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Privacy & Terms

Last Updated: 07/06/2018

iCash Ltd. (“iCash,” “we,” “our,” or “us”) values the privacy of individuals who use our website, platform, and related services (collectively, our “Services”). This Privacy Policy explains how we collect, use, share, and safeguard information from iCash users (“you" or "your") to facilitate our Services, including our iCash Token Sale platform, which allows you to purchase iCash tokens. This Privacy Policy also explains how we process Personal Information in the context of our customer, vendor and partner relationships. This Privacy Policy tells 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.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that information is necessary to provide you with the Services or if we are legally required to collect it. For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below.

By agreeing to this Privacy Policy during your account setup or by using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, the use of our Services is also subject to our Terms & Conditions. Please read this Privacy Policy carefully. If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at support@iCash.io.

 

Information We Collect

Information You Provide to Us.

Registration Information. If you register for iCash Token Sale, we ask you to provide your email address, password, and information necessary to verify your identity or otherwise required by applicable law. This information may include identity verification information such as your full name, address, phone number, and date of birth, a copy of your government-issued identification  (e.g., passport, driver’s license, or identity card), and investor accreditation information , to the extent permitted under applicable law.

Purchase Information. If you make a purchase through iCash Token Sale, we require that you provide certain financial information to facilitate the transaction. In addition, if you choose to make a Token Sale purchase as an entity, we ask for information such as the entity’s name, your position at the entity, and the date of purchase.

User Content. Our Services contain publicly accessible blog posts. If you choose to comment on our blog posts, we ask for your name and email address. Please be aware that your name, email address, and the content you post will always be visible to other iCash users. We are not responsible for other users’ use of such information, so you should carefully consider whether and what to post or how you identify yourself on our Services.

Communications. If you contact us directly, we may receive additional information about you. For example, when you email our Customer Support Team or sign up to receive updates regarding new products and/or services, we will receive your email address, the contents of your message, and any attachments that you may send to us.

 

Information We Collect When You Use Our Services.

When you use our Services, we may collect information from you through automated means such as cookies, web beacons, pixel tags, and web server logs. By using our Services, you consent to the placement of cookies, beacons, and similar technologies in your browser and on emails in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the use of our Services.

We may use this information, for example, to ensure that our Services function properly, to determine how many users have provided comments, or to prevent fraud. We also may use such technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message.   

We also work with analytics providers; such as HubSpot and Google Analytics; that use cookies and similar technologies to collect and analyze information about your use of our Services and report on activities and trends. These analytics service providers may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different websites and services. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available a https://tools.google.com/dlpage/gaoptout.

If you do not want information collected through the use of cookies, there is an option in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer of a particular cookie (or cookies) from a particular site to your computer. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html to learn more about how to manage cookies stored on your computer. If, however, you do not accept cookies, you may experience some inconvenience in using our Services.

 

Information from Other Sources.

You may direct us to retrieve information maintained online by institutions with which you have a pre-existing relationship. We work with one or more online service providers to access this information.

We may also process Personal Information about employees of our customers, vendors and partners (i.e., names and professional contact information) that those customers, vendors and partners provide to us in the context of our contractual relationships with them. 

 

How We Use the Information We Collect

We use the Personal Information we collect for a number of reasons, including:

  • To provide and maintain our Services, including Token Sale, which allows you to purchase iCash tokens;
  • To comply with our legal obligations, including by verifying your identity;
  • To understand and analyze how you use our Services;
  • To improve and enhance our Services and develop new products, services, features, and functionality;
  • To communicate with you, to provide you with updates and other information relating to our Services, to provide information that you request, to respond to comments and questions, and otherwise provide customer support;
  • To the extent permitted by applicable law, for marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
  • To send you text messages (including for two-factor authentication) and push notifications;
  • To anonymize your Personal Information;
  • To facilitate transactions and payments;
  • To respond to trust and safety issues that may arise;
  • To find and prevent fraud; and
  • For compliance purposes, including enforcing our Terms & Conditions, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental authority.

 

When We May Use Your Information

If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

  • You have consented to the use of your Personal Information, for example, to receive electronic marketing communications or provide you with tailored advertising;
  • We need your Personal Information to provide you with the Services, including for account registration or to respond to your inquiries;
  • We have a legal obligation to use your Personal Information, such as the obligation to protect IP rights and restrict content available on the Services based on your location;
  • We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to conduct business analytics, and otherwise improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

    We, or a third party verification provider , may perform automated ID checks which may lead to an automated refusal of access to our Services. However, we will not subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, unless you explicitly consented to the processing, the processing is necessary for entering into, or performance of a contract between you and iCash, or when we are legally authorized to use your Personal Information in this way, for example to prevent fraud.

 

How We Share the Information We Collect

Internal Disclosures. We may share Personal Information with our headquarters, affiliates and subsidiaries. Personal Information will only be available to those who need such access for the purposes listed above or where required by applicable law.

Vendors and Service Providers. We work with third party service providers that perform services on our behalf, and we may share your Personal Information with such providers retained in the provision of our Services, including all of the information described in the “Information We Collect” Section above. For example, we work with Token Soft to deliver our iCash Token Sale platform, and payment processors to process financial transactions. In addition, we use third party analytics vendors, such as HubSpot and Google Analytics, to evaluate and provide us with information about your use of our Services.

As Required By Law and Similar Disclosures. We and our vendors and services providers may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; (c) find and prevent fraud; and (d) protect your, our or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation, receivership, sale of our assets, or transition of our Services to another provider, then your Personal Information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Aggregate Data. Where legally permissible, we may share information about you with our partners in aggregated or de-identified form,

Consent. We may also disclose your Personal Information with your permission.

 

Your Choices and Rights

You can view and edit your account information, including your email address and password, at any time by visiting “Account Information” in your iCash Token Sale profile settings. You can unsubscribe from our commercial emails via the link provided in these emails. Even if you opt-out of receiving such emails from us, you may continue to receive service related messages from us. Note, there is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals at this time.

 If you are located in the European Economic Area ("EEA") or Switzerland, you may have the following additional rights: 

  • Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. If we subject you to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, you may have a right to obtain human intervention, to express your point of view and to contest the decision.

  • You may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

  • Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us at the contact information provided below.

 

Third Party Services

We may display third party content on our Services. Third party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of and/or interacting with the third-party content on our Services. The Services may also contain links to web sites and services provided by third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which our Services link. The inclusion of a link on our Services does not imply endorsement of the linked site or service by us or by our affiliates.

 

Security

We are committed to protecting your Personal Information. Even though we use certain safeguards that are designed to ensure the integrity and security of Personal Information that we collect and maintain, please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our safeguards. The foregoing may be subject to requirements under applicable law to ensure information security.

 

Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information 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 take into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

 

Children’s Privacy

Children under the age of 16 are prohibited from using our Services. They may not register or create accounts through our Services, or otherwise provide us with personal information. iCash does not knowingly collect information from children under the age of 13. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you may alert us at support@iCash.io.

 

International Visitors

 Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use our Services from the EEA, Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. Also, we may transfer your Personal Information from the U.S. to other countries or regions in connection with storing and processing Personal Information, fulfilling your requests, and operating our Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

When we transfer Personal Information outside of the EEA or Switzerland, we comply with applicable EU data protection laws. We may transfer your Personal Information to countries which provide an adequate level of protection under EU data protection laws, or we may use contractual protections for the transfer of Personal Information, such as the European Commission’s Standard Contractual Clauses.  We may also rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable.  You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area. 

 

Changes to this Privacy Policy

 We may make changes to this Privacy Policy. The "Last Updated" date at the top of this page indicates when this Privacy Policy was last revised. We encourage you to read this Privacy Policy periodically to stay up-to-date on our privacy practices. Your use of our Services following these changes means that you accept the revised Privacy Policy. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

 

Contact Us

iCash Ltd. Is the entity responsible for the processing of your Personal Information as described in this Privacy Policy. Please contact us with any questions about privacy on our Services, this Privacy Policy, or information we have about you, by email at support@iCash.io.

 

iCash Ltd.

Clarendon House

2 Church Street

Hamilton HM 11 Bermuda