Jump Finance, Inc. (“Jump Finance”, “we”, “us”) respects your privacy. The following policy describes the information we collect, what we do with it, who we share it with, and how you (the user of the Service) can control your information.

By downloading the Jump Finance iOS or Android app, or using any of the pages on the web app version on the jump-finance.com website (“Using the Software”), you consent to the following:

By using the software, I give consent to the collection and processing of my personal information for legitimate business purposes, including but not limited to determining my creditworthiness and providing a recommendation to a financial institution about providing me with a tuition loan for post-secondary studies. I hereby certify that the information I provide Jump Finance and its financial partners is accurate and honest to the best of my knowledge, and that any misrepresentations or falsity therein will be considered as an act to defraud Jump Finance and its financial partners.

I further authorize Jump Finance to verify and investigate the above statements/information as may be required, from the references I have provided and any other sources Jump Finance deems necessary and reasonable.

For this purpose, I expressly consent to the processing of any personal information and records relating to me that might be obtained from third parties, including government agencies, my educational institution, my employer, credit bureaus, business associates, and other entities you may deem proper for the purpose of determining my eligibility for a tuition loan which I am applying for.

I further agree that my loan application and all supporting documents and any other information obtained relative to this application shall be used by and communicated to Jump Finance until you request its removal. I expressly and unconditionally authorize Jump Finance to disclose to any bank or affiliate and other financial institution any information regarding me. In particular, I hereby acknowledge and authorize: 1) the regular submission and disclosure of my basic data as well as any updates or corrections thereof; and 2) the sharing of my basic credit data with other lenders, and duly accredited credit reporting agencies and businesses.

This Privacy Policy applies to information we collect from 1) your use of the Jump Finance software (“Software”), through email, text message, social media, on the Jump Finance website (“Sites”), or your mobile telephone or handheld device (“Device”) or otherwise, 2) your use of the services we provide (“Services”) and 3) information you otherwise communicate to us.

Terms used in this Privacy Policy shall have the following meanings:

“Authorities” includes any judicial, administrative, public, or regulatory body, any government, any Tax Authority, securities or futures exchange, court, central bank, or law enforcement body, or any of their agents with jurisdiction over Jump Finance.

“Compliance Obligations” means obligations of Jump Finance to comply with: (a) Laws or international guidance and internal policies or procedures, (b) any demand from Authorities or reporting, disclosure, or other obligations under Laws, and (c) Laws requiring us to verify the identity of our customers.

“Customer”, “User,” or “you” means any individual to which Jump Finance provides its products or services.

“Customer Information” means your Personal Data, including your Academic Data, confidential information, score results, Government Documents, and/or Tax Information, and other relevant information about you, your use of our products and services, and your relationships with Jump Finance.

“Financial Crime” means money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and/or any acts or attempts to circumvent or violate any Laws relating to these matters.

“Laws” include any local or foreign law, regulation, judgment, or court order, voluntary code, sanctions regime, an agreement between any member of Jump Finance and an Authority, or agreement or treaty between Authorities and applicable to Jump Finance.

“Personal Data” or “Personal Information” refers to information that can be used to identify an individual in a way that the identity of the individual becomes apparent or can be reasonably and directly ascertained by the entity holding the information, or that, when put together with other information, would directly and certainly identify an individual. This information could refer to data points such as your phone number, name, date of birth, academic information, pre-interview questionnaire, skills assessment and results, references, identification number or passport number, and such other information that will enable Us to identify you and comply with the regulatory “Know Your Customer” requirements.

“Reference” refers to an individual whom you choose and name in the loan application as someone who can verify your identity and speak to your capacity to pay back a loan.

“Sensitive Personal Information” refers to Personal Information (1) about an individual’s race, ethnic origin, family, marital status, age, color, and religious, philosophical or political affiliations; (2) about an individual’s health, education, genetic or sexual life, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings; (3) issued by government agencies peculiar to an individual which includes, but is not limited to, Government ID Numbers, Tax Identification Numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (4) specifically established by an executive order or other legislative act to be kept classified.

“Tax Authorities” means Gambian or foreign tax, revenue, or monetary authorities. “Tax Information” means documentation or information about your tax status.

In addition to the above definitions, unless the context requires otherwise, the singular shall include the plural and vice versa; a reference to any one gender, whether masculine, feminine or neuter, includes the other two; all the headings, subheadings, and bullet points in this Agreement are for convenience only and are not to be taken into account for the purposes of interpreting it; the recitals and schedules shall be deemed to form part of this Agreement.

As part of our student vetting process, we may collect, use, and share Customer Information. Customer Information may be requested by us or on our behalf or that of Jump Finance, and may be collected from you directly, from a person acting on your behalf (such as the References you include) or from other sources (including from publicly available information), and it may be generated or combined with other information available to us.

We may collect the following information about you, which may include non-public Personal Information:

1. Information you submit to us: provided by filling in forms in the Software or Sites; provided by corresponding with us (for example, by e-mail or chat); provided by registering to use the Software, downloading or logging in to any of our Apps, subscribing to any of our Services (such as applying for a tuition loan), searching for our Apps or Services, sharing data via social media functions on our Software or Service Sites, entering a competition, promotion or survey, and reporting a problem through our Software or Services; and including your name, address, e-mail address, and phone number, Device phone number, SIM card details, age, username, password, or other registration information, educational and work information, financial and credit information, personal description, and photograph.

2. Information we collect about you and your device. Each time you visit one of our Sites or use our Software the information we may collect includes but is not limited to the following:

technical information, including the type of mobile device you use, unique device identifiers (for example, your Device’s IMEI or serial number), carrier information, information about the SIM card used by the Device, mobile network information, your device operating system, the type of browser you use, or your Device’s location and time zone setting (Device Information); information stored on your Device, including anonymized contact lists, call logs, and limited information allowed from social media log-ins (Content Information);

details of your use of any of our Apps or your visits to any of our Sites including, but not limited to, traffic data, location data, weblogs, and other communication data.

3. Information we receive from other sources. We reserve the right to work with a limited number of third parties (including credit reference institutions, financial institutions, reference agencies, educational institutions, mobile network providers, and collection agencies) and may receive information about you from them.

4. Unique application numbers. When you install or uninstall an App or Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

We and our third-party service providers, including our marketing partners and analytics providers, may use mobile tracking technologies and/or website cookies to distinguish you from other users of the Software or Site. This helps us to provide you with a good experience when you use the Software or browse any of the Sites and also allows us to improve our Services.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include your internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data with other information we collect about you for reasons such as analysis, security, content generation, or marketing.

We may use analytics tools and software in order to develop and analyze use of the Service. Analytics companies may access anonymized data to help us understand how the Service is used. We may link the information we store within the analytics software to any Personal Information you submit within the mobile applications.

By cancelling your account through electronic communication, you can withdraw your consent from accessing your Customer Information in the future. We may keep and share stored Customer Information after the point of uninstall for as long as necessary for the fulfillment of the purposes for which Customer Information was obtained or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as permitted by law.

We collect information for the following purposes, including but not limited to (“Purposes”):

To provide our Software and Services to you;

To process your transactions;

To verify your identity and the identity of any individual(s) you ask to serve as Reference(s) on your behalf;

To disburse tuition loans and collect payments for your use of the Service;

To analyze customer behavior;

To allow our financial institution partners to fulfill their obligations to you;

To allow us to fulfill our obligations to our partners;

To troubleshoot problems with the Service;

To comply with applicable laws, regulations, and rules, such as those relating to “know-your-customer” and anti-money-laundering requirements;

To detect and prevent fraud and other illegal uses of the Service;

To send you marketing notices, service updates, and promotional offers;

To contact you by telephone using auto-dialed or pre-recorded message calls or text (SMS) messages (if applicable) as authorized for the purposes described in this Privacy Policy; and

To build the credit models and perform student credit scoring.

Uses made of the information

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Privacy Policy for as long as it is combined.

We do not disclose information about identifiable individuals to other parties, unless it is necessary for providing the Services. We may share limited personal information with select partners for research and development. We may provide other parties with anonymous information about our users for the purposes of compiling statistics relating to our user base or loan portfolio and may disclose such information to any third party for such purposes, provided that such information will always be anonymous.

We may occasionally send you push notifications through our mobile applications to send you marketing messages and other Service or transaction-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings or through the mobile application settings.

Sharing

By using the Services, you agree that we may, as necessary and appropriate for the Purposes, transfer and disclose any Customer Information to the following recipients globally (who may also process, transfer, and disclose such Customer Information for the Purposes):

any subcontractors, agents, service providers, or associates of Jump Finance (including their employees, directors, and officers);

persons acting on your behalf; payment recipients; beneficiaries; account nominees; intermediary, correspondent, and agent banks; clearing houses; clearing or settlement systems; market counterparties; upstream withholding agents; swap or trade repositories; stock exchanges; companies in which you have an interest in securities (where such securities are held by us for you);

any financial institutions, credit reference agencies, or credit bureaus, for the purposes of obtaining or providing credit references;

any third party to whom we provide introductions or referrals;

any party in connection with any Jump Finance business transfer, disposal, merger or acquisition, wherever located, including in jurisdictions which do not have data protection laws that provide the same level of protection as the jurisdiction in which the Services are supplied.

third-party service providers under contract with Jump Finance that help us with our business operations, such as transaction processing, fraud prevention, and marketing; and

law enforcement, government officials or other third parties, but only in connection with a formal request, subpoena, court order, or similar legal procedure; or

when we believe in good faith that disclosure is necessary to prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our User Agreement.

Jump Finance stores your information in the United States or The Gambia. The data that we collect may be transferred to, and stored at a destination outside the United States or The Gambia. It may also be processed by staff operating outside the United States or The Gambia who work for us or for one of our suppliers. By submitting your Personal Data, you agree to this transfer, storing, or processing of data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Where we have given you (or where you have chosen) a password or PIN that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

You agree to inform us promptly, and in any event, within 10 days, in writing if there are any changes to Customer Information supplied to us or a member of Jump Finance, and to respond promptly to any request from us.

Where:

you fail to provide promptly Customer Information that we reasonably requested, or

you withhold or withdraw any consents that we may need to process, transfer, or disclose Customer Information for the Purposes (except for purposes connected with marketing or promoting products and services to you), or

we have suspicions regarding Financial Crime or an associated risk.

We may:

be unable to provide new, or continue to provide all or part of the Services to you and reserve the right to terminate our relationship with you;

take actions necessary for us or a member of Jump Finance to meet the Compliance Obligations; and/or

block, transfer, or close your account(s) where permitted under local Laws.

In addition, if you fail to supply promptly your Tax Information and accompanying statements, waivers and consents, as may be requested, then we may make our own judgment with respect to your status, including whether you are reportable to a Tax Authority, and may require us or other persons to withhold amounts as may be legally required by any Tax Authority and paying such amounts to the appropriate Tax Authority.

You agree that we shall not be liable for any loss or damage arising from or incidental to our use, collection, processing, and sharing of Customer Information, and any action we have taken in relation to this Section.

Federal and state laws allow you to restrict the sharing of your Personal Information in certain instances. However, these laws also state that you cannot restrict other types of sharing. Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at help@jump-finance.com.

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. We welcome questions, comments, and requests regarding this privacy policy at help@jump-finance.com.