Privacy

Effective Date: January 20, 2026

1. Introduction

PassCash Investing LLC ("PassCash," "we," "our," or "us") respects your privacy and is committed to protecting the personal information you entrust to us.

This Privacy Policy explains how we collect, use, disclose, store, and protect your information when you access or use our website, mobile applications, digital wallet, payment services, virtual and physical debit cards, and any other products or services we make available (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect
Personal Information

When you register for an account or use our Services, we may collect information including:

1. Full name
2. Email address
3. Mobile phone number
4. Residential or mailing address
5. Date of birth
6. Government-issued identification
7. Selfies or biometric verification data where required for identity verification

Any additional information required to comply with applicable Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations

Financial Information

To provide our financial services, we may collect:

1. Wallet balances
2. Transaction history
3. Funding and withdrawal activity
4. Payment and transfer records
5. Debit card transactions
6. Merchant information
7. Referral, rewards, or affiliate program activity

Technical Information

When you access our Services, we may automatically collect:

1. IP address
2. Device identifiers
3. Browser type and version
4. Operating system
5. Device and application logs
6. Session information
7. Cookies and similar tracking technologies

Location Information

We may collect approximate location information, including your country or city, to:

1. Prevent fraud
2. Meet regulatory requirements
3. Determine service availability
4. Improve security

Location permissions can be managed through your device settings.

3. How We Use Your Information

We use your information to:

1. Create and manage your account
2. Provide and maintain our Services
3. Verify your identity
4. Prevent fraud, unauthorized access, and financial crime
5. Process payments, transfers, and card transactions
6. Comply with legal, regulatory, and compliance obligations
7. Respond to customer support requests
8. Send important account, security, and service notifications
9. Improve the performance, reliability, and security of our Services
10. Conduct analytics and develop new products and features

We do not use your personal information for purposes inconsistent with this Privacy Policy.

4. Legal Basis for Processing

Where applicable, we process personal information based on one or more of the following legal grounds:

1. Your consent
2. Performance of a contract with you
3. Compliance with applicable laws and regulations
4. Our legitimate business interests, including fraud prevention, security, risk management, and service improvement

5. Cookies and Similar Technologies

We use cookies and similar technologies to:

1. Authenticate users
2. Maintain secure sessions
3. Remember preferences
4. Analyze website usage
5. Improve the functionality of our Services

You may disable cookies through your browser settings; however, doing so may affect certain features of the Services.

6. How We Share Information

We may disclose your information to trusted third parties only where necessary to operate our Services, including:

1. Payment processors
2. Banking partners
3. Card issuers and payment networks
4. Identity verification providers
5. Fraud detection and compliance service providers
6. Cloud hosting and infrastructure providers
7. Professional advisers and auditors
8. Government agencies, regulators, law enforcement authorities, or courts when required by applicable law

We do not sell your personal information.

7. International Data Transfers

Your information may be processed or stored in countries outside your country of residence, including the United States and other jurisdictions where our service providers operate.

Where required, we implement appropriate safeguards designed to protect personal information during international transfers.

8. Data Retention

We retain personal information only for as long as necessary to:

1. Provide our Services
2. Meet legal and regulatory obligations
3. Resolve disputes
4. Detect and prevent fraud
5. Enforce our agreements and policies

Retention periods may vary depending on applicable legal and compliance requirements.

9. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction.

While we take reasonable measures to secure your information, no system or method of electronic transmission can be guaranteed to be completely secure.

10. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

1. Access your personal information
2. Request correction of inaccurate information
3. Request deletion of personal information, where permitted by law
4. Object to or restrict certain processing activities
5. Withdraw consent where processing is based on consent
6. Request a copy of your personal information in a portable format, where applicable

To exercise any of these rights, please contact us using the information below.

11. Children's Privacy

Our Services are intended only for individuals who are at least 18 years of age.

We do not knowingly collect personal information from anyone under the age of 18. If we become aware that personal information has been collected from a minor, we will take reasonable steps to delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, legal obligations, or business practices.

Any revisions will become effective upon publication of the updated Privacy Policy. Your continued use of the Services after changes are posted constitutes your acceptance of the revised Privacy Policy.

13. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

PassCash Investing LLC

Email: support@passcash.org

Website: www.passcash.org