone.

If RALY learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the RALY Services, you agree that RALY may communicate with you electronically. RALY may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), please email us at [email protected]

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun and customized experience. We may use your personal information to:

• provide the services and customer support you request;
• process transactions and send notices about your transactions or your network activity;
• resolve disputes, collect fees, and troubleshoot problems;
• prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
• create an account connection between your RALY account and a third-party account or platform;
• customize, personalize, measure, and improve our services and the content and layout of our website;
• send you updates about new products and services that we are offering to customers;
• compare information for accuracy and verify it with third parties; and
• perform other duties as required by law.

HOW WE SHARE PERSONAL INFORMATION WITHIN THE RALY NETWORK

To process payments on RALY, we need to share some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through RALY.

We work with vendors to enable them to accept payments from you using RALY. In doing so, a vendor may share information about you with us, such as your mobile phone number or RALY username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a RALY customer and that the vendor should enable RALY as a form of payment for your purchase.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through RALY, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.

HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

RALY does not share your personal information with third parties for their promotional or marketing purposes.

Some personal information is public information (including your RALY username, RALY profile photo, RALY profile first and last name, month, and year of RALY account creation, and public transactions in which you've been involved), and may be seen by anyone on the internet, whether or not they have a RALY account. Public information may also be seen, accessed, reshared or downloaded through RALY's APIs or third-party services that integrate with our products. In addition to any public information, your RALY friends list may be seen by any logged-in RALY user.

We may share your personal information with:

• Our parent company, TNX Inc. and affiliates and subsidiaries it controls, but only for purposes allowed by this document.
• Companies that TNX Inc. plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
• Law enforcement, government officials, or other third parties if RALY is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the RALY User Agreement, or as otherwise required by law.
• Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
• The other RALY user participating in the transaction and, depending on the privacy setting of each RALY account transaction, your RALY friends and the RALY friends of the other user participating in the transaction, or the public, through the RALY feed on our website and mobile application and elsewhere on the internet.
• Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
• Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.
• For the purposes of this privacy policy, an "account connection" with such a third party is a connection you authorize or enable between your RALY account and a non-RALY account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, RALY and the third-party will exchange your personal information and other information directly. Examples of account connections include: linking your RALY account to a social media account or social messaging service; connecting your RALY account to a third-party data aggregation or financial services company, if you provide such company with your RALY account log-in credentials; or using your RALY account to make payments to a merchant or allowing a merchant to charge your RALY account.
• If you connect your RALY account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your RALY account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.
• Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that RALY shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
• If you choose to use Siri or iMessage to send payments via RALY or to otherwise use the RALY Services, such use is subject to Apple’s terms and conditions for use of iMessage and/or Siri, as applicable, and the terms of the RALY User Agreement. By using Siri or iMessage, you authorize us to share some of your RALY account data (including your friends list, list of persons you have transacted with most recently and most frequently, transaction instructions, and transaction notes) with Apple to allow it to facilitate transaction requests made through Siri or iMessage on iOS. Data shared with Apple will be used pursuant to Apple’s then-current user agreements and privacy policies. You can grant or revoke Apple’s access to RALY on iOS at any time under the “Siri” or “iMessage” settings on your iPhone.

RALY does not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under the control of RALY and is subject to the terms of use and privacy policies of such third parties.

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

LINKS TO OTHER SITES

The website or mobile application may contain links to other third-party websites. RALY does not control the information collection of third-party websites that can be reached through links from the website. We encourage our users to be aware when they are leaving the website and to read the privacy statements of any third-party website that collects personally identifiable information.

CHANGES TO OUR PRIVACY POLICY

RALY is always improving. As the RALY Services evolve we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the "last updated date" stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our mobile application or website or by sending you an e-mail. It is your responsibility to periodically review this privacy policy; users are bound by any changes to the privacy policy by using the RALY Services after such changes have been first posted.

HOW TO CONTACT US

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy and the RALY Services that you would like us to consider, please email us at [email protected]