Privacy Statement
Updated May 2021

1. Overview

Cassbana has developed this Privacy Statement to explain how we may collect, retain, process, share and transfer your Personal Data when you use our Services. This Privacy Statement applies to your Personal Data when you use Services, and does not apply to online websites or services that we do not own or control, including websites or services of Cassbana Partners.

This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Services. Please note that our Service offerings may vary by region.

We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalized term in the Definitions section.

By opening a Cassbana account and using our Services, you agree to comply with all of the terms and conditions in the User Agreement. You also agree to comply with the additional policies and each of the other agreements on the Legal Agreements page that apply to you, including this Privacy Statement.

2. What Personal Data Do We Collect?

We may collect information about you when you use our Application or use our Services, including the following:

A. Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services. we may also ask you to grant us access to data stored on your mobile to allow us to determine your eligibility to receive our services.

B. Transaction and experience information – When you use our Services, for example, to make purchases from merchants, to receive money, to process payments, to send money, or to purchase on installment from any of Cassbana Partners, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.

C. Participant information – When you use our Services, we collect Personal Data you provide us about the other participants associated with the transaction. When you send or request money through the Services or make any purchases, we collect Personal Data such as name, postal address, telephone number, Device Information , and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.

D) Information about your devices, profile and your friends and contacts – to enable us to provide the Services to you, we need to access and link your contact list information with your Account and your profile and information available on your device. If you establish an account connection between your device or a social media platform, we will use your contact list information (such as name, address, email address) to improve your experience when you use the Services and to allow us to determine your eligibility to our Services.

E) Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, and to the extent permitted by law.

F) Other information we collect related to your use of our Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

3. Why Do We Retain Personal Data?

We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws or to comply with our obligations toward the merchants you made purchase from them. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.

4. How Do We Process Personal Data?

We may Process your information for the following reasons:

• To provide the Services, including to:
o initiate a payment, send or request money, add value to an account, or pay a bill;
o authenticate your access to an Account;
o communicate with you about your Account, or the Services;
o create an account connection between your Account and a third-party account or platform; and
o perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes.
o keep your Account and financial information up to date.

• To manage our business needs, such as monitoring, analyzing, and improving the Services and the Application performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services and transact with the merchants and partners.

• To manage risk and protect the Application, the Services and you from fraud by verifying your identity. Risk and fraud tools use Personal Data, Device Information, Technical Usage Data and Geolocation Information from your device, our Application that offer the Services to help detect and prevent fraud and abuse of the Services.

• To market to you about Cassbana products and Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to uniquely tailor the marketing content and certain Services or Site experiences to better match your interests on Cassbana and other third-party websites and applications.

• To provide personalized Services offered by Cassbana on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Statement to provide a targeted display, feature, Services or offer to you on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as merchant’s, advertising or analytics companies to provide these online services.

• To provide you with location-specific options, functionality or offers. we also use your Geolocation Information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.

• To comply with our obligations and to enforce the terms of our Services, including to comply with all applicable laws and regulations or taking any legal action.

• To make it easier for you to find and connect with others. For instance, we can suggest connections with people you may know and help others connect with you to send you money by letting them find your profile when they search for you by name, username, email, or mobile number. We may also associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide, to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.

• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

5. Do We Share Personal Data?
We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement.

We may share your Personal Data or other information for the following reasons:
With other members of the Cassbana corporate family: We may share your Personal Data with members of the Cassbana family of entities to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of Cassbana products, Services, and communications.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.

With financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer Cassbana-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.

With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds from merchants, and their service providers when you use the Services to pay for goods or services. The information includes:

• Personal Data and Account information necessary to facilitate the transaction;
• information to help other participant(s) resolve disputes and detect and prevent fraud; and
• aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for Cassbana’s business purposes or as permitted or required by law, including:
• if we need to do so to comply with a law, legal process or regulations;
• law enforcement, regulators, government officials, or other third parties to comply with any applicable law or rule; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;
• to protect the vital interests of a person;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of Cassbana’s business;
• in connection with shipping and related services for purchases made using a Service;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants.
• to banking partners as required by card association rules for inclusion on their list of terminated merchants;
• to credit reporting and collection agencies;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.
With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.

In addition, Cassbana may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. How Do We Work with Other Services and Platforms?

The Services may require authorizing us to connect with your third-party accounts, when you authorize such a connection, Cassbana and the third-party will exchange your Personal Data and other information directly. Examples of account connections include:

• linking your Account to a social media account or social messaging service;
• connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
• using your Account to make payments to a merchant or allowing a merchant to charge your Account.

When you create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection. For example, Personal Data that Cassbana shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.

7. How Do We Use Cookies and Tracking Technologies?

When you use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

8. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, and data encryption. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized. we are not responsible for any misuse or unauthorized access due to your failure to secure your passwords, accounts or devices.

9. Can Children Use Our Services?

Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

10. What Else Should You Know?

Changes to This Privacy Statement.
We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.

If the revised version includes a substantial change, we will provide you with 7 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.

Your continues use of our service shall be considered as an acceptance to any changes on our Privacy Statement.

Transfers of Your Personal Data to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Statement if your Personal Data is transferred to other countries. By using our Sites and Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Sites and Services are appropriate or available in any particular jurisdiction.

11. Contact Us

You may contact us if you have general questions about our Privacy Statement and practices or questions about your Account information or Personal Data.

12. Definitions

Account means a Cassbana account.

Application means Cassbana application.

Device Information means data that can be collected from any device used to access the Services or the Application. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Application or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity) and your contacts information and exchanged messages and other information stored in the device that Cassbana decided that its access to it is required to provide the service.

Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

Cassbana means Cassbana BV and subsidiaries or affiliates. In this Privacy Statement, Cassbana is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID). Personal Data does not include information that does not identify a specific User.

Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Cassbana. including the websites, mobile apps, official social media platforms, or other online properties through which Cassbana offers the Services and which has posted or linked to this Privacy Statement.

Technical Usage Data means information we collect from your device, or other device that you use to access the Application or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited and other usage and browsing information collected through Cookies.
User means an individual who uses the Services or installed the Application.