Privacy Policy – Cash4sms App

Preamble

This Privacy Policy governs the privacy of users (“User”, “You”, “Your”) of the website (“Website”) provided by SILK ROAD SIGNAL LLC (“Company”, “We”, “Us”, “Our”) and applies to any personal data (“Data”) collected, used, processed and stored by us or provided by you in connection with your use of this Website and our Services (“Services”) and explains your rights in this regard.

We respect your privacy, protect it and take it very seriously in accordance with applicable laws and regulations. Please read this Privacy Policy carefully.

By accessing and using this Website and our Services, you accept and agree to this Policy by abiding by the provisions set forth herein.

It is also the User’s responsibility to read any modified or updated version of our Privacy Policy posted on our Website. The provisions of updated versions will apply from the date of posting unless otherwise stated.

Controller

In order to comply with applicable data protection legislation, including the General Data Protection Regulation and any implementing legislation, we act as the Data Controller responsible for collecting and processing your personal data. Our company has appointed a Data Protection Officer who can be contacted at the contact details provided in the Contact Us section of this Policy.

This Policy is incorporated into our Terms of Use and applies to data collected by us as a result of your use of information, software, products and services provided through our Website.

What data is collected and when it is collected

We collect data provided to us by you when you specifically choose to do so, data collected automatically and data resulting from contracts entered into.

We may collect the following data in the following instances:

  • Identity Data (name, username or similar identifier) and Contact Data (payment/billing address, shipping address, address, phone numbers) when you contact us via the Website, email, phone, mail or other means; when you register, fill out contact forms, sign up for newsletters;
  • Financial data (payment card details, bank details, activity log, payment methods, etc.) when you use our services;
  • Technical data (IP address, login, web browser type and version, time zone, location, operating system, data from your devices when using Android and/or IOS mobile applications and other technologies on the devices you use to access our Website, the website address from which you linked to our Website) when you connect to our Website;
  • Usage data (the date of your visit, the time and frequency of your visit to our Website, preferences, interests, favorites and other characteristics of your use of our Website) when you connect to our Website.

We do not knowingly collect personal information from children. If you are under 18 years of age, please do not use our Website. If you register an account with us and provide personal data to someone under the age of 18, please notify us at the contact information provided in the “Contact Us” section of this Policy and we will delete that data and cancel that person’s account.

We do not collect data from third parties unless we are a party to the data processing (e.g. as a service provider, through agent(s), partners, etc.).

You confirm that you are only providing us with true and correct information.

Please note that if you directly disclose your personal information, including sensitive financial data through public features, this information may be collected and used by others.

Data storage security

We process personal data, including sensitive data where provided and applicable, in strict confidence and in accordance with industry standards and internal security policies.

Our employees responsible for the security of your data are specially trained and are required by law to maintain the confidentiality of the information to which they have access. Such employees will process your personal data confidentially and strictly in accordance with our instructions.

Our company adheres to relevant telecommunications and IT industry standards and applicable laws.

We will ensure the security of your data by using technical and organizational measures to protect your data (e.g. access to your user account is controlled by a password and unique username; data is stored on secure servers, etc.).

We have implemented appropriate security measures for your personal data to protect our users’ data from accidental loss, unauthorized access, use, destruction, alteration, disclosure; manage risks from third parties through the use of contracts and security checks; ensure business continuity and disaster recovery; and train our staff on data security and other organizational measures.

Our technical measures include measures to deal with suspected data breaches, where applicable, with appropriate notifications to our users and/or competent authorities.

You may need or be required to provide certain information, including passwords, in order to use the features of our Website. You are responsible for the security and confidentiality of your passwords and similar security information.

We adhere to all security measures, but any downloadable documents, software or media files obtained through our Website are provided to you at your own risk.

While we strive to do our best to protect your data, please note that information provided over the Internet is not absolutely secure and therefore is done at your own risk and discretion if it is beyond our reasonable control. Please notify us immediately of unauthorized access to your account or any other breach of security using the contact information provided in the Contact Us section of this Policy.

Data storage

Unless a longer retention period is required or permitted by law, we will retain your data on the systems for the period necessary to fulfill the purposes set out in this Privacy Policy or until you request us to delete/erase your data. However, please note that even if your data is deleted/erased, it may be retained on backup or archival media for legal, tax or regulatory purposes. Please also note that the deletion/erasure will be completed without undue delay, however there may be some delay in removing your data from our servers and backup storage.

Legal grounds for data processing

The legal basis for us to process your personal data is based on the following grounds:

    • Consent: where you explicitly agree to us processing your personal data for a specific purpose (e.g. accepting cookies, registering for an account, receiving newsletters and notifications, advertising and marketing, completing transactions, etc.).
    • Contract: when processing is necessary to fulfill contractual obligations.
    • Legitimate interests: this ground may be used by us for fraud prevention purposes, for marketing purposes, for commercial interests, etc.
    • Legal obligation: when processing is necessary to fulfill legal or statutory obligations that are not contractual obligations.

Purpose of data use and processing

The data is processed within the legal bases mentioned above and for the purpose of identifying/verifying our customers, providing our services, customizing the content of our Website according to your interests and our services, etc.

Once you have registered an account on our Website, your data will also be processed for the purpose of notifications (of possible changes to the services we provide to you, to the contract, to the terms of use and our policies and procedures, etc.).

We may and/or will also use and process your data for promotional mailings and direct marketing notices after you have given us your consent by ticking the checkbox to acknowledge receipt of promotional and marketing notices. When your data is processed for this purpose, you have the right to object to such processing, both initially and subsequently, at any time and free of charge. To exercise the right to object to the processing of data for advertising and marketing purposes, including both initial and subsequent processing, the user may notify us using the contact details provided in the “Contact Us” section. You can then object to the processing of data for advertising and marketing purposes by clicking “unsubscribe” in the notification.

We also process your data for information security purposes to prevent unauthorized access to your data.

We may use your personal data, including but not limited to, for the following purposes:

  • to identify/verify your data for the purpose of managing our customer relationships and complying (if applicable) with Know Your Customer (KYC) rules;
  • to comply with legal and regulatory obligations with respect to any illegal or criminal activity;
  • to ensure the safety and security of our Website;
  • for the proper operation of our Website and the provision of our services;
  • to analyze the use of our Website for general statistical purposes;
  • to send you a welcome letter after you have completed registration procedures and updates to our services;
  • to maintain the accuracy of our records, etc.

Data processing based on your consent may cease if you withdraw your consent. You may withdraw your consent at any time by notifying us using the contact details provided in the Contact Us section of this Policy.

You can also subscribe or unsubscribe from our newsletters by contacting us at our contact details or via the details provided in this post.

We also use information collected through cookies to improve your use of our Website.

Use of Socie files

We will use cookies and tracking technologies to store and manage our users’ preferences on our Website and analyze user data and usage data. Our Cookie Policy provides information about what types of cookies and technologies we use, why we use them and how you can manage them.

You can set your browser to refuse all or part of cookies. If you refuse or disable cookies, some features or information on our Website may not work properly.

User rights

You have the following rights in relation to your data (“data subject rights”) and may request the exercise of any of your rights below:

(i) right of access – the right to request copies of the information we hold about you at any time and the right to request that we change, update and/or delete such information; in which case we will not charge you for providing you with access to your personal data and will not refuse your request, provided that your requests are reasonable and justified;
(ii) right of rectification – the right to have your data corrected if it is inaccurate or incomplete;
(iii) right to erasure – the right to request that your data be deleted or removed from our systems;
(iv) right to restriction – the right to restrict our use of your data;
(v) right to object – the right to object to our use of your data, even for legitimate interests (please read the ‘Purpose of data use and processing’ section above carefully to find out how to proceed);
(vi) the right to data portability – the right to request that your data be moved, copied or transferred;
(vii) Withdrawal of consent – if the processing of your data is based on your consent, you can withdraw that consent to the processing of your data;
(viii) right to complain – if you are unhappy with the way we process your data, you can make a complaint using the contact details provided in the Contact Us section of this Policy.

Please note that your rights may be limited in certain circumstances (e.g., if the fulfillment of your request may disclose another person’s personal data, or if we are asked to delete data that we are required by law to retain).

It is important that the data we hold about you is accurate, up to date, true and genuine. Please notify us of any changes your personal data, if any and applicable, while we are storing it.

Third parties and links to other websites

Our company may transfer and disclose your data to third parties or countries. Our company may transfer or disclose your personal data to third parties or countries in accordance with the grounds established by applicable law.

We may and/or will also share your data with third parties or countries for promotional mailings and direct marketing notices after have given us your consent by ticking the checkbox to acknowledge receipt of promotional and marketing notices.

Please note that your details may be required where appropriate:

  • to provide our services or comply with the law;
  • in the event of a change in ownership and control of the business;
  • our subsidiaries or affiliates, if applicable;
  • contractors, agents, partners, etc.

If data is transferred to third parties, including other countries, we will apply all internet security measures required by industry standards, technologies, data protection measures, relevant software, applicable laws of the country where the data is located. In any case, we will ensure an appropriate level of protection for your data (e.g. contractual terms, data transfer agreements, etc.), if applicable.

This Privacy Policy applies only to interactions between us and our users with respect to our Website and services and does not apply to other websites or links, including but not limited to social media sites accessible from our Website where such links may be provided from time to time (to other websites, applications, plug-ins). We have no control over such third party websites and are not responsible for their content. When clicking on these links and leaving our Website, please read the privacy notice of each third-party website you visit.

Where applicable, we are not responsible for third-party downloads and uploads provided by external third-party websites.

Changes in business ownership and control

Our company may expand or reduce our business and this may include the sale or transfer of all or part of our company. Data provided by users will be transferred along with the business or part of the service if it is related to the business being transferred.

Contacts

You may notify us of any changes to your personal data and we will act on your requests and our obligations under data protection laws as set out above in this Policy. If you have any questions about this Privacy Policy or about the Company and our services, please contact us at:

Email support: support@cash4sms.today
Mailing address: Sarmen 1st Street, 2/1, Kentron, 0009 Yerevan, Armenia.

Android Application Privacy Policy

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