SimplyWise Privacy Policy

This Privacy Policy applies to information collected by SimplyWise, Inc. ("SimplyWise", "we", "us", or "our") when you interact with us as a current, prospective, or former customer of our goods and services, as well as:

• through the use of the SimplyWise website at https://www.simplywise.com/ and any subdomains thereof and the services, features, and information available on the Site and/or any mobile applications we may offer (the "Site"); and
• through the use of the SimplyWise applications that are made available via the Apple App Store, Google Play Store, or other publicly available app store or internet web page (each, an "App", and collectively, the "Apps").

As used herein: (a) the "Service" shall collectively refer to the Site and the Apps, along with associated and successor websites, applications, features, information, and services, or any part of the foregoing; (b) "you" and "your" mean a user of the Service; and (c) the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within SimplyWise or among our Corporate Affiliates within the United States or internationally.

As of the effective date of this Privacy Policy, our Apps include the following applications:

• SimplyWise: Cost Estimator
• SimplyWise: Company Mileage
• SimplyWise: Receipts, Expenses
• SimplyWise: AI Receptionist

This Privacy Policy serves to notify you of the following:

1. What information about me is collected?
2. Where and when is information collected (including through the use of cookies and action tags)?
3. Does SimplyWise collect information from children under 13 years of age?
4. What does SimplyWise do with the information it collects?
5. When does SimplyWise disclose information to third parties?
6. Does this Privacy Policy apply when I click a link or otherwise connect to other websites or services?
7. Is the information collected through the Service secure?
8. Could my information be transferred to other countries?
9. For how long will my information be kept?
10. What choices do I have regarding my information?
11. How will I know if there are any changes to this Privacy Policy?
12. Who do I contact if I have any privacy questions?

1. What Information About Me Is Collected?

In connection with your use of the Service, we may collect information about you. Such information may include the following categories of information (which will depend in part on which specific Apps you use):

• name,
• address,
• e-mail address,
• password,
• login credentials,
• telephone number,
• any information included in support requests (such as screenshots, attachments, message content, account details etc.),
• calendar data (including both read and write access which may be used to support appointment booking),
• microphone audio (for voice search, voice notes, dictation, and in-app voice support),
• billing and credit card information, which is collected directly from you by our Outside Contractors (as defined below) that are responsible for billing and payment processing services, which may include Stripe, Plaid, Apple, Google, and PayPal (the "Payment Services Providers"),
• transaction details such as account references, transaction amounts, line-item descriptions, timestamps, payouts, and dispute/chargeback notifications,
• in-app purchase receipts, which are collected from Apple and/or Google and which may include transaction ID, product ID, purchase date, and subscription state, and
• any information that you choose to share through the Service.

In addition to the above, below are categories of information collected by our specific Apps:

App	Categories of Information Collected
SimplyWise: Cost Estimator	estimates invoices project details (description, location, intake form responses, job-site address, photos, blueprints, property measurements, client name and contact info, etc.) LiDAR room scans AI-generated project renders client intake forms photos or live walk-throughs business information (including logo and license number) social media profiles voice-agent audio
SimplyWise: Company Mileage	device motion timestamped trip and route information and related motion/activity data precise geolocation, via background collection with platform-specific permissions (iOS always-allow and Android foreground service location)
SimplyWise: Receipts, Expenses	personal and business receipts itemized receipt data email and other communications you integrate with the Service (including attachments and metadata), as well as Amazon, PayPal, QuickBooks, and Plaid accounts transaction data merchant data invoice/receipt metadata photos you take and photo library contacts voice-agent audio
SimplyWise: AI Receptionist	voicemails audio recordings of calls caller identity and contact information contact list call transcripts AI-generated summaries of calls voice-agent audio microphone audio customer-support AI-agent audio bulk contacts calendar data

We may also collect other information that in some cases may be identifiable, such as demographic information, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, crash logs, diagnostics, device and browser/app information and identifiers, IP address, usage data, SDK callbacks, Apple's Identifier for Advertisers (IDFA), Google Advertising ID (GAID), install referrer (Android), other advertising identifiers, push notification tokens (APNs/FCM), and statistical data involving the use of the Service. Also, please note that we use session recordings and similar technologies provided by third parties to understand how users interact with the Service and to improve performance, fix errors, and support users. These tools may collect interaction data when you use our Service such as your screen, pages viewed, clicks, scrolling, mouse movements, and other interactions. By using our Apps, you consent to the use of such session recording tools.

2. Where and When Is Information Collected (Including Through the Use of Cookies and Action Tags)?

2.1 General Sources

We may obtain your information in the following ways:

• We will collect information that you submit to us (including through messages, emails, calendars, attachments, and other information that you upload to or integrate with the Service);
• Through third-party applications that you integrate with the Service;
• From third-party commercial partners, including advertising and marketing providers;
• From users of the Service;
• From third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service; and
• If you identify yourself to us by communicating with us including by sending us an e-mail with questions or comments.

Through your use of the Service, you may give us information about other people and businesses, such as when you use the AI Receptionist App to record call audio, create transcripts and summaries, or provide us with the caller identity; in connection with the Cost Estimator App when homeowners filling out your intake form; or in connection with invoicing and payment operations. If you provide information to SimplyWise about another person, including as described in this section, you represent and warrant to SimplyWise that you have provided notice and obtained all consents and rights from such other person as required by applicable law to enable SimplyWise to process, and determine the purposes and means of processing of, such information, including as described in this Privacy Policy. Do not give us information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Policy.

2.2 Registering to Use the Service and in the Course of Using the Service.

You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you may be required to provide us with certain of the information described in Section 1.

If you choose to access certain portions of the Service using the Google, Apple, or other single-sign-on (SSO) login feature, you may be providing us with access to all information, attributes, and data in your Google, Apple, or other SSO public profile. We may freely store and use such information in accordance with this Privacy Policy. Such information may be stored by us and may be used in connection with providing the Service or to contact you.

2.3 Cookies and Action Tags.

We may collect information passively using "cookies" and "action tags."

"Cookies" are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, or to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services. In the course of providing such analytics-related services, such third-party analytics services providers could place or recognize unique cookies on your browser or device.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers or devices offer instructions on how to do so in the "Help" section of the toolbar or settings menu. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Service uses third-party service platforms (including to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

The main third-party platforms we use include:

• Analytics providers
• Session replay providers
• Crash and diagnostic reporting
• Consent management
• Advertising and attribution partners
• Push notification delivery
• Single sign-on providers
• Payment processors
• Banking and financial data
• Email integration (user-authorized)
• AI, ML, and voice providers
• Telephony and SMS
• Maps and location
• Customer support
• Cloud hosting and infrastructure

Here are links to some of the main third-party platforms we may use:

• https://www.google.com/policies/privacy/
• https://stripe.com/cookie-settings
• https://www.apple.com/legal/privacy/en-ww/
• https://www.tiktok.com/legal/page/us/privacy-policy/en
• https://www.facebook.com/privacy/policy/
• https://plaid.com/legal/#consumers

In particular, we would like you to be aware that, when you make a payment through the Service and interact with our Payment Services Providers, the Payment Services Providers may place cookies on your computer or mobile device in connection with the provision of its services, including for fraud prevention purposes. Please see https://stripe.com/privacy and https://stripe.com/cookie-settings, https://www.paypal.com/us/legalhub/paypal/privacy-full, https://www.apple.com/legal/privacy/en-ww/, and https://www.google.com/policies/privacy/ for more information. Note in particular that in addition to the above we also use the Stripe Connect offering in order to process payments on the Service. Please be aware that we may use the information we handle in connection with the Stripe Connect offering for our own lawful business purposes, such as product improvement, and by using the portions of the Service that integrate with Stripe Connect, you consent to our use of such information for those purposes and you shall provide a copy of this Privacy Policy to any person you authorize to use the portions of the Service that integrate with Stripe Connect and obtain such person's consent to this Privacy Policy.

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

Note that information collected from cookies, pixels, action tags (including web beacons), and other similar technologies (which may include device identifiers) as well as storage technologies from third parties (including Meta and/or TikTok) may be used to collect or receive information from the Site and elsewhere on the Internet and third parties, including Meta and/or TikTok, use that information to provide measurement services, and target and deliver ads. In addition, information collected from cookies (including cookies placed by third-party vendors, such as Meta, TikTok, and Google and its partners) and other similar technologies (which may include device identifiers) may be used to deliver advertisements to users of our Site when such users are using other websites, including Facebook/Meta, LinkedIn, TikTok, and YouTube. These third-party vendors may use cookies and/or device identifiers to serve ads based on your past usage of our Site. You may opt out of a third-party vendor's use of cookies and/or device identifiers for personalized advertising or the collection and use of your information for ad targeting by visiting https://thenai.org/opt-out/, http://www.aboutads.info/choices, and/or http://www.youronlinechoices.eu/.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.

2.4 Log Files.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information as well as for security, fraud prevention, and debugging purposes. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

3. Does SimplyWise Collect Information From Children Under 13 Years of Age?

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13.

4. What Does SimplyWise Do With the Information It Collects?

We may use the information collected in the following ways:

• to provide the Service to you and process your transactions;
• if you integrate an outside account with the Service (such as your email account via the receipt scanner app), SimplyWise will have read-only access to the information in such account and this integration will allow SimplyWise to automatically upload your email receipts and bills directly to your SimplyWise account;
  • users should not include any highly sensitive information (such as Social Security numbers, financial information, or "protected health information" (as that term is defined by the Health Insurance Portability & Accountability Act) in any emails so that such data does not transfer to our servers (even if only temporarily);
  • we communicate with Google servers through the Gmail API (OAuth) and SimplyWise's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements and you can revoke access at any time;
• to help us understand who uses the Service;
• for internal operations such as operating and improving the Service;
• to contact you for customer service and billing purposes;
• to facilitate the delivery of advertising, our marketing campaigns, and/or analytics;
• when we believe it is necessary or appropriate to enforce our legal rights and to comply with applicable laws, lawful requests, and legal process (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities;
• to communicate with you, including to send you a welcoming e-mail that may confirm your username;
• unless you opt out (to the extent permitted by applicable law), to send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback;
• to send announcements and updates regarding the Service or, if applicable, about your billing account status (please note that you will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you or your Organization);
• to perform statistical analysis of user behavior or to evaluate and improve the Service, and to link some of this information to other information for internal purposes or to improve your experience with the Service; and
• to anonymize your information (so that it can no longer be associated with you), in which case we may use and/or disclose such anonymous information for our lawful business purposes and we will use reasonable safeguards designed to minimize the risks associated with the process of anonymizing your information.

If you opt in, please be aware that we may communicate with you at your mobile phone number via SMS/text message, including to contact you for support and customer engagement purposes. We may contact you about products, services, information, and news that may be of interest to you through the use of third party service providers (such as Twilio). For the avoidance of doubt, your plaintext mobile number and consent to receive text messages from us will not be shared with or sold to third parties or affiliates for those third parties' or affiliates' own independent marketing or promotional purposes. Any information we share with third parties or affiliates excludes your mobile number and consent to receive text messages from us (except to the extent necessary for third party service providers such as Twilio to provide services to us). Please be aware that message frequency may vary and that standard message and data rates may apply depending on your carrier. Also, our text messaging service provider may collect and monitor these messages to detect spam, fraudulent activity, and violations of their policies (available at: https://www.twilio.com/en-us/legal/aup).

5. When Does SimplyWise Disclose Information to Third Parties?

We generally disclose information we gather from or about you to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you. With respect to the third parties to whom SimplyWise discloses your information, SimplyWise takes commercially reasonable steps designed to ensure that such third parties will handle your information in a manner consistent with this Privacy Policy.

5.1 Laws and Legal Rights.

We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

5.2 Third Parties Generally.

We may provide information to third parties, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party advertisers, analytics service providers, and commercial partners) may directly collect information about our users' online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include potential or actual advertisers, providers of advertising products or services (including vendors, analytics services providers, and website tracking services), affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site "How Google uses data when you use our partners' sites or apps", currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google's website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

5.3 Professional Advisors.

We may provide your information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

5.4 Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Service, such as hosting and maintaining the Service, customer relationship management (CRM) services, providing credit card processing and fraud screening, including the Payment Services Providers, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. Please be aware that in connection with support inquiries, we may use artificial intelligence and machine learning models in connection with processing those inquiries. Accordingly, you should not submit any sensitive information in connection with such support inquiries. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

5.5 Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger, general corporate reorganization, or other transfer of all or substantially all of the assets of SimplyWise or any of its Corporate Affiliates (as defined below), or that portion of SimplyWise or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in SimplyWise, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

5.6 Affiliates.

We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with SimplyWise, whether by ownership or otherwise; and "control" means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

5.7 Reports Feature of Our Apps.

If you use the reporting feature of our receipt app ("Reports"), we will disclose your receipts, financial summaries, and other information to third parties designated by you. If you choose to use Reports, we will generate a UUID-link for you to use and we encourage you to enable the password protection option. Once you send a link to any third party using Reports please be aware that SimplyWise cannot control further distribution of that UUID-link and it is your sole responsibility to manage access to and recipients of that UUID-link.

6. Does This Privacy Policy Apply When I Click a Link or Otherwise Connect to Other Websites or Services?

Our Service may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third-party website or ability to connect to any other third-party service does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites or services. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us or on our behalf, including through the Service.

7. Is the Information Collected Through the Service Secure?

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

8. Could My Information Be Transferred to Other Countries?

Information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information.

9. For How Long Will My Information Be Kept?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. What Choices Do I Have Regarding My Information?

We generally use your information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must "opt in" and give us permission to use your information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in each applicable communication or such other directions we may provide or by contacting us using the details set out in Section 12.

Please note that to the extent you opt out of tracking via Apple's App Tracking Transparency settings, your IDFA will not be shared with us, however, this setting is limited to your Apple IDFA and does not otherwise opt you out of other tracking or online advertising.

Under certain circumstances and in compliance with applicable law, you may have the right to submit a request regarding your information. If you want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact us using the details set out in Section 12.

To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track.

The term "Do Not Track" refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

11. How Will I Know If There Are Any Changes to This Privacy Policy?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to "opt in" to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

12. Who Do I Contact If I Have Any Privacy Questions?

If you have any questions or comments about this Privacy Policy, please contact us in any of the following ways:

By e-mail:

support@simplywise.com

By postal mail or courier:

Attn: Privacy
SimplyWise, Inc.
369 Lexington Avenue, 3rd Floor #3115
New York, NY 10017
United States