Privacy Policy
Effective Date: November 10, 2023
Table of Contents
POLICY - OVERVIEW
POLICY - DETAILED
Our Data Processing Activities
How to Submit a Privacy Request
POLICY - OVERVIEW
About Us
Cashuu, Inc. (collectively (“Cashuu” or “us” or “we” or “our”) is a financial technology company that provides innovative digital payment solutions to our customers. To promote and provide our payment solutions to you and other customers online, we own and manage the website cashuu.com (“Site”) and related mobile and/or web applications (“Apps”). Collectively, the payment solutions we provide to you on our “Site” and “App” and/or any other interactions we have with you to provide Cashuu’s products or services are defined as the “Services”.
Our contact details are here.
Purpose
The purpose of this Cashuu, Inc. privacy policy (“Policy”) is to provide you with information on:
(1) who and what this Policy applies to;
(2) how, where, and for what purposes we collect, use, disclose, store, and protect (“process”) any information that, alone or in combination with other data, is reasonably capable of identifying or being associated with you (“personal information”) when you use or interact with our Services;
(3) your rights under applicable privacy, data protection, and related laws; and
(4) how you can exercise your privacy rights or otherwise contact us.
Policy Scope
Who Does this Policy Apply To?
Our Site is directed at and intended for individuals who reside in the United States and are 18 years of age or older (“Covered Person”). This Policy only applies to the processing of personal information of Covered Persons while visiting our Site. If you are not a Covered Person, you are NOT permitted to access or use the Services. If you learn that anyone who is not a Covered Person provided us with personal information, please contact us, and we will take steps to delete such information.
To the extent that we process your “Nonpublic Personal Information” pursuant to providing financial services to you that is subject to the Gramm-Leach-Bliley Act (“GLBA”), please review our GLBA Notice below.
What Does this Policy Apply To?
This Policy only applies to personal information we or our service providers collect from you through the Services.
Please note that we may link to third-party services (including social media services), external websites and/or external mobile applications (“Third Parties”) on our Site or App. However, we do not own nor control these Third Parties, and we are not responsible for the content or privacy practices of such Third Parties on their sites or applications, including their level of data sharing with other third parties. Additionally, we are not responsible for the data processing practices of the internet browser servicer you choose to use when accessing our Site. Such Third Parties and internet browser servicers may have their own privacy policies, and you should consult those policies accordingly before using or going to their websites or apps.
PRIVACY POLICY - DETAILED
Our Data Processing Activities
Our data processing activities may vary based on the Services you use. To learn more about how your personal information is handled, please see the tables below.
Personal information We Collect About You
|
Personal information Type |
Source |
Purpose |
|
Name & contact information (address, phone, email, etc.) |
From you directly |
|
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ID & log in details |
From you directly |
|
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Your device information (including IP address) and activity while on our Site and/or App or associated communications |
From your interaction with the Site and/or App |
|
|
The ratings and/or comments and other content you post on our Site or App |
From you directly when you post to the Cashuu Community Ratings and Reviews page |
|
|
Information regarding your income, financial transactions, and/or spending/shopping patterns and/or behavior |
From your interaction with our Cashuu products and services |
|
Sensitive Personal Information We Collect About You
To provide the Services, we may need to collect sensitive personal information about you.
|
Personal information Type |
Source |
Purpose |
|
Financial and/or payment information, including related information to verify ownership of your other financial accounts |
From you directly |
|
|
Social Security Number and a copy of your W-9 form |
From you directly |
|
|
Your credit history and credit reports |
From credit reporting agencies (subject to your consent) |
|
|
Precise Geolocation information |
From your device when you use our Geolocation Search tool |
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We will not ask for any sensitive personal information other than the information described in the above table. However, if you choose to voluntarily provide sensitive personal information to us, you hereby consent to us processing this sensitive personal information in accordance with our Policy.
General Purposes
Any personal information and/or sensitive personal information described in the tables above may also be processed for the following “General Purposes”:
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To provide customer / IT support;
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To maintain our Site;
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To comply with legal, law enforcement, and/or regulatory requirements or requests;
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To ensure the safety of our customers;
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To monitor for fraud or illegal activity and/or our obligations under anti-money laundering and counter-terrorism financing laws;
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To exercise our legal rights;
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To run our day-to-day business and facilitate corporate or other business transactions; and
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For our document retention/data storage purposes.
Personal information Recipients
|
Recipient Type |
Personal information Type |
Purpose |
|
Data storage providers |
All personal information and sensitive personal information described above |
Document retention / data storage |
|
Credit card / payment processors |
Financial / payment Information |
Facilitate payment for Cashuu products and/or services |
|
Third party banks, credit card companies, and/or other financial providers |
Financial / payment Information |
To connect your other financial account with our Cashuu account |
|
Third party merchants and/or shopping platforms |
Financial / payment Information |
To facilitate integrated payments with such merchants and shopping platforms |
|
Other Cashuu customers (e.g., individuals providing microloans and businesses providing “Buy It Now, Pay Later” services) |
Financial / payment Information, including your Cashuu Credit Score |
To facilitate payments, micro loans, and Buy It Now, Pay Later services with other Cashuu customers |
General Recipients
The following third parties may receive any personal information or sensitive personal information described above in certain instances:
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Our affiliates - to assist us with any purpose described in the tables above;
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Law enforcement, regulatory authorities, and judicial bodies – in the event of a legal requirement, inquiry, or investigation; and
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Potential purchasers of Cashuu, Inc. – in the event there could be a change in our ownership status.
How Long Do We Keep Your Personal Information?
We retain your personal information for 12 months after termination of your relationship with us or for longer periods if required to comply with applicable laws.
Online Tracking Technologies
We employ several tracking technologies to help maintain our Site and/or App, to personalize your experience on our Site and/or App and to give us a better understanding of how our users interact with our Site and/or App which are further described below.
Cookies are small text files containing data that can be used to identity your device. When you visit a particular website, the cookie is filed to a folder within your browser so that when you visit the website in the future, the website will recognize your device and, depending on the type of cookie being used, will perform different activities when you interact with the website. There are four different types of online cookies: essential, analytical, personalization, or marketing.
Essential Cookies. An essential cookie is a cookie that is needed to operate a website. Without these cookies, a website would not be able to function.
Personalization Cookies. Personalization cookies are cookies that help a website remember certain choices you have made on the website (such as language preferences or log in information) to personalize your experience with the site.
Analytical Cookies. Analytical cookies are used to track web traffic and how users interact with a website to allow us to better understand the website’s performance and how to improve user site experience.
Marketing Cookies. Marketing cookies are used so that a website, and in some cases other third parties, may market to you based on your website activity.
On our Site, we use essential cookies and personalization cookies. If you wish to opt out of certain cookies on our Site, please go to our cookie banner located on our home page and make your preferred selections.
General Browser Privacy Settings
With respect to opting out of the use of cookies on our Site, most browsers allow you to block and delete cookies. You can change browser cookie settings to block/delete the cookies by going to the browser settings page (see Chrome, Safari, and Firefox). If you are using any other web browser, please visit your browser’s official support documents. For instructions on how to opt out of Google pixel tracking please see the ‘Google Analytics Tracking’ section below.
Plugins
A plugin is a small piece of software that adds a specific functionality or content to a website or mobile application. Common types of plugins are used to help the website function such as run animation, videos, open adobe pdfs., print documents, and customize website fonts and images.
Websites may also have ‘social media plugin’, which allows a website user to connect to an organization’s social media page directly from the organization’s website. If the user has a social media account, the user may be able to interact with their social media account on websites he or she visits. For example, the social media account user may be able to ‘like’ or ‘share’ content on a website which then may be shared on the social media page. When using social media plugins, certain information about website users may be collected and shared with the third-party social media provider.
On our Site and/or App, we use the following social media plugins in the table below. You can opt out of having information shared with social media companies by following the directions noted in the table below.
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Third Party Plugin Source
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How to Manage Privacy Settings |
More Information |
|
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Go to interest based ads settings or Meta privacy control center |
Facebook Data Policy and Meta Cookie Policy |
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Instagram Data Policy and Meta Cookie Policy |
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X |
Go to privacy settings |
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Amazon |
Amazon Privacy Policy and Amazon interest based ads. |
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Plaid |
Go to your Plaid Portal to adjust privacy settings |
Plaid Privacy Policy |
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Dwolla |
Go to the “Privacy Options” link on the main page of the Dwolla website |
Dwolla Privacy Policy |
Tracking Pixels
A tracking pixel is a tiny invisible image embedded within a website that can be used gather your device and browser including your IP address or meta data derived from your IP address, along with information about your activity while on a website such as:
(i) which webpages you viewed,
(ii) what ads, videos, or third-party links you clicked on while using our site,
(iii) websites you have visited prior to visiting our Site,
(iv) your approximate age, gender, interests, and preferred language,
(v) location (city, state, and country) (based on IP address), and
(vi) what items you may purchase on the Site (“Pixel Information”).
This Pixel Information is then used by us for (i) website data analytics purposes to maximize a user’s experience on our Site and (ii) for our own advertising and marketing purposes. We may further share your Pixel Information with other third parties for targeted advertising purposes.
A tracking pixel can also be used on emails to help track the success of our email communications to you by seeing when you opened our email and/or clicked on any email embedded links.
On our Site and/or App, we use the following tracking pixels in the table below. You can opt out of being tracked through these tracking pixels by following the directions noted in the table below.
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Third Party Pixel Source
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How to Manage Privacy Settings |
More Information |
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|
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Go to interest based ads settings or Meta privacy control center |
Facebook’s Data Policy and Meta Cookie Policy |
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Instagram Data Policy and Meta Cookie Policy |
||
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Go to Google Analytics Opt-out Browser Add-on to opt out of being tracked via Google Analytics |
Google Privacy Policy |
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X (formally Twitter) |
Go to privacy settings |
Twitter (X) Privacy Policy |
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YouTube |
Go to YouTube privacy controls |
YouTube Privacy Policy and Google Privacy Policy |
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Amazon |
Amazon Privacy Policy and Amazon interest based ads. |
||
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Go to LinkedIn privacy controls |
LinkedIn Privacy Policy |
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TikTok |
Go to TikTok privacy controls |
TikTok Privacy Policy |
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Google Analytics
Our Site use Google Analytics, a web analytics service provided by Google Inc. (“Google”), that uses tracking technologies to analyze your use of and interaction with our Site. Information that Google may collect for this purpose may include page views, scrolls, videos, or links that were clicked, a unique client ID attributable to your device and browser information, your approximate age, gender, interests, language settings on your device or browser, and approximate location metadata derived from your IP address (city, state, and country) (collectively, “Google Analytics Data”). Google Analytics Data is transmitted to and stored on a Google server in the United States where it analyzed for purposes of generating reports on web traffic patterns on webpages and/or posted web content on our Site (“Google Analytics Report”). Google provides us with the Google Analytics Reports so that we may tailor our Site to accommodate the needs of our web users. Google may also transfer Google Analytics Data and Google Analytics Reports to third parties, if required by law or if third parties process such information on behalf of Google.
A general overview of Google’s data privacy practices for Google Analytics may be available at https://support.google.com/analytics/answer/6004245. For more information on Google’s privacy practices generally, please review Google’s privacy policy. To opt out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on.
Do Not Track Signals
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked.
Our Site and App is currently configured to respond to “do not track” or similar automated privacy controls with respect to any sharing of personal information for purposes of targeted advertising activities. To learn more about other ways to possibly opt-out of certain kinds of tracking that occur when you browse the Internet and lead to targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website.
Please note that options you select are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising. As previously described in above, third parties may collect or receive information through the Site and/or App. Since it is possible that some of these third parties may respond differently than us to “do not track” requests, you should consult the applicable privacy policies of those third parties described above for further information.
Mobile Device Data Collection
If you access our Services through our App, we may collect the following personal information about you: your device identifier, your mobile device’s operating system type, your mobile carrier, and your geolocation (your location while you are using the App). This information may be used and shared with third parties for advertising purposes.
Depending on how you interact with our App, we may also collect additional information that you provide to us including contact information, log in credentials, credit/debit or other payment card information, items that you add to your “favorites” and/or “interests” lists, any posts, or communications you make on our App, and your browsing/activity within and when using the App.
To opt out of certain data collection and sharing please go to your mobile device settings and following the instructions for your particular device (See instructions for Apple & Android). To opt out of targeted ads while using the App, you can also opt out using the Digital Advertising Alliance’s free mobile application AppChoices for each device you use.
Standard data and other fees may be charged by your mobile phone carrier when using the App, so please be aware of such fees.
Your Privacy Rights
Depending on where you reside, you may have certain rights or choices that allow you to make requests with respect to your personal information (subject to applicable legal exceptions) including rights or choices to:
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Obtain details about how we collect, use, and share your personal information;
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Access a copy of your personal information;
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Delete your personal information, (unless an exception under law applies);
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Correct your personal information;
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Opt out of the sale of your personal information (if applicable);
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Opt out of targeted advertising based on your browsing behavior before and after you visit or use the Services (if applicable);
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Opt-out of any processing of your personal information for the purposes of creating a profile based on your interests or behavior which is used in such a way that would produce legal ramifications or similarly significant real-world effects on you (if applicable);
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Opt out of any automated decision-making activities made with respect to your personal information (if applicable);
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Limit Processing of your sensitive personal information for purposes of inferring characteristics about you (if applicable);
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Submit an appeal to a regulatory authority if we reject your request; and/or
-
Not have discriminatory action taken against you for exercising your rights.
How to Submit a Privacy Request
If you would like to exercise any of the above rights described in What Are My Privacy Rights?, please contact us. We will not discriminate against you for exercising your rights under privacy laws. Further details on the steps needed to complete your Privacy Request are detailed below.
Step 1: Verifying your Request.
Before we can fulfill your Privacy Request, we need to (i) verify your identity or your authority to make the request (if you are submitting a Privacy Request as an agent) and (ii) confirm that the personal information you are requesting belongs to you. If you have a password-protected account with us, we may use our existing authentication procedures to verify your identity, however, you are not required to have an account with us to make a Privacy Request. For most other requests, we will ask you to provide information that matches at least two pieces of personal information we store about you before responding to your Privacy Request. If you would like to request specific pieces personal information that we have collected, or if you would like us to delete highly sensitive personal information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose personal information you are requesting. We may refuse any request made regarding collected personal information if we are unable to verify the identity of the person making the request or if we cannot authenticate the legitimacy of the request using commercially reasonable efforts. Under such circumstances, we may follow up with you for additional information as reasonably necessary to authenticate your request. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Authorized Agents
You may grant an authorized agent written permission to submit Privacy Requests, but we may deny authorized agent requests if we are unable to verify your identity directly as the subject of the personal information at issue. To verify a request from an authorized agent, we may require proof that you gave the authorized agent signed permission to submit the Privacy Request, such as by requiring you to directly confirm with us that you provided permission for the authorized agent to submit your request, and/or we may ask you to verify your identity directly with us.
Step 2: Responding to your Request.
After verifying your identity, we will respond to your request by either fulfilling your request or explaining why we are denying your request. The timeframe in which we respond will vary based on the applicable law where you reside. If we deny your request, you may have the option under applicable law to appeal this decision by contacting us using the contact methods described above. If you are concerned with the result of your appeal, you may have the right to contact your State Attorney General or applicable data protection supervisory authority.
Deletion Requests
Please note that for deletion requests, any removal of content by us does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties who act outside of any business relationship with us or may not cooperate with our request for them to delete your personal information, or federal or state law may require maintenance of the content or information. We will do its best to accommodate your request, but we cannot guarantee we can remove all personal information from the specified uses. Therefore, please be as specific as possible in your request. If the request relates to information that we needs to make the Services function properly for you, you may not be able to use those Services properly moving forward. We reserve the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your personal information.
Opt-Out of Certain Personal information Use and Sharing Activities
To opt out of certain online tracking activities, please follow the opt out instructions in the Online Tracking Technologies section above.
Data Retention
We retain personal information as needed to complete the Services or for other legitimate purposes such as ensuring security of our data and systems, complying with our legal obligations, complying with tax, audit, or other books and record policies, resolving disputes, and conducting internal investigations, and enforcing our agreements or other legal rights. Due to the different purposes for retaining your personal information, the actual retention timeframes may vary depending on the type of personal information we collect from you and the purposes for which we use your personal information. For more information on our data retention timeframes for different categories of personal information, please see Our Data Processing Activities.
If we determine that your personal information is no longer needed for the purposes described above, it will be deleted or anonymized so that it can no longer be attributed to you. Our collection times will be consistent with applicable law. Please note that residual copies of your personal information may be removed from backup systems subject to our backup data retention schedule.
Data Security
We have implemented technical and organizational measures to address the risk of loss, misuse, alteration, or unauthorized disclosure of personal information under our control. We limit access to your personal information to those employees, agents, contractors, and other third parties who have a need to know such information to provide the Services or in instances where disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. We require that such third parties only process your personal information to provide services to us and to implement security measures keep your information confidential and secure.
When we transmit highly sensitive information (such as a credit/debit or other payment card number) through our Site and App, we encrypt the transmission of that information using the Secure Sockets Layer (SSL) protocol. Credit/debit or other payment card information is encrypted in transmission and is not permanently stored on our web servers. We have processes in place to maintain conformance with PCI DSS (Payment Card Industry Data Security Standard) and other relevant security standards.
While we have employed security technologies and procedures to assist safeguarding your personal information, no system or network can be guaranteed to be 100% secure, and we cannot guarantee that the information you send over the internet is fully secure. You should exercise discretion in what information you disclose and/or transmit through our Site and App. The transmitted information may be intercepted by others before it reaches us. Please note that e-mail communications may not be encrypted and therefore should not be considered secure. If you are concerned about sending information to the we over the Internet, please send the information by mail or call us to make other arrangements. We are not responsible for the security of information transmitted online. Likewise, when you click on Third-Party links from our Site or App, we cannot control the security measures used on such Third-Party sites or applications. If you have an account with us, you are responsible for maintaining the secrecy of your log in credentials and account information, and for controlling access to your email account and any electronic communications from us.
Changes To Our Policy
We reserve the right to change this Policy at any time. Since this Policy may change as we modify or expand our Services or to comply with changes in applicable laws, we suggest you check back from time to stay informed of such changes. Any substantive changes to this Policy will be described at the beginning of this Policy for a period of thirty (30) days. Our Policy’s effective date will always be set forth at the beginning of the Policy. Any changes will be immediately incorporated into this Policy and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so. Your continued use of the Services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Services. We will not collect new types of personal information beyond what is disclosed in this Policy without providing you notice prior to the collection of that personal information. We will not use your personal information for an unexpected purpose beyond what is disclosed in this Policy without first providing you notice of such change by sending a notice to the email address you provided us and/or by posting a new a revised Privacy Policy with a new “Last Updated” date and, to the extent required under law, obtaining your consent.
Terms of Use
This Policy is incorporated into and governed by our Terms and Conditions/Legal Notice located here: https://cashuu.com/terms-conditions/.
IF YOU DO NOT AGREE WITH ANY ASPECT OF THIS POLICY, THEN PLEASE DO NOT ACCESS OR USE THE SERVICES OR OTHERWISE PROVIDE US WITH YOUR PERSONAL INFORMATION. YOUR CONTINUED USE OF OUR SERVICES SIGNIFIES YOUR ACCEPTANCE OF THIS PRIVACY POLICY.
IF YOU LEARN OF A POTENTIAL VIOLATION OF THIS POLICY BY US OR AN OUTSIDE PARTY, PLEASE CONTACT US.
How to Contact Us
If you have any questions regarding this Policy, please contact us at:
Email: support@cashuu.com
Phone: 844-422-7485
Attention: Data Protection Officer
You can also contact us through our Site at: https://cashuu.com/contact-us/
GLBA Notice
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Cashuu, Inc. Rev. November 10, 2023 |
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FACTS |
WHAT DOES CASHUU, INC. DO WITH YOUR PERSONAL INFORMATION? |
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Why? |
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
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What?
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The types of personal information we collect and share depend on the product or service you have with us. This information can include Social Security number, account balances and payment history, and credit history and credit score. |
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When you are no longer our customer, we continue to share your information as described in this notice. |
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How? |
All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Cashuu chooses to share; and whether you can limit this sharing. |
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Reasons we can share your personal information |
Does Cashuu share? |
Can you limit this sharing? |
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For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
YES |
NO |
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For our marketing purposes— to offer our products and services to you |
YES |
NO |
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For joint marketing with other financial companies |
NO |
NO |
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For our affiliates' everyday business purposes— information about your transactions and experiences |
NO |
NO |
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For our affiliates' everyday business purposes— information about your creditworthiness |
NO |
YES |
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For our affiliates to market to you |
NO |
YES |
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For nonaffiliates to market to you |
NO |
YES |
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Questions? |
Call 844-422-7485 or go to https://cashuu.com |
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Page 2 |
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Who we are |
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Who is providing this notice? |
Cashuu, Inc. |
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What we do |
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How does Cashuu, Inc. protect my personal information? |
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. Please see our Main Cashuu Privacy Policy for further information. |
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How does Cashuu collect my personal information? |
We collect your personal information, for example, when you
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Why can't I limit all sharing? |
Federal law gives you the right to limit only
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State laws may give you additional rights to limit sharing. |
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Definitions |
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Affiliates |
Companies related by common ownership or control. They can be financial and non-financial companies. |
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Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies. |
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Joint marketing |
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. |
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Other important information |
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For further information on how we process your Nonpublic Personal Information please see our Main Cashuu Privacy Policy. |
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