Four Key Commitments

1. We will never disclose, share, or sell your data. Your data belongs to you. We will never share it without your explicit consent.
   
2. We will keep your data secure at all times. We will use the highest industry-standard security technology to protect your data while it is stored on your phone, in transmission over the internet, and on our servers.
   
3. Your data will always be available to you. You will always be able to access your personal data, even if you stop using our products. We will never charge you to access your own information.
   
4. We will remove your data from our systems anytime you want.  If you decide to stop using our products and no longer want your historical information to be saved by us, we will immediately remove it from our servers.

How We Collect Data

1. Directly when you provide it to us. When you create an account in our products, you enter personal information such as your name, phone number, and passcode. This information is used to complete your user profile, send you personalized transaction summaries, and allow you to securely log in and access your private information.
   
2. Automatically as you use our products. When you use our products, we also collect information automatically to personalize your user experience and help us support you proactively when you have questions or problems. This data is kept secure at all times and is never disclosed to third parties. The following information may be collected automatically through the normal usage of our products. 
   

How We Use Your Data

We use the information we collect in our products in several ways:

• Help you use the product for its primary purpose.
  

• Personalize your experience by storing helpful information about your preferences.
  

• Provide personalized support when you have questions or problems.
  

• Notify you when updates are available.
  

• Improve our products by better understanding how people are using them.
  

Data Security and Loss Prevention

Sharing General and Aggregate Data

When DreamSave groups enter the Partner ID and agree to allow the partner to view their records, that Partner and its affiliates will be able to view aggregated information about the group through the DreamSave Insights dashboard for monitoring and evaluation purposes. Partners with registered groups and accounts on the Insights dashboard will only have permission to view specific types of information about your group based on the consent given during the creation of your DreamSave account. Such information includes group transactions, saving and loan history, gender, age, education profile, as well as activity levels. 

No person or organization will ever be able to access or view user data through DreamSave Insights unless they are an official partner or affiliate of DreamStart Labs with a verified account. Each Insights user account will only be able to view data for the groups they support within a given partner project/program and country. 

Aggregated data shared with partners and/or their affiliates will never identify, reveal, or expose the private information of any individual user or group of users in any way without their explicit consent. 

Lastly, as a thought leader in our industry, we may at times also share broad general trends and insights based on aggregate data from our systems, in the public domain in the form of blogs or news articles.  Such data will never identify, reveal, or expose the private information of any individual user. 

Accessing, Correcting, or Deleting Your Personal Data

Data Deletion

There are two ways user accounts may be deleted:

1. User-Requested Account Deletion: Savings groups who wish to permanently delete their group account information from our systems can do so by choosing the “Delete Group Account” option under the account setup tab. This process will require two of the group's elected officers and one other member to enter their respective passcodes on the DreamSave app to authorize the account deletion. An SMS will be sent out to alert members of group account deletions. Individual members with personal accounts can also request for their data to be permanently deleted by clicking on the “Delete My Account” button at the bottom of the account dashboard screen from their Personal Login.
   
1. Groups or individual users are able to request the restoration of their accounts and data via the DreamSave app in one of two ways: within 30 days of the account being deleted. Account restoration requests can either be made by clicking on the “Restore Deleted Account” button on the homepage, or by requesting a group account be restored when prompted by the app when trying to log into a group account.
   
2. If 30 days have lapsed since an initial account deletion request was made and no reactivation request has been received and a saving group’s cycle has come to an end and share-out has taken place, the account will be deleted immediately.
   
2. Automatic Deletion due to Dormancy: If group accounts are found dormant within a 6-month period (no meeting recorded or data synced online) and those account owners have failed to reactivate their dormant account within 30 days, DreamStart Labs will delete the account.
   
1. User accounts are automatically flagged as dormant if not a single meeting has been synced or recorded within 6 months of registering the account.
   
2. CS representatives confirm the intentional inactivity of accounts and permission for account deletion by 1) ensuring that no technical issues are preventing active use of the DreamSave app, and 2) groups fail to request reactivation of their accounts within 30 days of it being deleted. CS Representatives confirm account activity through monthly engagements between CS representatives and partners to discuss partner data and group validation.
   
3. The account will be permanently deleted if: 1) 30 days have lapsed without a request for an account to be restored², and 2) if a saving group’s cycle has come to an end and shareout has taken place, and 3) dormant accounts remain deleted after 30 days.
   
4. Additionally, the DreamStart Labs engineering team conducts annual reviews to ensure the effective operation of automated data destruction protocols and alerts if preconditions mentioned above are met.
   

Children Under the Age of 13

Additional Legal Disclaimers

In full accordance with the above guidelines and policies, please note that we also reserve the legal right to disclose data in the following specifically defined circumstances:

• When required by law to comply with a court order or legal process.
  

• If disclosure is necessary or appropriate to protect the legal rights, property, or safety of our customers, stakeholders, or other key parties, including fraud protection and credit risk reduction.
  

• To enforce legal rights arising from any contracts or license agreements entered into between DreamStart Labs and our users.
  

• Note that third-party service providers under contract with DreamStart Labs may at times need access to our systems to support our business. These entities are bound by strict contractual obligations to support our data privacy policy, to keep personal information confidential, and to use it only for the purposes for which we engage them in the full support of our users.
  

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated. We will also include a direct link to this page from within the user interface of all relevant products.

Contact Information

To ask questions or comment about this privacy policy and our privacy

DreamStart Labs, Inc.

2907 Shelter Island Dr., Suite 105 San Diego, CA 92106, USA