Soljari Privacy Policy

Last updated: Octomber 17th, 2022

Scope

Welcome to Soljari’s Privacy Statement. Your right to privacy and online security is important. This Privacy Statement describes Soljari Inc.’s collection, protection, disclosure, and use of your information. This Privacy Statement applies to all of Soljari’s websites, mobile applications, and/or online services, that link to or reference this Privacy Statement. It covers your personal information that is provided or collected through the use of our services and how we use that information in connection with our services.

By using Soljari, you agree to this Privacy Statement. If you do not agree with any term in this Privacy Statement, please do not use our services.

Here's a quick overview:

Soljari is a shared ledger for friends. Expenses you add in Soljari are not public. Friends who are included on an expense can view that expense, and, if an expense is added in a group, other group members can view expenses shared on Soljari. You choose who you share your expenses with and what kind of expenses you want to share. Anyone shared on an expense or in a shared group has the ability to edit, delete, and undelete the expenses that have been shared with them.

In order to use Soljari, we ask that you create an account. When you sign up we'll ask for some registration information such as name, email address and phone number. We need this information to create an account so that we can contact you about your account, so that your friends can find you, and so you can access your account from anywhere.

In addition to sharing your registration information to set up your account, we collect some other information about you, such as the type of device you use and your IP address. We may also collect information about the type of expenses you add, or the groups you create. We use this information to help improve and secure our service and to show ads based on your usage of our services.

You have control over the type of information you provide and how we use it. We don’t share your registration or personal information for marketing purposes. We will never share your information with other parties for use other than what’s laid out in this policy without your consent. You can view your Privacy and Notification Settings from your Account Settings page. If you have any questions please contact us at support@soljari.com.

Soljari or its partners or service providers may maintain operations in the United States or any other country, and therefore your personal information may be processed outside the country where you are located. By using and providing information to us, you agree and consent to the transfer, storage, and processing of your information in other countries, including for example outside the European Economic Area. Countries that we transfer your information to may not have data protection laws similar to those of where you are located.

Soljari is not intended for use by children under 13 years of age or minors. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, they should contact us at support@soljari.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files immediately.

DATA WE COLLECT

When you use Soljari, we may collect the following information about you:

• Registration information: When you sign up for an account with Soljari, you will be asked for registration information, such as your name, email address, phone number, and a password. We require you to provide an email address in order to use Soljari so that we can contact you about your account, and so that you can access your data from any device. Friends will be able to add you using your email address. We require you to provide a name for your account, this is the name your friends will see when adding expenses with you. Providing a phone number gives your friends another way to find you and adds an extra layer of security to your account. You can make changes to this information at any point from your Account Settings page or by emailing us at support@soljari.com.
• User-generated content: We also collect and store the information you provide to us when using our service to share expenses, payments, and communicate with others. This data includes, for example, group names, expense descriptions and amounts, payments and their confirmation numbers, comments and reminders, receipt images, notes, and memos, in addition to any other information that you attach or share while using Soljari. You may share this information with contacts you specify in the course of using the Service. For example, if you add an expense with a group of roommates, those roommates will be able to see that bill, while users who are not the roommates group will not. You are solely responsible for which contacts you share this information with.
  
  • We may offer bulletin boards, blogs, chat rooms, message boards, or similar public forums where you can communicate with us or other users. Any information that you submit or post to these blogs or other forums could be viewed by other viewers or may otherwise be publically available. For example, new feature suggestions posted in our public suggestion forum are public and can be viewed by anyone. We don’t recommend posting personal information in public forums. If you choose to post personal information, other viewers may use this information to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these blogs and other forums, so please be careful about what you disclose and do not post any information that you expect to keep private. If you would like to request removal of your information from our blogs or other forums, please contact us at support@soljari.com.
• The way you use our service: We collect information about how you use and interact with Soljari. Such as the types of expenses you add, the features you use, the actions you take, and the time, frequency and duration of your activities. For example, we log when and how often you add images to a bill and may use that information to improve our service or suggest new features we offer.
• Information Shared By Others: Other Soljari users may share information with you using your contact information (such as email or phone number), and that information will be stored in the course of using Soljari. For instance, if a contact of yours shares a bill with you or adds you to a group using your email address, Soljari may notify you and store that information under your account according to your preferences.
• Device and Location information: When you download or use Soljari, we may receive information about your device and location, which allows us to provide increased account security and regulatory compliance. It also allows us to provide location-based services such as targeted advertising, search results, and other personalized content. We also collect information about your interaction with Soljari including, but not limited to, your computer browser type, pages visited, advertisements clicked on, average time spent on our Sites, your IP address, unique identifiers of your device, the operating system version and app version.
• Payment information: Soljari may offers paid premium services (“Splitwise Pro”) in some markets. If you choose to subscribe to this service, we will ask for additional information. This includes your payment information, such as your credit or debit card number, other card information, and other account and authentication information, as well as billing, and contact details. For certain services, you may be required to provide your checking account number and routing number. For security purposes, you may also be asked to provide identification information to confirm your identity, including your first and last name, address, and phone number, or in some cases, last four digits of a social security number or a copy of an identification document.
• Information related to Third Party Integrations: Soljari may collect information about you from third parties to help improve our service, or for security and support reasons. If you choose to use some of the optional integrations the third party services that we offer we may collect information about you from those services. For example, if you choose to send payments to your friends using one of the payment services we integrate with we may collect information from that payment service (i.e. your username for that service, the status of that payment).
  • Google accounts: As part of using Soljari, you may be presented with the option to link one or more parts of your Google account to your Soljari account. If you authorize Soljari to use your Google Account to login to Soljari, your name, contact information (usually an email address) and other basic account details (profile picture, age, gender, birthday) may be shared with Soljari at your discretion. Sharing this data is not required to start a Soljari account. These details will be stored by Soljari and will generally be treated as if you had manually provided that data to Soljari under this privacy policy (for instance: to sign in with Google in the future, to contact you, display your profile picture, reset your password, set a default currency).
• Contests and surveys: From time to time, you may be offered an opportunity to participate in a contest, survey, or other voluntary promotion. We may collect contact or marketing information in connection with one of these promotions.
  • When we run a contest, sweepstake or game relating to our Sites, it will be accompanied by a set of rules. The rules for each contest, sweepstakes or game will specify how the information gathered from you for entry will be used and disclosed if it is different than as described in this Privacy Policy. In conjunction with your entry in such contest or sweepstakes, your information will be collected if you voluntarily submit it.
• Information from other sources: We may use publicly available information about your name, email address, phone number, or other demographic data to help you during support, to address fraud or security concerns, or to personalize your experience, including by providing ads or offers. For instance, if you have a public avatar stored on a service such as Gravatar associated with your email, we may automatically populate your user avatar on Soljari. We may also collect information about you that we may receive from other sources or from our offline interactions with you to, among other things, enable us to verify, update information contained in our records, and to better customize the Service for you.
• Other information: We may request or receive other information such as feedback, questions, comments, suggestions, or ideas to provide you with other benefits or to improve upon the Service.

HOW WE USE DATA

WE WILL NOT PROVIDE ANY OF YOUR PERSONAL INFORMATION TO ANY THIRD PARTY EXCEPT AS OUTLINED IN THIS POLICY OR WITH YOUR CONSENT

We use your information for the following purposes:

Soljari is designed to help people share expenses and informal IOUs with friends. We process your information to provide, support, and secure our service (both automatically and manually). For example, we may use your information in some of the following ways:

• To record informal records of expenses, IOUs, and payments.
• To fulfill your requests for certain products and Services.
• To help your Soljari contacts manage their Soljari relationship with you. For example, we may display your Soljari email address to your Soljari friends and group members so they may identify that they are sharing bills with the correct person.
• Respond to your inquiries about our Services. For example, if you or a Soljari friend of yours contacts us for support, or as part of a random account audit, we may go into your account in "administrator mode" to help provide support to you or a friend.
• To detect and protect against errors, fraud, or other criminal activity.
• We may use your information for internal security purposes. For example, if you have activated a feature that limits access to a Service from a specific device, our systems will access the Device ID from each device you attempt to access the Service with to determine if the device is the specific authorized device. Additionally, we may use identifying information to monitor suspicious activity. For example, if we detect that a single account on a Site is being accessed from multiple devices, as determined by tracking the Device IDs that access an account, we may contact the user to ensure that such access has been authorized by the user.
• To verify your identity in the event you contact us for assistance.
• To analyze Site usage, perform market research, project planning, product development, troubleshooting problems, analysis of user behavior, internal marketing and promotions, or other efforts to improve our service quality.
• To pre-fill form fields or store preferences for your convenience.
• To alert you to software compatibility issues and to improve our web design and functionality.
• To communicate with you. For example, we will email you when we release new features, have important news, and when you have a notification generated by activity (including a monthly summary). All of these emails are optional and can be set by going into your Account Settings. Some emails, such as, updates to our Privacy Policy, information about your account, password resets, or other security issues are not optional.
• To enforce our Terms of Service

Friends can find your account on Soljari by conducting a search via your email address or phone number. When friends add you on Soljari they’re only able to see what you’ve shared with them. You can manage your preference for this setting from your Account Settings page.

We may receive and collect information about you from Third Parties and affiliates that help us provide, support, and secure our services. In general, data shared with Soljari in this manner will be treated under the same privacy restrictions as any other data shared with Soljari. For example:

• If you choose to settle up via one of the third party payment integrations we offer we may collect information from the service. We will use the data you’ve supplied in your account to assist in completing that payment. We may use information from that Service to display the status of that payment to you. We may also use information about payments sent via third party services to address fraud, security, or support issues.
• If you give Soljari access to your Google Contacts as part of using our service, this contact data may be used in a limited way: to send Soljari invitations on your behalf to friends (to individuals specifically authorized by you; not in bulk), to locate your friends who already use Soljari, to recommend friends to invite to Soljari, and to improve our services (for example, to identify common email spelling errors in user support). If you share access to your Google account contacts, Soljari may store some of this information for those purposes.
• For some services, Soljari uses Plaid Technologies, Inc. (“Plaid”) to gather End User’s data from financial institutions. If you use a service like this, you grant Client and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy (https://plaid.com/legal). We will request your permission before granting such access.

Where permitted by Applicable Law, we may use your email/phone, location, usage and expense information to show you specific advertisements or offers on our own site that we believe may be of interest to you. For instance, we may show ads for apartments cheaper than your current apartment based on the rent expense you share on our system.

HOW WE SHARE YOUR INFORMATION

We will not, without your permission, sell, publish, or share your personal information to third parties for their marketing purposes. We help you track and manage shared expenses with your friends by sharing your information in the following ways:

Soljari is designed to help you track and share expenses with your friends. We share some of your personal information (name, email address, phone number, user avatar) with your friends and groupmates on Soljari. Someone who knows your email address and/or phone number will be able to add you as a friend and see your name, email address, and user avatar. They will not be able to see expenses that you’ve added with other friends unless you include them on those expenses or in a group.

• Soljari allows you to keep track of expenses in groups. These groups are private, and information and expenses posted in a group is only visible to other members of the group. However, any user in that group may add additional members to the group, so it is the joint and sole responsibility of group members to safeguard who they invite into their group sharing platform.
• Soljari lets friends add, edit, delete and undelete content shared privately.

We employ third party agents, subsidiaries, affiliates, and/or service providers to enable them to help support and improve our services. For example, maintenance services, database management, cloud hosting, web and mobile analytics, receipt scanning services and OCR. Third parties acting on our behalf that are given access to your personal information are contractually obligated to abide by our privacy practices and are not allowed to use the information for any other purposes. We may share your personal information with other third parties with your consent or instructions to do so.

• Where permitted by law, third parties may use data provided to them to improve their own services; for instance, a third party receipt-scanning service may improve the OCR quality of their OCR service by training an algorithm on receipts you provide to Soljari.

• to respond to subpoenas, court orders, or legal process;
• in order to investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites, or Services;
• to respond to claims that any posting or other content violates the rights of third parties;
• in an emergency, to protect the health and safety of our Sites' users or the general public; or
• as otherwise required by any applicable law.

If our company or our assets are acquired by another company, or in the event of a merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties, information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us. Such third parties will assume responsibility for the personal information collected by us in connection with our business operations or through our Sites and such third parties will assume the rights and obligations regarding such information as described in this Privacy Statement and according to applicable regulations.

Soljari provides a third party API which allows other applications which you sign up for to have access to the data you have provided Soljari. You are in control of this process - we do not disclose any data to these third parties unless you specifically authorize your account with their application by using the Soljari username and password prompt provided. We do not control these third parties and do not warrant that they are safe or non-fraudulent, and you agree that Soljari is not responsible, liable for anything which occurs on these services. You indemnify Soljari Inc. from all damages if you authorize your Soljari account with one of these 3rd party applications.

We may disclose information that does not personally identify you in any other manner that we deem appropriate, including to third parties for their research, marketing, and promotional purposes and to help us determine how we can improve our Sites. We will also disclose non-personal information to our service providers and other third parties about how our users collectively use the Sites.

SECURITY

We take the security of your information seriously. We use technical and administrative security measures such as but not limited to encryption techniques and authentication procedures, among others, to maintain the security of your online session. Please understand, however, that while we try our best to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

We will contact you regarding any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal information to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Identity theft and the practice currently known as "phishing" are of great concern to Splitwise®. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission's website at http://www.ftc.gov.

COOKIES

Like many websites, we use tracking technologies such as cookies, web beacons and similar technologies to record your preferences, track the use of Soljari and exposure to our online advertisements. We may also use these technologies to monitor traffic, improve Soljari, and make it easier to use and more relevant.

We partner with third party advertising companies who also use these tracking tools to provide advertisements on our Websites or other websites. These third parties may use these technologies to collect information about you when you use our services. They may collect information about your online activities over time and across different websites and other online services. They may also use persistent identifiers to track your Internet usage across other websites in their networks beyond the Websites. They may use this information to provide you with interest-based advertising or other targeted content. While we do not knowingly provide these entities with information that personally identifies you such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us. To learn more about the third-party collection and use of your information, please visit the Digital Advertising Alliance and/or the Network Advertising Initiative.

Some content or applications on our Sites, including advertisements, are served by unaffiliated third parties. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

Your browser or device may include “Do Not Track” functionality. Soljari’s information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received. To learn more about how Do Not Track works, please visit

You also have choices to limit some tracking mechanisms that collect information when you use our Services. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline cookies if you prefer. If you choose to decline cookies, certain features of our Services, including the Service itself may not function properly or remain accessible to you. For example, you cannot log into soljari.com if you've disabled all cookie use.In addition, you may also render some web beacons unusable by rejecting or removing their associated cookies. Note that if you choose to remove cookies, you may remove opt-out cookies that affect your advertising preferences.

You may opt out of tracking of analytics data by Google Analytics, one of our customer usage analytics providers, by clicking here

Many of the third parties advertisers that place tracking tools on our Sites are members of programs that offer you additional choices regarding the collection and use of your information. You can learn more about the options available to limit these third parties’ collection and use of your information by visiting the websites for the Network Advertising Initiative and the Digital Advertising Alliance, as well as the webpages for Facebook’s ad preferences tool and privacy policy

Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see

Apple: http://support.apple.com/kb/HT4228

Android: http://www.google.com/policies/technologies/ads/

Windows: http://choice.microsoft.com/en-US/opt-out

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Sites or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.

You may access, review, and update the personal information you have submitted to us at any time. You can make changes to your personal information from your Account Settings page. If you need help updating or correcting your information please contact us at support@soljari.com.

Users can export data from their groups and friendships by following the instructions found here. We’re happy to help provide exports from your account. You can request exports by contacting us at support@soljari.com.

• Personal information: You may choose not to provide your personal information, such as your name, address, phone number or payment information, but then you might not be able to take advantage of many of our Sites’ features.
• Emails, Newsletters, and other communications: We may send periodic Site related alerts, monthly summaries, notifications, newsletters, promotions, or other information via email or push notifications. You may choose whether or not you’d like to receive alerts, summaries, newsletters and promotions by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in the email you receive. Please note that certain Services-related messages (such as password resets) that we send are necessary for the proper functioning and use of the Services and you may not have the ability to opt-out of those messages.
• Location Tracking: Most mobile devices allow you to control or disable the use of location services by any application on your mobile device through the device’s settings’ menu.
• Allow friends to find you: You can choose whether or not you want friends to know if your email address of phone number is already associated with a Soljari account from your Account Settings page. Friends with your contact information will still be able to send you invitations and share expenses with you.
• Third parties: You have the ability to choose whether or not you’d like to use many of the third-party integrations we offer. If you authorize an account connection from a third-party account or platform, such as a Google or Facebook account, you can manage your connection preferences from the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.

You may choose to close your account at any time. You can close your account from your Account Settings page, or request that we close it for you by writing to us at support@soljari.com. When you close your account in this way, we may allow you to reactivate it by writing to us at support@soljari.com.

In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. We may also retain personal information to comply with law, prevent fraud, resolve disputes, enforce our Terms of Service, and as permitted by applicable law.

If you would like to fully delete your account and the information in it, you can write to us at support@soljari.com. We will use commercially reasonable efforts to remove your personal information from our services so long as we do not have any legal reason or obligation to retain the record. It may take up to 90 days for your information to be cleared from our servers.

When you change or delete personal information, or close your account from your Account Settings page, expenses involving you (either that you have shared or that have been shared with you) and your name may remain visible to people with whom they have been shared as part of their records (just as deleting an email account does not unsend emails that have already been sent).

Soljari complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

Soljari has certified to the Department of Commerce that we adhere to the Privacy Shield Principles, including those relating to Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. We commit to subject to the Principles all personal data received from the EEA in reliance on the Privacy Shield. These Principles include without limitation (i) the possibility for the individual to invoke binding arbitration and (ii) our liability in the case of onward transfer to third parties. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights an individual may have to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit https://www.privacyshield.gov

Soljari commits to resolve complaints about privacy and our collection or use of personal information in compliance with Privacy Shield Principles. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Soljari at support@soljari.com. Soljari further has committed to refer unresolved privacy complaints to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit

https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint. The services of JAMS are provided at no cost to the individual.

The Federal Trade Commission has enforcement authority regarding Soljari’s compliance with the Privacy Shield Principles

CHANGES

We may update this Privacy Statement periodically. Changes are effective immediately upon posting. The date last revised appears at the top of this Statement.

CONTACT US

If you have questions or concerns regarding this Privacy Statement, our security practices, or our information handling practices please contact Soljari in writing:

• Email: support@soljari.com