Privacy Policy

GENERAL

This Privacy Policy explains how Cashero SA, Company registered under Swiss Law with company No.: CHE-386.804.353 and having its registered address at Vernier, Canton Geneva (“Cashero” or “we,” “us,” or “our”) collects, uses, and discloses information about you when you visit, access, or use Cashero App (hereinafter the “App”), Cashero website (hereinafter the “Site”), software, and other online products and services (collectively, the “Services”) or when you otherwise interact with us. By visiting the Site or the App or otherwise using our Services, you acknowledge the practices described in this Privacy Policy. We will occasionally change this Privacy Policy. We encourage you to review the Privacy Policy whenever you access the Services or the Site, use the App or otherwise interact with us to stay informed about our information practices and the choices available to you.

This Privacy Policy complies with data protection law applicable to Cashero, including the Swiss Federal Act on Data Protection (CC 235.1 Federal Act of 19 June 1992 on Data Protection (FADP)) and the EU General Data Protection Regulation 2016/679, their successors or implementing texts.

“Personal Information” refers to information that identifies an individual, such as name, address, e-mail address, financial information, and banking details. “Personal Information” does not include anonymized and/or aggregated data that does not identify a specific user. Cashero is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

• The types of Personal Information we collect and how it may be used;
• How and why we may disclose your Personal Information to third parties;
• The transfer of your Personal Information;
• Your right to access, correct, update, and delete your Personal Information;
• The security measures we use to protect and prevent the loss, misuse or alteration of Personal Information; and
• The Company’s retention of your Personal Information;
• This Privacy Policy also covers some basics of our use of cookies; however, for more details please see also our Cookie Policy;

We control the ways of collecting your Personal Information and determine the goals for which We use Personal Information. We are the data controller under this Privacy Policy, which sets out the manner in which Cashero, as data controller, may use your Personal Data.

COLLECTION AND USE OF PERSONAL INFORMATION

PERSONAL INFORMATION WE COLLECT

We collect the following Personal Information:

• Contact information, such as name, home address, e-mail address, telephone number, IP address, etc.;
• A contact list on your device;
• Account information, such as username and password;
• Financial information, such as transaction activity, history, commissions charged, etc.;
• Identity verification information, such as images of your government-issued ID, passport, national ID card, driving license, or other documents requested by our compliance department;
• Residence verification information, such as utility bill details or similar information;
• Other information, obtained during our KYC procedures, such as information about your financial state and source of funds;
• We also automatically collect certain computer, device, and browsing information when you access the Site, the App, or use the Services. This information is aggregated to provide statistical data about our users' browsing actions and patterns and does not personally identify individuals.

This information may include:

• The information about the computer or mobile device you use to access our App, including the hardware model, operating system and version, the web browser you use, IP addresses, and other device identifiers;
• The Site and App usage information, the server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at our App, and the websites you visit just before and just after our App;
• The bandwidth upload and download speeds, the amount of free and used storage space on your device, and other statistics about your device;
• We may automatically capture, store and otherwise process information about you even if you abandon the completion of an online application or registration form.

USE OF COOKIES AND SIMILAR TECHNOLOGY

The website uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies are typically stored on your computer's hard drive.

Our website uses cookies to enable you to use the website, the Services we offer, and some materials on the App. Cookies are also used to distinguish you from other users. This helps us to provide you with a good experience when you use our website and also allows us to improve our services.

You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences. You can select which categories of cookies you accept or reject. Essential cookies cannot be rejected, as they are strictly necessary to provide you with services.

We may update this Cookie Policy section from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please, therefore, re-visit the Privacy Policy and Cookie Policy regularly to stay informed about our use of cookies and related technologies.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your Personal Information to:

• Process your transactions and deposits. We will process your Personal Information only for the purpose(s) for which it has been provided to us;
• Fulfill our legal or regulatory requirements;
• Verify your identity following the applicable legislation and the Company’s Anti-Money Laundering policy, as well as address other law enforcement needs. We also may share your information with other financial institutions and with tax authorities if such actions are required from us due to any applicable legislation;
• Detect, investigate and prevent fraudulent transactions or unauthorized or illegal activities;
• Protect our rights and property;
• Personalize your Services experience;
• Analyze the App usage and improve our Site, App, and offerings. Analyzing and tracking data to determine the usefulness or popularity of certain content and to better understand the online activity of our App users;
• Help us respond to your customer service requests and support needs, answer your inquiry or respond to a communication from you;
• Contact you about the Services. The email address you provide may be used to communicate information and updates related to your use of the Services. We may also occasionally communicate technical notices, support or administrative notifications, company news, updates, promotions, and related information relating to similar products and the Services provided by Cashero;
• Using your contact list to generate a list of your contacts who also use the app. We do not use your contact list for any analytical processing;
• Administer a contest, promotion, survey, or other features as will be more explained on the Site or the App;
• Link, connect, or combine Personal Information we collect from or about you with other Personal Information;
• Carry out any other purpose or reason for which the Information was collected;
• We do not perform behavioral tracking of a customer's activities on our App or across different websites, nor do we allow third-party data collection through our services. If you wish to stop receiving marketing communications from us, please contact us to opt-out.

DISCLOSING AND TRANSFERRING PERSONAL INFORMATION

We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your Personal Information as described below:

DISCLOSURES TO THIRD PARTIES

• In processing your transactions and deposits we may share some of your Personal Information with our third-party service providers who help with our business operations. In order to improve and develop our app we are using third-party analytics (SDK). Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide Services or as required by law. By using the App or Services you consent to the disclosure of your Personal Information as described in this Privacy Policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses.
• The Company’s third-party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective than those described in this Privacy Policy, or those we are subject to under applicable data protection laws.
• Cashero SA uses Sum And Substance Ltd a KYC, KYB, and AML service provider (Data protection No. ZA222205);

DISCLOSURES TO LEGAL AUTHORITIES

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

• Compelled by subpoena, court order, or other legal procedure;
• We believe that the disclosure is necessary to prevent physical harm or financial loss;
• Disclosure is necessary to report suspected illegal activity;
• Disclosure is necessary to investigate violations of this Privacy Policy or any of our agreements with you.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We store and process your Personal Information in data centres around the world, wherever Company facilities or service providers are located. As such, we may transfer your Personal Information between such data centres. Such transfers are undertaken following our legal and regulatory obligations and are performed only via protected channels.

OTHER CIRCUMSTANCES FOR DISCLOSURE OF PERSONAL INFORMATION

We also can disclose your Personal Information in the following circumstances:

• With your consent or at your instruction. Certain information you may choose to share may be displayed publicly, such as your username and any content you post when you use interactive areas of our App, like our online forums;
• With our current or future parent companies, affiliates, subsidiaries, and other companies under common control or ownership with us or our offices internationally. We ensure that listed parties will be bound by terms no less protective than those described in this Privacy Policy or those we are subject to under applicable data protection laws;
• If the sharing of Personal Information is necessary for the protection of our rights and property, or rights and property of the current or future parent companies, affiliates, subsidiaries, and with other companies under common control or ownership with us.

EXTERNAL WEBSITES

Occasionally, the App may provide references or links to other websites (“External Websites”). We do not control these External Websites’ third-party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External websites referenced or linked from the App, including, but not limited to, site content, policies, failures, promotions, products, services, or actions and/or any damages, losses, failures or problems caused by, related to, or arising from those sites. External Websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our App and welcome any feedback about External Website information provided on the App.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

You can exercise all rights foreseen by legislation if this does not contradict the legal requirements concerning the prevention of money laundering and terrorist financing laws, our record-keeping obligations, etc.

You have the following rights:

• The right to be informed about the fact that we're processing your Personal Information and which data exactly we are processing and the right to data portability. In certain circumstances, you have the right to obtain all your Personal Information we store in a machine-readable format;
• The right to object to the processing of your Personal Information;
• The right not to be subject to automated decision-making, including profiling, if it doesn't intervene in performing the contract between you and us;
• The right to access your Personal Information, to correct, update, and block inaccurate and/or incorrect data;
• The right to withdraw your consent to Personal Information processing;
• The right to erase your Personal Information from our servers upon your justified request (the right to be forgotten).

To exercise these rights, contact us.

Within 40 days of receipt of your written request, we will provide you with your Personal Information, including the purposes for which it was used and to whom it was disclosed, following applicable legislation. We reserve the right to request additional information from you that may be necessary to provide the duly response to your request, following applicable legislation and you agree with such right. Also, if you wish to correct, update, and block inaccurate and/or incorrect data, we have a right to request a confirmation of correct data from you, for example, official documents containing such data.

Please note that if we are unable to verify your identity, or in the case of reasonable doubts concerning your identity, we may ask you to provide proof of identity, including by personal appearance in our office. This is the only way we can avoid disclosing Personal Information to a person who can perpetrate identity.

In some cases, we will not be able to change your Personal Information. In particular, such a case can include the event when your personal information has already been used during the execution of any agreement or transaction specified in any official document, etc. You have the right to withdraw consent to personal data processing. You may also exercise your right to be forgotten and erase your Personal information from our servers. In cases stipulated in Article 17 of GDPR, we will delete the Personal Information we process, except for that Personal Information which we are obliged to store by the requirements set forth by the applicable legislation.

Please be advised that in case of realization of your right of withdrawal of consent to personal data processing or the right to be forgotten, we will not be able to provide you with our products or services, and we have a special right to terminate all our current agreements with you with the application of legal consequences of such termination, and you irrevocably acknowledge such our right.

To withdraw the consent to personal data processing and/or exercise your rights to be forgotten, please contact us. Furthermore, in this case, for safety reasons, we may request you provide your ID document.

SECURITY OF PERSONAL INFORMATION

We use a variety of security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration, or destruction. These security measures include, but are not limited to: Password protected directories and databases.

Secure Sockets Layered (SSL) technology ensures that your information is fully encrypted and sent across the Internet securely. 2FA and traffic encryption are used to limit access to hosting. All financially sensitive information is transmitted via SSL technology and encrypted in our database. Only authorized Company personnel is permitted access to your Personal Information, and personnel is required to treat the information as highly confidential. The security measures are reviewed regularly to comply with new and relevant legal and technical developments.

RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our legal and regulatory obligations. By our record-keeping obligations, we will retain your account and other Personal Information for at least five years after the termination of the respective agreement.

UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be revised, modified, updated, and/or supplemented at any time, without prior notice, at the sole discretion of Cashero. When we make changes to this Privacy Policy, we make the amended Privacy Policy available on our App.