Nevly’s Privacy Policy

The Basics

1. About Us

We are Nevly, a financial technology company. The Privacy Policy covers Nevly’s services in the United States.

WE (AND OTHERS ACTING ON OUR BEHALF) ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.

We will:

2. Why do I need to read this notice?

We will collect your personal information when you use:

THIS POLICY CONTAINS IMPORTANT INFORMATION

This document explains what information we collect, how we use it, and your rights if you want to change how we use your personal information.

If you have concerns about how we use your personal information, you can contact us at privacy@nevly.com.
This Policy is originally written in and governed by the English language. If this text is translated into another language and there is a conflict between the English and non-English versions, the English text will prevail.

YOUR PERSONAL INFORMATION

3. What information do you collect about me?

WE COLLECT DIFFERENT TYPES OF INFORMATION FROM YOU AND OTHERS

The list below explains what personal information we collect and use.

Information you give us

We collect information you provide when you:

fill in any forms;
correspond with us;
register to use the Nevly app;
open an account or use any of our services;
take part in online discussions, surveys or promotions;
speak with a member of our customer support team (either on the phone or through the Nevly app);
enter a promotion; or
contact us for other reasons.

We will collect the following information:

your name, address, and date of birth;
your email address, phone number and details of the device you use (for example, your phone, computer or tablet);
your username, password and other registration information;
details of your bank account, including the account number, sort code and ABA routing number or SWIFT code;
details of your bank account, including the account number, sort code and ABA routing number or SWIFT code;
details of your debit cards and credit cards, including the card number, expiration date and CVC (the last three digits of the number on the back of the card);
identification documents (for example, your passport or driving license number), copies of any documents you have provided for identification purposes, a photograph of you, and any other information you provide to prove you are eligible to use our services;
records of our discussions, if you contact us or we contact you; and
your photo (if you upload one).
information from your device whenever you use our website or the Nevly app, we collect the following information:
- technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and so on;
- information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page;
- information on transactions (for example, payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, details of device used to arrange the payment and the payment method used; and
- information stored on your device, including if you give us access to contact information from your address book, log-in information, photos, videos or other digital content, check-ins (sometimes, we call this content information). The Nevly app will regularly collect this information in order to stay up to date.

Information about your location

Information from others

Information from social media

4. How do you use my information?

Keeping to our contracts and agreements with you

Legal obligations

Providing our services

Whenever you apply for a product or service, we will use your personal information to check your identity (as part of our KYC process) and decide whether or not to approve your application.
If you are already a Nevly customer, we use your personal information to meet our obligations relating to any transactions you make (for example, making payments into and out of your Nevly account, withdrawing cash or making payments with your Nevly Card). If you ask us to exchange the currency of the money you hold in your Nevly account, we’ll use your personal information to help us do that.
We also use your personal information to give you details of our products and services.
We also use your personal information to contact you by phone and provide you with customer support services. We may record these calls, but only for internal training and quality-control purposes.

The types of information we use are:

information you have given us; and
information from third parties (as explained in the “What information do you collect about me?” section above).

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION TO PROVIDE OUR SERVICES

If you apply for a credit product, we (or our lending partner) will carry out a credit check to better understand your financial circumstances and repayment history.

Our legal basis for collecting your information includes:

keeping to contracts and agreements between you and us;
legitimate interests (we will be efficient about how we meet our obligations, and we want to provide you with a good service); and/or
legal obligations.

Protecting against fraud

We use your personal information to check your identity to protect against fraud, comply with financial crime laws and to confirm that you are eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your Nevly account.

The types of information we use are:

information you have provided;
information from your device;
location information; and/or
information from third parties.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION TO PROTECT AGAINST FRAUD

If you have switched on location services in the Nevly app and your mobile phone tells us that you’re in the US, but your Nevly Card is being used in Spain, we may determine not process that transaction.

Marketing and providing new products and services that might interest you

We use your personal information to do the following:

provide you with information about other goods and services we offer that are similar to those you have already used or asked about;
provide you with information about our goods or services, and our partner’s promotions or offers, which we think you might be interested in. To help us do so, we may use information we hold about you in order to better understand your interests. You can opt out of this by using the in-app help service or by emailing privacy@nevly.com;
if you agree, allow our partners and other organizations to provide you with information about their goods or services;
measure or understand the effectiveness of our advertising, and provide relevant advertising to you; or
process applications for products and services available through us and make decisions about whether to approve applications.

Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices within the app.

The types of information we use are:

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION FOR MARKETING
If you are a Nevly customer, we may contact you about optional extras or promotional offers. We may use information we gather about you through your use of our services to tailor these offers to you.

To keep our services up and running

We use your personal information to manage our website and the Nevly app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device. For more information, please see our Cookies Policy
We also use your personal information to allow you to take part in interactive features of our services, to tell you about changes to our services, and to help keep our website and the Nevly app safe and secure.

The types of information we use are:

information you have provided; and/or
information from your device.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION TO RUN OUR SERVICES
If any changes we make to our services affect you, we’ll normally contact you using the email address you gave us when you signed up, or through the Nevly app, to tell you about the changes.

Helping with customer service

We use your personal information to provide customer service, help you complete transactions, and to add extra functions in order to provide a better experience.

The types of information we use are:

information you have provided;
information from your device; and/or
location information.

HERE’S AN EXAMPLE OF HOW WE USE YOUR PERSONAL INFORMATION FOR SOCIAL INTERACTIONS

We’ll let you know if any of your contacts who are Nevly customers have used our products, upgrades or features or are in the same area as you (if they have consented to connecting to contacts within Nevly and location services switched on).

If you have the relevant settings in the Nevly app switched on, we’ll use the contact list on your phone, or your photo gallery, so you can easily make payments to your contacts and send photos with the Nevly app.

Advertising based on location

We use your information to provide relevant advertising to you (for example, information on nearby merchants).

The types of information we use are:

information you have provided; and
location information.

HERE’S AN EXAMPLE OF HOW WE USE YOUR LOCATION INFORMATION
If you go abroad, the Nevly app may automatically tell you the exchange rate in that country.

The legal basis for collecting your information includes:

keeping to contracts and agreements between you and us;
legitimate interests (to develop and market our obligations and keep to regulations that apply to us); and/or
consent (to track you when you have location services switched on).

Meeting our legal obligations, enforcing our rights and other legal uses

We may need to share information about you:

with other entities (for example, fraud prevention vendors);
if it is necessary to meet our legal obligations or in connection with legal claims; and/or
to help detect or prevent crime.

You can find out more in the “Do you share my information with anyone else?” section below.

The types of information we may share include:

information you have provided;
information from your device;
location information;
information from third parties; and/or
social media information.

5. Do you carry out credit checks or make any automated decisions about me?

WE WILL CARRY OUT A CREDIT CHECK IF YOU APPLY FOR A CREDIT PRODUCT

We (and our lending partners) use credit reporting agencies to carry out credit checks on you. This means that when you apply for credit products, or we suggest credit products to you through the Nevly app, we can better understand your financial circumstances and repayment history and can tailor our credit products to your needs.

WITH YOUR CONSENT, WE MAY CARRY OUT A CREDIT CHECK TO OFFER YOU CREDIT PRODUCTS AND SERVICES YOU MAY QUALIFY FOR.

Some of the searches leave a ‘soft footprint’ on your credit history. This means that the search will be registered on your credit file but will not be visible to others if they search your credit history. (Basically, you will be able to see this footprint but other people won’t – see here for more information.) A soft footprint will not affect your credit rating.
Some of our third-party providers, such as fraud prevention vendors, may also use credit reference agencies to help us check your identity and prevent fraud. These searches also only leave a trace on your credit history.
You can withdraw your consent for credit checks by contacting us through the Nevly app.

6. How do you use my information for marketing?

If you sign up to our services, we will assume you want us to contact you by post, email and phone (including text message) with offers and promotions. We may use the information we have collected about you in order to tailor our offers to you.

You can adjust your preferences or tell us you don’t want to hear from us, at any time. Just use the ‘Privacy’ section within the ‘Profile’ section of the Nevly app or click on the unsubscribe links on any marketing message we send you.

We won’t pass your details on to any organizations outside the Nevly group of companies for their marketing purposes without your consent. You can find out more in the “Do you share my information with anyone else?” section.

YOUR RIGHTS

7. What are my rights?

You have the right to be informed about how we use your personal information.

We provide this privacy notice to explain how we use your personal information.

You can ask to see the personal information we hold about you (this is called making a data subject access request, or DSAR for short).

You can also ask for information about what information we process about you and why. If you make a DSAR, we will provide a copy of the personal information we hold about you.
This right is subject to exceptions. For example, we can only provide you with information as required and permitted under the Law and we cannot provide you with personal information about other people.

You can ask us to correct your personal information if you think it’s wrong.

You can have incomplete or inaccurate information corrected. Before we update your file, we may need to check the accuracy of the new information you have provided.

You can ask us to delete your personal information.

You can ask us to delete your personal information if:

There’s no good reason for us to continue using it;
You gave us consent to use the information and you have now withdrawn that consent;
You have objected to us using the information;
We have used the information unlawfully; or
The law requires us to delete the information.

Just to let you know, we may not be able to delete some of your information. We will keep certain customer information for at least six years (we’ve explained this in more detail below). If you’ve closed your Nevly account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We will always let you know if we can’t delete your information.

You can object to us processing your personal information for marketing purposes.

You can tell us to stop using your personal information for marketing.

You can object to us processing other information (if we are using it for legitimate interests).

If our legal basis for using your personal information is ‘legitimate interests’ and you disagree with us using it, you can object.
However, if there is an overriding reason why we need to use the information (for example, legal reasons), we will not accept your request
If you object to us using information which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services.

You can ask us to restrict how we use your personal information.

You can ask us to suspend using your personal information if:

You want us to investigate whether it is accurate;
Our use of the information is unlawful but you do not want us to delete it;
We no longer need the information, but you want us to continue holding it for you in connection with a legal claim; or
You have objected to us using your information (see above), but we need to check whether we have an overriding reason to use it.

You can ask us to transfer personal information to you.

If we can, and are allowed to do so under regulatory requirements, we will provide your personal information in a structured, commonly used, machine-readable format.

You can withdraw your consent.

If you have given us any consent we need to use your personal information, you can withdraw your consent at any time by changing your settings in the Nevly app (or sending an email to privacy@nevly.com). (Note, it will have been lawful for us to use the personal information up to the point you withdrew your consent).

8. How do I exercise my rights?

To exercise any of your rights set out in the previous section, you can contact us through the Nevly app or send us an email at privacy@nevly.com.

Nevly will verify your identity before it fulfills your request. We may do that in different ways:

We may require government-issued identification documents and a recent photograph.
You may also be required to verify your email address.
Before Nevly can produce personal Information, Nevly may ask you to submit a signed declaration attesting to your identity under penalty of perjury.
Depending on your existing relationship with Nevly, Nevly may ask you to provide identifying information you previously provided to Nevly for verification.
You can designate an authorized agent to make a request on your behalf. Nevly will ask you to provide a written authorization or power of attorney. Please reach out to privacy@nevly.com to process an authorization.

Nevly will not discriminate against you in any way because you exercise any rights conferred by this Privacy Notice.

If you are unhappy with how we have handled your personal information you can file a formal complaint by sending us an email to complaints@nevly.com.

9. Do you share my information with anyone else?

NEVLY GROUP COMPANIES

We share your personal information within the Nevly group of companies in order to provide you with the best service.

OTHER NEVLY CUSTOMERS

Certain Services on the Nevly platform will connect you with other customers. In order to provide you with these services, we may ask you to let us sync your mobile phone contacts. This will help you to identify which of your trusted mobile phone contacts are Nevly customers. Your ‘trusted contacts’ will also be able to see if you are a Nevly customer through our ‘Payment with Friends’ functionality.
We use technological safeguards to ensure a ‘trusted contact’ is somebody you already know and who knows you (for example, you have each other saved in each other’s mobile phone contacts lists or have already received or given money through a peer-to-peer payment with them).
Both you and your trusted contact must have synced your mobile phone contacts lists with Nevly to be viewable to each other in the Nevly app.
We only show your basic contact details in the Nevly app to your trusted contacts who are also Nevly customers (for example, your name (as saved in your friend’s contacts list), mobile phone number, Nevly username, your Nevly profile photo (if you have one)).
You can, of course, choose not to sync your contacts list with Nevly. This means that you will not be able to identify which of your mobile phone contacts are Nevly customers.
You can also turn off ‘Payments with Friends’ through the privacy settings in the Nevly app.

SUPPLIERS

The list below explains which suppliers we normally share your personal information with.

Suppliers who provide us with IT, payment and delivery services

To help us provide our services to you

Our banking and financial services partners and payments networks, including Visa and Mastercard

To help us provide our services to you – this includes banking and lending partners, banking intermediaries and international payment service providers

Card manufacturing, personalization and delivery companies

To create and deliver your personalized Nevly Card

ADVERTISERS

To promote our services (we provide anonymous information only)

Analytics providers and search information providers

To help us improve our website

Customer service providers, survey providers and developers

To help us to provide our services to you

Communications services providers

To help us send you emails, push notifications and text messages

PARTNERS WHO HELP TO PROVIDE OUR SERVICES

We may share your personal information with our partners in order to provide you with certain services you have asked us for.

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR INFORMATION WITH OUR PARTNERS

If you have asked for rent reporting services, we will share relevant information to the provider of rent reporting services.

We will only share your personal information in this way to provide you with the relevant service.

From time to time, we may work with other partners to offer you co-branded services or promotional offers, and we will share some of your personal information with those partners. We will always get your consent before sharing your information for these purposes. You can withdraw your consent at any time by contacting us through the Nevly app.

Our partners will have their own privacy notice explaining how they use your personal information. It’s important that you read those privacy notices as well.

CREDIT REPORTING AGENCIES

If you apply for a credit product, we’ll share your personal information with credit reporting agencies.

FOR LEGAL REASONS

We also share your personal information with fraud-prevention agencies to check your identity, protect against fraud, comply with anti-money-laundering laws, and confirm that you are eligible to use our products and services.

HERE’S AN EXAMPLE OF WHEN WE MIGHT SHARE YOUR PERSONAL INFORMATION FOR LEGAL REASONS

If you give us false or inaccurate information and we identify fraud, we will let fraud-prevention agencies know. Law-enforcement agencies may request and use this information.

WE MAY ALSO NEED TO SHARE YOUR PERSONAL INFORMATION WITH OTHER THIRD-PARTY ORGANIZATIONS:

if we have to do so under any law or regulation;
if we sell our business;
in connection with criminal or fraud investigations;
to enforce our rights (and those of customers or others); or
in connection with legal claims.

Nevly does not sell your personal information to third parties. Nevly has both used third parties to collect personal information and has disclosed personal information to third parties to accomplish the business purposes described above.

NEVLY AND YOUR PERSONAL INFORMATION

10. Will my information go outside the United States?

We may transfer your personal information outside the US to provide our services. We may store your personal information outside of the United States or use affiliates or service providers located outside of the United States to offer you our products and services.

For example, if you ask to make an international payment, we will send funds to banks overseas. We might also send your information overseas to keep to global legal and regulatory requirements, and to provide ongoing support services.

We may share your personal information with credit reporting agencies and fraud-prevention agencies outside the US.

We will take all reasonable steps to make sure that your personal information is handled securely and in line with this privacy notice and data protection laws.

If you would like more information, please contact us through the Nevly app or by sending an email to privacy@nevly.com.

11. How do you protect my personal information?

We store your information on our secure servers.
Any payment transactions carried out by us or our payment processing providers will be encrypted using Secured Sockets Layer technology or a secure virtual private network.
If you use a password for the Nevly app or our website, you will need to keep this password confidential. Please do not share it with anyone.
Unfortunately, providing information online is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee that all information you provide through the Nevly app or our website will be secure. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
When you use our services, which include social features and chat functions, do not share any personal information that you don’t want to be seen, collected, or used by other users, as this information will become publicly available.

12. How long will you keep my personal information for?

Under anti-money laundering laws we will hold information about you and your transactions for a minimum of five years.

Generally, we will not hold your personal information for more than six years after our business relationship with you has ended, unless we need to hold it for longer because of a potential or ongoing claim, suspected fraud, or another legal reason.

13. How will you keep me updated on how you use my information?

If we change the way we use your personal information, we will update this notice and, if appropriate, let you know by text message, by email, through the Nevly app or through our website.

14. Cookies

We use cookies to analyze how you use our website. Please read the Cookies Policy for more information about cookies.

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This Policy was last updated on May 3h, 2022.
We are incorporated in Delaware and have our registered office at A Registered Agent, Inc., 8 The Green, Suite A, Dover, Kent DE, 19901. Our US headquarters is based in Austin, TX. Nevly provides services only to U.S. residents.