Privacy Policy of Cashcloud S.A.

The definitions provided to You in Our General Terms of Use apply also to this Privacy Policy.

This Privacy Policy describes how Cashcloud handles Your personal information. It applies to the Cashcloud Mobile Wallet, Website and all related services and tools regardless of how You use or access them. We encourage You to review the policy whenever You use Our Services.

Cashcloud collects certain information in order to operate effectively and to provide You the best service and experience. Some information You provide directly to Us when registering, and some We collect when You interact with the Cashcloud Mobile Wallet, Our Website, products and marketing communications.

Subject to the provisions of Article 14 of Our Terms You are always entitled to receive information about Your stored personal data, as well as to having them corrected, blocked or deleted free of charge, unless such data may not be immediately deleted for administrative or regulatory reasons, in which case We may be required to store it for a certain period of time.

Information We may collect

Information You provide to Us directly when registering or modifying Your profile. If certain information is not provided, You may not be able to use some of Our Services. This necessary information includes:

  • Contact information: name, email address, address and mobile phone number.
  • Detailed personal information: date of birth, gender, country and city of residence, language preference, avatar (photo), other information provided as part of creating a Cashcloud account and any information You choose to make available to others as part of Your Cashcloud account;
  • Banking and payment information: Your bank account’s IBAN and BIC, credit card number and/or related information;
  • Correspondence between You and Us.

Information is automatically collected when You are using the Cashcloud Mobile Wallet, Website and Services: This information helps Us determine how You interact with the Cashcloud Mobile Wallet, Our Website, Services and marketing communications. This information is necessary to identify You as an authorized User, to detect fraud against You and Us, to enable Us to offer personalized ads to You and to offer You rewards for certain campaigns. This information may include:

  • Device information: Device type, device model, IP address, user agent (if one exists), device ID, OS version, Android ID (Android device), in-app events, location, time zone, and network status (WiFi/3G), iOS IFA (Apple Identifier for Advertisers), Google AID (Google Advertising Identifier), user ID (if authorization token is available). If necessary, We may associate Your device identifiers together with Your mobile phone number with Your Cashcloud account;
  • Usage information: The products and services You have ordered, information about how You use Our services, web pages You have viewed and links You click;
  • Location information: We may receive this information from Your mobile network carrier or from Your mobile device. We may use it to provide You with location-based services, such as coupons, campaigns and other personalized content. You should be able to change or disable location services using Your device's settings menu.
  • Access tokens: When You connect Your Cashcloud account with another account (such as Facebook or Twitter), We use the access tokens to make it easier for You perform certain actions such as log in or share). The access token acts in place of a password for authentication.

How We use Your Information

We use the collected information in order to provide, maintain, improve, protect and personalize Our software, products and features. We may use Your personal information to:

  • provide Our services to You
  • enable other users to search for You and to interact with You, using the Cashcloud Mobile Wallet by sending You money, requesting money from You or chatting with You
  • process transactions and send notifications about Your transactions
  • communicate with You - for example, informing You whether a subscription is active, letting You know when You have new transactions, letting You know when We updated Our Terms, or to organize and carry out marketing or promotional campaigns, offers, contests and similar events
  • provide customer support
  • resolve disputes and protect Your interests, as well as Our interests, including, in particular, enforcing Our Terms and preventing and fighting against fraud and money laundering.
  • improve Our services by customizing Your user experience
  • measure performance and improve content and layout
  • provide targeted marketing and advertising, provide service update notices, and deliver promotional offers based on Your preferences

How We protect, process and store Your personal data

We use Your personal data solely for order processing purposes. Your personal data is processed and stored in compliance with the provisions of the Law of Luxembourg of 2 August 2002 on personal data protection, as amended. We store and process Your personal information on Our servers. We may collect and store information locally on Your device, using mechanisms such as browser web storage (including HTML 5) and application data caches.

Our Website, as well as the Cashcloud Mobile Wallet and other applications and systems, are protected by technical and organisational security measures to prevent loss, destruction, unauthorised access, modification or dissemination of Your personal data by unauthorised persons.

Sharing Your Information

Some of Our Services allow You to share information, news and usage patterns with others. Remember that when You share information publicly, it may be indexed by search engines and by social network operators. We may also use this information in order to communicate with You via subscription channels or interesting and advantageous offers provided by Us or third parties. Our Services may provide You with different options on sharing content.

When You perform transactions with other Cashcloud users, We may provide information about You to those parties which is necessary to complete the transaction, such as Your name, email address, mobile phone number or other information needed to promote the reliability and security of the transaction. The receiving party is not allowed to use this information for unrelated purposes, such as to directly marketing to You, unless You agreed to this.

If someone sends You money and enters Your email address or Your mobile phone number, We will provide them with Your registered name and/or email address and/or mobile phone number, in order for them to verify they are sending the money to the correct account.

Mobile phone push notifications

We may use notification services available for Your device to inform You about incoming transactions, accepted transactions and messages from other Users when You are not actively running or using the Cashcloud Mobile Wallet. These services may be provided by a third party (e.g. messages sent to an Apple device may use Apple’s Push Notification Services). Notification services may receive information about the caller, sender of the message and the content of the message as part of providing the service and may use the information in accordance with their terms and conditions and privacy policy. We are not responsible for data collected by third party notification services.

If You do not want to use third party notification services to receive notification of incoming transactions and messages, You can disable this in Your notification settings either in the settings of the Cashcloud Mobile Wallet or in the notification settings found in Your device settings.

Cookies and similar technologies

Our Website and Cashcloud Mobile Wallet use "cookies", which are small text files stored on Your device, to help operate the Website and the Cashcloud Mobile Wallet and help collect information about Your activity. The text in a cookie often consists of a string of numbers and letters that uniquely identifies Your device, but it may contain other information as well. Most Web browsers are initially configured to accept cookies, but You can change this setting so Your browser either refuses all cookies or informs You when a cookie is being sent. Furthermore, You are free to delete any existing cookies at any time.

Other Information

From time to time We may ask You to give Us and/or Our Partners permission to use third party software tools, links or plug-ins within the Cashcloud Mobile Wallet and Our Website. In such cases You will be notified to accept or decline the use of these services.

In these cases, however, the volume of data and information disclosed is limited to the minimum necessary and such third party providers may use Your personal data only for transaction processing purposes or for delivering content necessary for Your account.

To give You a better overview, please find below important notices from these third party providers:

Privacy Statement for the Use of Google Analytics:

For Our Website and application We use Google Analytics, a web analytic service provided by Alphabet Inc. Google Analytics uses cookies. The information generated by the cookie about Your use of the Website is generally transmitted to a Google server and stored there. In case of enabling the IP anonymizer function on a website, Google will first truncate Your IP address within EU member-states or other countries which are signatories to the European Economic Area Agreement.

Only in particular cases full IP addresses are transmitted to a Google server and stored there. On the instruction of a website operator, Google will use this information for the purpose of evaluating Your use of the website, compiling reports on website activity and providing other services to the website’s operator in connection with website and internet usage. The IP address sent by Your browser within Google Analytics is not combined with other Google data.

You may modify Your browser so that the storage of cookies is prevented. In this case, it might not be possible to use all the functions on this website to their full scope. Furthermore, You may prevent Google from compiling data generated by a cookie and related to the website usage (incl. Your IP addresses), as well as the processing of such data by Google, by downloading and installing a browser plug-in available from Google.

Privacy Statement for the Use of Facebook Plug-ins:

We may use plug-ins run by the social network Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA on Our Website and in the Cashcloud Mobile Wallet. You will be able to recognize the Facebook plug-in on Our sites based on the Facebook logo, and/ or the "Connect or Like” Button. An overview of the Facebook plug-ins can be found on Facebook web page.

When using Our Website and the Cashcloud Mobile Wallet, a direct connection between Your browser, Your Cashcloud Mobile Wallet and the Facebook servers might be established using such plug-in. Thus, Facebook receives information that You have visited Our sites or application via Your IP address. Thereby, Facebook can associate the use of Your Cashcloud Mobile Wallet to Your Facebook user account. We would like to draw Your attention to the fact that, We, as providers of the Cashcloud Mobile Wallet and Website, have no knowledge of the contents of the transmitted data or of their use by Facebook. You can find more information by visiting the Facebook privacy protection section.

If You do not want Facebook to link Your visit to Our sites to Your Cashcloud account on the social network, You have to log-out of Your Facebook account prior to accessing Our Services.

Privacy Statement for the Use of Twitter:

The provider of these functions is Twitter Inc., Twitter, Inc. 1. 355 Market St, Suite 900, San Francisco, CA 94103, USA. When using Twitter and the re-tweet-functions, the web pages You visit are linked to Your Twitter account and disclosed to other users. Data will also be transferred to Twitter.

We would like to draw Your attention to the fact that We, as providers of Our Website and the Cashcloud Mobile Wallet, have no knowledge of the contents of the transmitted data or of their use by Twitter. For more information, please refer to the Twitter privacy policy.

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