CODECASH Privacy Policy

INFORMATION COLLECTION. These terms govern your use of the CodeCash app (the “App”).

INFORMATION YOU PROVIDE TO ENCODE

  • In an attempt to deter terrorism and money laundering, Encode Inc. (“Encode”), the owner of the App, follows a strict policy of identifying all users of the App. Encode will collect the following information from all people creating an account on the App and cross-check said information with the list of Specially Designated Nationals and Blocked Persons maintained by the Office of Foreign Assets Control (“OFAC”) of the United States Department of the Treasury and any and all other appropriate lists maintained by OFAC:
  • Name
  • Date of Birth
  • Street Address
  • Social Security Number.
  • No one may open an App account if their identity cannot be confirmed by Encode or if they are prohibited from doing so by OFAC.
  • Encode will collect additional information that identifies you as a specific individual and can be used to contact or identify you, such as your photograph, email address, company address and telephone number (such additional information and the information described above, “Personal Information”).
  • Personal Information also includes the banking account and/or debit card number you use as your funding source for payment made and received through the App.
  • Encode may request documents to verify Personal Information, such as a copy of your government-issued identification, a photo or a billing statement.
  • You will have the opportunity to create a user profile (“Profile”) which will give you the option of including Personal Information. Your Profile may be visible to all CodeCash users and the general public subject to the privacy choices you make within your Profile. If, in any case, you believe that an unauthorized Profile has been created about you, you can request for it to be removed by contacting CodeCash customer support.
  • Encode may provide you the opportunity to post comments, questions and other content (collectively, “User Forum Content”) publicly in forums and on blogs (“Community Forums”). Your name and Profile may be publicly displayed along with your User Forum Content. Note that any User Forum Content you post to a Community Forum is public — others will have access to your User Forum Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information in your User Forum Content or use Community Forums to link to your Profile, that information will be considered public information and the protection of this Privacy Policy will not apply.
  • Encode does not knowingly collect Personal Information from anyone younger than age 18. If Encode becomes aware that a child younger than 18 has provided Encode with Personal Information, Encode will use commercially reasonable efforts to delete such information from its files. If you are the parent or legal guardian of a child younger than age 18 and believe that Encode has collected Personal Information from your child, please contact us at legal@codecash.com.
  • Encode may aggregate information collected from Encode registered and non-registered users (“Users”).
  • Encode also may collect other information, such as zip codes, demographic data and information regarding your use of the App (“Non-Identifying Information”). Encode considers usernames to be Non-Identifying Information. Usernames are made public through the App and are viewable by other Users.
  • In some cases, Encode may render Personal Information (generally, email addresses) into a form of Non-Identifying Information referred to in this Privacy Policy as “Hashed Information.” This is typically accomplished using a mathematical process (commonly known as a hash function) to convert information into a code. The code does not identify you directly, but it may be used to connect your activity and interests.
  • Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences). Encode may combine your Personal Information with Non-Identifying Information, but Encode will treat the combined information as Personal Information.
  • Encode collects feedback from Users about their experience with the App and other Users. Please note that any feedback you provide or feedback provided about you may include Personal Information and will be publicly viewable via the App. You have no obligation to provide feedback to Encode.

INFORMATION YOU PROVIDE TO ENCODE

  • Encode and its third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the App. This information may include, among other information: the browser and operating system you are using; the URL or advertisement that referred you to the App; the search terms you entered into a search engine that led you to the App; areas within the App that you access; and the location of and internet protocol address or other unique device identifier for any device (computer, mobile phone, tablet, etc.) used to access the App. Encode may combine this automatically collected log information with other information Encode collects about you. Encode does this to improve services it offers you, its marketing, its analytics and the functionality of the App.

The technology used to automatically collect information about you may include the following:

Cookies: 

  • A cookie is a small data file that is transferred to your device’s hard disk for record-keeping purposes. Encode uses both persistent cookies that remain on your device (such as to save your registration ID and login password for future logins to the App and to track your compliance with the CodeCash Terms of Use) and session ID cookies, which expire at the end of your session (for example, to enable certain features of the App, to better understand how you interact with the App and to monitor aggregate usage and traffic). You may be able to instruct your mobile device, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie. If you do not accept cookies, however, you may not be able to use all functionality of the App.

Web Beacons: 

  • Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including without limitation to count visitors to a website, to monitor how users navigate a website, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed. Encode and its marketing partners, affiliates, analytics, and service providers may use web beacons and similar technology to help Encode keep track of what portions of the App are effective as well as to send relevant advertising to you.

Embedded Scripts: 

  • An Embedded Script is programming code that is designed to collect information about your interactions with the App, such as the links you click on. The code is temporarily downloaded onto your device and is deactivated or deleted when you disconnect from the App.
  • Encode and its marketing partners, affiliates and service providers may use a variety of other technologies, including without limitation technologies that collect information for security and fraud detection purposes.

CREDIT CARD AND BANKING INFORMATION

Electronic Fund Transfers (EFTs) and Account Balances

  • CodeCash partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers (EFTs). When you create a CodeCash account, link a bank account, or initiate an EFT, you are authorizing us to share your identity and banking information with Sila and Evolve to support your account. You are also agreeing to the terms of Sila’s privacy policy, https://silamoney.com/privacy-policy/, Evolve’s privacy policy, https://www.getevolved.com/privacy-policy/, and Evolve’s communications consent and disclosure, https://silamoney.com/evolve-electronic-communications-consent-and-disclosure/ (the “Partner Terms”). It is your responsibility to make sure the data you provide us is accurate and complete, which is necessary for our partners to process EFTs on your behalf. The Partner Terms may be modified from time to time, and the governing versions are incorporated by reference into this Privacy Policy. Any term not defined in this section but defined in the Partner Terms assumes the meaning as defined in the Partner Terms. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR CODECASH ACCOUNT, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.
  • To process payments on CodeCash, Encode needs to share some of your Personal Information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through CodeCash.
  • Encode works with vendors to enable them to accept payments from you using the App. In doing so, a vendor may share information about you with Encode, such as your mobile phone number or App username, when you attempt to pay that vendor. We use this information to confirm to that vendor that you are a CodeCash customer and that the vendor should enable CodeCash as a form of payment for your purchase.
  • Regardless, Encode will not disclose your debit card number or bank account number to anyone you have paid or who has paid you through the App, except with your express permission or if we are required to do so to comply with a subpoena or other legal process
  • As indicated by a Self-Assessment Questionnaire, Encode is in compliance with the data security standards established by the Payment Card Industry Security Standards Council.

INFORMATION ENCODE RECEIVES FROM THIRD PARTIES

Encode also may receive information about you from third parties. For example, Encode may supplement the information it collects with outside records, or third parties may provide information in connection with a co-marketing agreement at your request. If Encode combines the information it receives from others with information Encode collects through the App, Encode will treat the combined information as Personal Information.

INFORMATION ENCODE RECEIVES FROM SOCIAL NETWORKING SERVICES.

  • You may create an Encode account using a third party social networking service such as Facebook or LinkedIn (an “SNS”). If you choose to register via an SNS, or to later link your Encode account with an SNS, Encode will use the Personal Information you have provided to the SNS to create and/ or maintain your Encode account. Encode has no responsibility for the Personal Information Encode obtains about you through an SNS.
  • If you choose to “like” or share content and/or transactions via an SNS, your interactions with that third party SNS are governed by the respective privacy policies of those third parties and Encode has no responsibility for the use of your Personal Information by any third party SNS.
  • If you link your Encode account with an SNS or share Encode content via an SNS, you represent that you are entitled to use your SNS account for those purposes without obligating Encode to pay any fees or making Encode subject to any usage limitations imposed by such SNS.
  • You can disable the link between your Encode account and your SNS account at any time though the “Settings” section of your account.

USE AND RETENTION OF INFORMATION: Encode uses information it collects:

  • To provide and improve the App, complete your transactions, address your inquiries, process your registration, verify that the information you provide Encode is valid
  • To contact you with administrative communications and Encode newsletters, marketing or promotional materials (on behalf of Encode or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from Encode, please follow the instructions in the Opting Out section of this policy below;
  • To tailor content Encode displays to you and offers Encode may present to you, both on the App and elsewhere online; 
  • To administer and develop the business relationship between Encode and you and, if applicable, the corporation or other legal entity you represent;
  • To enforce and comply with the law, including without limitation to conduct an investigation, to protect the property and rights of Encode and/ or third parties, to protect the safety of the public or any person, or to prevent or stop activity Encode may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity; and
  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.
  • UNLESS YOU REQUEST THAT ENCODE DELETE CERTAIN INFORMATION, ENCODE RETAINS THE INFORMATION IT COLLECTS FOR AT LEAST 5 YEARS AND MAY RETAIN THE INFORMATION FOR AS LONG AS NEEDED FOR THE BUSINESS AND LEGAL PURPOSES OF encode

INFORMATION SHARING AND DISCLOSURE:

  • Encode may share and/ or disclose Non-Identifying Information (including, without limitation, Hashed Information) with third parties. Encode does not share your Personal Information with third parties for those third parties’ marketing purposes unless Encode first provides you with the opportunity to opt-in to or opt-out of such sharing. Encode may also share the information it has collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy or in the following circumstances:
  • Encode may employ third party companies and individuals to facilitate the App and to perform App-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of App features) or to assist Encode in analyzing how the App is used. These third parties may have access to your Personal Information in order to perform these tasks.
  • You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties through the App. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party and will be subject to the privacy policy and practices of that third party. Encode is not responsible for the privacy policies and practices of third parties, and if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third party application, that Encode share information about you with a third party and Encode will typically do so under those circumstances.
  • Encode will share information with government agencies as required by law, including without limitation in connection with reporting earnings. Encode cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Encode will disclose information about you (including Personal Information) to government or law enforcement officials or private parties as Encode, in its sole discretion, believes necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), at the request of governmental authorities or other third parties conducting an investigation, to protect the property and rights of Encode and/ or third parties, to protect the safety of the public or any person, or to prevent or stop activity Encode may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
  • Encode may share information, including Personal Information, with its affiliates, primarily for business and operational purposes. Encode may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including without limitation, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy. You will be notified via email and/or a prominent notice on the App of any change in Encode ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
  • Encode may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.

THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES

Encode works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide Encode with information regarding App usage; to serve Encode advertisements on other web sites, within mobile apps and elsewhere online; and to provide Encode with information regarding the use of the App as well as the effectiveness of advertisements. Encode service providers may collect certain information about your activity on the App as well as other apps, websites and/or services; they may set and access their own tracking technologies on your device; and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you use the App or other online websites and services. Encode may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to Encode

YOUR CHOICES AND OPTING OUT

  • Registered CodeCash users may update their choices regarding the types of communications they receive from Encode through their accounts. You also may opt-out of receiving marketing emails from Encode by following the opt-out instructions provided in those emails. Please note that Encode reserves the right to send you certain communications relating to your account or use of the App (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.
  • Registered CodeCash users may, with permission, receive push notifications. Similarly, registered CodeCash users who access the App by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser. You may opt-out of receiving text messages by replying “STOP” to any text message received.
  • While Encode may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”), self-regulating organizations which set and enforce standards for online advertising. Both of these organizations provide “opt-out” procedures. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online. 

CHANGING YOUR INFORMATION OR CLOSING YOUR ACCOUNT

  • Upon request Encode will provide you with information about whether Encode holds any of your Personal Information. You are responsible for maintaining the accuracy of the information you submit to Encode, such as your contact information. You may access, correct, or request deletion of your Personal Information by making updates to that information or by contacting Encode through your account. If you request to access all Personal Information you’ve submitted, Encode will respond to your request to access within 30 days. If you completely delete all such information, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the App. If you would like Encode to delete your account, you can do so through the App.
  • Encode will use commercially reasonable efforts to honor your request to delete your Personal Information; however, certain information will actively persist on the Encode servers even if you close your account. In addition, your Personal Information may remain in the archives of Encode, and information you update or delete, or information within a closed account, may persist internally or for the administrative purposes of Encode. It is not always possible to completely remove or delete information from the Encode databases. In addition, Encode typically will not remove information you posted publicly. Bear in mind that neither you nor Encode can delete all copies of information that has been previously shared with others.

SECURITY

Encode takes commercially reasonable steps to help protect and secure the information it collects and stores about CodeCash users. All access to the App is encrypted using industry-standard transport layer security technology (TLS). When you enter sensitive information (such as a tax identification number), Encode encrypts the transmission of that information using secure socket layer technology (SSL). Encode also uses HTTP strict transport security to add an additional layer of protection for App users. But remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. Thus, while Encode strives to protect your Personal Information, Encode cannot ensure and does not warrant the security of any information you transmit to Encode.

NO INTERNATIONAL USE

  • The App is not available to users who are not residents of the United States.
  • As the App is not available to users who reside in the European Union and/or Switzerland, Encode is not obligated to comply with the General Data Protection Regulation promulgated by the European Commission.

LINKS TO OTHER SITES

The App may contain links to third-party websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that the App links to a website is not an endorsement, authorization or representation of any affiliation between Encode and that third party, nor is it an endorsement of their privacy or information security policies or practices. Encode does not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Encode encourages you to read the privacy policies or statements of the other websites you visit.

PHISHING

Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to Encode. For more information about phishing, visit the website of the Federal Trade Commission at http://www.consumer.ftc.gov/articles/0003-phishing. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be Encode, please report it to customer support.

CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:

Exercising the Right to Know. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months:

  • the categories and specific pieces of personal information we have collected;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected it;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information about you that we disclosed for a business purpose.
  • Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
  • Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.
  • Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
  • To submit a request to exercise any of the rights described above, you may contact CodeCash either via email to info@codecash.com.
  • Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

CHANGES TO THIS POLICY

Encode may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way Encode treats your Personal Information, Encode will display a notice through the App prior to the change becoming effective. Encode may also notify you of any such change by email, in the sole discretion of Encode.

CONTACT US

If you have any questions about this Privacy Policy, please contact customer support or send your questions by email addressed to: info@codecash.com

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