Novi Privacy Policy.

Collection of Information

Novi collects information about you when you download, install, access, or otherwise use our Services. We collect this information to help you use our Services and ensure they are safe for everyone, and for the reasons described below. The types of information we collect vary depending on which Services you use and how you use them.

Information you or others provide when using the Services. Novi collects the information that you and others provide us when using our Services. Information we collect includes:

• Account and contact information. When you create an account, Novi may ask you for information such as your name and phone number. We also may collect other contact information you provide us when using our Services. For example, we collect your email address when you subscribe to marketing communications through our website.

• Identification information. Novi collects information about you to verify your identity, as required by law and to fight financial crime, such as your address, date of birth, and government-issued identification documents and identification number (e.g., driver’s license or Social Security Number).

• Financial and transaction information. Novi collects information about your transactions on our Services and payment methods linked to your account. This includes payment card information, bank account information, billing details, account balances and transaction history. We may collect additional information to fulfill our obligations to combat financial crime and perform other compliance activities, such as information about the source of your funds and income, including occupation.

• Your connections. Novi collects information about the people or accounts you transact with on our Services, for example when you send or receive digital currency.

• Face recognition. Every time you choose to verify your identity using our automatic face verification feature, Novi may create a temporary template for that verification to compare with other images of you. The Face Recognition templates we create may constitute data with special protections under the laws of your country or region. Learn more about how we use Face Recognition.

• Information and content you provide. When you communicate with Novi or with other users through Novi (such as including transaction notes along with your transactions), we receive and store those communications and information associated with them, such as the date and time of the correspondence.

• Information others provide. Novi also receives information about you when another user completes a transaction with you, uploads a contact book with your name or phone number, or otherwise uses our Services. For example, if someone you know sends you an invite to use Novi through the app, Novi would receive your phone number.

Information we collect from and about your device. We collect certain information automatically from your device including:

• Device attributes. information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, plugins, and app and file names and types of the Facebook Company Products’ applications you have installed on your device.

• Device operations. information about Novi’s operations and behaviors when you use Novi on your device, such as if you have backgrounded the Novi app, which may indicate that an action in the app is taking too long. We also identify if you have the Facebook app installed on the same device.

• Identifiers. unique identifiers, device IDs, and other identifiers, and Family Device IDs associated with the same device or account (or other identifiers unique to Facebook Company Products associated with the same device or account, if applicable).

• Network and connections. information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, and connection speed. To reduce risk and meet regulatory obligations, we collect your IP address, which can provide information about the general location where you’re using Novi. Changing your preferences in the location settings on your device will not disable the collection of your IP address for such purposes.

• Log and usage data. service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files.

• Cookie data. data from cookies stored on your device, including cookie IDs and settings, web beacons, local storage, and other similar technologies. Learn more about how we and our partners (including Facebook, Inc.) use cookies and similar technologies in the Novi Cookie Policy.

When you are connected to our Services, and enable location services in your device settings, we also collect information about your location, by using GPS, nearby Wi-Fi access points, beacons, and cell towers.

Information from other sources. We may also receive information about you from other sources, such as:

• Affiliated companies. Novi receives information about you from other Facebook Companies (including Facebook, Inc. and Facebook Payments, Inc.) as described below in “How Does Novi Work With the Other Facebook Companies?”

• Third-party sources. Novi may receive information about you from other third parties, including companies we use for identity verification, fraud prevention, and advertising services. We also collect information from publicly available sources. We may combine information from third parties with other information we have about you.

Use of Information

Novi uses the information we have about you as described below, and to provide and support our Services. Here’s how:

• Provide our Services. Novi uses the information we have to provide you with our Services and process your transactions. For example, we use this information to create and maintain user accounts, facilitate your payments and transactions, transfer funds between accounts, and provide the products and Services that you request.

• Personalize our Services. Novi uses the information we have to personalize the content you see from us. For example, on our Services, we could show you people you’ve recently transacted with to make transacting with them in the future easier.

• Improve our Services. Novi uses the information we have to understand how you use our Services, features, and content; and to improve and develop your experience on our Services. For example, we use information to conduct surveys, analyze how our products and Services are used, troubleshoot technical issues, and test and develop new products and features.

• Promote safety, integrity and security. Novi uses the information we have (including information collected through other Facebook Companies) to secure users’ accounts; detect, prevent, and mitigate fraud, funds loss and other abuses of our Services; and combat financial crime and other harmful activities. For example, we use information to verify accounts and activity; detect, prevent and address fraud, spam and other non-compliance with our policies or terms and other bad experiences and criminal activity; maintain the integrity of our Services; and promote safety and security on and off of our Services.

• Communicate with you. Novi uses the information we have to communicate with you regarding our products and Services, and respond to you when you contact us.

• Advertise Novi to you. While we do not have third-party ads on our Services, we use information we have about you and your interactions with the Services to advertise Novi’s products and Services and provide you relevant offers and promotions, and send marketing communications to which you subscribe. We may use Facebook’s business tools to show you advertising. If you don’t want to see ads for Novi when you’re on Facebook, you can change this in your Facebook settings. If you would like to opt out of receiving marketing emails, please follow the instructions contained in those emails.

• Research and innovate for social good. Novi may conduct research and innovation on topics such as financial inclusion and economic opportunity. Information used for research is aggregated and de-identified or anonymized.

• Legal purposes. Novi also uses the information we have to comply with applicable laws and regulations. For example, in order to meet our obligations to combat financial crime, we must collect and store certain information that helps us identify and verify our customers. We also use information to protect or exercise our and others’ legal rights, defend against legal claims, and when otherwise required by law.

Sharing of Information

Novi works with affiliates, such as Facebook, Inc., as well as with third parties who help us provide and support our Services. We don’t sell your information.

Novi shares information with:

• People and accounts you transact with. When you send or receive digital currency or otherwise interact with others through our Services, Novi shares certain information to complete your transaction or interaction. For example, when you initiate a transaction to send digital currency to another person on our Services, we will provide the recipient with certain information about you as part of the receipt of the transaction. We also share your contact information (including legal name) with financial institutions involved in your transactions, in accordance with applicable laws.

• Vendors and service providers. Novi shares your information with third parties for specific purposes in connection with the services they provide us. For example, we share information with service providers for our everyday business purposes, such as to process your transactions, maintain your account(s), enable you to withdraw funds, or enhance the security of our Services by verifying your account or identity and providing fraud detection services. We may also share risk and compliance data with third parties to promote the safety, security and integrity of the Services and as necessary to meet their compliance obligations. We may also share your information with third parties who provide us advertising and marketing services.

• Affiliated companies. Novi shares limited information with other Facebook Companies as described below.

• Regulatory, law enforcement and judicial authorities. Novi shares information with regulatory, judicial, and law enforcement authorities in accordance with applicable laws and regulations. Novi may share information to the extent required pursuant to applicable law, a court order, or legal process, to detect, prevent, and report unlawful or other suspicious activity, unauthorized transactions and other liability; for institutional risk control; and to protect and defend the rights, interests, safety, and security of our Services, our affiliates, owner, users, or the public.

• New Owner. If the ownership or control of all or part of Novi or our assets changes, we may transfer your information to the new owner.

• Third parties with your consent. Novi may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

We also may share aggregated and de-identified or anonymized data relating to the performance of our products and Services, such as the total number of users. Aggregated and de-identified or anonymized data is not subject to this Privacy Policy because that data does not identify a specific person.

If you use third-party services that are integrated with Novi, these services may be able to collect information about you, including information about your activity on Novi. These services are outside our control and are not covered by this Privacy Policy. You should review the privacy policies of any third party with whom you share your information.

How Does Novi Work With the Other Facebook Companies?

Novi is a regulated financial company from Facebook, Inc. We have strict controls in place to limit what is shared with the other Facebook Companies, and the purpose for which it is shared. Novi will only share information with other Facebook Companies to help us keep Novi safe for everyone, comply with the law, provide basic functionality, and allow Novi to advertise its services.

We also receive information from the other Facebook Companies that we combine with the information Novi has collected for these same purposes. For example, we and the other Facebook Companies share information to comply with applicable laws and regulations; secure customer accounts and services; detect, prevent, and mitigate fraud, funds loss, and other harmful activities; respond to requests from law enforcement or regulators; process payments; and provide you with functionality, including integrations with other Facebook Companies. We encourage you to review the other Facebook Companies’ privacy notices, including the Facebook Data Policy, for more information about how they collect, use and share information.

We may use Facebook or other companies to help show you ads. When we use Facebook’s advertising services, this is similar to how other companies partner with Facebook for their own advertising purposes. In these cases, Facebook uses the information we provide and information it has about its users to provide its advertising services. However, we do not share your Novi financial information with Facebook for its own advertising purposes. You can learn more about how this works by reading our Cookie Policy.

Privacy Notice for California Residents

If you are a California resident, you can learn more about your consumer privacy rights by reviewing the California Privacy Notice.

Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will provide notice of the changes, as appropriate. For other changes, such as administrative changes, we will update the “Effective Date” at the top of this Privacy Policy and post the updated Privacy Policy. We recommend that you review this Privacy Policy each time you visit the Services to stay informed of our privacy practices. Any changes will be effective from when we post the updated Privacy Policy.

For More Information

In accordance with applicable laws, you may have the right to access, rectify, port and erase your information, as well as the right to restrict and object to certain processing of your information. You can learn how to access and delete information by visiting Settings in the Novi app.

If you have any questions about this Privacy Policy or our practices, please contact us online or by mail at:

Novi Financial, Inc.

Attn: Legal Department

1601 Willow Road

Menlo Park, California 94025

For state-specific information, please refer to the Novi Licenses page.

Cookie Policy

Our Privacy Policy explains our principles when it comes to the collection, processing, and storage of your information. This policy specifically explains how we, our partners, and users of our Services deploy cookies, pixel tags, local storage, mobile advertising IDs, and other similar technologies (collectively, “cookies”) when you use our websites and online Services, as well as the options you have to control them.