Last Updated: March 26, 2024.We at XcoinX (the XcoinX entities listed in Section 11 below, referred to here as “we”, “us” or “our”) respect and protect the privacy of those who explore our Services (“Users”) and Users who sign up for and access our Services (“Customers”) (together referred throughout this policy as “you” and “your”).This Privacy Policy describes how we collect, use, and share personal information when you explore, sign up for or access our “Services”, which include the services offered on our websites, including XcoinX.com, XcoinX.com/exchange, XcoinX.com/prime, XcoinX.com/futures, XcoinX.com/cloud (each a “Site” and collectively the "Sites") or when you use the XcoinX mobile app, the XcoinX Card App, XcoinX Exchange, XcoinX Prime, Dapp Wallet, or XcoinX Custody application programming interface (“API”) or third party applications relying on such APIs (together, our “Apps”) and related services. If you reside outside of the UK and the European Economic Area (the “EEA”), accessing and using our Services means that you accept this Privacy Policy and its terms. It is important that you understand how we use your information. You should read this page in full, but below are the key highlights and some helpful links:Our goal is to simplify your crypto experience. If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Services.We collect and use your information in order to provide and improve our Services and your experience, protect the security and integrity of our platform, and meet our legal obligations.To learn more, explore Section 1. What Information We Collect and Section 2. How We Use Your Information.We share your information with other XcoinX companies, as well as trusted third parties and service providers, in order to offer our Services and fulfill legal requirements.To learn more, explore Section 3. How And Why We Share Your Information.We offer privacy tools for you to request access to or deletion of information we hold about you. You can use these tools by visiting your Privacy Rights Dashboard. Depending on where you live, you may also have other privacy rights under law.If you have any questions, please contact us on our Support Portal or at dpo@XcoinX.com. See Section 9. How to Contact Us With Questions for more information.1. WHAT INFORMATION WE COLLECT
We collect the following personal information and documentation:Information You Provide to Us
Information Collected Automatically
Information we obtain from Affiliates and third parties2. HOW WE USE YOUR INFORMATION
We use your personal information to deliver, personalize, operate, improve, create, and develop our Services, to provide you with a secure, smooth, efficient and customized experience as you use them, and for legal compliance, loss prevention, and anti-fraud purposes. Learn more about how we use your personal information and our legal basis for each such data use:Data use necessary to perform our contract with you
Data use to comply with our legal obligationsData use for our Legitimate InterestsData use based on your consentData use to protect your or others’ vital interests3. HOW AND WHY WE SHARE YOUR INFORMATION
We work with service providers, partners and other third parties to help us provide our Services, and as a result we need to share certain information with these third parties. Here’s how:Affiliates
Linked Third Party Websites
TRUST
Professional advisors, industry partners, authorities and regulators
Asset Transfer or Company Acquisition
Third-Party Service Providers4. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
We retain your information as needed to provide our Services, comply with legal obligations, or protect our or others’ interests. While retention requirements vary by country, we maintain internal retention policies on the basis of how information needs to be used. This includes considerations such as when the information was collected or created, whether it is necessary in order to continue offering you our Services, whether we are required to hold the information to comply with our legal obligations, including AML/KYC compliance or other financial regulatory obligations, or information preservation requirements. We also keep certain information where necessary to protect the safety, security and integrity of our Services, Customers, and Users. Our third-party electronic identity verification providers collect and retain biometric information for the period required for financial regulatory compliance or otherwise as required by applicable law. They retain this information for as long as set out in their applicable notices/policies.In line with these considerations, we delete information that is no longer needed for the above purposes when you close your account, or when you request deletion of your information (which you can initiate through your Privacy Rights Dashboard).5. CHILDREN'S PERSONAL INFORMATION
The Sites and Services are not directed to persons under the age of 18, and we do not knowingly request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information through the Sites or Services. If a User or Customer submitting personal information is suspected of being younger than 18 years of age, XcoinX will require the relevant Customer or User to close his or her account, and will take steps to delete the individual’s information as soon as possible.6. INTERNATIONAL TRANSFERS
To facilitate our global operations, XcoinX, its Affiliates, third-party partners, and service providers may transfer, store, and process your personal information throughout the world, including Ireland, Germany, Singapore, the UK, the US, and the Philippines. See here for more information. If you reside in the EEA, Switzerland, or the United Kingdom, we rely upon a variety of legal mechanisms to facilitate these transfers of your personal information (collectively, “European Personal Data”).We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of European Personal Data to third countries, including from our EU operating entities to XcoinX, Inc. in the United States. For a copy of the Standard Contractual Clauses, please contact dpo@XcoinX.com. In addition, we may rely on certain exemptions provided for under data protection law for our international transfers. We also rely on adequacy decisions from the European Commission where available and exemptions provided for under data protection law. For example, because XcoinX operates and provides its Services globally, we need to share information with our Affiliates and to data centers outside the EEA in order to develop, offer, and improve our Services (Article 49(1)(b) GDPR). In addition, we may rely on certain exemptions for sharing personal information with law enforcement outside of the EEA in emergency situations (Article 49(1)(f) GDPR).EU-US, UK-US, and Swiss-US Data Privacy FrameworkXcoinX complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) (together referred to as the “Data Privacy Frameworks”) and the DPF Principles as set forth by the U.S. Department of Commerce. XcoinX has certified to the U.S. Department of Commerce that it adheres to:the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF;the UK-U.S. Data Privacy Framework Principles (EU-UK DPF Principles) with regard to the processing of personal data received from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF; andthe Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. In the context of an onward transfer, XcoinX has responsibility for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as a service provider, partner and/or other third party to help us provide our Services on our behalf (as described in Section 4 of this policy). XcoinX remains liable under the DPF if any such third party processes personal data in a manner inconsistent with the DPF, unless XcoinX can prove that we are not responsible for the event giving rise to the damage. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, visit https://www.dataprivacyframework.gov In compliance with the Data Privacy Frameworks, XcoinX commits to resolve all DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the relevant Data Privacy Frameworks should first contact XcoinX at: dpo@XcoinX.com For unresolved complaints concerning our handling of personal information in reliance on the Data Privacy Frameworks, XcoinX is a member of and relies upon the ICDR-AAA services for the Data Privacy Framework Program, see here https://go.adr.org/dpf_irm.html, which may involve, under certain conditions, binding arbitration.The Federal Trade Commission has jurisdiction over XcoinX’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).7. YOUR PRIVACY RIGHTS AND CHOICES
Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. For any of your privacy rights and choices referenced below, requests relating to your personal information can be made by logging into your account and going to your Privacy Rights Dashboard or by submitting a request via our Support Portal or at dpo@XcoinX.com. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, XcoinX has absolute discretion in providing you with these rights.Right to access and portability: You may request that we provide you a copy of your personal information held by us through your Privacy Rights Dashboard, or by submitting a request via our Support Portal. Right to rectification: You may request us to rectify or update any of your personal information held by XcoinX that is incomplete or inaccurate by logging in to your account and clicking the Profile or My Account tab.Right to deletion/erasure: You may request to erase your personal information, subject to applicable law. If you close your XcoinX Account, we will retain or delete information associated with your account as described in Section 4. How Long We Keep Your Personal Information.Right to withdraw your consent: To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. The lawfulness of XcoinX’s processing before you withdraw your consent will not be affected by such withdrawal.Right to object to or restrict processing: You may have the right to restrict or object to us using or transferring your personal information based on our legitimate interests, in the public interest, or for direct marketing. We may continue to process your personal information where permitted or required by applicable law. You can opt-out of receiving marketing communications from XcoinX through your account settings or by submitting a request via our Support Portal. Right to non-discrimination: We will not discriminate against you for exercising any of your rights provided to you under law.Right to lodge a complaint: If you reside in the EEA, Switzerland, or the UK, you have the right to lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state. In the UK, the relevant data protection authority is the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, +44 (0303) 123 1113, email: casework@ico.org.uk. In Ireland, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: info@dataprotection.ie or by using the following online form: Forms for Data Protection.If you reside in Australia or the Philippines, you may lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country. In Australia, the relevant data protection authority is the Office of the Australian Information Commissioner, and complaints may be made through their website at www.oaic.gov.au. In the Philippines, the relevant data protection authority is the National Privacy Commission, email: complaints@privacy.gov.ph.To protect your privacy and security, we may take steps to verify your identity before complying with your request and we may decline your request if we are unable to verify your identity.Under certain US data privacy laws, as well as in Brazil, you may also designate an authorized agent to make these requests on your behalf. These rights are not absolute, and may be denied: (a) when granting access or assisting portability would adversely affect the rights and freedoms of others; (b) to protect our rights and properties; (c) where the request is frivolous or vexatious; or (d) as otherwise permitted by law.8. PRIVACY NOTICE FOR UNITED STATES RESIDENTS
If you are a United States Resident, you can learn more about how we use your information and your privacy rights by reviewing our United States Privacy Notice. Any terms defined in the California Consumer Privacy Act (as amended) (“CCPA”) have the same meaning when used in the US Privacy Notice. 9. HOW TO CONTACT US WITH QUESTIONS
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us on our Support Portal, at dpo@XcoinX.com, or by writing to us at the address of your XcoinX service provider (provided in Section 11. Our Relationship With You below).10. CHANGES TO THIS PRIVACY POLICY
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.We may provide additional "just-in-time" disclosures or information about how we collect or use your information in the context of specific Services; these in-product notices may supplement or clarify our privacy practices or may provide you with additional choices about how we use your information.11. OUR RELATIONSHIP WITH YOU
If you reside in the EEA or Switzerland, XcoinX Ireland Limited, XcoinX Europe Limited and XcoinX Germany GmbH act as joint controllers in respect of your personal information. XcoinX Ireland Limited is the joint controller with primary responsibility for your personal information, including with respect to providing you with information and responding to any requests you may make under the GDPR. Please see more about how you can exercise your rights under the GDPR through our Privacy Rights Dashboard.
These Additional Cash Terms of Service (the “CashTerms”) govern your use of the CashMe application, and the website at cash.me(the “Cash Site”), and the electronic money and payment services provided toyou through the Cash Site and CashMe (the “CashMe Service”).
The CashMe Service is provided by Cash, Inc, a company incorporated in Delaware, United States company number08957689, whose head office is at 447 Broadway, New York, NY, 10013, United States.
Cash, Limited, a company incorporated in England and Wales with company number583287 whose registered office is at Fumbally Cash, Inc, Fumbally Lane, Dublin8, Ireland (‘Cash, Inc International’ and together with Cash, Inc Europe, “Cash,Inc” “we,” “our,” or “us”), provides all other services, including the SaaSServices (as defined in the Point-of-Sale, Saas, andService Terms) (the “SaaS Terms”) related to the CashMe Service.
By using the CashMe Service, you agree to be bound by these Cash Terms, the SaaS Terms and the General Terms (collectively, the “Service Terms”), and acknowledge that they constitute a legally binding contract between us and you. Defined terms have the same meaning as those found in the General Terms, unless otherwise defined herein. To the extent there is any inconsistency between these Cash Terms and any other terms applicable tot he CashMe Service, these Cash Terms shall prevail. If you do not agree to allof these terms, you are not permitted to access or use the CashMe Service, andyou should not proceed further.
You shouldread these terms carefully. You can always see the most current version of theService Terms on cashme.com/legal. Please print or download a copy and keep itfor future reference. If you want a paper copy, please contact Cash Supportat https://cashme.com/help.
I. Ourstatus
Cash, Inc is an Electronic Money Institution authorised by the Financial Conduct Authority (the “FCA”) under the Electronic Money Regulations 2011 (firm reference number900846) for the issue of electronic money and provision of payment services.Details of our authorisation are available on the public register https://register.fca.org.uk/.
II.Overview of the CashMe Service
The CashMe Service enables you to store funds in your Cash Balance and to transmit or receive payments with other CashMe customers. You can make payments from the funds you hold in your (i) CashBalance (ii) your linked U.K. bank account (your “Bank Account”), or (iii) your linked U.K. debit card (“Debit Card” and each, an “Eligible Debit Account”).You can also receive payments into your your Eligible Debit Account.
III.Eligibility
You must be a resident of the United Kingdom and at least 18 years of age to use the CashMe Service and you must register for an account (your “Cash Account”). You must only create a Cash Account with an tomwildgust1@gmail.com address or a mobile telephone number that you own.
IV. CashAccount
In order to use the CashMe Service you must create an account by providing us with certain information (your “Cash AccountInformation”). You represent and warrant that any information you enter in yourCash Account is true and accurate. It is your responsibility to regularly checkyour Cash Account Information and to ensure that all of your Cash AccountInformation is up to date and accurate at all times.
We may request that you provide us with certaininformation, including but not limited to your name, email address,text-enabled mobile telephone number, street address, postcode, date of birth,and a government issued form of identification. You acknowledge and understandthat, directly or through third parties, we may make any inquiries we considernecessary to validate and authenticate your identity and Cash AccountInformation. This may include asking you for further information anddocumentation about your usage of the CashMe Service or identity, or requiringyou to take steps to confirm ownership of your email address, mobile telephonenumber or Eligible Debit Account, and verifying your information against thirdparty databases or through other sources.
The first time you access your Cash Account using anew device we may require you to authenticate your Cash Account with additionalinformation. If your Cash Account cannot be verified you may be required to setup a new account.
You authorise Cash, Inc International, in order toprovide you with the CashMe Service, including the SaaS Services, to view,monitor and analyse all activity in your Cash Account and to track, predict,report on and monitor fraud and other suspicious or financially risky activity.You further authorise Cash, Inc International to investigate any potentialfraud, suspicious or financially risky activity, as it may deem appropriatetaking into account Applicable Law. Your authorisations permit Cash, IncInternational to: report to you on Cash, Inc Europe transferring funds for thepurpose of reversing transactions; assess the onboarding, transactional andrelated data in your Cash Account and request additional information andconfirmations from you; assess your transaction history for root cause orsystemic issues with a view to suggesting to you appropriate preventativemeasures for fraud and suspicious activity; and conduct investigations andresolve any pending disputes related to your use of the CashMe Service.
Where Cash, Inc International’s analysis of yourCash Account indicates that there is an undue likelihood of fraud, suspiciousactivity or financially risky behaviour occurring that can be eliminated,reduced or prevented by taking any action permitted hereunder (including butnot limited to suspending or declining Payments), you further authorise Cash,Inc International to recommend that Cash, Inc Europe implement such action inorder to mitigate such likelihood.
If you refuse to (a) cooperate in an investigation(b) provide confirmation of your identity or, (c) provide confirmation of anyinformation you provide us, then we may close, or refuse to open, your CashAccount.
V. CashIDs
You may select a unique alpha-numeric name toidentify yourself for the purposes of using the CashMe Service (a “CashID”).Your CashID must accurately and truthfully represent your personal identity.You may not select a CashID that misleads or deceives others as to youridentity or creates an undue risk of mistaken payments. We may require you tochange your CashID or details of your profile in our sole discretion, and wemay reclaim or make unavailable CashIDs without liability to you.
VI. AccountStatements
All of your CashMe Service transactions arerecorded and can be accessed in your “Transaction History” portion of the CashMeor on the Cash Site. You agree that we will provide you with a monthly accountstatement through the CashMe and the Cash Site. You are able to download orprint your monthly account statement to retain permanently and we advise thatyou do so. You should monitor your Transaction History on a regular basis andnotify us of any transaction activity you do not recognize by contactinghttps://cashme.com/help.
You should ensure your device and software is up todate to ensure that you can access your monthly account statements through CashMeor on the Cash Site.
VII.Communication
We will provide communications to you (1) throughthe notification channel you choose in your CashMe profile, (2) by making themavailable in CashMe, or (3) on the Cash Site.
You may opt out of receiving promotional messagesfrom CashMe at the time you set up your Cash Account by visiting the“Notifications” section of your profile in CashMe or on the Cash Site or byfollowing the instructions in those messages as set out in the privacy policy.If you opt-out of receiving such promotional communications we will still sendyou messages about your use and our provision of the CashMe Service.
Depending on the information you provide us, andyour settings at the “Notifications” sections of CashMe or on the Cash Site wemay send you CashMe Service related and promotional communications (if you havenot opted out) via email, text (SMS) or via CashMe.
If you provide us with the email address, CashID ormobile number of any other person when initiating or requesting a paymentthrough the CashMe Service, we will contact that person via email address, text(SMS) message or via CashMe person to notify the other person of your requestto make such payment.
Standard text messaging rates may apply based onyour plan with your mobile phone carrier.
VIII. CashSupport
If you needto contact us or make any notifications to us in connection with the CashMeService or under these Cash Terms, you should contact Cash Support at https://cashme.com/help.
IX.Security Credentials
Upon registration for a Cash Account, you have anoption to go to your settings within the CashMe and enable touch ID and upondoing so you will be prompted to set a four (4) digit personal identificationnumber “PIN”, and for devices that do not have touch ID functionality, onlysetting a PIN (each a “Security Credential”). Once you enable your SecurityCredential you will then be prompted to use a Security Credential each time youattempt to transfer funds.
In the event that you attempt to log in to yourCash Account from a new device, we will prompt you to enter your PIN to accessyour Cash Account from such new device.
You must take all reasonable steps to keep your Security Credentials, and any device on which the CashMe is installed, secure at all times and you must not share your Security Credentials or device with any third party. You should note that your obligations under this Section have a direct impact on Cash, Inc Europe’s responsibility to reimburse you for unauthorised payment transactions in accordance with Section XIII(3) of these Cash Terms.
X.Compromised, or Threat of Compromised, Accounts
If you become aware of or suspect: (i) any loss, theft or compromise of your Security Credentials or any device paired to yourCash Account or (ii) any unauthorised use of your Security Credentials or CashAccount, you must notify Cash, Inc Support immediately by contacting us athttps://cashme.com/help. You should note that your obligations under thisSection have a direct impact on our responsibility to reimburse you for unauthorised payment transactions in accordance with Section XIII(3) of theseCash Terms.
If you notify us of a security concern regarding your Cash Account, or if Cash, Inc has grounds to suspect a fraud or security threat to your Cash Account, we will contact you using the designated email or mobile number registered to your Cash Account. In such communication we will provide you with a link to our support center, which will require that you provide your Security Credentials for access, and through this secureconnection we will provide you with further information about the suspectedfraud or security threat to your Cash Account. You should contact usimmediately if we contact you about suspected fraud or security threat as wemay suspend your Cash Account until the issue is resolved. Please note, incommunications with you, Cash Support staff may ask you security relatedquestions in order to verify that you are the registered owner of the CashAccount. Cash Support staff will not however ask you to reveal remote accesslog-on information and you should keep this confidential and secure. Due to ourlegal obligations, we may need to verify certain facts before we are able to discussa suspected fraud or security issue openly with you. We recommend that you keepaccess to your designated email or data sent to your mobile phone numberpersonal to you and secure.
If you have informed us of a security breach inrelation to, or if we otherwise suspect the fraudulent or unauthorised use of,your Cash Account, we may suspend further use of your Cash Account inaccordance with this Section and we require you to change your SecurityCredentials.
We will inform you of any intention to suspend theuse of your Cash Account, specifying the reasons for doing so, unless theprovision of this information would compromise reasonable security measures orwould otherwise be unlawful. Where it is not possible to notify you beforehand,we will do so immediately after suspending the use of your Cash Account. Wewill allow the use of your Cash Account as soon as practicable after the reasonfor stopping its use ceases to exist.
XI. CashBalance
**1. Funding your Cash Balance
Payments you receive from other CashMe customerswill be held in your Cash Balance. You can also transfer funds into your CashBalance using your linked debit card or bank account.
**2. No Interest
You will not receive interest on or other monetarybenefit related to the length of time during which we hold your funds in theCash Balance. Your Cash Balance is not a deposit and you do not have any rightto seek compensation under the UK’s Financial Services Compensation Scheme ifyou suffer any financial loss of the Cash Balance.
**3. Transferring Money from your Cash Balance toYour External Account
**i. Generally
You may transfer funds from your CashMe to yourBank Account. You can choose to transfer funds using the standard transfer orthe “Instant Deposit” (if Instant Deposit is available to you). With a standardtransfer the deposit will be made available to you by the end of the nextBusiness Day. For the purpose of these Cash Terms, “Business Day” means a dayother than a Saturday, Sunday or a public holiday in England when banks inLondon are open for business.)
Instant Deposits will be transferred to your BankAccount within thirty (30) minutes. Instant Deposits are subject to the feelisted in the CashMe during the Instant Deposit experience. We reserve theright to delay transfers if we consider it necessary for security or anti-moneylaundering purposes or in order to comply with Applicable Law. We may requestthat you provide additional information to verify your identity beforecompleting the transfer.
**ii. Limitations
You may not transfer funds from your CashMe to yourBank Account to evade an investigation. If you attempt to transfer funds fromyour Cash Balance while we are conducting an investigation, we may hold yourfunds for up to 180 days to protect Cash, Inc or a third party against the riskof reversals, chargebacks, claims, fees, fines, penalties and other liability.You will remain liable for all obligations related to your account even afterthe account is closed.
**4. Making Payments Using Funds in Cash Balance
You can transfer funds to another CashMe customerin accordance with Section XII below. If you have insufficient funds in yourCash Balance to cover the entirety of the amount to be transferred we will pullthe full transaction amount from your Bank Account or Debit Card.
**5. Limitations
Cash, Inc may limit the payment methods that youcan use to load your Cash Balance.
We may impose limitations on the amount you canhold in your Cash Balance and the maximum amount or frequency with which youload funds into your Cash Balance.
XII. MakingPayments
1. General
You may transmit funds or receive funds using the CashMeService for personal, non-commercial purposes. If you attempt to transmit fundsto an individual who does not have a Cash Account, we will contact thatindividual using the contact details provided by you and we will invite them tocreate a Cash Account as set out in Section XII(2) below.
2. SendingMoney
Once you have registered for a Cash Account and (i)have funds available into your Cash Balance; or (ii) linked Bank Account orDebit Card, you will be able to initiate fund transfers. As a party initiatinga transfer (“Sender”), you can transfer funds to your selected recipient(“Recipient”) by (i) logging into your Cash Account, (ii) designating theRecipient by entering their CashID, email or phone number, (iii) indicating theamount of money you want to send, and (iv) selecting the confirmation action (a“Payment Instruction”). Once you have confirmed the Payment Instruction, youauthorise us to debit funds from your Eligible Debit Account and transfer themto the designated Recipient (a “Payment”). By submitting a Payment Instruction,you are also authorising us to move the funds back to your Eligible DebitAccount for Payments that are cancelled or otherwise returned (a “Credit”).
You cannot revoke a Payment Instruction once it hasbeen received by us. You understand and agree that when you initiate a PaymentInstruction the funds will be deducted from your Cash Balance on the same dayas we receive your Payment Instruction. However, the Recipient will only beable to receive the transferred funds once they have registered for a CashAccount. You hereby authorise and direct us to retain such funds until theearlier of: (i) such time as the Recipient has successfully registered for a CashAccount or (ii) fifteen (15) days. If the Recipient has not registered for aCash Account you are permitted to cancel the order at any time, and if you donot and the Recipient has not registered for a Cash Account within fifteen (15)days, we will return the funds to you. If we are not able to return funds toyour Eligible Debit Account, we may use other reasonable means to return thePayment to you, as permitted by Applicable Law.
You agree that we shall incur no liability if weare unable to complete any transaction because of: (i) insufficient funds inyour Eligible Debit Account; (ii) malfunction of the CashMe Service due tocircumstances beyond our control or due to circumstances that you were alreadyaware of at the time you initiated your Payment Instruction; (iii) aninaccurate or insufficient Payment Instruction; or (iv) failure of theRecipient to claim the Payment.
3.Requesting Cash
You may also initiate a request for funds to betransferred to you by designating the amount of funds requested and yourselected Sender (a “Cash Request”). If the Sender approves your Cash Request,your Cash Request will become the Sender’s Payment Instruction and be processedas described in these Cash Terms.
4.Receiving Cash
You will receive payments made to you from otherCash customers into you Cash Balance. You can store the funds received intoyour Cash Balance to use for future payments or you can transfer the funds toyour Bank Account in accordance with Section XI.1(c).
5. InvalidPayments
If you receive a Payment and we later determine inour sole discretion that the Payment was invalid for any reason and should bereversed, then you authorise us to deduct funds held in your Eligible DebitAccount for an amount equal to the Payment.
6.Limitations on Use
You agree that you are independently responsiblefor complying with all Applicable Laws in all of your activities related toyour use of the CashMe Service, and for all communications you send through theCashMe Service.
As an electronic money institution we are requiredto mitigate the risks that your Cash Account would be used for financial crime,money laundering or other unlawful purposes. As such, Cash, Inc Europe reservesthe right to Cash, Inc, refuse, or reverse any Payment Instruction made underthese terms where it reasonably believes, including upon the recommendation of Cash,Inc International, that it must do so: (i) to protect the security of your CashAccount, (ii) if there is suspected unauthorised or fraudulent use of your CashAccount, (iii) you are in breach of the Service Terms or (iv) the transactionis or is determined by Cash, Inc Europe, in its sole discretion upon takinginto consideration any relevant recommendations from Cash, Inc International,likely to be unlawful. We will notify you promptly if we decide to do so,unless such notification would be unlawful.
Neither we nor third parties to whom we assign ordelegate rights or responsibilities will be liable for any claims or damagesresulting from Senders’ initiation of prohibited Payments. All costs for thefollowing will be your sole responsibility and not ours, which we reserve theright to charge at actual pass-through costs: (a) where you have indicated thewrong unique identifier (i.e. where you have provided us with the wrong CashID),and Cash, Inc must make reasonable efforts to recover the funds (b) in theevent we refuse a Payment Instruction as reasonably justified as a matter ofApplicable Law, and (c) in the event a customer revokes a payment order.
7. Limitson Payment Amounts
Additional identification information will berequired to send more than two hundred and fifty pounds (£250) in any onetransaction or in multiple transactions over any seven (7) day period or toreceive more than five hundred pounds (£500) in any seven (7) day period. Afterwe have verified your additional identification information, Senders may sendup to one thousand five hundred pounds (£1,500) in any one transaction or inmultiple transactions and Recipients may receive up to ten thousand pounds (£10,000)over any seven (7) day period. We may adjust these limits at any time in ourreasonable discretion for the purpose of mitigating the risk of financial crimeor fraud.
8. Fees
There are currently no fees for sending orreceiving money using the CashMe Service. If you choose to deposit funds toyour Bank Account using Instant Deposit, you will be charged the fee that isshown to your prior to your confirmation of the transaction.
XIII.Liability For Unauthorised or Incorrectly Executed Payment Transactions
1. Duty tonotify
We shallhave no liability for unauthorized or incorrectly authorized paymenttransactions made from your Cash Account that have not been authorised by youor have been incorrectly executed unless you notify us:(a) without undue delayon becoming aware of the unauthorised or incorrectly executed paymenttransaction; and (b) in any event, no later than 13 months after the date ofthe payment transaction. Such notifications should be made to Cash Supportat https://cashme.com/help.
2. Ourliability for unauthorised payment transactions
We will refund any unauthorized paymenttransactions made through your Cash Account provided you have notified us inaccordance with Section XIII(1) above and save to the extent you are liable forany part of the payment transaction as set out in the Section XIII(3) below.
3. Yourliability for unauthorised payment transactions
Unless you have acted fraudulently, you will haveno liability for a payment transaction not authorised by you after you havemade a notification under Section XIII(1) of these Cash Terms.
You will be liable for the first £35 of anyunauthorised payment transaction if it arises from the loss or theft of yourSecurity Credentials or the misappropriation of your Cash Account.
However, you will be liable for the entire amountof the unauthorised payment transaction if you have acted fraudulently or youhave intentionally or with gross negligence failed to: (a) use your CashAccount in accordance with these Cash Terms, (b) notified us under SectionXIII(1) of these Cash Terms of these terms; or (c) keep your SecurityCredentials safe.
4. Ourliability for incorrectly executed payment transactions
We will refund any payment transactions madethrough your Cash Account that have not been correctly executed provided youhave notified us of the incorrectly executed transaction in accordance withSection XIII(1). However, we will not be liable to you for an incorrectlyexecuted payment transaction when:
(a) we can demonstrate that the recipient hasreceived the transfer; or (b) the problem has arisen as a result of youproviding us with the incorrect information.
In the event of (b) above, we will make reasonableefforts to recover your funds. And regardless of liability under this Section,on request from you, we will immediately and without charge, make efforts totrace any non-executed or incorrectly executed transaction, and notify you ofthe outcome.
XIV.Privacy
We willonly use your personal information as set out in our Privacy Policy.
XV. Term,Amendment and Termination of Service
The Cash Terms are effective from the point youagree to these Cash Terms. The Cash Terms are conducted for an indefiniteperiod and will continue to apply until terminated by you or us in accordancewith these Cash Terms.
We may amend the Cash Terms from time to time byproviding you with two months’ notice of such changes before they come intoeffect. We will give you notice by providing you with a link to a copy of therevised Cash Terms in a form that you can save and print and will notify you ofthe proposed date of entry into force. You understand that you will be deemedto have accepted the changes to the Cash Terms unless you terminate your use ofthe CashMe Service and the Cash Terms before they come into force. If youreject any changes, you have the right to terminate free of charge and witheffect at any time until the date the changes would have applied.
You may close your Cash Account and terminate theCash Terms at any point in time for any reason by selecting that option withinyour Cash Account.
We reserve the right to terminate the Cash Terms orcease to provide CashMe Services to you either:
1. on two (2) months’ notice; or
2. with or without prior notice, if: (a) you no longersatisfy the eligibility criteria for the CashMe Service; or (b) we have reasonto believe you are using your Cash Account in connection with fraudulent orunlawful activities, money laundering or terrorist financing, or other criminalor illegal activity; (c) you have breached the Service Terms or any ApplicableLaw, or (d) we are required to do so by any competent court of law, governmentauthority, public agency or law enforcement agency.
Any termination of the Cash Terms or cessation of CashMe Services does not relieve you of obligations to pay Fees or costs accrued prior to the termination.
XVI.Complaints and Disputes
In the event of any dispute or problem with the CashMe Service please contact CashSupport at https://cashme.com/help inthe first instance. In the event that your query is not satisfactorilyresolved, you may lodge a complaint with us or request details about ourcomplaint handling procedures by following the instructions on the CashMe Site or contact support at https://cashme.com/help.
The Financial Ombudsman Service is an independentbody that helps settle complaints between customers and firms regulated by theFCA. If we are unable to resolve your complaint satisfactorily you may qualifyto escalate your complaint to the Financial Ombudsman Service by post,addressing your complaint to the Financial Ombudsman Service, Exchange Tower,London E14 9SR, by email to complaint.info@financial-ombudsman.org.uk or bytelephone on 0300 123 9 123 or 0800 023 4567. Financial Ombudsman Service’s websiteis http://www.financial-ombudsman.org.uk. Further information regarding theFinancial Ombudsman Service and whether you qualify for this service isavailable on the Financial Ombudsman Service’s website or can be requested bycontacting Cash, Inc Support. In addition, please note that disputes may besubmitted for online resolution to the European Commission Online DisputeResolution platform.
These Cash Terms shall be governed by English law,except that if you live in Scotland or Northern Ireland, there may be certainmandatory Applicable Laws of your country which apply for your benefit andprotection in addition to or instead of certain provisions of English law.
Any claims arising out of or relating to the CashTerms or the provision of the CashMe Service that cannot be resolved by contacting Cash Support may be settled through the Financial Ombudsman Service.In the event that you are not eligible or do not elect to make a complaint to the Financial Ombudsman Service, you agree that any dispute between you and us regarding these Cash Terms or the CashMe Service will only be dealt with by theEnglish courts, except that if you live in Scotland or Northern Ireland, you can choose to bring legal proceedings either in your country or in England, but if we bring legal proceedings, we may only do so in your country.
XVII. OTHERLEGAL TERMS
1.Intellectual Property Rights
We license, but do not sell, to you the CashMe. We remain the owner of CashMe at all times.
All intellectual property rights in the Cash Site and CashMe and in any content of the Cash Site and CashMe (including text,graphics, software, photographs and other images, videos, sound, trademarks andlogos), are owned by us or our licensors. Except as expressly set out here,nothing in these terms gives you any rights in respect of any intellectualproperty owned by us or our licensors and you acknowledge that you do notacquire any ownership rights by downloading CashMe or any content from the CashSite or CashMe.
2. ReferralPrograms
From time to time, Cash, Inc International mayoffer referral programs or incentives for inviting others to use the CashMeService (a “Referral Program”). Any bonuses or incentives under such ReferralProgram shall be subject to the then current Referral Program terms, ifapplicable, and otherwise at our sole discretion.
3.Limitations.
We may impose limitations on the value andfrequency of payments that you can make using the CashMe Service. We reservethe right to change the limitation at any time for security reasons or where weconsider it necessary to comply with Applicable Law. We reserve the right torefuse any request to transfer funds if processing the transfer will exceedthese limits. Each funding source will have different dispute resolution rightsand procedures in the event your transaction turns out to be unsatisfactory.Your dispute resolution rights are determined by the funding source used tofund your transaction
4. Taxes
As a Recipient, you may be asked to provide certaininformation used to assist us in complying with certain U.K. tax reporting /disclosure obligations, as may be required. Also, you are responsible for an ytaxes which may be applicable to your use of the CashMe Service, and it is your responsibility to collect, report and pay the correct tax to the relevant tax authority.
5. Language
These Cash Terms and all information we provide to you in connection with the CashMe Service will be in English.
6. CashMeand Cash Site features and Content
You agree that access and use of the Cash Site anddownloading, access and use of CashMe, since they are made available free ofcharge, are on an ‘as is’ and ‘as available’ basis and at your sole risk.
We reserve the right to change the format andfeatures of CashMe and the Cash Site by updating the Cash Site and making theupdated CashMe available for you to download and, where your device settingspermit it, by automatic delivery of updates to CashMe. You are not obliged todownload updated versions of CashMe, but we may cease to provide and updatecontent to prior versions of CashMe and, depending on the nature of the update,in some circumstances you may not be able to continue using CashMe until youhave downloaded the updated version.
Where we make content available through the CashSite or CashMe, you acknowledge that such content may be updated at any time.We reserve the right to cease to provide and update content to the Cash Siteand CashMe, with or without notice to you, if we need to do so for security,legal or any other reasons.
Except as set out in these terms, we make or giveno representation or warranty as to the accuracy, completeness, currency,correctness, reliability, integrity, quality, fitness for purpose ororiginality of any content of CashMe and the Cash Site and, to the fullestextent permitted by law, all implied warranties, conditions or other terms ofany kind are hereby excluded and we accept no liability for any loss or damageof any kind incurred as a result of you or anyone else relying on the contentof CashMe and the Cash Site.
6. GeneralProvisions
These Cash Terms are between you and us. No otherperson shall have any rights to enforce any of its terms.
Each of the paragraphs of these terms operatesseparately. If any court or relevant authority decides that any of them areunlawful, the remaining paragraphs will remain in full force and effect.
If we do not insist immediately that you doanything you are required to do under these Cash Terms, or if we delay intaking steps against you in respect of your breaking these Cash Terms, thatwill not mean that you do not have to do those things and it will not preventus taking steps against you at a later date.
You may not transfer, assign or deal in any othermanner with any or all of your rights and obligations under these Cash Termswithout our prior written consent. We reserve the right to transfer, assign ornovate these Cash Terms without your consent. This does not affect your rightto close your Cash Account.
This Privacy Notice describes how Cash, Inc. and our affiliates (collectively, “CashMe,” “we,” and “us”)collect, use, disclose, transfer, store, retain or otherwise process your information when you (“you,” “your”) download CashMe through a relevant app store and sign up for a CashMe account and other services through the app or online at https://cashme.com (collectively,“Services”).
This Privacy Notice applies to your use of ourServices, and covers only information collected in connection with your accessto and use of our Services. Please read this Privacy Notice carefully. Bycontinuing to interact with our Services, you are consenting to the practicesdescribed in this Privacy Notice.
Our Privacy Notice explains:
o Information we collect about you
o Sourcesof Information We Collect About You
o Howwe use your information
o Whenand with whom we share your information
o Cookiesand Other Similar Automated Technologies
o Third-PartyAnalytics Services
o HowLong We Keep Your information
o YourChoices
o Rightsof California Residents
o Additional Disclosures for Canada Residents
o Security
o Storageand Processing
o Changesto this Privacy Notice
o Howto Contact Us
INFORMATIONWE COLLECT ABOUT YOU
We use your data to make CashMe’sproducts and services work better for you and for others. This describes whatdata we get about you (which can vary depending on where you live).
We need to collect information about you to provideyou with the Services or the support you request. Specifically, we collect(and/or have collected during at least the 12-month period preceding theeffective date of this Privacy Notice) the categories of personal informationdescribed below. Additionally, you can choose to voluntarily provideinformation to us.
Information You Provide toAccess our Services
We use data you put into oursystems when you use CashMe, like financial information, information thatidentifies who you are, transaction information, and any other data you giveus.
We collect information you provide when you applyor sign up for a CashMe account, go through our identity or accountverification process, authenticate into your account, communicate with us,answer our surveys, participate in contests or promotions offered by us or ourpartners, or otherwise use our Services.
We collect the following categories of informationabout you when you use our Services, including:
o Identification Information, such as: Your name, email address, zip or postalcode, phone number, CashID, signature, and authentication credentials (forexample, information you use to log in to your Cash account), includingInternet Protocol (“IP”) address.
o Additional Identification Information forVerified Users, such as: Your full mailingaddress; date of birth; government-issued identification, including SocialSecurity number, passport, or driver’s license; and photograph, facial scan andbiometrics extracted from such image if you choose to share such information inorder to send and receive larger payment amounts or purchase Bitcoin.
o Financial Information, such as: Bank account and payment card numbersyou add to your CashMe account, as well as your CashMe Card number if you haveone.
o Contacts Information. In order to provide you with the Service, wewill also need to collect information from you about the intended recipient ofthe payment you request us to make. We will therefore ask you to providecontact details of your intended recipient. You can do this by manuallyentering a phone number or email address into the CashMe. You can also chooseto let us access your phone contacts information, as described below(under Information You Provide to Enhance Your Experience).
o Transaction Information. When you use our Services to make, accept, orrequest payments, we collect information such as: when and where thetransactions occur, the names of the transacting parties, a description of thetransactions, the payment or transfer amounts, and the devices and paymentmethods used to complete the transactions.
InformationYou Provide to Enhance Your Experience
We also use data you give us tomake your experience with CashMe better, like contacts you choose to upload tomake it easier for you to exchange money with them.
You can choose to provide us with additionalinformation to improve your user experience when using our Services:
o Contacts Information. You can choose to let us access and uploadyour phone contacts information to make it easier for you to find the peopleyou want to send money to, to help you invite your friends to CashMe, foraccount and identity verification and fraud prevention purposes, to reduce therisk you will send payments to the wrong person, or to provide otherpersonalized services. You can update your settings to stop sharing your phonecontacts with us at any time, although we will always need a recipient’s phoneor email address to send money to them as requested by you.
o Other Information You Provide. We collect information that you voluntarilyprovide to us, including your photograph, if you choose to upload a picture tothe Services; survey responses; participation in contests, or other prospectivemarketing forms or devices; suggestions for improvements; referrals; or anyother actions you perform on the Services.
Information We Collect From YourUse of our Services
We also get data from thedevices you use when you interact with our systems, like your location andinformation about the device you’re using. We need this data to do things likehelp protect your account from hackers, combat fraud, check if payments arebeing made or received legally and by you, and making our products and servicesbetter for you and others.
We collect information about you and the devicesyou use to access the Services, such as your computer, mobile phone, or tablet.The information that we collect includes:
o Geolocation Information. The location of your device, including yourIP address, device language, and location of your network provider. This mayinclude precise geolocation information. For more information and to learn howto disable collection of precise geolocation information from your mobiledevice, please see below.
o Device Information. Information about your device, including yourhardware model, operating system and version, device name, unique deviceidentifier, mobile network information, and information about the device’sinteraction with our Services. If you use an iOS device, we also automaticallydetect if you have downloaded Chrome, so we can ask you which browser youprefer to use to open links from your CashMe.
o Internet or other electronic network activityinformation. Information about how youuse and interact with our Services, including your access time, “log-in” and“log-out” information, browser type and language, country and language settingon your device, IP address, the domain name of your internet service provider,other attributes about your browser, mobile device and operating system, anyspecific page you visit on our platform, content you view, features you use,the date and time of your use of the Services, your search terms, and thewebsite you visited before you visited or used the Services.
o Inferences drawnfrom any of the information we collect to create a profile about you that mayreflect, for example, your preferences, characteristics, and behavior,including for account security purposes or to enhance our Services to you.
SOURCES OFINFORMATION WE COLLECT ABOUT YOU
We also need to check that youare using our services legally, that you are eligible for the services you wantto use, and we protect your data and our services from fraudsters who may putyou and your money at risk. To do this, we may collect data about you fromcompanies that help us verify your identity, do a credit check, prevent fraudor assess risk.
We collect (and/or have collected during at leastthe 12-month period preceding the effective date of this Privacy Notice)information about you from the following categories of sources:
o You directly, when you submitinformation to us or allow us to access information
o Your devices and how youinteract with our Services
o Our group companies oraffiliates
o Other sources, including:
o Identity Verification. Information from third-party verificationservices (e.g., identity verification agencies and companies which providethird party analytics (see “Third-Party Analytics” below)), and publiclyavailable sources. In some circumstances, where lawful, this information caninclude your government-issued identification number.
o Credit, Compliance, and Fraud. Information about you from third parties forany credit investigation, credit eligibility, identity or account verificationprocess, fraud detection process, or collection procedure, or as may otherwisebe required by applicable law. This includes, without limitation, the receiptand exchange of account or credit-related information with any credit reportingagency or credit bureau, where lawful, and any person or corporation with whomyou have had, currently have, or may have a financial relationship, includingwithout limitation past, present, and future places of employment, financialinstitutions, and personal reporting agencies.
HOW WE USEYOUR INFORMATION
We use your data to do thingslike make sure the products you are using work, help you log in to youraccount, verify who you are, secure your data, fight fraud, follow the law,enforce our agreements, figure out what new products we can build, and marketand tailor our products to you.
We may collect, use and share (or have collected,used or shared during at least the 12-month period preceding the effective dateof this Privacy Notice), information about you for the following reasons:
Providing, Improving, andDeveloping our Services
o Determining whether the Servicesare available in your country;
o Processing or recording paymenttransactions or money transfers;
o Providing you with the CashMeproduct and features you choose to use;
o Displaying your historicaltransaction information;
o Connecting you with people youalready know;
o Providing, maintaining andimproving our Services;
o Developing new products andservices;
o Delivering the information andsupport you request through the use of our Services;
o Improving, personalizing andfacilitating your use of our Services, content and applications;
o Measuring, tracking andanalyzing trends and usage in connection with your use or the performance ofour Services, including promotions or discounts offered by us or our partners;and
o Otherwise providing you with theproducts and features you choose to use.
Communicating with You About ourServices
o Sending you surveys and gettingyour feedback about our Services; and
o Sending you information we thinkyou may find useful or which you have requested from us about our products andservices.
Protecting our Services andMaintaining a Trusted Environment
o Conducting investigations,complying with and enforcing any applicable laws, regulations, legalrequirements, and industry standards, and responding to lawful requests forinformation from the government or to valid legal process;
o Contacting you to resolvedisputes, collect fees and help you with our Services;
o Debugging to identify and fixerrors that impair how our Services function;
o Making sure you follow our Termsof Service or other applicable agreements or policies;
o Investigating, detecting,preventing, recovering from, or reporting fraud, misrepresentations, securitybreaches or incidents, other potentially prohibited, malicious, or illegalactivities, or to otherwise help protect your account, including to disputechargebacks on your behalf;
o Protecting your, our, or ourother customers’ rights or property, or the security or integrity of ourServices;
o Verifying or maintaining thequality and safety of our Services; and
o Verifying your identity (e.g.,through government-issued identification numbers).
Advertising and Marketing
o Marketing our Services to you;and
o Communicating with you aboutopportunities, products, services, contests, promotions, discounts, incentives,surveys, and rewards offered by us and select partners.
If we send you marketing emails, each email willhave instructions on how you can “opt out” of getting future marketing from us.
Other Uses
o For any other reason we may tellyou about from time to time, with your consent.
WHEN ANDWITH WHOM WE SHARE YOUR INFORMATION
We share your information withothers in the circumstances described in this section. For example, with otherpeople with whom you interact when you use our services; within our family ofcompanies who may offer services that we think could be useful to you; withservice providers who help us run our services; or if we need to share yourinformation to comply with the law.
We may share the information described in the“Information We Collect About You” section with the following categories ofservice providers and third parties:
With Other Users of our Services
o With other users of ourServices. For example, we may share information with the person(s) with whomyou transact when you make or accept a payment or money transfer using ourServices. This helps them know they’re getting money from you (or that you requesteda payment from them). We may also make certain information available to other CashMecustomers to help them know they’re making a payment to the right person, suchas when you joined CashMe and whether you appear in their contacts, and thenumber of people in their contacts who have also transacted with you. We mayalso make certain information available to person(s) with whom you choose tocommunicate using our Services to help them know they are communicating withthe right person, such as your name, CashID, and prior transaction history withsuch person. If you choose, we may also allow you to share additionalinformation about you and your use of our Services with other CashMe customers.
With our Affiliates and GroupCompanies
o With our group companies andcorporate affiliates, for the reasons outlined above. For example, we may shareyour information internally to provide you with enhanced services from CashMeand our other company products you use, to understand how you engage with ourcompany products to help make our Services better for you and for everyone, andto help us build Services tailored to your preferences.
With our Service Providers
o With service providers who helpus provide, maintain, and improve our Services (e.g., vendors who help us withfraud prevention, identity verification, and fee collection services), as wellas financial institutions, payment networks, payment card associations, creditbureaus, carrying brokers, and other entities in connection with your payment,money transfer process, investing activity, or otherwise to help us provide theServices;
With Advertising Partners
o With advertising partners whohelp us run our advertising campaigns, analyze our site, run contests, specialoffers, or other events or activities, and track metrics on our behalf or inconnection with our Services.
Business Transfers and CorporateChanges
o To a subsequent owner, co-owner,or operator of one or more of the Services; or
o If we do or try to do acorporate merger, consolidation, or restructuring (including during duediligence and negotiation of these); the sale of substantially all of our stockand/or assets; the financing, acquisition, divestiture, or dissolution of all ora portion of our business; or other corporate change.
Safety and Compliance with Law
o If we believe that disclosure isreasonably necessary (i) to comply with any applicable law, regulation, legalprocess or governmental request (e.g., from creditors, tax authorities, lawenforcement agencies, in response to a garnishment, levy, or lien notice,etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforceor comply with our Terms of Service or other applicable agreements orpolicies; (iv) to protect our or our customers’ rights or property, or thesecurity or integrity of our Services; (v) for an investigation of suspected oractual illegal activity; or (vi) to protect us, users of our Services or thepublic from harm, fraud, or potentially prohibited or illegal activities.
With Others with Your Consent
o With your consent. For example:
o At your direction or asdescribed at the time you agree to share;
o When you authorize a third partyapplication or website to access your information.
Aggregated and AnonymizedInformation
o We also may share (within ourgroup of companies or affiliates, or with service providers or other thirdparties) aggregated and/or anonymized information that does not specificallyidentify you or any individual user of our Services.
COOKIES ANDOTHER SIMILAR AUTOMATED TECHNOLOGIES
Digital cookies and similartechnologies help us make our services better to use by doing things likerecognizing when you’ve signed in, analyzing how you use our services so we canmake them more useful to you, giving you a more personalized experience, andmaking our ads to you work better.
When you interact with our online services, or openemails we send you, we obtain certain information using automated technologies,such as cookies, web server logs, web beacons, and other technologies. A“cookie” is a text file that websites send to a visitor’s computer or otherinternet-connected device to uniquely identify the visitor’s browser or tostore information or settings in the browser. A “web beacon,” also known as aninternet tag, pixel tag, or clear GIF, is a tiny graphic image that may be usedin our websites or emails.
We use these automated technologies to collect yourdevice information, internet activity information, and inferences as describedabove. These technologies help us to:
o Remember your information so youdo not have to re-enter it;
o Track and understand how you useand interact with our online services and emails;
o Tailor our online services toyour preferences;
o Measure how useful and effectiveour services and communications are to you; and
o Otherwise manage and enhance ourproducts and services.
We set some of these automated technologiesourselves, but others are set by third parties who deliver services on ourbehalf. For example, we may use other companies’ web analytics services(described in the “Third-Party Analytics Services” section), which useautomated technologies to help us evaluate how customers use our websites.
Your browser can alert you when cookies are placedon your device, and how you can stop or disable them via your browser settings.Please note, however, that without cookies all of the features of our onlineservices may not work properly. If you use a mobile device, you can manage howyour device and browser share certain device data by changing the privacy andsecurity settings on your mobile device. You can learn more about cookies andhow to manage your preferences by visiting http://www.allaboutcookies.org.
THIRD-PARTYANALYTICS SERVICES
We use other companies asservice providers to help us analyze our site, and track metrics. These serviceproviders generally promise us under contract to keep data private.
We may use third-party analytics service providersto help us with our online services, such as BugSnag. The analytics providersthat administer these services use technologies such as cookies, web beacons,and web server logs to help us analyze how you use our online services. We maydisclose your site-use information (including IP address) to these analyticsproviders, and other service providers who use the information to help usfigure out how you and others use our online services. To learn more about BugSnag,please visit https://docs.bugsnag.com/legal/privacy-policy/.
HOW LONG WEKEEP YOUR INFORMATION
We keep your information as longas you keep using our products and services. After that, we keep it for as longas we need it to do things like fight fraud, collect fees you owe, resolvedisputes with (or involving) you, follow the law, enforce our agreements anddefend our rights in court.
We keep your information as longas is necessary for the purposes identified in this Privacy Notice, includingto provide you the Services, to comply with applicable law and legalobligations, and to defend our legal rights, property and users. Even after youdeactivate your account, we can retain copies of information about you and anytransactions or Services in which you may have participated for a period oftime that is consistent with certain criteria, such as applicable law,applicable statute of limitations, or as we believe is reasonably necessary tocomply with applicable laws, regulations, legal processes, or governmentalrequests, to detect or prevent fraud, to collect fees owed, to resolvedisputes, to address problems with our Services, to assist with investigations,to enforce our Terms of Service or other applicable agreements orpolicies, or to take any other actions consistent with applicable law.
YOURCHOICES
You can see, change or fixinformation you gave us, ask us to deactivate your account, control yourlocation information, or opt out of receiving promotional messages from us.
If you live in California or Canada, you have additional rights, which wedescribe below.
Personal Information
You can access, change, orcorrect information that you have provided by logging into your CashMe accountat any time or by making a request to us using the contactdetails below. We will need to verify your identity before grantingaccess or otherwise changing or correcting your information.
Deactivating Your Account
If you wish to deactivate youraccount, you can do so at any time by logging into your CashMe account andvisiting https://cashme/support.
If you would like to have youraccount closed permanently, please contact us at https://cashme/support.
Location Information
In order to provide certain Services, we mayrequire access to location information, including precise geolocationinformation collected from your device. If you do not consent to collection ofthis information, certain Services will not function properly and you will notbe able to use those Services. You can stop our collection of locationinformation at any time by changing the preferences on your mobile device. Ifyou do so, some of our mobile applications will no longer function. You alsomay stop our collection of location information via mobile application byfollowing the standard uninstall process to remove Cash mobile applicationsfrom your device.
Do Not Track
Certain web browsers allow you to instruct yourbrowser to respond to Do Not Track (“DNT”) signals to website you visit,informing those sites that you do not want your online activities to betracked. At this time, our websites are not designed to respond to DNT signalsor similar mechanisms from browsers.
Promotional Communications
You can opt out of receiving in-app pushnotifications containing promotional messages from us by following theinstructions on screen or by following the instructions in those messages. Ifyou decide to opt out, we may still send you non-promotional communicationsin-app, or via email and text, such as transaction receipts and messages aboutyour account, or our processing of your information in accordance with theprovision of our Services.
RIGHTS OFCALIFORNIA RESIDENTS
If you live in California, the following additionalrights apply to you.
Right to Know
You may have the right to request, up to twice in a12-month period, to see the following information about the personalinformation we have collected about you:
o The categories and specificpieces of personal information we have collected about you;
o The categories of sources fromwhich we collected the personal information;
o The business or commercialpurpose for which we collected the personal information;
o The categories of third partieswith whom we shared the personal information; and
o The categories of personalinformation about you that we disclosed for a business purpose, and thecategories of third parties to whom we disclosed that information for abusiness purpose.
California law also gives you the right to ask ifwe share your personal information to third parties for their direct marketingpurposes (we do not disclose your personal information for unaffiliated thirdparties’ direct marketing purposes).
Right of Deletion
You have the right to ask us to delete the personalinformation we have collected from you (subject to exceptions the lawprovides). Please note that you may no longer be able to use our Services ifyou delete your personal information.
Right of Correction
You have the right to correct the personalinformation we have collected about you (subject to exceptions the lawprovides).
Right of Non-Discrimination
You have the right to not be discriminated againstif you exercise these privacy rights. We will not discriminate against you,deny, charge different prices for, or provide a different quality of goods orservices if you choose to exercise these rights.
Rights to Opt-Out
You have the right to opt-out of the sharing of your personal information for purposes of certain targeted advertising known as cross-context behavioral advertising. If we share your personal information to third parties for such purposes, we will provide you the right to opt out of such sharing (subject to exceptions the law provides).
Although some of the information we collect and process about you may be considered sensitive personal information, we only process such information for purposes authorized by law, such as to provide services you request from us or to verify your information.
Although we disclose your personal information to third parties as described above, we do not sell your personal information.
How to Exercise Your Rights
You may submit an access, deletion, or correction request by logging into your CashMe account and visiting https://cashme/support. To help protect your privacy and maintain security, we take steps to verify your identity and may require you to be logged in to your CashMe account before granting you access to your personal information or complying with your request. You may also designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.
To the extent permitted by applicable law, we maycharge a reasonable fee to comply with your request.
Exceptions to These Rights
California law provides for certain exceptions tothe rights described above. We reserve the right to avail ourselves of theseexceptions where applicable.
ADDITIONALDISCLOSURES FOR CANADA RESIDENTS
If you are a resident of Canada, CashMe is providedto you by, and your personal information is under the control of, CashMe CanadaPayments ULC, with its offices at 1600 - 925 West Georgia St., Vancouver, BCV6C 3L2.
You have the right to request access to thepersonal information that CashMe has about you, to request information abouthow that personal information has been processed, and to withdraw your consentto our processing of your personal information. You also have the right torequest that CashMe correct any erroneous personal information we have aboutyou, and to request that personal information be deleted in certaincircumstances. You can exercise your rights by logging into your CashMe accountand visiting https://cashme/support. Please note that these rights are subjectto certain exceptions, and we may require that you take certain steps to verifyyour identity before responding to your request. You can contact our DataProtection Officer and privacy team with any questions or concerns regardingthis Privacy Notice at the address above or https://cashme/support.
CHILDREN’S PERSONAL INFORMATION
If you are a child under 13,please don’t use our services. If we collect your data and later learn you area child under 13, we will delete it.
Our Services are general audience services notdirected at children under the age of 13. We do not knowingly sell or share forcross-context behavioral advertising the personal information of children underthe age of 16. If we learn that any information we collect has been provided bya child under the age of 13, we will promptly delete that information.
HOW WESECURE INFORMATION
We do a lot to keep your datasafe. While we think we have strong defenses in place, no one can everguarantee that hackers won’t be able to break into our sites or steal your datawhile it is stored or flowing from you to us or vice versa.
We take reasonable measures, includingadministrative, technical, and physical safeguards, to protect your informationfrom loss, theft, and misuse, and unauthorized access, disclosure, alteration,and destruction. Nevertheless, the internet is not a 100% secure environment,and we cannot guarantee absolute security of the transmission or storage ofyour information. We hold information about you both at our own premises andwith the assistance of third-party service providers.
For more information about our security practices,please visit https://cashme/security.
STORAGE ANDPROCESSING
We operate in many countries,and we (or our service providers) may move your data and process it outside the country where you live.
We may, and we may use third-party service providers to, process and store your information in the United States, Canada,Japan, the United Kingdom, the European Union, and other countries. Authorized employees, representatives, and agents will have access to your information for the purposes described in this Privacy Notice.
CHANGES TO THIS PRIVACY NOTICE
We can change this privacy notice. When the changes impact your rights or how we use your data in important ways, we’ll tell you first, which may be through our app, website, or by email.
We may amend this Privacy Notice from time to timeby posting a revised version and updating the “Effective Date” above. Therevised version will be effective on the “Effective Date” listed. We willprovide you with reasonable prior notice of material changes in how we use your information, which may include notification in CashMe through our app orwebsite, or by email, if you have provided one. If you disagree with thesechanges, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Privacy Notice.
HOW TO CONTACT US
You can contact our privacy teamwith any questions or concerns as described below.
Please contact our privacy teamwith any questions or concerns regarding this Privacy Notice at Cash, Inc. 1955Broadway, Suite 600, Oakland CA 94612, U.S.A. or by logging into your CashMeaccount and visiting https://cashme/support.
If you have any questions or concerns regarding ourprivacy notice, or if you believe our privacy notice or applicable lawsrelating to the protection of your personal information have not beenrespected, you may file a complaint with our privacy team listed above. We willrespond to let you know when you can expect a further response. We may requestadditional details from you regarding your concerns and may need to engage orconsult with other parties in order to investigate and address your issue. Wemay keep records of your request and any resolution. If you remaindissatisfied, you can also make a formal complaint to the applicable privacyregulator in your jurisdiction.