Privacy Policy

Last updated: May 8, 2024

We take your privacy seriously. This Privacy Policy explains our practices with respect to our collection, transfer, storage, disclosure, and other uses of Your Information and certain other information collected by us through our mobile Application called KESPAM powered by Leap Financial, including any of its subdomains and each of its available tools (the “Platform”) which are operated by Leap Financial Inc.  Hereinafter KESPAM and the Platform will be called the “Services”. This Privacy Policy does not apply to information collected by us through mediums other than our Services, or to information collected by any person or entity other than us, even if related to our Services (such as a third-party website, content, or application).

Please read this Privacy Policy carefully before using our Services. By using our Services, or by clicking to accept or agree to our Terms when this option is made available to you, you accept and agree to be bound and abide by our Terms, including this Privacy Policy. If you do not want information used or disclosed in the manner described in this Privacy Policy, or if you do not agree with any term or condition in this Privacy Policy or our Terms, then you must not access or use our Services or submit information to us. Capitalized terms used in this Privacy Policy but not otherwise defined have the meanings ascribed to them by our Terms. You may also consult our GLBA Privacy Policy for reference to the procedures and controls our company has implemented to ensure the security and confidentiality of consumers' private information.

1. Our Collection of Your Information and Information of Third Parties.

From time to time, you may provide us with Your Information or the information of third parties. Instances, where you may provide Your Information or information of third parties, include when you register for or create an account with our Services when you initiate your transactions or other activities conducted on or through our Services, and when you otherwise communicate with us (including our Customer Service) or with third parties with which we have relationships.

Additionally, we collect information that you generate when using our Services. For example, our Services may allow you to communicate, share or post information with us as well as other users through our Services, such as when you may request funds from third parties on or through our Services. We may also collect information about you from sources other than you, such as from our third-party service providers, like our identity verification and electronic database service providers. Some examples of the information we collect because of the practices described above include:

• Your name, date of birth, mailing address, phone number, email address, contact preferences, and credit card information.
• Information you provide us about third parties, such as name, mailing address, email address, and phone number.

It is important to note that our Services require access to your contact list to simplify and optimize some transactions. The types of information we collect from your contact list include a) Contact names and b) Phone numbers. We use the data to initiate your fund request and confirm the payment's status.

We do not share your contact list information with any third parties except for cases mentioned in Section 8.

We take your and your contact's data security seriously, so we have implemented robust measures to protect your data from unauthorized access, alteration, or destruction.

2. Other information we collect (non-personally identifiable information).

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose this for any purpose. The following are some examples of non-personally identifiable information that we collect and how we may use it:

• We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a product is used so that we can better understand customer behavior and improve our products, services, and advertising.
• We may collect information regarding customer activities on our website and Mobile Cloud Services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and Services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
• We may collect and store details of how you use our Services, including search queries. This information may be used to improve the relevance of results provided by our Services. Except in limited instances to ensure the quality of our Services over the Internet, such information will not be associated with your IP address.
• With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information, the combined information will be treated as personally identifiable information for as long as it remains combined.

3. Cookies and Other Technologies.

We and third parties acting on our behalf may use various technologies to collect and store information when you use our Services, including sending cookies, web beacons, pixel tags, or other anonymous identifiers to your device. These technologies help us know that you are logged on to or using our Services, provide you with features based on your preferences, help us understand when and how you are interacting with our Services, and compile other information regarding your use of our Services.

The information collected through these technologies, standing alone, cannot be used to determine your identity. Such information may, however, be combined in a way that makes it become personally identifiable information (i.e., information that can identify you). For example, we may tie this information to personal information about you that we collect from other sources or that you provide to us. If this happens, we will treat the combined information as personally identifiable information.

It may be possible to disable some (but not all) Cookies through your device or browser settings but doing so may affect the functionality of our Services. The method for disabling Cookies or other automatic collection technologies may vary by device and browser but can usually be found in preferences or security settings. For example, iOS and Android devices each have settings that are designed to limit forms of ad tracking.

We partner with a third party to either display advertising on our Services or to manage our advertising on other sites or mediums. Our third-party partner may use technologies such as cookies to gather information about your activities on our Services and other sites to provide you advertising based on your browsing activities and interests. If you wish to opt out of interest-based advertising, you may do through email at: support@numiapps.com or by mail at 2900 Southwest 28^th Terrace, Suite 202, Coconut Grove, FL 33133, USA.

4. Other Certain Information.

General Use and Preference Information. We may collect, receive, and store information regarding your general use of our Services (such as details of how and when you used our Services, interactions with our Services, login information, resources that you access, your Internet protocol address, your browser type, and your device type), as well as your preferences.

Device Information. When you access or use our Services through your computer, mobile phone, or another device, we may collect information regarding and related to your devices, such as hardware models and IDs, device type, operating system version, the request type, the content of your request, and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events, such as crashes, and associate that temporarily with your account (if any) to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

Location Information. If you submit your zip code or other geographic information to us, you may provide us with your location information. Furthermore, if you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device’s GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers) or obtain your location information from third parties.

Other IP Information. We gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, administer the site, learn about user behavior on the site, improve our product and Services, and gather demographic information about our user base.

Click-Through Data. In some of our email messages, we use a "click-through URL" linked to content on the KESPAM website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Additionally, pixel tags enable us to send email messages in formats customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

5. Third-Party Collection of Information via Our Services.

Certain features or functionalities of our Services may be served by third parties, such as Unidos, Visa, and other content and application providers. These third parties may collect information about you when you use our Services. We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

6. Children Under the Age of 13.

Our Services are intended to be accessed and used only by adults and are not directed to minors. We do not knowingly collect personally identifiable information from anyone under the age of 13 and you should not provide us with any information regarding any individual under the age of 13. If we learn that we have inadvertently gathered information from anyone under the age of 13, we will take reasonable measures to promptly remove that information from our records.

7. How we use information collected by us.

We and our affiliates will use the information we collect consistent with this Privacy Policy. We may use the information we collect for various lawful business purposes. Among others, these purposes may include using such information:

• To provide our Services to you, for example, to process your transactions conducted on us through our Services,
• To help us create, develop, operate, deliver, and improve our products, services, content, and advertising,
• For loss prevention and anti-fraud purposes, or to prevent loss, fraud, or other illegal uses of our Services,
• To comply with applicable law, rules, or regulations, including with respect to any applicable anti-money laundering mandates,
• To verify identity, assist with identification of users, and determine appropriate services,
• To send important notices, such as communications about your transactions and changes to our Terms,
• For internal purposes such as auditing, data analysis, and research to improve KESPAM's products, Services, and customer communications,
• To resolve problems and disputes, and engage in other legal and security matters, for example, to comply with, monitor compliance with and enforce this Privacy Policy, our Terms (including any terms and conditions incorporated or referenced in our Terms), and any other applicable agreements and policies, meet other legal and regulatory requirements, and protect the security and integrity of our Services, and to display advertisements to our advertisers' target audiences. Note, even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

8. Sharing Information with Our Affiliates.

Our policy is to ensure that all regulatory processes are properly accepted, processed, and retained in compliance with all applicable laws, rules, and regulations, including the procedures for sharing information with our affiliates that is strictly necessary to perform the transaction or provide technical and operational support. This guarantees information assets' confidentiality, integrity, and availability within acceptable risk levels.

Suppose our affiliate requires additional information about a client or transaction information for regulatory reasons. In that case, it must request the list of clients (name and last name) or the transaction identification through a Compliance Request Report we will provide.

9. Our disclosure of information we collect - General Disclosures.

We may disclose the information we collect:

• To our affiliates and their respective employees, agents, and representatives involved in delivering our Services and other products and services to you,
• To any person who, in our reasonable judgment, is authorized to receive such information as your agent, including because of your business dealings with that person (for example, your attorney),
• To our third-party vendors who provide support for our internal and business operations, including for the handling of data processing, data verification, data storage, research, internal marketing, delivery of promotional, marketing, and transaction materials, and our Services’ maintenance and security,
• To fulfill the purpose for which you provide it,
• As required by applicable law or ordered by a court, regulatory, or administrative agency,
• As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, restriction, or regulation, or are otherwise interfering with another’s rights or property, including our rights or property,
• If requested by any governmental authority or an agency thereof,
• To enforce our Terms, including this Privacy Policy, and any other applicable agreements and policies,
• With your consent,
• To enforce or protect our rights, and
• In connection with a Business Transfer (see “Other Disclosures by Us of Your Content” below).

Please note that the list above is not exhaustive and that we may, in our sole discretion, share, loan, rent, sell, or otherwise disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you.

When we disclose the information, we collect to third parties, this information will become permanently subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of such information. As a result, such third parties may further disclose, share and use such information. By submitting information to us, you expressly consent to such disclosure and use of such information. If you do not want information shared as described above, then you should not provide us with such information.

10. Other Disclosures by Us of Information.

Aggregation and De-Personalization. We may take the information we collect and de-identify it either by combining it with information about others (for example, by aggregating such information with information about other persons) or by removing characteristics (such as your name) that make the information personally identifiable to you (i.e., de-identifying such information). We may use and disclose this de-identified information for any lawful purpose, including for any commercial purpose.

Your Communications with Third Parties. If our Services allow you to send, share or communicate to or with third parties, then please be aware that: (i) we may display your e-mail address or another mode of communication to such third parties; and (ii) we may use any information that you provide about your such third party to facilitate the communication and as otherwise set forth in this Privacy Policy.

Business Transfers. We may disclose, lease, sell, assign, or transfer the information we collect to third parties in connection with a Business Transfer. A "Business Transfer" means a sale, acquisition, merger, consolidation, reorganization, bankruptcy, or other corporate change involving us, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part of or our whole business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, or assets (including our Services) to an affiliate or independent third party at any time, for any lawful purpose, without notice or compensation to you.

11. Security of Information We Collect.

We take the security of Your Information very seriously. However, please be aware that methods of transmission and electronic storage are not completely secure, and we cannot guarantee the security of the information we collect, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, we are not responsible for circumvention of any privacy settings or security measures of our Services. Therefore, you use our Services at your own risk, you should not expect that the information we collect will always remain private, and we do not guarantee the performance or adequacy of our security measures. If an unauthorized third party compromises our security measures, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate such information.

12. Choices About How We Use and Disclose Information.

Below are some mechanisms that provide you with control over the information we collect:

Cookies. If you do not wish us to collect cookies, you may set your browser to refuse cookies or to alert you when cookies are being sent. If you do so, please note that some or all parts of our Services may then be inaccessible or may not function properly.

E-mail Offers. If you do not wish to receive e-mail offers or other information or communications from us, you can opt-out of receiving such e-mail offers or other information or communications from us (other than e-mails or other information or communications related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions on or through our Services) by using the unsubscribe process at the bottom of the e-mail. Please be aware that it can take up to 15 business days to remove you from our marketing e-mail lists. If you opt-out from receiving our marketing e-mails, you may continue to receive confirmation and shipping status e-mails.

Please note that our website does not currently recognize "do-not-track" signals from your browser.

13. Updating Your Information.

KESPAM makes it easy for you to keep Your Information accurate, complete, and up to date. Specifically, if a portion of our Services allows you to create an account with us, then you can review and update some of Your Information by logging into that portion of our Services, visiting your account profile page, and making changes.

14. Information that You Disclose to Third Parties.

Our Services may contain links or access to websites or services operated by third parties that are beyond our control. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their respective websites, applications, products, services, or practices. We are not responsible for the privacy policies, terms, and conditions, practices, or the content of such third parties. All information that you disclose to such third parties will be subject to the privacy policies and practices of such third parties. You should review the privacy policies and practices of such third parties prior to disclosing information to them. If you have any questions about how these third parties use this information, you should review their policies and contact them directly.

15. International Operation of our Services.

We provide our Services in the United States and in several other international jurisdictions. As a result, the information we collect may be processed by us in the country where it is collected as well as in other countries where laws regarding the transfer and processing of such information may be less stringent than the laws in your country. By using our Services or providing us with information, you consent to this transfer and processing.

16. Changes to Our Privacy Policy.

We may amend this Privacy Policy at any time and from time to time. Amendments will take effect immediately upon us posting the updated Privacy Policy on our Services. Accordingly, you are encouraged to revisit this Privacy Policy from time to time to review any changes that we have made. The date on which this Privacy Policy was last updated will be noted immediately above this Privacy Policy.

17. Contacting Us.

If you have questions or concerns about our privacy practices or wish to make a request regarding the information we request or to opt-out of these policies, please contact us via email at: support@numiapps.com or by postal mail at 2900 Southwest 28^th Terrace, Suite 202, Coconut Grove, FL 33133, USA.

18. The Metropolitan Commercial Bank.

KESPAM is a program of the Metropolitan Commercial Bank (Member FDIC).

To know what the Metropolitan Commercial Bank does with your personal information, please visit www.mcbankny.com/privacy-policy or call 1-866-363-8226.

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