ClubCash Privacy Policy (Draft for Legal Review)

Important: This is a commercial draft for review by qualified legal counsel before publication. It is not legal advice.

1. Introduction

ClubCash is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain and protect your personal information when you use the ClubCash mobile application, website and related services.

2. Data Controller

The applicable ClubCash operating entity identified in the application or on the official website is the controller of your personal information unless otherwise stated.

3. Information We Collect

We may collect:

  • Identity information (name, date of birth, government ID where required)
  • Contact information (email, telephone number)
  • Account credentials
  • Device information (IP address, operating system, app version)
  • Payment and transaction information
  • Wallet addresses and blockchain transaction references where applicable
  • Club membership information
  • Merchant payment history
  • Customer support communications
  • Marketing preferences

4. How We Collect Information

We collect information directly from you, automatically through your device, from payment providers, identity verification providers, merchants, clubs, and where legally permitted, from fraud prevention and sanctions screening services.

5. How We Use Your Information

Your information may be used to:

  • Create and manage your account
  • Provide custodial wallet services
  • Process EURC and other supported transactions
  • Verify your identity (KYC)
  • Prevent fraud, money laundering and financial crime
  • Comply with legal obligations
  • Improve our services
  • Respond to customer support requests
  • Send important service notifications

6. Legal Bases for Processing

Depending on your jurisdiction, we process personal information because it is necessary to perform our contract with you, comply with legal obligations, pursue legitimate business interests, or based on your consent where required.

7. Sharing Information

We may share information with regulated payment providers, banking partners, blockchain infrastructure providers, identity verification providers, fraud prevention services, cloud hosting providers, regulators, law enforcement where required by law, and professional advisers under confidentiality obligations.

8. International Transfers

Your information may be processed in countries outside your own. Where required, ClubCash will implement appropriate safeguards such as Standard Contractual Clauses or equivalent legal mechanisms.

9. Data Retention

We retain information only for as long as necessary to provide the Services, satisfy legal and regulatory obligations, resolve disputes and enforce agreements.

10. Security

ClubCash uses commercially reasonable administrative, technical and organisational measures to protect personal information. No system can be guaranteed completely secure.

11. Cookies and Analytics

The website and application may use cookies, analytics technologies and similar tools to improve functionality, measure performance and detect fraud. A separate Cookie Policy may apply.

12. Your Rights

Where applicable you may have rights to:

  • Access your information
  • Correct inaccurate information
  • Request deletion
  • Restrict processing
  • Object to processing
  • Data portability
  • Withdraw consent where processing is based on consent
  • Lodge a complaint with your supervisory authority

13. Children’s Privacy

ClubCash is not intended for children. We do not knowingly collect personal information from anyone below the minimum permitted age.

14. Marketing

You may opt out of promotional communications at any time. Service-related communications may still be sent where necessary.

15. Blockchain Data

Transactions recorded on public blockchains may be publicly visible and cannot generally be altered or deleted. ClubCash cannot erase information recorded on public blockchain networks.

16. Apple App Store

If you download the ClubCash application through the Apple App Store, Apple may independently collect information in accordance with Apple’s own privacy practices. This Privacy Policy applies only to information processed by ClubCash.

17. Google Play

If you download the application through Google Play, Google may independently process information under its own privacy policies.

18. Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be communicated where required by law.

19. Contact

Questions, privacy requests and complaints should be submitted using the contact details published on the official ClubCash website.