Privacy Policy

Introduction
1. Bixie Limited (hereinafter also referred to as “Bixie”, “we”, “us” or “our”) is a software as a service platform that offers goal setting, financial literacy, account aggregation, community, automated expense tracking and access to 3 rd party financial products via our mobile application (hereinafter also referred to as “the App”) as well as our website. This Privacy Policy governs the manner in which Bixie collects, uses, maintains and discloses Personal Data collected from you as the users (hereinafter also referred to as “users”, “you” or “your”) of our App and website. We will also explain the measures being, and to be, taken to ensure that your Personal Data stays secure and confidential in compliance with the applicable data protection laws. This Privacy Policy applies to the services offered by Bixie.
Definitions
1. “Personal Data” is in reference to the “Personal Financial Data” and the “Personal Identification Data”. “Personal Financial Data” and “Personal Identification Data” are both defined in paragraph 4 below.
2. “Non-Personal Data” is data that is not reasonably practicable to directly or indirectly identify you, including, but not limited, to aggregated data, application usage, in-app browsing activity, and application activity including user interface elements, etc.
3. “Third-party partners” are individuals or organizations that cooperate with us for the purpose of facilitating or improving our services or third-party partners’ services provided to you.
Our Privacy Principles
1. Bixie’s business is built on trust between our users and us. Security and safety of our users’ Personal Data are our top priorities. To safeguard the confidentiality of all Personal Data you provide to us, we maintain the following privacy principles:
  1. We only collect Personal Data that we have identified in this Privacy Policy which we will use to deliver our services to you, and to facilitate third party services at your consent , operate our business, and help make the App and our offering work better for you.
  2. We maintain and design strict security systems to prevent unauthorised access to your Personal Data by anyone, including our employees, agents and contractors.
  3. Any members of the Bixie team and affiliates, including our employees, agents and contractors, who are permitted access to any Personal Data may only do so for a specific and limited purpose and specific and limited period of time– and during such access, are specifically required to strictly observe our confidentiality obligations.
  4. Unless specified in provision 4.7 of this Privacy Policy, we do not disclose, sell, trade or rent your personal data to any third parties.
The data we collect
1. We may collect and process Personal Data from users in a variety of ways, including, but not limited to, at the time of registration and when you install, download, access or use the App, or contact us in relation to the App. However, we commit to only using your Personal Data as set out in the terms below, and in accordance with the applicable laws.
2. When you register for and use the Bixie App or website, we collect your email address and device ID which we use to:
  1. provide you with our offers and services via the Bixie App or website;
  2. identify you and the accounts that you have registered with us;
  3. communicate with you;
  4. customise the Bixie App based on your preference; and
  5. notify you of any changes to the Bixie App or to our terms & conditions and/or services that may affect you.
3. We may at times use your mobile device’s built-in biometric authentication tools to provide you with additional security as a way of preventing unauthorized access to the App:
  1. When you use the App to access or connect to your online financial accounts, which may include, but is not limited to, online banking accounts, electronic payment accounts, insurance accounts, online payment accounts, and third party mobile wallets; we may collect and process details such as account name, credit limit, currency of the account, outstanding balance, your transaction details and history, payment dates and names , and addresses of goods and services merchants/providers that appear in your account (collectively known as “Personal Financial Data”), for the purposes of displaying this account information and transaction data to you in order to provide you with services on the App (e.g. budgeting).
  2. If you use the App to apply for third party financial services, we may request and store your identifications such as mobile number, and date of birth (collectively known as “Personal Identification Data”) for the purpose of making the application process convenient for you. Your Personal Identification Data will only be used at your request or with your consent.
4. We may collect or store any usernames and passwords, or other authentication details, inter alia, bank account numbers or credit card numbers for your online accounts. Online log-in credentials always remain encrypted on your device or securely stored on our server. Personal Financial Data for this purpose does not include information that is aggregated with similar data from other users to produce Aggregated Data (as defined in section 5 below), or is otherwise no longer identifiable to any specific App user.
5. We may record some Non-Personal Data, such as application usage, in-app browsing activity, and application activity including user interface elements. We may also use cookies, as well as third-party tracking technologies, such as Amplitude, OneSignal and Google Analytics, to record similar information regarding you and your activity on the App. We may grant access to this Non-Personal Data and tracking activity to certain trusted third-party services providers that we work with, but only to perform services on our behalf with restricted access to Personal Data on a need-to-know basis only, and always in compliance with this Privacy Policy.
6. If you make any purchases on Bixie, your credit card information and other data are not collected by us, but only by third party payment processors.
7. We may share the Personal Data, Non-Personal Data or Aggregated Data to third parties in the following situations:
  1. When we cooperate with our business partners to deliver their services to you– with your consent through our business partner– we may provide some of your Personal Data, Non-Personal Data or Aggregated Data to our business partners, on a need-to-know basis. All information and data we share with our business partners will also be subject to their own privacy policies.
  2. Security, legal and regulatory requirements: we reserve the right to disclose the data about you that is appropriate or necessary to (i) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (ii) take precautions against liability, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the services we provide and any facilities or equipment used to make those services available, (v) comply with any law or regulatory requirement, including pursuant to a court order or other legal process, or (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
Aggregated Data
1. For the purpose of producing research and statistical data about our App users and to provide you with services on the App, we may aggregate your Personal Financial Data together with similar data from other App users (“Aggregated Data”). Aggregated Data will be produced in such a manner that the underlying data will no longer be identifiable to any specific user. We may share Aggregate Data amongst users as part of the services provided, and also with our third party partners to help us make improvements and/or enhancements to our services and for marketing, research and academic purposes. This Aggregate Data cannot be linked to an individual or user in any way.
2. We will take all reasonable steps to anonymise the Aggregate Data, but please be informed that these measures are provided on a best-effort basis. In the event that you believe that any of your Personal Data is or has been inadvertently captured in the App or in any report generated or services provided by us, whether within or outside the App, it is your responsibility to immediately notify us at info@mybixie.com so that we are able to promptly rectify the situation.
Data Retention
1. We shall take all reasonably practicable steps to ensure that the Personal Data collected is kept no longer than is necessary for the fulfillment of the purpose for which it is or is to be used. In some situations, upon collecting the Personal Data, Non-Personal Data and/or Aggregate Data from you, and transferring such data to our business partners to facilitate our business partners to supply their services to you, we may immediately delete the data that has been passed to our business partners, and we may not store any such data on the App and our website.
2. Unless otherwise specified in provision 6.1 of this Privacy Policy, Non-Personal Data including Aggregate Data will continue to be stored and retained on our servers indefinitely. We reserve the right to retain and use Aggregate Data derived from the use of the App.
Data Deletion, Correction and Access to Personal Data
1. You have the right to request that your App account or any of your Personal Data be deleted from our servers at any time. You can make this request to us by contacting us at info@mybixie.com. Please note that once your account is deleted, any data linked to the App shall be excised permanently from our servers and further access to your account will be impossible.
2. At the end of your trial period, you will still have an option to request for Personal Data deletion anytime either using means listed out in 7.1 or through a feature within the Bixie app.
3. You have the right to request access to and correction of your Personal Data held by Bixie. We will respond to your request of data access or correction as soon as practicable upon receiving your request. A reasonable administrative fee may be charged for responding to a data access request to reflect the cost of responding to the request.
Data Security
1. Your responsibility:
  1. The App requires a user ID and password and/or biometric verification to log in. You should safeguard your user ID and password and keep them secret and confidential. Bixie will never ask you for your password given that you should be the only person who knows it. We recommend that you choose a strong password that is difficult to guess and that you change your password regularly. In public areas, please exercise caution , especially when logging-in/registering, and refrain from leaving your mobile device unattended or susceptible to theft whilst logged into your account.
  2. If you suspect that your credentials have been stolen or been made known to others, it is your responsibility to change your password immediately and contact us promptly at info@mybixie.com. We shall not be responsible for any loss or damage resulting from any unauthorised access to your account due to any failure to comply with these precautions or through any violation of this Privacy Policy or the Terms of Use.
  3. You should only download the App and its updates from the official Play Store and App Store and not from any unofficial sources.
2. Our commitment to safeguarding your Personal Data:
  1. To maintain the safety and security of your Personal Data, and to protect the App accounts and systems from unauthorized access, we use a combination of firewall barriers, encryption techniques and authentication procedures, inter alia. Our system will always prompt you to enter your credentials or biometric authentication for your privacy and security. The Personal Data that is collected from you in accordance with this Privacy Policy is transmitted securely to our servers. Access to our systems requires multiple levels of authentication. Our databases are protected from general employee access.
  2. However, the aforementioned security efforts do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not warrant that our servers or network will be immune from such attacks. We are not liable for any loss or damage arising from such risks.
Changes
1. If there are any significant changes to this Privacy Policy, we will send you a notification and to give you the opportunity to review the revised Privacy Policy before the change becomes effective. By continuing to use our services, you will be deemed to accept the change of the Privacy Policy.
2. Your use of the App and website is subject to Bixie’s Terms and Conditions. By using the App, you are deemed to have accepted and agreed to be bound by the Terms and Conditions. We reserve the right to make changes to the Terms and Conditions from time to time. We shall notify you of such changes by any reasonable means, including posting the revised version of the Terms and Conditions on our App and/or the Bixie website. It is your responsibility to frequently check on the changes. By continuing to use the App after the changes to the Terms and Conditions, you are accepting these changes.
Governing Law
1. This Privacy Policy will be governed by and construed in accordance with the laws of the Philippines.
Your Acceptance of these terms
1. By using our App or website, you signify your acceptance of this Privacy Policy.
Contact/Request for Data Deletion
1. If you have questions or concerns about this Privacy Policy or about our use or retention of your Personal Data, please contact us via email at info@mybixie.com.
2. If you would like to delete your account, you can do so at any time in the Bixie app; if you have any questions or concerns about deletion of your data and account, please contact us via email at info@mybixie.com with Subject: Account/Info Deletion.