Houston Privacy Policy

Privacy Policy

Colu values your privacy, and has therefore created this Privacy Policy to let you know what information  is retained about you, how it is shared and with whom. Please note that this policy is set to be compliant  with the Israeli law. Israel is certified by the EU as having adequate protection of privacy, and this privacy policy is set to let you know more about your rights. 

This Privacy Policy forms part of Colu’s Business Term & Conditions and Colu’s End-User Terms for Mobile Applications, both of which are set forth above (collectively, “Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms. 

Consent and Modification You are not legally obligated to provide us personal information, and you hereby confirm that providing us personal information is at your own free will. By using the Colu  Platform and\or the Colu Application (collectively, “Services”), you consent to the terms of this Privacy  Policy and to our collection, processing and sharing of your personal information for the purposes set  forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services.  We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be  effective 10 days following posting of the revised Privacy Policy, and your continued use of the Services  thereafter means that you accept those changes. 

How Is Information About You Collected? Colu collects information about you in the following ways: when you use the Colu Application, some information is stored about you on Colu’s servers, when you use the Colu Application to send or receive E-Money, Colu saves these transactions, and when you share information with others, Colu also saves this information. Moreover, if you connect your account with Facebook, then Colu may also collect information through Facebook. 

What Personal Information Does Colu Retain? Colu retains your phone number, your IP address and your approximate geolocation, which it receives when you signed up. It also may retain your name and other personally identifiable information you directly submit it. If you connect your Facebook Account,  

Colu may retain your name, user ID, profile picture, gender and network; as well as information relating  to your language and country, your timezone and whether you are a verified user. If you are a merchant, then Colu may retain your bank details in order to allow you to withdraw money.  Colu also saves a list of your E-Money and the use of your E-Money (such as when you ride the bus or pay for beer). 

Please note that when you install the Colu Application, it also transmits and saves your mobile phone’s contact list. This is used solely to provide you with the services and to allow you to send payments to  your friends and/or businesses you interact with. 

What Non Personally Identifiable Information Does Colu Retain? Colu retains statistic, aggregated, non personally-identifiable information about your use of the Application and services, such as your “hot zones”, the number of times you opened the Application, your stay time, and similar information. 

Who Has Access To This Information? Colu’s employees and contractors, who are under strict confidentiality obligations, have access to this information. Moreover, the E-Money issuers who send you E-Money, as well as your friends and contacts who send you E-Money (or receive E-Money from you), may receive some of the information, all according to the Colu Platform’s functionality. If you make a payment using a Colu wallet then the entity you paid shall have access to your name and payment features. Colu may also use aggregated, non personally identifiable information for research and improvement of  the services. 

Who Else Has Access To This Information? Colu uses a selected number of third party service  providers who have limited access to the information under strict confidentiality obligations. These are  Parse, Twilio, Bitcoinj, Github and Amazon. 

How Can You Review Your Information? There are two ways to review your information. First, by sending Colu an email requesting to review your information. Second , you may view your information through the Application itself. 

Amending This Policy. Colu may amend this policy from time to time, and shall notify you upon such changes. 

What Can You Do If You Feel Your Privacy Was Invaded? If you feel your privacy was invaded, please contact Colu’s privacy officer at privacy@Colu.com. Colu’s privacy officer shall inspect the complaint and public periodic reports with aggregated, anonymous data. 

Children’s Privacy The Services are not structured to attract children under the age of 13 years. Accordingly, Colu does not intend to collect personal information from anyone it knows to be under 13 years. If Colu learns that it has collected personal information from a child under 13 years, Colu will  delete that information as quickly as possible. If you believe that Colu might have any such information,  please contact Colu at privacy@Colu.com 

Security The security of personal information is important to Colu. Colu follows generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the personal information submitted to it. However, no method of transmission over the Internet,  or method of electronic storage, is 100% secure. Therefore, while Colu strives to use reasonable  commercially acceptable means to protect your personal information, it cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact Colu  at privacy@Colu.com. 

Merger, Sale or Bankruptcy. In the event that Colu is acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, Colu reserves the right to transfer or assign personal information in connection with the foregoing events. 

Deletion of Content from California Residents. If you are a California resident under the age of 18 and  a registered user, California Business and Professions Code Section 22581 permits you to remove content  or personal information you have publicly posted. To remove, please email privacy@Colu.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does  

not ensure complete or comprehensive removal of the content or personal information you have posted  and that there may be circumstances in which the law does not require Colu to enable removal of content.