Effective Date: Dec 31, 2024

Trust is our #1 value. Our top priority is the security and privacy of the data that we are entrusted to protect. This Privacy Statement applies to Merchant and User accounts and helps to provide you with information on how we collect, use, disclose, transfer, store, retain and process your information when you use Power Cash online at https://app.power.cash and https://agent.power.cash/ (collectively, “Services”).

This Privacy Notice governs and outlines how we collect and handle information you provide through your use of our Services. By using our Services, you agree to the practices detailed here. We periodically update this Privacy Notice to reflect changes in our business, Services, or legal requirements. Where required by law, we will notify you of material changes 30 days in advance by posting on the “Policy Updates” or “Privacy Statement” page of our website. Otherwise, updates will be effective as of the published date.

Our Privacy Notice explains:

• Information we collect about you
• Sources of Information we collect about you
• How we use your information
• Disclosing Personal Information and why?
• Cookies and Other Automated Technologies
• Third-Party Analytics Services
• How Long we Keep your information
• Your Data Protection Rights
• Rights of California Residents
• Security
• Changes to this privacy Policy
• How to contact us

INFORMATION WE COLLECT ABOUT YOU

We collect various information when you interact with our Services, including applying for an account, verifying your identity, logging in, communicating with us, responding to surveys, and participating in promotions or contests offered by us or our partners. This includes information you directly provide to us and also information we may obtain through automated means.

The types of information we collect about you.

Information You Provide Us:

• Identification Information: This includes your name, email, address, phone number, date of birth, login credentials (passkeys), Geolocation coordinates and IP address.

• Additional Verification Information (for identity verified users): This includes your full address, date of birth, government-issued ID details (such as Social Security number, passport, or driver’s license), and biometric data like a photograph.

• Financial Information: We collect routing number, account number and balance of any bank accounts linked to your account.

• Transaction Information: We gather details about your transactions, including dates, locations, parties involved, transaction descriptions, amounts, and the devices and methods used.

We collect your information to comply with applicable laws and rules and enforce our agreements with you and other people who use our services.

Information Collected Automatically. As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information, including:

• Geolocation Information: Details about your device’s location, like IP address, device language, and network provider location. This may include precise geolocation data. For details on disabling precise geolocation on your mobile device, please visit our help center (http://power.cash/faq).

• Device Information: Details about your device, including hardware model, operating system and version, device name, unique identifier and how your device interacts with our Services.

• Internet or Network Activity Information: Information about your use of our Services, including access times, log-in and log-out details, browser type and language, country and language settings, IP address, and your internet service provider. We also collect details on specific pages visited, viewed content, used features, dates and times of activity.

• Inferences: Insights drawn from the above information to build a profile that may reflect your preferences, characteristics, and behaviors. We use this data to enhance account security and improve our Services.

Do Not Track: As there is no common understanding about what a "Do Not Track" signal is supposed to mean, we don’t respond to those signals in any particular way. See further information below regarding how you may be able to withdraw your consent for the use of certain tracking technologies like cookies and pixel tags.

Information Collected from Third-Party Companies. We may receive information about you or related to you from service providers and other sources/companies that offer their products and/or services to us or to you, for use in conjunction with our Service, or whose products and/or services may be linked from our Service. We may add this to the data we have already collected from or about you through our Service. This information may include, for example:

• Third-party services that provide data transfer networks to support transfer of funds;
• Data analytics providers;
• Vendors who provide communication and identity verification services to us and which you choose to use;
• Information from third parties for purposes such as credit checks, identity or account verification, fraud detection, or collection processes, as legally required. This may involve sharing account or credit details with credit agencies or bureaus and any entities with whom you have or may have a financial relationship, including past, present, and future employers, financial institutions, or reporting agencies; and
• Other vendors who provide us information necessary to run our business or enforce our Terms of Service.

HOW WE USE YOUR INFORMATION

We may collect, use, and share your information for the following purposes:

• Providing, Improving, and Developing Services:

  • Determining Service availability in your location.
  • Processing and recording payments.
  • Displaying your transaction history.
  • Connecting you with merchants nearby.
  • Maintaining and enhancing our Services.
  • Managing fraud and risk
  • Creating new products and features.
  • Delivering information and supporting any requests made by you.
  • Improving, personalizing, and streamlining your experience with our Services, content, and applications.
  • Analyzing trends and usage patterns in relation to your use of our Services, including promotions or discounts from us or our partners.
  • Providing access to products and features you select.

• Communicating our Services

  • Sending surveys to gather your feedback on our Services.
  • Sharing information we believe may be useful to you, or that you have requested, about our products and services.

• Safeguarding Our Services and Building Trust:

  • Carrying out investigations, ensuring compliance with relevant laws and standards, and addressing government or legal inquiries.
  • Reaching out to resolve issues, handle payments, and assist with any service-related needs.
  • Troubleshooting and fixing issues that affect our Services’ performance.
  • Enforcing our Terms of Service and other agreements or policies.
  • Identifying, preventing, and addressing instances of fraud, security incidents, misrepresentations, or other restricted or illegal activities, including supporting chargeback disputes.
  • Protecting the rights, property, and safety of our users, our Services, and our company.
  • Verifying the quality and security of our Services.
  • Confirming your identity, including through official identification when necessary.

• Promotions and Marketing:

  • Advertising our Services to you. Informing you about opportunities, products, services, events, promotions, discounts, surveys, rewards, and incentives from us and our selected partners.

DISCLOSING PERSONAL INFORMATION AND WHY?

• With Other Users of Our Services
  We may share information with other merchants / users you interact with through our Services. For instance, when you send or receive a payment, we may provide details to the other party to confirm the transaction. Certain information, like name, age and email may be shown to help others identify you. Additionally, if you choose, you can share more details about yourself and your interactions with our Services with other Power Cash users.

• With Our Affiliates and Group Companies

We may share information with our affiliates to support the purposes outlined above. For example,
we might share data internally to enhance your experience with Power Cash and other company
products, gain insights into your engagement, and develop Services that align with your
preferences.

• With Our Service Providers
  We work with service providers who support us in maintaining, enhancing, and delivering our Services (e.g., vendors assisting with fraud prevention, identity verification, and fee collection). We may also share information with financial institutions, payment networks, card associations, credit bureaus, brokers, and other entities connected to payments, money transfers, or other Services.

• With Merchants
  When you make purchases with merchants using Power Cash, we share necessary information with them to process and complete your transaction.

• Business Transfers and Corporate Restructuring
  In the event of a change in business ownership, such as a merger, acquisition, restructuring, sale of assets, financing, or similar corporate event, we may transfer information to the new owner or relevant parties involved in the process.

• For Legal, Security, and Compliance Reasons
  We may disclose information when reasonably necessary to (i) comply with legal obligations, regulations, or requests from authorities (e.g., tax authorities, law enforcement); (ii) protect our legal rights or respond to legal processes; (iii) enforce our Terms of Service or other policies; (iv) protect the security and integrity of our Services; (v) investigate potential illegal activities; or (vi) protect our users, the public, or our business from harm or fraud.

• With Others When You Consent
  We may share information with third parties when you provide consent. For example, this may occur when you authorize another application or website to access your information.

• Aggregated and Anonymized Information
  We may also share aggregated or anonymized data, which does not personally identify you, with our affiliates, service providers, or other third parties.

COOKIES AND OTHER SIMILAR AUTOMATED TECHNOLOGIES

When you use our online services or open our emails, we gather certain details through automated tools like cookies, server logs, web beacons, and similar technologies. A “cookie” is a small text file that a website sends to your computer or another device to uniquely identify your browser or store data such as your preferences and settings. A “web beacon” (sometimes called a pixel tag or clear GIF) is a small graphic image used in our website pages or emails.

These automated tools collect information about your device, internet activity, and inferred preferences, as outlined above. This data helps us to:

• Retain your information, so you don’t need to re-enter it on future visits;
• Monitor and analyze how you interact with our online services and emails;
• Customize our online services to suit your preferences;
• Evaluate the usefulness and effectiveness of our communications and services;
• And, more generally, to improve and manage our products and services.

Some of these automated tools are set by us, while others are implemented by third-party partners who provide services on our behalf. For instance, we may use third-party analytics services (described in the "Third-Party Analytics Services" section) that apply automated tools to help us understand customer usage patterns on our websites.

You can configure your browser to alert you when cookies are being placed on your device, and to manage or disable cookies in your browser’s settings. Please keep in mind, however, that some features of our online services may not function correctly without cookies. If you’re using a mobile device, you can adjust the privacy and security settings to control how your device and browser share specific data. To learn more about managing cookies, visit allaboutcookies.org.

THIRD PARTY ANALYTICS SERVICES

We may use third-party analytics providers to assist with our online services. These providers use technologies like cookies, web beacons, and server logs to help us analyze how you interact with our online services. We may share your site usage information, including your IP address, with these analytics providers and other service partners, who use this data to help us understand how you and others use our services.

HOW LONG WE KEEP YOUR INFORMATION

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including providing you with our Services, complying with relevant laws and legal obligations, and protecting our legal rights, property, and users. Even if you deactivate your account, we may keep records of your information and any transactions or Services you’ve used for a period that aligns with legal requirements, such as applicable laws, statutes of limitations, or what we deem necessary to comply with legal processes, regulations, or government requests. This also includes retaining data to prevent fraud, collect owed fees, resolve disputes, address issues with our Services, assist in investigations, enforce our Terms of Service, and take other actions permitted by law.

YOUR DATA PROTECTION RIGHTS

Your Rights to Access, Correct, Delete, and Limit the Use or Sharing of Your Personal Information

In accordance with applicable data protection laws, you have certain rights regarding the collection, storage, use, and sharing of your Personal Information.

We understand the importance of your control over how your Personal Information is handled. To support you, we offer multiple ways for you to exercise your rights to access (the right to know), correct, delete (erase), and limit the sharing or use of certain data (such as opting out of sharing and limiting the use and disclosure of sensitive personal information).

We will not deny you services, impose higher fees, or provide a lower level of service simply because you choose to exercise your privacy rights. If you are a California resident, please refer to how we handle your privacy rights in the relevant section.

Your Personal Information
You can view, access, edit, or delete your information and information about you for certain aspects of the Service via your Settings page. Depending on applicable law where you reside, you may have certain rights in relation to information about you. However, such rights are not absolute and may apply only in certain circumstances. If such rights are not provided under law for your operating entity or jurisdiction, Power Cash has full discretion in fulfilling your request.

1. Rights available may include the right to (i) request access and obtain a copy of your personal information, or certain details regarding the ways in which we use and disclose your personal information; (ii) request correction/rectification of inaccurate personal information that we hold about you; (iii) request deletion of your personal information; (iv) object to or restrict the processing of your personal information; (v) request portability of your personal information and (vi), if we have collected and processed your personal information based on your consent, you may have the right to withdraw your consent at any time,
2. If you wish to exercise your rights under an applicable data protection or privacy law, please contact us by submitting a request to support@power.cash, specify your request, and reference the applicable law. We may ask for additional information to verify your identity (such as your email address or government issued ID) or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. You may designate an authorized agent to make requests on your behalf to exercise your rights, but before accepting such a request from an agent, we will require them to provide proof you have authorized them to act on your behalf and may need you to verify your identity directly with us. We will not discriminate against you for exercising any of these rights.

Deactivating Your Account
If you wish to deactivate your account, you can do so by emailing us at support@power.cash from the email associated with your Power Cash account.

Location Information

To provide certain Services, we may need access to your location data, including precise geolocation information from your device. If you choose not to allow this data collection, some Services may not work as intended, and you will be unable to access those features. You can disable the collection of location information at any time by adjusting the settings on your browser. Please note that if you do this, some of our applications may no longer function properly.

Do Not Track

Some web browsers offer a feature known as "Do Not Track" (DNT), which allows you to signal websites that you prefer not to have your online activity tracked. Currently, our websites do not respond to DNT signals or similar features from web browsers.

Promotional Communications

You have the option to opt out of receiving promotional emails from us within the application. Even if you opt out of promotional communications, we may still send you non-promotional notifications, such as transaction receipts, account updates, or other communications related to the processing of your information in connection with the Services we provide.

RIGHTS OF CALIFORNIA RESIDENTS

If you are a California resident, the following additional rights are available to you:

Right to Access

You may request, up to twice per year, the following details about the personal information we’ve collected about you:

• The categories and specific types of personal information we have collected;
• The sources from which we obtained the personal information;
• The business purposes for which we collected the personal information;
• The third parties with whom we have shared the personal information;
• The types of personal information we’ve disclosed for business purposes, and the third parties to whom we disclosed that information.

Under California law, you can also inquire if we share your personal information with third parties for their direct marketing purposes (we do not disclose your personal information for such purposes).

Right to Deletion

You have the right to request that we delete the personal information we hold about you, subject to certain legal exceptions. Please note that if you delete your information, you may lose access to some of our Services.

Right to Correct

You may request corrections to the personal information we have collected about you, subject to legal exceptions.

Right to Non-Discrimination

You have the right to exercise your privacy rights without fear of discrimination. We will not treat you unfairly, deny services, charge higher fees, or offer lower quality goods or services simply because you choose to exercise these rights.

Right to Opt-Out

You have the right to opt-out of having your personal information shared for targeted advertising purposes, including cross-context behavioral advertising. If we anticipate sharing your information for such purposes, we will provide a way for you to opt-out (subject to legal exceptions).

While some of the information we process may be considered sensitive personal data, we only use it for lawful purposes, such as to provide services you request or verify your information.

We do not sell your personal information to third parties.

How to Exercise Your Rights

To exercise your rights to access, delete, or correct your personal information, please email us at support@power.cash from the email registered with Power Cash. To protect your privacy and ensure security, we take steps to verify your identity, which may require you to be logged into your account before fulfilling your request. You may also designate an authorized agent to make a request on your behalf as permitted by law, but we will need written consent from you for the agent and may need to verify your identity directly.

In certain cases, we may charge a reasonable fee to process your request, in line with applicable laws.

Exceptions to Your Rights

California law provides certain exceptions to the rights mentioned above. We reserve the right to apply these exceptions when appropriate.

SECURITY

We implement reasonable security measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, or destruction. However, it's important to note that no online system is entirely secure, and we cannot guarantee the absolute security of your information during transmission or storage. We store your information both on our premises and with third-party service providers.

CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice periodically. The updated version will become effective on the date specified. We will notify you in advance of any changes to the Privacy Notice as to how we use your information, which may be communicated through the Power Cash website, or via email if you’ve provided one. If you do not agree with the changes, you can cancel your account at any time. By continuing to use our Services, you accept the revised Privacy Notice.

HOW TO CONTACT US

Please contact us with any questions or concerns regarding this Privacy Notice at Golden Order, Inc. 611 Gateway Blvd, Suite 120, South San Francisco, CA, 94080, U.S.A. or by emailing us at support@power.cash.