INTRODUCTION AND OVERVIEW
Protecting the privacy and confidentiality of your information is critically important to KASH. We adhere strictly to the policies and procedures described herein in order to maintain the integrity of that information. As a fundamental principle embodying our respect for your privacy, we do not sell your information to third parties. Except for the limited reasons set forth below, primarily to provide you with your requested services (with your consent) or to comply with applicable law, we do not transfer your information to third-parties.
If you still have any questions or concerns, please contact us at email@example.com.
WHAT INFORMATION DO WE COLLECT
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Platform, express an interest in obtaining information about us or our Services, when you participate in activities on the Platform or otherwise when you contact us.
The personal information that we collect depends on the context of your interactions with us and the choices you make using KASH. The personal information we collect may include the following:
- Personal information provided by you via KASH Account registration. - We can collect your name and e-mail address during the Account registration process. Also, you can voluntarily provide your address and phone number via your Account.
- Payment Data and Transactions. Our Service Providers may collect data necessary to process your payments if you make transactions via KASH, such as your payment instrument number (such as a credit card number); the security code associated with your payment instrument. All payment data is stored by our Service Providers according to applicable laws and security standards. We mainly receive and process data from the Service Provider about the status of a particular transaction without directly receiving the data specified in this paragraph for purposes of the execution of the contract and support.
- Sensitive Information. We do not collect and process sensitive information directly. When necessary, with your consent or as otherwise permitted by applicable law, our Service Providers may process the following categories of sensitive information: social security numbers; other government identifiers, and other information collected during KYC procedures conducted by our Service Providers. We mainly receive and process data from the Service Provider about the status of a particular KYC procedure without directly receiving the sensitive information specified in this paragraph.
- Social Media Login Data. We may provide you with the option to register with us using your existing social media Account details, like your Facebook, Google, Twitch or Discord. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list and profile picture, as well as other information you choose to make public on such a social media platform.
- Communication. We collect the content of messages you send to us, such as feedback you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the Services you use.
Information Collected Automatically
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Platform.
We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Platform and other technical information. This information is primarily needed to maintain the security and operation of our Platform, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in the Section about Cookies below.
The information we collect automatically includes:
- General personal data. We collect such data as the user`s name, email, country. for communication with our users and/or for making user base analysis. Some sensitive personal data: Name (first and last names), age and country.
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Platform and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in KASH.
- Device Data. We collect device data you use to access the Platform. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Platform. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
The information we collect automatically is used primarily as statistical data and does not include personal information. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns. However, we may store information about your preferences, allowing us to customize our Platform according to your individual interests, speed up your searches, and recognize you when you return to Kash, although you may opt out of such use as discussed below.If you interact with us on a social media platform using your social media account (e.g. Facebook or Discord), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
HOW DO WE USE YOUR INFORMATION
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Platform for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
- To manage user accounts and Application performance: We may use your information for the purposes of managing your account and keeping it in working order, to analyze crash logs, bug reports etc.
- To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- To send you necessary communications and administrative information. We may use your personal information to send you service and new feature information and/or information about changes to our terms, conditions, and policies.
- For marketing purposes. To analyze performance of marketing campaigns and track signup channels.
- For Usage behavior analysis. To analyze users usage behavior on the App, such as: web sessions, page visits, transaction records.
- For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platform, Services and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
WILL YOUR INFORMATION BE SHARED WITH ANYONE
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent. We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests. We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract. Where we have entered into a contract with you (please, follow our Terms and Conditions), we may process your personal information to fulfill the terms of our contract.
- Legal Obligations. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Service Providers. We may share your data with third-parties - service providers, who perform services for us or on our behalf and require access to such information to do that work. Service Providers assist us with services such as payment processing, credit checks, data analytics, marketing, and promotional services, promotions, website hosting, and technical support.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third Parties Social Media Service. We may share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service, and advertising effectiveness, and enabling other enhancements.
Without limiting the foregoing, in our sole discretion, we may share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose (including cases of legal disputes as it will be regulated by applicable law) except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “YOUR PRIVACY RIGHTS” below. Except as described in this section, we will not share your personally identifiable information with any third party unless you expressly consent to such disclosure in advance.
LINKS TO OTHER WEBSITES
We provide links or pointers to third-party sites, blockchains or applications, including, without limitation: (i) third party payment providers, such as Transak and Ramp that will enable you to purchase fiat or virtual currency (each, a “Payment Provider”, and together, the “Payment Providers”); (ii) the Ethereum and other blockchains; (iii) DeFi protocols; (iv) Wallet providers; and (v) DEXs (together, the “Third Party Sites”). As Kash is a provider of non-custodial pricing data aggregation services only, your use of the Third Party Sites is subject to the following:
- Kash makes no representations about any Third Party Sites that may be accessed from the Kash Platform.
- If you choose to access any such Third Party Sites you do so at your own risk.
- Kash has no control over the contents of any such Third Party Sites and accepts no responsibility for such Third Party Sites and the level of safety they propose for user's personal data.
- You are subject to any terms and conditions, privacy policies of such Third Party Sites. You will need to consider and review the privacy policies of such Third Party Sites to be sure your personal data is safe and you agree with the rules drafted in such privacy policies.
We carefully select our Service Providers in accordance with the criterion of compliance with the technical and organizational level of security of generally accepted standards, however, nevertheless, we cannot be held responsible for their violation of applicable legislation in the field of PII protection and the provisions of this policy.
The Service may contain links to websites that are not affiliated with us and that may or may not have practices in place to protect the privacy of your information. We are not responsible for privacy practices employed by these website owners and Service Providers and encourage you to review their privacy statements so that you will be aware of their data collection, use, and distribution policies.
HOW LONG DO WE KEEP YOUR INFORMATION (RETENTION PERIOD)
We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements) including, as applicable, (i) for as long as we have an ongoing relationship with the individual to whom the information pertains; (ii) as long as needed to provide users, our customers, or our partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (v) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for processing the personal data, whether the purposes of processing can be fulfilled by other means, and any applicable legal requirements.
We implement and maintain reasonable administrative, physical and technical security safeguards to help protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for illegal or unauthorized circumvention of any privacy settings or security measures contained on the Platform.
KASH EXERCISES ALL EFFORTS TO SAFEGUARD THE SECURITY AND CONFIDENTIALITY OF YOUR PERSONAL DATA; HOWEVER, TRANSMISSIONS PROTECTED BY INDUSTRY STANDARD TECHNOLOGY AND ADMINISTERED BY HUMANS CANNOT BE GUARANTEED TO BE SECURE. KASH WILL NOT BE LIABLE FOR UNAUTHORIZED DISCLOSURE OF PERSONAL DATA THAT OCCURS THROUGH NO FAULT OF KASH INCLUDING, BUT NOT LIMITED TO, ERRORS IN TRANSMISSION, ACCESS TO YOUR ACCOUNT BY ANYONE USING YOUR USER ID AND PASSWORD, OR YOUR FAILURE TO COMPLY WITH YOUR SECURITY OBLIGATIONS.
YOUR PRIVACY RIGHTS
GDPR provide users with rights related to their personal information. Consistent with those laws, KASH gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your KASH account information, you may also remove certain optional information that you no longer wish to be publicly visible such as your name, you can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
- You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.
- You have the right to request that we rectify inaccurate information about you.
- In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of KASH.
- If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
TRACKING TECHNOLOGY CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods, and generally may be controlled through your browser settings.
Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Advertising Technology. We may use certain advertising analytics technology, like that Google Analytics to analyze your use of the Service or advertising that was displayed to you. Some information about your use of the Service and certain Third Party Service (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Service Providers.
Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in the e-mails to click on the unsubscribe link or emailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or the Company’s ongoing business relations.
SMS Messaging and Phone Calls. Certain portions of the Services may allow us to contact you via telephone or text messages. You agree that the Company may contact you via telephone or text messages (including by an automatic telephone dialing system) at any of the phone numbers provided by you or on your behalf in connection with your use of the Services, including for marketing purposes. You understand that you are not required to provide this consent as a condition of using the Service.
Push Notifications. We may request to send you push notifications regarding your account or the Service. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s or browser's settings.
Our Platform is not intended for children under 18 years of age. No one under the age of 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Platform or through any of its features, register on the Platform, make any purchases, actions, transactions through the Platform, use any of the interactive or public comment features of this Platform (primarily through the blog), or provide any information about yourself to us. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information promptly. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
ACCESSING AND CORRECTING YOUR INFORMATION
Based on the applicable laws of your state or country, you may have the right to request access to the personal data we collect from you, change that information, or delete it in some circumstances.
You can review and change your personal information by logging into the Platform, visiting your account profile page, and changing any information. You may also send us an email at email@example.com to correct or delete any personal information that you have provided to us. We cannot delete the entirety of your personal information without deleting your account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
UPDATES TO THIS POLICY
If you have questions or comments about this Policy, you may email us at firstname.lastname@example.org