This Data Privacy Statement applies to the use of the "CashDirect" app (hereinafter referred to as "CashDirect"), provided by DCD Media (hereinafter referred to as "we" or "us") for use on your mobile device. We value your privacy, and this Privacy Policy is designed to explain how we collect, use, process, share, and safeguard your Personal Information collected through our websites, including cd.money (the "Sites"), and the CashDirect applications (collectively, the "Services"). It also informs you about your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns. By using the Services, you agree to the processing of your Personal Information as described in this Privacy Policy. In addition to the Privacy Policy, your use of the Service is subject to our Terms of Service.
For App Users:
Users are allowed to create only one account in the App. Creating multiple accounts or transferring or selling a user account to third parties is prohibited. It is not permissible to use a virtual private network (“VPN”), proxy, or any other means to conceal the true source of traffic when using the Services. Similarly, using any electronic means, such as an internet bot or web robot (“Bot”), to generate automated views, clicks, or conversions, or engaging in any misleading practices, such as repeated manual clicks to artificially inflate user activity and/or revenues while using the Services, is not permitted. Any activity that uses a VPN, proxy, or Bot will be considered fraudulent activity and will be blocked by our fraud prevention system. Using a VPN, proxy, or Bot can lead to your device being permanently blacklisted, and your user account being either suspended or terminated.
This agreement shall remain in effect throughout your use of the Services. You may discontinue your use of the Services at any time by either uninstalling the App from your mobile device or contacting us to close your account. However, CashDirect may terminate or suspend your account at any time without notice, at its sole discretion, if it believes that you have breached this Agreement. Upon termination of this Agreement by CashDirect, you must discontinue your use of the Services. Nevertheless, termination of this Agreement by CashDirect shall not release you from any outstanding payment obligations, if applicable, and shall not preclude CashDirect from pursuing any available remedies, including injunctive relief. You acknowledge that CashDirect may immediately deactivate your account and delete your data and accumulated rewards after termination of your account and/or use of the Services, and that CashDirect shall not be held liable to you or any third party for such termination of your access to the Services or deletion of your data.
CashDirect is entitled to suspend or delete any account without notice if it has been inactive for a continuous period of one hundred and eighty (180) days. An account is deemed inactive if there have been no redeemed or credited Units or new referral sign-ups using the account's referral link. In such cases, any Units or Rewards in the account shall be considered void without notice.
Personal Information You Provide to CashDirect:
If you wish to access certain features on the Earn App and earn points, you may need to become a registered user and provide certain types of Personal Information to CashDirect. This information includes your registration data such as your name, email address, age, gender, and in-app purchase history. Additionally, we may ask for optional information such as your country or city, tastes, preferences, and other survey questions. You may be rewarded for providing this optional information with Earn App points.
In order to prevent fraud, bonuses earned through the use of CashDirect are only possible after additional user verification via a selfie taken with your device's camera when you first request a bonus. By consenting to the processing of your personal data, you are agreeing to the processing of these photos. It is important to note that selfies are considered special-category personal data per Art. 9 para. 1 GDPR, and your express consent is required for processing.
We use your selfies exclusively for the purpose of fraud prevention and to ensure that bonuses have not been earned through the fraudulent use of automated software. Your face will be recorded using your device's camera, and the recording will be used to create an individual and anonymous digital user ID (in the form of a hash value). This user ID is not linked to your account and is used to verify that the bonus has actually been earned by a real person, and that this person has not already requested or received a bonus with another account. For reasons of data economy, this process is only necessary if you want to receive bonuses. If you do not wish to receive bonuses, you may use CashDirect without providing any selfies. Your selfies will not be used for any other purposes.
Personal Information Collected Automatically from Your Use of the Services:
When you use our Services, we and our third-party service providers may collect information from you through automated means, such as cookies, web beacons, and web server logs. By using our Services, you agree to the placement of these technologies on your browser and emails in accordance with this Privacy Policy. This information includes your IP address, data provider, device IDs and characteristics, country code, operating system version, and language preferences. We work with analytics providers, such as Google Analytics, to collect and analyze information about the use of our Services and report on activities and trends.
If you do not want information collected through cookies, most browsers allow you to decline cookies or choose to accept or decline the transfer of a particular cookie (or cookies) from a specific site. Your mobile operating system should also provide the option to manage your cookies and advertising preferences (found in the "settings" function on your device). However, not accepting cookies may result in inconvenience when using our Services.
How We Use Your Personal Information:
We use Personal Information for internal and Service-related purposes, such as operating, providing, and maintaining the Services. For example, we use information collected automatically and from third parties to calculate Earn App Point rewards.
We and our service providers use Personal Information to monitor and analyze the usage of the Services, including your location and activities, to improve and enhance the Services.
We may send push notifications to your device and periodic communications to the email address you provide, if you choose to receive such notifications and communications.
We and our advertising partners may use your Personal Information, including your location and activities on the Services, to facilitate the delivery of advertisements.
How We Share Your Personal Information
We share Personal Information collected in the context of the CashDirect Services with third parties in certain circumstances. This includes sharing Personal Information with our affiliates and subsidiaries, as well as with third-party service providers who perform various services on our behalf, such as website hosting, payment processing, data analysis, information technology and related infrastructure provision, customer service, email delivery, online advertising, auditing, and other services. We do not sell Personal Information and only share it with third-party service providers to operate our Services.
We may share Personal Information with our service providers that provide user support and perform other business operations on our behalf, under our instructions, and in compliance with appropriate technical and organizational security measures to protect your data. For example, we may partner with other companies to provide support services, authentication services, prevent fraud on our Services, surveys, perform analytics, maintain the accuracy of our databases, fulfill your product purchases, and administer your rewards or payments. We do not sell your Personal Information, but we may rent, sell, and share other information that cannot be used to identify you with merchant partners, third parties, or affiliates.
Data Retention & Security
We take measures to delete your Personal Information or keep it in a form that does not allow you to be identified when it is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we consider various factors, such as the type of products and services requested or provided, your ability to claim rewards earned through our services, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and the statute of limitations.
We maintain administrative, technical, and physical safeguards intended to appropriately protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.
European Privacy Rights
If you are located in the European Economic Area or Switzerland, you may have additional privacy rights regarding your Personal Information. These rights include the ability to request access to and receive information about the Personal Information we hold about you, to correct inaccuracies, to restrict or object to the processing of your Personal Information, to have the information deleted or anonymized, and to exercise your right to data portability. You also have the right to withdraw any consent you previously provided to us at any time, free of charge. If you exercise any of these rights, it will not affect the lawfulness of the processing that occurred before your request. Additionally, you may have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where the incident took place.
If you wish to exercise any of these rights, please contact us as described in the "Contact Us" section below. We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity before granting access to your Personal Information. We will make reasonable efforts to respond to your requests within the timeframes required by law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
California Privacy Rights
Those rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as specified below.
As of January 1, 2020, California residents also have the following rights provided to them under the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA): (1) Right to Know About Personal Information Collected. California residents have the right to request that a business disclose to them the Personal Information it collects, uses, discloses, and sells, subject to certain exceptions and limitations. (2) Right to Request Deletion of Personal Information. California residents also have the right to request the deletion of their Personal Information collected or maintained by CashDirect, subject to certain exceptions and limitations. (3) Right to Opt-Out of the Sale of Personal Information. California residents have the right to opt-out of the sale of their Personal Information. Under the CCPA, the “sale” of Personal Information broadly includes any communication of Personal Information to any business that is deemed to be a “third party” (as defined in the CCPA) for monetary or other valuable consideration, subject to certain exceptions and limitations. (4) Authorized Agent. California residents may use an authorized agent to exercise certain privacy-related requests and rights on their behalf. The authorized agent’s exercise or request on your behalf sent by mail shall include a power of attorney or a notarized statement properly signed by you appointing such authorized agent for such purpose. If your authorized agent submits the exercise or request online via the link below, a copy of the power of attorney or the original notarized statement shall be mailed to the following address: CashDirect: 4 Kirkham Drive, Ajax, ON - L1S 5L1, Canada; Attention: Privacy, within five (5) days after submitting such online request, or we may in our discretion otherwise verify the agent’s authority to our reasonable satisfaction. (5) Notice of Financial Incentive. California residents have the right to receive notice of financial incentives provided to them by a business. (6) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. California residents have a right not to receive discriminatory treatment by a business in the event that the California resident exercises one or more of their privacy rights conferred by the CCPA. (7) How to Submit Your Request. CashDirect offers California consumers (or their authorized agent) two (2) ways to submit requests concerning their California privacy rights under the CCPA: (i) by emailing us at [email protected] (Attn: California Privacy Requests); or (b) by mailing your request to the following address: CashDirect: 4 Kirkham Drive, Ajax, ON - L1S 5L1, Canada (Attn: California Privacy Requests). CashDirect will review all properly-submitted requests and respond in a timely manner in accordance with the CCPA and applicable regulations thereunder. As part of this process, and to prevent unauthorized use of your Personal Information, you may be asked to verify your identity so that we can match you to a person in our systems. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question, Service activity and other information; such verification may be conducted by a third-party on our behalf. (8) Publication of CCPA Statistical Data. Starting January 1, 2021, and updated each year thereafter (if and as required by the CCPA), CashDirect will publish a summary of statistical data pertaining to the following categories of California-resident consumer privacy requests: (1) “Requests to Know”, (2) “Requests to Delete”, and (3) “Requests to Opt-Out of Sale.” The statistical data CashDirect will publish will include: (A) the number of requests CashDirect received in each category of California-resident consumer privacy request, (B) the number of such requests that CashDirect complied with in (in whole or in part), (C) the number of such requests which CashDirect denied, and (D) the median number of days within which such requests were responded to.
Use of Services By Children
Children under the age of thirteen (13) are not the intended audience for our Services, and we kindly ask that they refrain from providing any personal information through the Services. We do not knowingly collect, maintain, or utilize Personal Information (as defined in the Federal Trade Commission's Children's Online Privacy Protection Act Rule) from children under the age of thirteen (13). For users located in the European Economic Area or Switzerland, we do not knowingly collect, maintain, or use Personal Information from children under the minimum age required by each country within the European Economic Area. If a parent or guardian becomes aware that their child has provided us with Personal Information, they should immediately contact us at [email protected], and we will promptly delete the information.
International Cross-Border Data Transfer
CashDirect is product of DCD Media, based in Canada. If you are accessing the Services from Europe or other regions that have data collection and use laws, please note that your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. By providing your Personal Information to the Services, you consent to any transfer of your Personal Information to the United States and other countries in accordance with this Privacy Policy. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Policy.
Updates To This Privacy Policy
We reserve the right to modify or amend this Privacy Policy at any time, so please review it frequently. Any changes to this Privacy Policy will be posted on this page, and we will indicate at the top of the page the date the Privacy Policy was last updated. If we make any material changes to this Privacy Policy, we will provide notice on the Services or by other means as appropriate. Your continued use of the Services following any changes to this Privacy Policy constitutes your acceptance of such changes.
Contact Us
If you have any questions or concerns regarding these Terms or your use of any DCD Media Sites and Features or our Services, please contact us by using the "Contact Us" feature or by mail to: DCD Media | 4 KIRKHAM DRIVE, AJAX, ONTARIO, L1S 5L1, CANADA
Contact Us
If you have any questions or concerns regarding these Terms or your use of any DCD Media Sites and Features or our Services, please contact us by using the "Contact Us" feature or by mail to:
DCD Media | 4 Kirkham Drive, Ajax, ON L1S 5L1, Canada
