CASHWISE
PRIVACY POLICY

1. Introduction

This Privacy Policy (the “Policy”) represents the policy of Cashwise Inc., a Delaware corporation (together with all subsidiaries thereof, the “Company”) regarding the collection, use, and management of personal data belonging to:

  • All visitors (“Site Visitors”) to the Company’s website located at  https://www.cashwise.finance (the “Website”);
  • Anyone who downloads or uses (“Application Users”) the Company’s mobile application (the “Application”)
  • Anyone who enrolls for the Services of the Company (“Clients”)

Site Visitors, Application Users, and Clients are referred to collectively as “Users”. The Website and the Application together with the Services (as defined below) and all content contained therein are referred to collectively as the “Resources” as further described in the User Agreement.

Ownership and reservation of rights

This Privacy Policy explains how Cashwise collects, uses, and discloses your personal information. Please carefully review this document to understand our practices. Using Cashwise resources signifies your acceptance and agreement to these practices.

We require permission to collect, use, and disclose your personal information, with exceptions determined by applicable law. These exceptions include legal, medical, or security reasons where seeking consent is impractical or impossible.

2. Introduction

This Privacy Policy (the “Policy”) represents the policy of Cashwise Inc., a Delaware corporation (together with all subsidiaries thereof, the “Company”) regarding the collection, use, and management of personal data belonging to:

  • Personal identification: Name, date of birth, email, address, phone number
  • Supplemental identification: Government-issued IDs, tax identification numbers, employment information
  • Financial information: Income/wealth verification documents, bank account statements
  • Device and browsing information: Browser type, IP address, location, device details
  • Website usage data: Pages viewed, links clicked, keystrokes, actions taken
  • Demographic information: Age, gender, interests
  • Transaction information: Service requests, dates, times, payment methods, sender/recipient names, etc.
  • Location data: User searches and location tracking (background and foreground)
  • Communication data: Messages, comments, file transmissions
  • Internet connection information: Details about your connection and equipment
  • Personal calendar information: With your explicit permission
  • Additional verification information: Utility bills or other documents (at our discretion)

3. Children's Personal Information:

Our Resources are not designed for users under 18. If you are under 18, refrain from providing any information on the Resources. We do not knowingly collect data from individuals under 18. If such information is discovered, we will reject applications, close accounts, and delete the data. Contact us at compliance@cashwise.finance if you suspect we possess information about a child under 18.Data Collection Methods:

  • User registration and order placement
  • Customer surveys and feedback
  • Cookies and website browsing
  • Content submission (reviews, messages, comments)
  • Location tracking (with user permission)

4. Data use:

  • Providing Cashwise services and resources
  • Enhancing user safety and security
  • Customer support and research & development
  • Enabling user communication
  • Sending marketing and non-marketing communications
  • Legal proceedings and contractual obligations
  • Billing and collection
  • Advertising effectiveness measurement and personalization
  • Providing requested information, products, or services
  • Fulfilling intended purposes and user consent
  • Any other purpose with user consent

5. Data Use

Cashwise does not sell or share user personal information with third parties for their direct marketing, except with explicit user consent.

Data for Service Provision:

Cashwise provides software services as defined in the User Agreement. To perform these services, we may collect data from our clients. You acknowledge that without such data collection, Cashwise may not be able to provide the full functionality of its services.This revised Privacy Policy clarifies Cashwise's data collection and use practices, ensuring transparency and user understanding.

Restrictions

6. Protecting Your Information:

The Company takes data security seriously and employs robust measures to safeguard your personal information. These measures include physical, electronic, and administrative controls designed to prevent accidental loss, unauthorized access, use, alteration, and disclosure of your data. We store all user data on secure servers protected by firewalls. Additionally, any payment transactions are encrypted using SSL technology.

However, data security also depends on individual user responsibility. If you have chosen a password for accessing certain resources, it's crucial to keep it confidential and avoid sharing it with anyone.

Transfer and Storage of Data:

User data is securely stored on servers leased from a reputable third-party hosting service located in the United States. While the Company strives to protect your information, no transmission method over the internet is completely secure. Therefore, we cannot guarantee the absolute security of your data transmitted to our resources. Any personal information transmission occurs at your own risk.

The Company may also process, store, and transfer your personal data to a foreign country with different privacy laws. These laws may or may not be as comprehensive as those in your own country. In such circumstances, foreign governments or law enforcement agencies may be able to access your data under the laws of that country.

7. Contact List Access and Use:

With your explicit permission, we may access your mobile device's contact list. This allows you to easily find and connect with friends and family on Cashwise, enabling you to send them money quickly through their phone number, email address, or username.

The information obtained from your contact list is solely used for the following purposes:

  • Filtering your friends on Cashwise
  • Enabling transactions with your connected friends and contacts

We will never access your contact list without your express consent. If you choose to provide this information, we may use it to identify other Cashwise users within your contacts, making it easier to send them money.

Furthermore, we will never send messages to your contacts or use their information for any other purpose besides facilitating your transactions within Cashwise.

8. Contact List Access and Use:

Cashwise retains your personal data for as long as necessary to fulfill the purposes for which it was collected. This includes:

  • Providing you with our services: We retain your user profile, transaction data, and other necessary information to facilitate your use of Cashwise.
  • Meeting legal and regulatory requirements: We may retain data for accounting, reporting, and legal compliance purposes.
  • Safety, security, and fraud prevention: We may retain certain information to prevent fraud, protect users, and maintain security. This includes deactivating accounts for unsafe behavior and retaining data to prevent future account creation by the same user.You can request deletion of your account at any time. We will delete your data within a reasonable timeframe, except for information we are legally required to retain. This includes:
  • Regulatory, tax, and insurance data: This data is retained for a minimum of 7 years.
  • Litigation and legal claims data: This data is retained until the claim or dispute is resolved.

In certain circumstances, we may be unable to delete your account immediately. This could be due to an outstanding credit on your account or an unresolved issue. We will delete your account as soon as the issue is resolved.

You can also request the revision or update of your personal information. We will process your request in accordance with our policies and applicable laws.

We may anonymize your personal information so that it can no longer be associated with you. We can then use this anonymized data for legitimate business purposes without further notice or consent.

For more information or to submit a request regarding your data, please contact us.

9. Data Usage and Processing

Cashwise collects and uses your personal data only when we have a lawful basis to do so under applicable privacy laws. These grounds vary depending on your location but generally fall into the following categories:

1. To provide requested services and features:

  • User profile data: We use this to create and manage your account, verify your identity, communicate with you about your account, and enable payments.
  • Usage data: This helps us maintain, optimize, and improve our services.
  • Transaction information: This allows us to process your transactions securely and efficiently.Customer support information: This enables us to provide you with the best possible support.
  • Regulatory, tax, and insurance data: This data is retained for a minimum of 7 years.
  • Litigation and legal claims data: This data is retained until the claim or dispute is resolved.

2. For legitimate interests of Cashwise or other parties:

  • Safety and security: We use your data to maintain a safe and secure environment for all users. This includes preventing fraudulent activity and keeping banned users from rejoining.
  • Combating fraud: We use your data to detect and prevent fraud.
  • Improving our services: We use your data to improve our services and develop new features.
  • Research and development: We use your data to better understand our users and their needs.
  • Enforcing the User Agreement: We use your data to enforce our legal agreements with users.
  • Protecting the rights and safety of others: We use your data when necessary to protect the rights and safety of others.

3. To fulfill legal obligations:

  • We comply with applicable laws and regulations. This may involve sharing your data with law enforcement or other authorities.

3. To fulfill legal obligations:

  • We may request your consent to collect and use your data for specific purposes, such as voluntary surveys. You can withdraw your consent at any time, but this may limit your ability to use certain services or features.We take data privacy seriously and are committed to protecting your information. We only collect and use the data necessary for the purposes described above, and we only share your data with third parties when it is necessary to provide our services or comply with legal requirements.

For more information about how we use your data, please contact us.

10 Data Sharing and Disclosure

Cashwise shares certain data with other users or third parties under specific circumstances. This data may include personal information. Here are the specific situations where sharing occurs:

To provide requested services and features:

  • We share your personally identifiable information that you share on the application, including your profile information

At your request:

  • We share data with other users at your express request.
  • We share data with company business partners if you use services or features offered through a partnership. This may include sharing data with other services, platforms, apps, or websites that integrate with Cashwise's APIs.

With the general public:

  • Questions or comments you submit through public forums, such as our blogs or social media pages, may be publicly viewable, including any personal information you provide.

With the user account owner:

  • If someone else operates your account, we will share information with the registered user account owner.

With Cashwise subsidiaries and affiliates:

  • We share data with our subsidiaries and affiliates to provide our services or conduct data processing on our behalf. For example, we may process data in the United States for our international subsidiaries.

With service providers and business partners

  • We share data with vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
  • Payment processors and facilitators
  • Background check and identity verification providers (when applicable)
  • Cloud storage providers
  • Marketing partners and marketing platform providers, including social media advertising services
  • Data analytics providers
  • Research partners
  • Vendors who assist us in enhancing the safety and security of our applications
  • Consultants, lawyers, accountants, and other professional service providers
  • Insurance and financing partners
  • Vehicle solution vendors or third-party vehicle suppliers

For legal reasons or in the event of a dispute:

  • We may share your personal data if required by law, regulation, court order, or government request. This includes sharing data with law enforcement officials, public health officials, or other government authorities.

We take data privacy seriously and are committed to protecting your information. We only share data when necessary and with authorized third parties. We also have safeguards in place to protect your data from unauthorized access, use, or disclosure.

11. Marketing

Cashwise may send you information about our products and services, but only with your consent. You may grant this consent when you sign up for our services, as outlined in the User Agreement.

Even if you've opted in to receive marketing materials, you can always change your mind later. You have the right to stop receiving marketing communications from Cashwise at any time.

12. Your Data Protection Rights

Cashwise takes the accuracy and currency of your personal data seriously. Please keep us updated if your information changes.

By law, you may have specific rights regarding your personal data, including:

  • Access: You may request copies of your personal data from Cashwise. A small fee may apply.
  • Rectification: You may request that Cashwise correct any inaccurate or incomplete information about you.
  • Erasure: Under certain circumstances, you may request that Cashwise erase your personal data.
  • Restriction of processing: You may request that Cashwise limit the processing of your personal data in certain situations.
  • Objection to processing: You may object to Cashwise processing your personal data in certain circumstances.
  • Data portability: You may request that Cashwise transfer your personal data to another organization or directly to you in certain circumstances.

When you provide your personal data to Cashwise, you do so under the terms of our User Agreement. This agreement governs the retention, return, transfer, and destruction of your data.

If you wish to exercise any of your data protection rights, please contact us using the information below. We will respond to your request within the timeframe prescribed by applicable privacy laws.

13. California Privacy Rights

California Civil Code Section 1798.83 grants residents of California the right to request a list of third parties to whom we have disclosed certain personally identifiable information for direct marketing purposes during the preceding calendar year. We are only required to respond to one such request per calendar year.

To submit a request, please contact us using the information provided below. In your request, please confirm that you are a California resident and provide your current California address for our response.

Please note that not all information sharing is covered by this law, and our response will only include information that falls under its provisions.

14.  Identity Verification and Data Access

California Civil Code Section 1798.83 grants residents of California the right to request a list of third parties to whom we have disclosed certain personally identifiable information for direct marketing purposes during the preceding calendar year. We are only required to respond to one such request per calendar year.

To verify your identity, we typically require a successful login to your account or sufficient matching of information you provide to our records. While we aim to minimize the data collected during such requests, certain cases may necessitate additional information. In some situations, we may decline your request to exercise your data rights, especially if we cannot verify your identity.

By submitting a request, you consent to an electronic database search for identity verification. We will retain records of these searches in accordance with our policies and applicable laws. Additionally, we reserve the right to share relevant information about you and your transactions with law enforcement agencies if deemed necessary.

California Residents:

California residents can designate an authorized agent to submit access or deletion requests on their behalf. This requires:

1. Written and signed permission: You must provide your authorized agent with written and signed permission to act on your behalf.

2. Direct identity verification: You must verify your own identity directly with us.

Please note, we may deny requests from unauthorized agents or those unable to verify their identity. We will respond to authorized agents who provide proof of their registration with the California Secretary of State or submit evidence of power of attorney under California Probate Code sections 4121 to 4130.

Cookies and Tracking Technologies

15. What are cookies and tracking technologies?

Cookies are small text files placed on your device by websites you visit. They collect standard internet log information and visitor behavior data. We use similar technologies, such as pixel tags and web beacons, which serve a similar purpose.

16. How do we use cookies and tracking technologies?

We use cookies and other tracking technologies for various purposes, including:

  • Authentication: Recognizing you when you log in to our website.
  • Preferences: Remembering your language and other preferences.
  • Content Popularity: Understanding which content is most popular.
  • Advertising: Delivering and measuring the effectiveness of advertising campaigns.
  • Analytics: Analyzing website traffic and trends to improve your experience.

We may also allow third parties to use cookies and tracking technologies for audience measurement, advertising delivery, and performance tracking.

17. How to manage cookies and tracking technologies:

Most web browsers allow you to manage cookies and tracking technologies. You can choose to block or delete them, but this may affect certain website functionalities.

18. Privacy of other websites:

Our website may contain links to other websites. This Privacy Policy applies only to our website. When visiting other websites, please review their respective privacy policies.

19. Changes to our Privacy Policy:

We may update our Privacy Policy from time to time. We will post any changes on this page and notify you through email or in-app notifications for significant updates. Please review our Policy periodically for any changes.

20. Data Security Breach Notifications:

Cashwise takes data security seriously and implements appropriate measures to protect your information. In the event of a data breach, we will notify affected users by email. Please ensure you keep your registered email address updated to receive these notifications.

By continuing to use Cashwise products and services, you consent to receiving electronic notifications regarding data breaches and other important updates.

21. Get in Touch with Us

For any inquiries regarding this Policy, the information we have about you, or if you want to exercise your data protection rights as per applicable privacy laws, feel free to reach out to our Data Privacy Officer at compliance@Cashwise.finance. The Company is committed to providing you access to your personal information within 30 calendar days, barring any unforeseen circumstances beyond our control. If you can demonstrate inaccuracies or incompleteness in the information held by the Company, you have the right to request corrections.

Contacting Relevant Authorities 

If you need to file a complaint or believe that the Company hasn't addressed your concerns adequately, please contact your local Data Protection Authority.

For Canada: Office of the Privacy Commissioner of Canada 30, Victoria Street Gatineau, QC K1A 1H3, Canada www.priv.gc.ca/en/For the United Kingdom: The Information Commissioner’s Office Wycliffe House, Water Ln Wilmslow SK9 5AF, UK www.ico.org.uk