At Cashtalk, SA. (“Cashtalk”, “we, us”) we consider the privacy and the security of personal data to be extremely important.
We process personal data for (1) our own purposes and (2) under instructions of our customers who use Manychat service (“Service”), upload and keep certain information in it. In the second case, we strictly adhere to customers’ instructions and do not use data for any other purposes than providing the Service.
In this Privacy Policy, we describe how we process the personal data of the following data subjects for our own purposes:
- Our customers, their end users and representatives
- Website users
- Newsletter subscribers
- Potential customers
- Our counterparties and their representatives
It covers information collected in the Service, on our website https://cashtalk.sadaargroup.com/, or other websites administered by Cashtalk where Privacy Policy is placed (the “Site”), in our Mobile apps and in other sources.
If you have any questions or suggestions concerning our privacy practices, please email us at privacy@Cashtalk.com. Please also send us an email if you would like to request data access or deletion, or to exercise other rights as a data subject.
How We Collect Personal Data
What personal data we collect depends largely on the interaction that takes place between you and Cashtalk, most of which can be categorized under the following:
- When you use Cashtalk Service: We store all the content you provide, including information related to you as a customer or an end user of the Service. We gather this information from you directly when you enter it, or from integrations that you linked to the Service (Facebook, Instagram, etc.). When you ask us to sign DPA or other documents, we also receive data about you and your representatives. In some cases, we can receive information from third parties, e.g. from a payment service provider on whether your payment was successful.
- When you send us emails or message us: We can store the content of such emails, attachments as well as your contact details.
- When you submit forms on the Site or participate in our events: We collect your contact details and information you complete in the form.
- When you use the Site: We collect certain information that may, alone or in combination with other information, constitute personal data (e.g. cookie files).
- When you join our communities: We can see data in your profile and process comments you posted in our groups. However, we don’t gather that information or copy it into our systems, but rather just have access to it.
What Types of Personal Data We Process
We collect and process the following personal data:
- Customer account details: To create or update your account and provide the Service we collect from you and third-party integrations (e.g. Facebook, Instagram) information about you, as a customer or end-user of the Service. This includes id, name, email, status, linked pages and accounts, products in use, location, etc.
- Financial information: To process your payments for the Service subscription, we need your credit card details (last four digits of the card number), account details and payment information.
- Contact details and business data: We receive information about our customers and potential customers for cooperation and communication purposes. This includes full name, title, company, email or other contact details as may be necessary.
- Requests, messages and submitted forms details: We receive and process your messages, support requests, emails and information you share with us via online forms or social media accounts. This includes the content of such communications as well as your contact details if any.
- Usage data, logs and other technical data: When you interact with the Service, metadata and log files are collected automatically. Log data may include the Internet Protocol (IP) address, your browser type and settings, the date and time you used the Service, information about browser configuration plugins, language preferences, the pages or features which you browsed, time spent on those pages or features, the frequency of pages and functions use, the links clicked on or used. If you use the Service from your phone, this may also include the type of device, operating system, device settings and device identifiers.
- Email performance data: To track engagement and performance metrics of our newsletters, we can use a ‘clear image’ (gif) in email communications. Much of this data is aggregated. If you wish to turn off this tracking, you can do so by turning off images in the email itself.
- Website cookies and similar technologies: We use cookie technology on the Site.
- Customer Content: As you use our Service, you may import into our system personal data you have collected from your users, customers, prospective customers, social media and messaging platform contacts (collectively “Subscribers”) or other individuals. We process this data only on your behalf as our customer. We have no direct relationship with your Subscribers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission and legal basis for us to collect and process information about those individuals. We ask that you not send or disclose to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise.
For Which Purposes We Use Personal Data
We collect and process your personal data for the following purposes:
- To operate the Service: We use data to enter into the agreement with you as a customer and operate, maintain and administer your account in the Service, as well as to communicate with you regarding the account (sending announcements, technical notices, updates, security alerts, and support and administrative messages) and to respond to Service-related requests, questions and feedback. We also use your data to perform our billing obligations. To provide the Service we process Customer Content information on your behalf as a customer.
- To communicate with you and inform you about the Service: If you request information from us, register for the Service, complete a form or feedback on a Site, or participate in our surveys, promotions or events, we may send you Cashtalk-related marketing communications if permitted by law. In all such communications, we will provide you with the possibility to opt-out.
- To conduct events and communicate with you: We use your personal data, which you provided while registering for the event, to send you reminders about the event, communications related to the event and Cashtalk-related services. As well, we may ask for your feedback. In communications, we always provide the possibility to opt-out from communications.
- To comply with law: We use your personal data as necessary to comply with applicable laws, including sanction requirements, accounting and tax obligations, legal processes or audits, to respond to subpoenas or legally binding requests from government authorities. Before disclosing any information to an authority upon its request, we check the validity of such request carefully.
- To negotiate, enter and perform agreements: We have to collect and process information about our counterparties and their representatives to negotiate and enter into legally valid agreements and cooperate with them.
- For compliance and safety: We use your personal data as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share Personal Data
We do not sell your data to third parties for commercial or advertising purposes. We share your data as described in this Privacy Policy or upon obtaining your consent for such data sharing.
Your Data Protection Rights & Choices
You have the following rights:
- If you wish to access your personal data that Cashtalk collects, you can do so at any time by contacting us.
- You can also contact us to update, correct or delete information in your account.
- If you are in the European Economic Area (“EEA”), the UK, or Switzerland, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data where it is technically possible.
- Similarly, if you are in the EEA, the UK, or Switzerland, and provided we have collected and processed your personal data under your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on other lawful processing grounds.
- You have the right to complain to a data protection authority about our collection and use of your personal data. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the U.S. and Canada) are available here.
You may submit your request by sending an email to privacy@Cashtalk.com.
Access to Data Controlled by our Customers: We don’t have any direct relationships with customers’ Subscribers, i.e. the individuals whose personal data is stored by our customers the Service. An individual who seeks access, or who seeks to correct, amend, or delete personal data processed in the Service by our customers should direct their request to the customer directly.
For How Long We Retain Personal Data
We will retain and process personal data until you terminate the Agreement with us as set forth under the Terms of Service. We may also store some data during a retention period required by law or timeframe necessary to resolve disputes, prevent abuse, and enforce our agreements.
International Data Transfers
Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, including in the U.S.
By accepting the terms of this Privacy Policy, you acknowledge and agree to (1) the transfer to and processing of personal data on servers located outside of the country where you reside and (2) our collection and use of your personal data as described herein and in accordance with the data protection laws of the countries in which we have facilities or in which we engage service providers, which may be different and may be less protective than those in your country.
EU-US Data Privacy Framework program, the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework
In compliance with the EU-U.S. DPF, the Swiss-U.S. DPF, and the UK Extension, Cashtalk commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the Swiss-U.S. DPF and the UK Extension to ICDR-AAA DPF IRM Service, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. AAA services are provided at no cost to you.
To learn more about the Data Privacy Framework (DPF) program and to view our certification, please visit https://www.dataprivacyframework.gov/. We are committed to subjecting all personal data received from the EU EEA, UK, and Switzerland to the applicable Principles of the Data Privacy Frameworks, including with respect to onward transfers of personal data for which we will remain liable.
In compliance with the Data Privacy Framework, we also commit to resolve complaints about our collection or use of your personal data, and individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact us at privacy@Cashtalk.com. If you do not receive timely acknowledgment from us of your complaint or if we have not resolved your complaint, please contact or visit the applicable data protection authorities for more information or to file a complaint. These services are provided at no cost to you.
Cashtalk commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
Children’s Information
We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to observe, participate in, and/or monitor, and guide their online activity. The Site and/or the Service are not intended for use by anyone under the age of 18, nor does Cashtalk knowingly collect or solicit personal data from anyone under the age of 18.
If you are under 18, you may not attempt to register for the Service or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we confirm that we have collected personal data from someone under the age of 18 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 18 and believe that we might have any information from or about such a child, please contact us. We do not sell any Personal Data of our customers, including those aged between 13 and 18.
Security
Safeguarding Your Information
We take reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.
Despite these efforts to store personal data collected on and through the Site and/or the Service and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage in our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.
The credit card processing vendor we work with uses security measures to protect your information both during the transaction and after it is complete.
If you have any questions about the security of your personal data, you may contact us by email privacy@Cashtalk.com.
Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or your Subscribers, then we will notify you as soon as possible and later report the action we took in response.
Safeguarding Your Information
We take reasonable and appropriate measures to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.
Despite these efforts to store personal data collected on and through the Site and/or the Service and otherwise by us in a secure operating environment that is not available to the public, we cannot guarantee the security of personal data during its transmission or its storage in our systems. Further, while we attempt to ensure the integrity and security of personal data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to personal data. We do not warrant or represent that personal data about you will be protected against, loss, misuse, or alteration by third parties.
The credit card processing vendor we work with uses security measures to protect your information both during the transaction and after it is complete.
If you have any questions about the security of your personal data, you may contact us by email privacy@Cashtalk.com.
Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or your Subscribers, then we will notify you as soon as possible and later report the action we took in response.
Changes to Our Privacy Policy
We may need to change this Privacy Policy from time to time to reflect legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you before its entry into force, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by data protection laws applicable to us.
You can see when this Privacy Policy was last updated by checking the “EFFECTIVE DATE” displayed at the top of this Privacy Policy. The new Privacy Policy will apply to all current and past users of the website and will replace any prior notices that are inconsistent with it.