PRIVACY POLICY FOR GENIE SERVICES

The Privacy Policy below governs your use of your Genie account and products, services and any other features, technologies or functionalities offered by us (collectively "the Genie Services") (including, without limitation, any information you provide in relation to the Genie Services).

1. Overview
Our slogan "Everyone should mind their own business" describes our privacy policy in just six words. However given the current state of technology, as well as the potential for more sophisticated advancements, the time is ripe to consider taking steps that ensure the protection of privacy into the future. Otherwise, privacy as we know it may not exist in the next decade. To address these concerns AllCom is taking the most aggressive steps in our industry to protect your privacy. By consenting to, and agreeing the terms of, this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. Genie takes the processing of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy.

We will not sell or rent your personal information to third parties for their marketing purposes under any circumstances. It is important for you to review and understand our unique approach to this Privacy Policy as it applies to all the Genie Services.

By accepting the Privacy Policy at registration, you expressly consent to our use of your personal information and direct us to do so in the manner described in this Privacy Policy. If you disagree with the terms of this Privacy Policy, please do not register for or use any of the Genie Services provided by AllCom. Notification of Changes

This Privacy Policy may be revised over time as new features are added to the Genie Services or as we incorporate suggestions from our Subscribers. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. In addition, if we propose to change this Privacy Policy in a substantial manner, we will provide you with at least 30 days' prior notice of such a change by posting notice on the "Policy Updates" page of our website(s). After this 30 days' notice, you will be considered as having expressly consented to all amendments to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

A Special Note about Minors With the exception of students, establishing a Student Account, minors are not eligible to use our service and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the Genie Services.

2. Information We Collect - Required Information
To open a Genie account or use the Genie Services, you must provide your name, address, phone number, and email address. In order to make and receive payments through the Genie Services, you must provide your credit card, debit card and bank account information. This information will ONLY be used by AllCom internally to provide you the Genie Services and it will not be shared with any buyers, sellers, or other Genie Subscribers. To complete transactions and purchases from other Genie Subscribers you will only need to provide your Genie Number or your phone number. We also ask you to choose different security questions to answer (such as your city of birth or your pet's name). This required information is necessary for us to process transactions, issue a new password if you forget or lose your existing password, protect you against fraud, and contact you should the need arise in administering your account or the Genie Service. When you access Genie using a mobile device, we may additionally collect and store device sign-on data (including device ID) and geolocation data in order to provide our services.

Transaction Information
When you use the Genie Services to send money to someone else or request money from someone else, we ask you to provide information related to that transaction, consisting of the amount of the transaction, the type of transaction (purchase of goods, purchase of services, or simple money transfer) the email address, the Genie Number or the phone number of the third party. We retain this information for each of your transactions through the Genie Services and may add this information to your account profile to be used for future transactions that you may make with us. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your Genie account or use the Genie Services, in order to help detect possible instances of unauthorized transactions.

Information about You from Third Parties
In order to protect all our Subscribers against potential fraud, we verify the information you provide with the "Payment Processors" and/or "Credit Reference and Fraud Agencies". In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you register a credit card or debit card with Genie, we will use card authorization and fraud screening services to verify that your card information and address match the information you supplied to Genie, and that the card has not been reported as lost or stolen. If you send or receive high overall payment volumes through the Genie Services, in some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit reference or fraud agency such as Dun & Bradstreet. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. Genie, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.

Additional Verification
If we cannot verify the information that you provide, or if you request a withdrawal by check to an address other than your verified credit card billing address, we may ask you to send us additional information by fax (such as your driver's license, credit card statement, and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information.

Website Traffic Information
Because of the way Internet communication standards work, when you arrive at or leave the Genie website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website. We use this information to try to understand our Subscribers' preferences better and to manage the load on our servers, so as to improve our services and your experience with Genie.

Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a Genie Subscriber if you return to our website using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Genie account by entering your Genie Number and password or otherwise use the Genie Services. These cookies allow us to recognize you if you visit multiple pages on our site during the same session, so that you don't need to re-enter your password multiple times.

3. Our Use and Disclosure of Information
Internal Uses

We collect, store and process your personal information on servers located in the United States and operated by AllCom and elsewhere in the World where AllCom facilities are located. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customized experience.

Disclosure to Other Genie Customers
Your credit card number, bank account and other financial information will not be revealed to anyone whom you have paid or who has paid you through the Genie Services or third parties that use the Genie Services. If you are buying goods or services and pay through Genie, we may provide the seller with the delivery address for the goods and your billing address to complete your transaction. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.

We work with third parties including merchants to enable them to accept or facilitate payments from or to you using the Genie Services. In doing so, a third party may share information about you with us such as your Genie Number, email address or phone number, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a Genie Subscriber and that Genie can be enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if you request that we validate your status as a Genie Subscriber with a third party, we will do so. Please note that third parties you buy from and contract with may have their own privacy policies, and Genie is not responsible for their operations, including but not limited to their information practices.

Our Contact with Genie Customers

We communicate with our users on a regular basis via email and text to provide requested services. We also communicate with our users by phone to:

resolve Subscriber complaints or claims made by users via the Genie Services;

1. respond to requests for Subscriber service;
   
2. inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
   
3. confirm information concerning a user's identity, business or account activity;
   
4. carry out collection activities;
   
5. conduct Subscriber surveys; and
   
6. investigate suspicious transactions.

We use your email or physical address to confirm your opening of a Genie account, to send you your Genie Card, to send you notice of payments that you send or receive through Genie (including referral payments described below), to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.

4. Information Security
Genie is committed to handling your information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. The security of your Genie account also relies on your protection of your Genie password. You may not share your Genie password with anyone. Genie representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorized and suspicious. If you do share your Genie password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings.

5. CashCodes and Authorization Codes
To avoid fraud when making a purchase or sending money through the Genie Services Buyers / Senders obtains a single purpose single use authorization code often referred to as a CashCode. Buyers / Senders provide their Genie Number with the specific CashCode and dollar amount to the Seller for verification purposes and to complete the transaction. WHEN USING GENIE SERVICES THE SELLER CANOT REQUEST AN AUTHORIZATION FOR A PURCHASE IT MUST ALWAYS BE PROVIDED BY THE BUYER.

6. Accessing and Changing Your Information
You can review the personal information you have provided us and make any desired changes to such information, or to the settings for your Genie account, at any time by logging in to your account on the Genie website and change your preferences. You can also close your account through the Genie website. If you close your Genie account, we will mark your account in our database as "Closed", but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.