Privacy Policy

Updated 5/15/2021

This Privacy Policy describes the way Zofi Cash LLC and its subsidiary, Zofi Cash Services Limited., corporations doing business through our mobile phone application, ZOFI, and its affiliates (collectively, "ZOFI" or "us") obtains, uses, stores, manages and disposes of certain information that you, as a User of our services, provide to us. You have certain rights, described below, to know what information we collect, how we use it, and how you may obtain and correct it.

ZOFI first collects information about you (“the User”) and about your Employer from the data you supply on the ZOFI application (the "App/ Platform"). When you provide information to ZOFI, through the App or otherwise, you are warranting to ZOFI that all of the information you provide to us about yourself and about your Employer is accurate and complete. ZOFI is relying on your warranty when ZOFI provides the Service to you. The information you provide includes personal data, which is defined as information that can be used, on its own or with other information, to identify you.

In addition to the information you provide, ZOFI may have, or may obtain from third parties, information about you or your Employer, some of which may be personal data. More information about these third parties appears below. ZOFI uses this information to provide its services to you, and to help protect you, the ZOFI service, your Employer and the general public from mistakes, fraud, money-laundering and other problems.

In addition to the information provided above, details of each Zofi Group company can be found in Annex 1 to this Privacy Policy. This will be updated as the need arises.

Ownership of Site

Welcome to, including any linked websites and mobile applications (the “Site”). The Site is owned and operated by ZOFI CASH LLC and its subsidiaries including and not limited to Zofi Cash Services Limited and affiliates operating under the Zofi Cash brand (collectively, “ZOFI CASH,” “Company,” “we,” “our,” or “us”). These Terms govern your use of the Site and any of the products and services made available via the Site (“Services). Your compliance with these Terms is a condition to your use of the Site and Services. By using our Site or using or applying for a Service, you are agreeing to these Terms and the terms of our Privacy Policy. These Terms constitute a legal contract between you and ZOFI CASH governing your use of the Site and Services, to the extent not superseded by the terms and conditions of any contract we enter into with you for Services. Please see the “Additional Terms” section below for more information.

In addition to the information provided above, details of each Zofi Group company can be found in Annex 1 to this Privacy Policy. This will be updated as the need arises.

Legal Basis of Processing

Users’ data is processed in accordance with the following legal reasons:
• To perform the contractual relationship following Users’ registration on the Platform.
• On the basis of our own legitimate interest (such as monitoring for the prevention of fraud through the Platform).
• To fulfil our legal obligations (such as when competent authorities request data in connection with court investigations and/or with the filing of the necessary actions to protect ZOFI’s interests.
• Express INFORMED consent for the use of data for a number of uses and disclosure of Users’ data to third parties for the purpose of making commercial communications.

Collection of Information

The initial information we collect from you is the information that you provide to us on the ZOFI App. This includes information about yourself, such as your full legal name, address, date of birth, telephone number, email address, last four digits of your social security number (if a U.S. Citizen), as well as other information and/or documentation that will allow us to verify your identify. You must also provide us with information about an approved payment source, such as your debit card, and information about your Employer, which may include sensitive personal information such as your Employer's name, address, mobile phone number and/or bank account information. ZOFI may also collect information from your mobile phone or other device from which you access the ZOFI App, including your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the App. ZOFI may also collect information about the websites you have visited prior to accessing the ZOFI service. ZOFI may keep and store such information and associate it with your use, in order to help ZOFI identify you and facilitate your use of our service in the future.

ZOFI may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the ZOFI App) with third parties, including financial institutions, regulators and industry stakeholders that issue, regulate or use the payment platform you propose to use, and the telecommunications company or financial institution through which your money is sent. ZOFI may also verify such information with identify verification services, electronic databases, social media companies and credit reporting agencies. ZOFI may share your information with the banks, telecommunications providers and other financial services firms who facilitate payment to you. From time to time, ZOFI may require you and/or your Employer to provide us with additional information and/or documentation to confirm your identify and your eligibility to use the ZOFI service.

When you access the ZOFI app, ZOFI may collect and store information regarding your use of the App and the service. This includes information about the frequency with which you access the App, the time you spend there, the way you move through the site, your transfer history, and details regarding the amount of money you transfer and your Beneficiaries.

If you contact us for any reason, whether by telephone, email, text or otherwise, ZOFI may record and store communications that you have with us

Recipients of the Data

ZOFI warrants that all commercial partners, technicians, suppliers or independent third parties that access the data are bound by contractually binding promises to process the information shared with them in accordance with ZOFI’s indications, this Privacy Policy and the applicable data protection legislation. We will not disclose your personal data to any third party who does not act under our instructions, and no communication will involve selling, renting, sharing or in any other way revealing customers’ personal information for commercial purposes in breach of the commitments made in this Privacy Policy

Use of Information

ZOFI may maintain and use all of the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties, in order to provide the ZOFI service to you, and to enable ZOFI to comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system. ZOFI may use your information to contact you as necessary to confirm or complete a transaction, and to allow our agents, partners and service providers to fulfill their obligations in providing the ZOFI service to you. ZOFI may also use your information to improve our service, to troubleshoot problems, to develop new products and services, and to create advertising, marketing and promotional campaigns. (More information about ZOFI's use of your data for marketing and promotion is below.) Finally, ZOFI may disclose your information to third parties, including but not limited to government agencies, when ZOFI reasonably determines that such disclosure is required by law, such as responses to subpoenas and information requests by law enforcement, financial services regulators or national security authorities.

ZOFI will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with ZOFI for the purpose of advertising, promoting or selling other services to you. However, where and to the extent allowed by law, ZOFI may work with third parties to analyze the information that we gather from you when you visit us on-line, including our website, our Facebook page, and our Facebook advertisements, whether or not you use the ZOFI service. ZOFI may use the information we gather there, along with the information we obtain from your use of our service, which may include personal data, to advertise and promote ZOFI services to you and to others. For example, ZOFI provides data to Facebook's Ad Manager account and SDK programs, which provide us with information about the ways customers and other visitors access, view and use the ZOFI website and application. We use that information to create advertisements and promotions; such advertisements and promotions may appear in your Facebook feed or on other sites owned or operated by Facebook, such as Instagram. We may customize our marketing and promotional messages to you based on your use of our service, the information that you provide to us or which we otherwise obtain about you, and algorithms designed to help us anticipate your potential needs, based on your information and the information of others who use ZOFI services. ZOFI believes that such programs provide valuable information and benefits to our current and potential users. ZOFI strictly shares such information with third parties in line with the use disclosed herein and does not take liability for any possible misuse by a third party outside the identified use.However, if you live in the European Community or another jurisdiction where such use of your data for marketing and promotional purposes requires your permission, ZOFI will not use your data for these purposes unless you "opt in" to such uses.

Protection of personal information collected by ZOFI

ZOFI's leading security experts and practices help ensure that your personal data is secure. All such information is stored on servers with state-of-the-art data protection technology, and is accessible only to ZOFI employees who, for business purposes, need to access it. We use 128-bit encryption and encode your debit card or related information as soon as it is entered in the ZOFI app, a process that overwrites your details so that they are unreadable by unauthorized parties.

No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Although ZOFI uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, ZOFI cannot absolutely guarantee its security. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

Promotion and commercial offers (on-line and off-line)

ZOFI uses technology integrated in its Platform for the purpose of collecting Users’ data and preferences and using this with CRM systems and advanced technology for the benefit of Users. The following processing will thus be carried out on their data through the information collected:

  • ZOFI may send e-mails with promotional messages and/or offers relating to the service offered by it that may be of interest to Users. Zofi may gauge and personalise such advertising in accordance with its Users’ preferences. If a User does not wish to receive this information and/or commercial communications, he/she may at any time opt to “Unsubscribe” in the e-mail, and ZOFI will immediately stop sending the aforementioned information.
  • ZOFI may also send Users messages and/or offers relating to such services through “push” notifications consisting of sending such promotional messages and/or offers to their mobile phones. If a ZOFI User does not wish to receive the commercial communications described in this clause and in 3.1 above, he/she may remove them all by disabling them with a single click in the privacy preferences of his/her profile.
  • ZOFI and/or the third parties associated with Zofi may use the information entered by the User for the purpose of carrying out promotional activities for products of the service related to ZOFI which may be of interest to the User
  • As a result of using the Zofi Platform, Users may also receive commercial communications from third parties associated with the Platform, this in accordance with the privacy preferences set by each User on the said Platforms.

Sharing User data with third parties

In order to continue providing the services offered through the Platform, ZOFI may share certain personal data of Users with:

  • Service providers: ZOFI’s third-party service providers that send parcels, carry out requests and/or resolve incidents with deliveries will have access to Users’ personal information as may be necessary to carry out their functions, but they may not use it for any other purposes. They must process the said personal information as provided in this Privacy Policy and in the applicable data protection legislation.
  • Payment Service Providers: When a User enters his/her card number on the Zofi Platform, this is stored directly by the Payment Platforms contracted by ZOFI, which will allow payment to be made to the User’s account. Payment service providers have been chosen based on their security measures and in any event complying with the security measures stipulated in the payment service legislation.
  • Service providers for fraud control purposes: ZOFI will share Users’ data with fraud control service providers to assess the risk of the transactions carried out.
  • Service providers for the anonymisation of some data: In order to prevent the misuse of Users’ data by third-party service providers, ZOFI may disclose Users’ data for the purpose of anonymising it so that it can be used solely for the provision of the service to Users
  • Security companies and Law Enforcement Forces and Agencies: ZOFI may disclose personal information and data on its customers’ accounts if it believes that such disclosure is necessary to comply with the law, to enforce the law or to protect ZOFI’s interests, its users’ or third parties’ rights, property or safety. The above therefore includes the exchange of information with other companies and organisations as well as with Law Enforcement Forces and Agencies to protect against fraud and reduce credit risk. After being required to do so by law, ZOFI may share information with bodies of executive authorities and/or third parties in relation to requests for information relating to criminal investigations and alleged illegal activities.
  • Call centre and incident management services: In order to provide a Customer Service and call centres, actions to measure Users’ degree of satisfaction and the provision of administrative support services, ZOFI may disclose Users’ data to companies located outside the jurisdiction of thr transaction, provided it is authorised to do so and the security requirements mentioned in the preceding section have been met.
  • Telecommunications services: In order to be able to provide Users with telephone contact services, ZOFI may contact telecommunications companies that provide secure lines and systems for the purpose of contacting Users.
  • Companies in the ZOFI group: In order to be able to provide its services, ZOFI may transfer certain personal data of Users to subsidiaries, based on the geographical area from which users request our services. Users are hereby informed that, when they register on the Platform from any country in which ZOFI operates, their data will be stored on ZOFI’s database, which is located in New York.
  • Third parties associated with ZOFI for the purposes of commercial communications: Zofi may, with a User’s express consent, transfer his/her personal data to third parties associated with Zofi, provided that the User has given his/her express informed and unequivocal consent to such transfer of data and is aware of the purpose and recipient of such transfer.
  • Changes of ownership: If ZOFI’s ownership changes or the majority of its assets are acquired by a third party, Users are informed that ZOFI will transfer their data to the acquiring organisations in order to continue to provide the services subject to the processing of data. The new file controller will inform Users of its identification data. ZOFI states that it will comply with its duty of information to the relevant Supervisory Authority in the event of such circumstances arising, and it shall inform Users of the change of file controller if and when this happens. This processing shall be carried out under the contract entered into with ZOFI.
  • Insurance companies: Zofi may provide users’ data to those insurers and insurance brokers with which it has an agreement in place for the management and processing of claims and losses arising from the activity carried out by Zofi and the parties that collaborate with it.

Insurance companies: Zofi may provide users’ data to those insurers and insurance brokers with which it has an agreement in place for the management and processing of claims and losses arising from the activity carried out by Zofi and the parties that collaborate with it.

International Data Transfers

When choosing service providers, ZOFI may transfer users’ data outside the borders of the jurisdiction in which the transaction occurs. In such cases, ZOFI will ensure before sending the data that such service providers are in compliance with the minimum security standards established by the legal framework of that jurisdiction and that they always process the data in accordance with ZOFI’s instructions. ZOFI may have a contractual relationship with them under which the service providers agree to comply with ZOFI’s instructions and to put in place the necessary security measures to protect Users’ data.

Use of Cookies and other Tracking Devices

ZOFI uses "cookies" and other tracking devices to help us recognize you, remember your preferences and facilitate your future transactions and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our App, in order to help us improve it and make it easier for future use. You may be able to disable your device's use of cookies, but that may slow or prevent your ability to use the ZOFI service.

Exercise of Rights by User

Users may exercise their rights free of charge at any time using the form available on the Platform. They may also exercise their rights by sending an e-mail to the following e-mail address: [email protected]. The e-mail must specify which right they wish to exercise, as well as, where applicable, the identifying data registered on the Platform. We will contact the User if we need additional data to that provided in order to verify his or her identity.

You may exercise the following rights vis-à-vis ZOFI:

  • The right of access to your personal data in order to know which data is being processed and the processing operations carried out thereon;
  • The right to correct any inaccuracies in relation to your personal data
  • The right to the erasure of your personal data, where possible;
  • The right to request the restriction of processing of your personal data when the accuracy, legality or need for processing of the data is in question, in which case we may retain the data for the purpose of filing or defending claims.
  • The right to object to the processing of your data in order to resolve any query you may have raised with us through the contact form, and the right to object to the processing of your data on social media and/or for the purpose of processing your CV. In addition, you may withdraw your consent to the receipt of commercial communications at any time, through the Platform User profile, either by sending an e-mail or by using the link provided for this purpose in every commercial communication.

If you believe that ZOFI is in breach of data protection law, please do not hesitate to contact us at the e-mail address [email protected] telling us what you consider to be the case, so that we can resolve the problem as soon as possible

Security Measures

ZOFI has taken the necessary steps recommended by the competent authority to maintain the required security level, according to the nature of the personal data processed and the circumstances of the processing, in order to avoid, to the extent possible and always in accordance with the state of the art, its alteration, loss or unauthorised access or processing. As mentioned above, the personal data supplied will not be disclosed to third parties without the data subject’s prior authorisation.

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