Privacy Policy

CashCard24 is a digital banking platform operated by CashCard24 Digital Bank, a company registered in United States under company number CC240024, with its registered office at 383 Madison Ave, New York, NY 10179, United States (“CashCard24”, “we”, “us” or “our”).

CashCard24 Digital Bank is the controller responsible for your personal information when you visit our website, apply for or hold an account, or otherwise interact with us. We have appointed a Data Protection Officer, who can be contacted at privacy@cashcard24.com.

We collect the following categories of personal information, either directly from you, from your use of the Services, or from third parties such as identity-verification and fraud-prevention providers:

• Identity information — full name, date of birth, nationality, tax identification number, and copies of government-issued identification documents and selfie images used to verify that the document belongs to you.
• Contact information — residential and mailing address, email address and mobile phone number.
• Financial and transaction information — account and card numbers, balances, transfers and payments, payee details, source of funds, employment and income information, and statements.
• Business information — for business accounts, details of the business, its directors, beneficial owners and authorised users.
• Device and technical information — IP address, device identifiers, browser and operating system type, approximate location derived from IP address, sign-in times, and information collected through cookies and similar technologies.
• Security information — hashed credentials, two-step verification settings, trusted devices and security event logs. We never store your password or transaction PIN in readable form.
• Communications — records of your messages, emails and calls with us, support requests, complaints and survey responses.
• Marketing preferences — your choices about receiving marketing from us.

We use your personal information to:

• verify your identity and assess your application to open an account;
• open, operate and service your accounts and cards, and process your transfers and payments;
• send you one-time codes, transaction alerts, statements and service notices;
• prevent, detect and investigate fraud, unauthorised access and other financial crime, including reviewing transactions that are held for review;
• comply with our legal and regulatory obligations, including anti-money-laundering, sanctions screening, tax reporting and record-keeping;
• respond to your enquiries and complaints and provide customer support;
• maintain, secure, test and improve the Services; and
• with your consent where required, tell you about products and features that may interest you.

We do not sell your personal information, and we do not make decisions that produce legal or similarly significant effects about you based solely on automated processing without appropriate safeguards, including the right to request human review.

Where data protection law requires a legal basis for processing, we rely on the following:

• Contract — to provide the Services you have requested and to take steps at your request before entering into an agreement.
• Legal obligation — to verify your identity, prevent financial crime, keep records and report to authorities as required by law.
• Legitimate interests — to protect you and us against fraud, secure our systems, improve our Services and manage our business, where those interests are not overridden by your rights.
• Consent — for optional cookies and certain marketing. You can withdraw consent at any time.

We share personal information only where necessary and with appropriate safeguards in place. The categories of recipients are:

• Service providers acting on our instructions, including identity-verification and screening providers, our email delivery provider, our SMS and messaging provider, cloud hosting and data storage providers, card processors and payment networks, customer-support tooling, and professional advisers such as auditors and lawyers.
• Payment recipients and other financial institutions involved in processing your transfers, who will receive the information needed to complete the payment.
• Fraud-prevention agencies and law enforcement, where we are required or permitted by law to do so.
• Regulators, tax authorities and courts, where required by law or to establish, exercise or defend legal claims.
• A buyer or successor in the event of a merger, acquisition or sale of all or part of our business, subject to equivalent confidentiality protections.

A current list of the categories of sub-processors we use is available on request from privacy@cashcard24.com.

Some of our service providers are located, or store data, outside United States. Where we transfer personal information internationally, we make sure it receives an equivalent level of protection by relying on adequacy decisions, standard contractual clauses or other transfer mechanisms recognised by applicable law. You can request details of the safeguards we use by contacting our Data Protection Officer.

We keep personal information only for as long as we need it for the purposes described in this policy. In general:

• account, identity and transaction records are kept for the life of your relationship with us and for 5 years afterwards, as required by financial-services and anti-money-laundering laws;
• records of applications that do not proceed are kept for 12 months;
• security and access logs are kept for 12 months; and
• marketing preferences are kept until you change them.

When information is no longer needed, we securely delete or anonymise it.

We use administrative, technical and physical safeguards designed to protect your personal information, including encryption in transit, hashing of credentials, two-step verification, role-based access controls for our staff, audit logging and regular security testing. No system is completely secure, so please also play your part by keeping your Credentials confidential. We will never ask for your password, transaction PIN or a one-time code. If we become aware of a personal data breach that is likely to affect you, we will notify you and the relevant authorities as required by law.

Depending on where you live, you may have some or all of the following rights in relation to your personal information:

• to access the information we hold about you and receive a copy;
• to correct information that is inaccurate or incomplete;
• to ask us to delete your information, subject to our legal retention obligations;
• to restrict or object to certain processing, including direct marketing;
• to receive your information in a portable format;
• to withdraw consent at any time, where we rely on consent; and
• not to be subject to a decision based solely on automated processing that significantly affects you.

To exercise any of these rights, contact privacy@cashcard24.com. We will respond within the time required by applicable law and may need to verify your identity first. You also have the right to lodge a complaint with JP Morgan Chase, although we would appreciate the chance to address your concerns first.

We use cookies and similar technologies that are strictly necessary to keep you signed in securely and protect your account, and — with your consent where required — to remember your preferences and understand how our website is used. For full details and how to manage your choices, see our Cookie Policy.

Our Services are not directed at children, and we do not knowingly collect personal information from anyone under the age of 18 except as part of an account product specifically designed for minors and opened with the consent of a parent or guardian. If you believe a child has provided us with personal information, please contact us so that we can delete it.

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page shows when it was last revised. If we make material changes, we will notify you by email or in the Services before they take effect.

If you have any questions about this policy or how we handle your personal information, please contact:

• Data Protection Officer: privacy@cashcard24.com
• Customer support: support@cashcard24.com · +1 (212) 270-09993
• Post: Data Protection Officer, CashCard24 Digital Bank, 383 Madison Ave, New York, NY 10179, United States