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Privacy Policy Template

This Privacy Policy is dated 3 December 2019 and is between GoDo, which includes all affiliates and subsidiary entities (“GoDo”), and users of GoDo’s services (“users”, “you” or “your”).

We may revise this Privacy Policy and the revised Privacy Policy will be effective at the time it is made available on the GoDo application or website.

If a revision to this Privacy Policy reduces your rights or increases your obligations we will give you at least twenty one (21) days’ notice.

If you use GoDo after a Privacy Policy has been revised, you will be bound by the revised User Agreement. If you do not agree to the terms of the revised Privacy Policy, you must immediately cancel your GoDo Account and stop using GoDo’s services.

Where terms are not defined in this Privacy Policy, they are taken from the User Agreement.

APPLICABILITY OF PRIVACY POLICY

This Privacy Policy applies to all information we collect through GoDo’s internet, iOS or Android application from current and former GoDo users, including you and your employer. When you no longer use GoDo or close your GoDo account, we continue to share your information as described in this policy.

The term "personal information" describes information associated with a specific person that can be used to identify that person. Personal information does not include information that has been aggregated and/or anonymized so that it does not identify a specific person.

THE INFORMATION WE COLLECT

When you visit the GoDo website or use the GoDo application, we collect your IP address, and standard web log information, such as your browser type and the pages you accessed on our website. We also may collect certain geo-location information. If you do not agree to our collection of this information, you may not be able to use GoDo.

If you open a GoDo Account, we collect the following information from you:

● Account Information - text-enabled cellular/wireless telephone number, machine or mobile device ID and other similar information.
● Identification Information - your name, street address, email address, date of birth, and SSN (or other governmental issued verification numbers).
● Device Information - information about you: (a) from your mobile device such as your device type, machine or mobile device identification number, geo-location, time zone, language setting, browser type, and IP address, and (b) from third parties for purposes of transaction processing, identity verification, fraud detection or prevention and other similar purposes. For fraud prevention purposes, we also may link your machine ID with the machines of others who use your same payment cards.
● Social Web Information - including but not limited to your Facebook Connect credentials and email account information. If you authorize Facebook Connect, the plug in allows us access to your email address, Facebook friends list, and public profile (including profile picture). We may also allow you to import data from other social web services and email service providers. You may manage certain contact preferences and notifications in your account settings.
● Financial Information - bank account information, bank account and routing numbers and debit cards linked to your GoDo account. GoDo does not share financial information with third party social networking services such as those listed above.

We may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance whilst you have a GoDo Account. We may also obtain information about you from third parties such as identity verification, fraud prevention and similar services.

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

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

INFORMATION FROM CHILDREN

GoDo is not directed to children under the age of 13. If we obtain actual knowledge that we have collected personal information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data.

HOW WE USE COOKIES

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

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

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

HOW WE PROTECT & STORE PERSONAL INFORMATION

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

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

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

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

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

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

HOW WE SHARE PERSONAL INFORMATION WITHIN GoDo

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

We will not disclose your credit/debit card number or bank account number to anyone except with your express permission or if we are required to do so to comply with a legal process.

HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

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

Some personal information is public information, and may be seen by anyone on the internet, whether or not they have a GoDo account. Public information may also be seen, accessed, reshared or downloaded through GoDo’s APIs or third-party services that integrate with our products.

We may share your personal information with:

● Our parent company and its affiliates and subsidiaries it controls;
● Companies that GoDo plans to merge with or be acquired by or, in the event of any bankruptcy, a bankruptcy estate. Should such a combination occur, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice and the opportunity to communicate preferences you may have, if applicable.
● Law enforcement, government officials, or other third parties if GoDo is compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the GoDo User Agreement, or as otherwise required by law.
● Third party service providers who assist us in providing services to you or who provide fraud detection or similar services on our or any vendor’s behalf.
● Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services). Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
● Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform.

○ For the purposes of this privacy policy, an "account connection" with such a third party is a connection you authorize or enable between your GoDo Account and a non-GoDo account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, GoDo and the third-party will exchange your personal information and other information directly. Examples of account connections include: linking your GoDo account to a social media account or social messaging service; connecting your GoDo account to a third-party data aggregation or financial services company, if you provide such company with your GoDo account log-in credentials; or using your GoDo account to make payments to a merchant or allowing a merchant to charge your GoDo account.

○ If you connect your GoDo account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third- party’s service. For example, if you connect your GoDo account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.

○ Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your personal information as part of the account connection. For example, personal information that GoDo shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

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

HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

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

You may request access to any personal information we hold about you at any time by contacting us by email. Where we hold personal information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request, nor charge you for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, would result in a breach of confidentiality, is contrary to natural justice or is prohibited by law. If this happens we will tell you when you request access to it.

If you believe that the personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

You are entitled to ask us to erase your personal information or restrict its processing. These rights are limited in some circumstances – for example if we have a legal requirement to process your personal information. In some instances, this may mean that we may retain some of your personal information even if you withdraw your consent.

LINKS TO OTHER SITES

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

HOW TO CONTACT US

If you have questions or concerns regarding this privacy policy, or any feedback pertaining to your privacy and the GoDo Services that you would like us to consider, please email us at support@godolife.com.

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