Effective Date: 2026-01-20

1. Introduction

Welcome to PassCash Investing LLC (“PassCash”, “we”, “us”, or “our”).

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access or use our website, applications, digital wallet services, physical or virtual debit cards, and related financial products and services (collectively, the “Services”).

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

A. Personal Information You Provide

We may collect the following information when you create or use a PassCash account:

• Full name
• Email address
• Phone number
• Residential address
• Date of birth
• Government-issued identification and verification data (for identity verification and compliance purposes)

B. Financial and Transaction Information

We may collect:

Wallet balances and transaction history

Debit card usage and merchant information

Funding, withdrawals, and transfer activity

Agent, referral, or program participation details

C. Technical and Usage Information

We may collect:

• Internet Protocol (IP) address
• Device identifiers
• Browser type and operating system
• Log files and diagnostic information
• Cookies and similar tracking technologies

D. Location Information

We may collect approximate location information such as country or city to support fraud prevention, regulatory compliance, and service availability. Location permissions may be managed through your device settings.

3. How We Use Your Information

We use your information to:

• Provide, operate, and maintain our Services
• Verify identity and prevent fraud
• Process transactions and debit card services
• Comply with legal and regulatory obligations, including AML and KYC requirements
• Communicate important account and service-related notices
• Improve security, functionality, and performance
• Provide customer support and respond to inquiries

4. Legal Basis for Processing

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

• Your consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests, including fraud prevention and security

5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our Services, enhance security, and understand usage patterns. You may adjust your browser settings to refuse cookies; however, some features of the Services may not function properly.

6. Data Sharing and Disclosure

We may share your information with:

• Payment processors, card networks, and financial partners
• Identity verification and fraud prevention service providers
• Cloud hosting, analytics, and infrastructure providers
• Regulatory authorities, law enforcement, or courts when required by law
• We do not sell your personal information.

7. International Data Transfers

Your information may be processed and stored in the United States or other jurisdictions where data protection laws may differ from those in your country. We implement reasonable safeguards to protect your personal data during such transfers.

8. Data Retention

We retain personal data only for as long as necessary to provide our Services, meet legal and regulatory requirements, resolve disputes, and enforce our agreements.

9. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect your personal data. However, no method of transmission over the internet or electronic storage is completely secure.

10. Your Privacy Rights

Depending on your location, you may have rights to:

Access your personal data

• Correct inaccurate or incomplete information
• Request deletion of personal data, subject to legal requirements
• Object to or restrict certain processing activities

Requests may be submitted by contacting us at support@passcash.org.

11. Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted with a revised effective date. Continued use of our Services constitutes acceptance of the updated policy.

13. Contact Us

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Email: support@passcash.org
Website: www.passcash.org