Privacy Policy

Privacy Policy last revised: January 10th 2023.

For the Terms of Service of the ChaChing Platform, and for any defined terms herein, see: Terms.

ChaChing respects the privacy rights of our users and is strongly committed to protecting your privacy. ChaChing’s mission is motivated as much by a desire to give you the best deals possible when shopping as it has been driven by a desire to let you separate your social activity from your shopping and put you back in control of managing your online privacy. In summary, we will use your data to provide you with the best possible opportunities to save when shopping but we will not sell or profit from the transfer of your data to any third party outside the operation of the Platform in accordance with the Terms.

This Privacy Policy applies to the use of the ChaChing Platform website, any other Platform mobile applications made available or operated by ChaChing from time to time, other directly related services offered from time to time by ChaChing, any subscription to recurring information or updates in connection therewith, sales, promotions, marketing or other events, information collected when you register, link a Payment Card, submit or reply to Listings or postings, participate in the communication functionalities of ChaChing, and any other service or product of ChaChing, including other websites, mobile applications, or other digital properties, as expressly indicated by ChaChing in connection with the Platform such as through a link or other display of this Privacy Policy (collectively, the “Site”). It does not apply to site or applications operated by third parties and not indicated or operated by ChaChing or in connection with the Platform which are subject to their own respective privacy policies. ChaChing and ChaChing Platform are owned and operated by ChaChing Me Inc (ChaChing Me Inc. and its affiliates “we”, “us”, or “ChaChing”). “You” or “User” refers to You as a user of the Site or services.

Please read this Privacy Policy and Privacy Statement carefully before you register with the Site, transact with other users or use the Site or the Services as it will help you understand what information we collect, what we do with the information we collect and your rights.

Collection And Use Of Personal Information and Transaction Data

ChaChing and its Third Party Providers (as defined below under Disclosure Of Your Personal Information) carefully differentiate between the collection and management of personal or company information and transaction data. 

ChaChing and where relevant service providers designated by ChaChing collect personal information that you choose to provide or we receive from other sources. This may include personal information you provide upon participating in activities on the Site, contacting us, expressing an interest in obtaining information, registering, linking a Payment Card, or otherwise through the Site, on third-party websites and applications when subscribing digitally to ChaChing, otherwise through requesting certain ChaChing services or products, by submitting the information to enter a contest, or other promotion or otherwise offline.

We and service providers designated by ChaChing may obtain the following types of personal information in connection with the Site:

  • Name, email address, postal address, account names and passwords, or other contact information
  • Signature, online identifier, Internet Protocol address, or other similar identifiers
  • Professional, industry, employment-related, or education information, including, inter alia, job titles and job applications, background or credit checks, purchase history and financial information, past and present associates 
  • Internet or other electronic network activity information, including, inter alia, URLs, browsing history, app usage, search history, preferences, and information regarding a user’s interaction (including reading habits) with an internet website, application, advertisement
  • Demographic information
  • Social media login data where you elect to register using social media account details
  • Payment Card Networks data, payment data and billing information, payment instrument details (including, inter alia, credit card number), and security information associated therewith or other financial information, and transaction data
  • Device data such as, inter alia, device ID and hardware specification, operating system, system configuration, application and browser type and identification numbers, internet or mobile service provider, internet protocol (IP) address and proxy servers 
  • Geolocation

Personal information is obtained directly from you, from others authorized to provide the information, from any activity on the Site, and from other parties with whom we work, such as, inter alia, service providers, business partners, advertisers, advertising technology providers, advertising servers, data analytics providers, and social networks. If you submit personal information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

If you choose to link your social media or other third-party accounts to our services, to the extent supported by the Platform, we may obtain your personal information from these sources. You may restrict or disconnect this link at any time by visiting your account page on these third-party platforms or the settings page of your mobile device.

We use this information for carefully considered purposes which benefit our users and which include some or all of the following:

  • to provide and facilitate our services and products
  • to operate our services, products, and systems properly and diligently including, inter alia, the management of user accounts, verification of transactions, execution of transactions by third party Sellers and Advertisers, and administration and execution of payment, cash back and credit processes and other Rewards 
  • to communicate with you and enable and support user-to-user communication
  • to post testimonials
  • to help ChaChing improve, upgrade, or enhance our Platform, services and products and develop and communicate new services and products
  • to provide support for our services and products,
  • to maintain the security, quality and safety of services and products, and for internal quality control purpose including debugging to identify and repair errors that impair existing intended functionality or security
  • to provide you with, and administer, offers, promotions and marketing communication about services and products of ChaChing or of other parties that may be of interest to you, coupons, Rewards, prize draws or competitions, and personalized content
  • to enhance your experience with the Site, including to save your preferences and login information, providing customized content or contextual advertisements, and providing tailored advertisements
  • to analyze website usage, analyze use of the Site, analyze and measure ad impressions, and to protect the interests, rights, safety, or property of ChaChing, users or others, analyze and verify third party transactions by yourself in connection with the Site, to monitor compliance with and enforce the terms of any agreement with ChaChing and keep ChaChing and the users free from harm
  • to monitor to detect security incidents and protect against unethical, malicious, deceptive, fraudulent, or illegal activity, and hold those responsible for that activity to account
  • to investigate and respond to legal requests, prevent harm, enforce our terms and conditions and policies and to comply with legal and regulatory requirements

ChaChing or a designated service provider may also take photographs and video at ChaChing offices and premises for security and other internal or business purposes.

Collection of Personal Data for Buyers

By registering your account as Buyer and by submitting your Payment Card information and agreeing to the Terms and this Privacy Policy, you consent to ChaChing and the relevant Payment Card Network monitoring and sharing relevant personal data and transaction data with our service providers (including, e.g., Fidel), ChaChing, and the relevant Seller or Advertiser for the purposes of operating the Platform, including, inter alia, identifying and verifying relevant transactions and carrying out related reward management services. You also acknowledge and agree that relevant transaction details may be shared with involved third parties to enable reward management processes, in accordance with ChaChing’s Terms and Privacy Policy and such third parties’ privacy policy. You may opt out of transaction monitoring on the Linked Payment Card at any time by removing your Linked Payment Card in your account settings, however, this may result in your ineligibility for participation in ChaChing’s core functionality of participating in cashback and reward schemes.

Collection of Personal or Company Data for Vendors and Advertisers

By registering your account as vendor or advertiser and by submitting relevant payment card or account information and agreeing to the Terms and this Privacy Policy, you consent to ChaChing and the relevant payment card network or bank account provider monitoring and sharing relevant personal or company data and transaction data with our service providers and ChaChing for the purposes of operating the Platform, including, inter alia, identifying and verifying relevant transactions, effecting related payments and carrying out related reward management services. You also acknowledge and agree that relevant transaction details may be shared with involved third parties to effect payments or enable reward management processes, in accordance with ChaChing’s Terms and Privacy Policy and such third parties’ privacy policy.

Transaction Data And Usage

Notwithstanding anything to the contrary in the Terms or Privacy Policy, ChaChing and its Third Party Service Providers (including Fidel) will use transaction information solely as follows:

- Use transaction data such as transaction amount, transaction time and merchant location to confirm a qualifying purchase or return to match transactions to confirm whether you qualify for rewards;

- Share transaction data with the participating merchant where a transaction occurred as needed for the merchant to confirm a specific transaction occurred. For example, the date and amount of your purchase and the last 4 digits of your card number so the merchant can verify your purchase with its records if there is a missing, incomplete or disputed transaction;

- Provide participating merchants aggregated and anonymized information relating specifically to registered card activity solely to allow participating merchants and Third Party Service Providers to assess the results of their campaign;

- Create a record of the transaction data and thereafter maintain and use data in connection with operating the ChaChing platform; and

- Provide information in order to respond to a request from a government authority or a payment organization involved in a transaction with you or a merchant.

You authorize the sharing, exchange and use of transaction data described above and herein by and among ChaChing, Third Party Service Providers and applicable Payment Card Networks and applicable merchants.

Transaction Monitoring

By registering a payment card in connection with transaction monitoring, you authorize ChaChing and Third Party Service Providers (including Fidel) to share your payment card information with Visa, Mastercard and AMEX (Payment Networks) so it knows you enrolled. You authorize Mastercard and Visa to monitor transactions on your registered card(s) to identify qualifying purchases in order to determine whether you have qualified for or earned an offer linked to your payment card, and for Visa, Mastercard and AMEX (Payment Networks) to share such transaction details with ChaChing and Third Party Service providers (including Fidel) to enable your card-linked offer(s) and target offers that may be of interest to you. You may opt-out of transaction monitoring on the payment card(s) you have registered by navigating to your settings menu to remove your registered card(s) in which case features or functionalities of the Site or Services may be impaired or no longer available to you.

Use Of Cookies And Other Electronic Technologies

ChaChing and the parties with whom we work (e.g., service providers, Sellers, Advertisers, ad technology providers and advertising servers) may place, view, and/or use “cookies”, web server logs, web beacons, pixels or other electronic technologies to collect statistical and other information about you and your use of the Site. This information may include, inter alia, information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geolocation data, the state or country from which you accessed the Site services, the webpages visited, the date and the time of a visit, the websites you visited immediately before and after visiting the Site, the number of links you click within the Site, the functions you use on the Site, the databases you view and the searches you request on the Site, the data you save on or download from the Site and the number of times you view an advertisement.

ChaChing and the parties with whom we work may use the information collected for various purposes, either on behalf of ChaChing or for the other parties’ own purposes, including research, analysis, to better serve visitors to the Site (such as, inter alia, by enabling log-in, providing access to certain sections of the Site, providing customized content or customized contextual advertisements, or presenting online advertising on the Site or other websites or apps tailored to your interests as described further below), to compile aggregate and anonymous information about usage of the Site and Seller or Advertiser websites or apps, and other statistics, etc. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on the cookie information disabled. 

To assist us with the uses described in this Privacy Policy, information collected about you and your use of the Site or other websites may be aggregated, analysed or combined with personal or other information about you from other online or offline sources. If you prefer that we not combine non-personal information that has been collected, through cookies, about your use of the Site or other websites with personal or other information about you, then please delete and disable cookies for each browser on each device you use to surf the web or access an app.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices also allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the web or access the Sites, Services or applications. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the web from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable certain cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Site, Services or applications, such as, inter alia, the polls, surveys, promotions, contests, and sales, and certain areas of the Site or Services for which you need to log in, will not function properly, and specific promotions and advertising you receive when you visit the Site may not be advertisements tailored to your interests.

Opt-Out

You may opt out of interest-based advertising by Sellers or Advertisers on our Site and Services or instruct ChaChing at any time not to use your personal information covered by this Privacy Policy to provide you with offers and promotions by clicking here or through your account settings. Please note that if you exercise your choice in this manner, you will continue to receive communications concerning your account and products and services you requested, if any, and in response to any requests for information by you. Depending on the level of opt-out, features or functionalities of the Site or Services may be impaired or no longer available to you. Please also note that this opt-out process may take some time to complete, consistent with applicable law.

Advertisements

ChaChing, its designated service providers, Sellers or Advertisers or their advertising servers may also place or recognize unique cookies on your device or use other electronic technologies in order to help display advertisements that you see on the Site or on other websites. Information about your visits to, and activity on, the Site and other websites, an IP address, the number of times you have viewed an advertisement, your interests and preferences and other such usage information is used, alone or in combination with other information, to create aggregate groups of users and to display advertisements that may be of particular interest to you or a group of users with similar interests to you. We may use web beacons, provided by third-party advertising companies, and other information provided to us by third party service providers to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits the Site, and to learn which banner ads bring users to the Site. The use and collection of your information by third-party service providers and third-party advertisers and their advertising servers upon leaving the Site is not covered by this Privacy Policy. 

To opt out of advertising cookies for your online choices if you are based in the EU, please click here.

Disclosure Of Your Personal Information

ChaChing may disclose your personal information to Payment Card Networks, service providers (including, e.g., Fidel), other designated service providers, for the purposes set out in this Privacy Policy and the Terms. ChaChing may also disclose to certain third parties, including, inter alia, Sellers and Advertisers, advertising networks, and data analytics providers, your use of our Site, including, inter alia, online identifier, Internet Protocol address, device and internet or other electronic network activity information, and the services provided by us for the purposes of operating the Platform set out in this Privacy Policy and the Terms. ChaChing may disclose your personal information (excluding security photographs or video, if any) with a Seller or Advertiser, Payment Card Network or reward management provider (“Third-Party Provider”) that provides you with offers or promotions that may be of interest to you. You may instruct ChaChing at any time not to share your personal information covered by this Privacy Policy with such Third-Party Providers by email to privacy@chaching.me with your email address and “Do Not Share Personal Information With Select Partners” in the email subject. Please note that (i) this opt-out process may take some time to complete, consistent with applicable law; (ii) even after such opt-out process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and, to the extent permitted by law and provided for in the Terms, designated service providers, and (iii) the opt-out may adversely affect the functionality of the Platform and administration of cash backs and Rewards.

ChaChing may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order, or other legal process, subject to ChaChing’s Law Enforcement Data Request Statement; (b) protect the interests, rights, safety, or property of ChaChing, users or others; (c) monitor compliance with and enforce any terms of service on the Site; (d) provide our Services and products as may be operated from time to time (including allowing a purchaser of ChaChing or a ChaChing division to continue to serve you); (e) perform other activities related to the Site, Services and products, including, inter alia, billing and collection; (f) provide you with offers,  promotions or advertisements from ChaChing; or (g) operate the systems that provide the Site, our Services and products properly.

If you participate in certain features of the Site (e.g., posting or replying to Listings, promotions, posting reviews, or sharing information related thereto), please note that any information you or others voluntarily disclose through use of these features, may become available to the public and/or other users. If you choose to provide access to designated users or individuals, please be aware that any information you post will be visible to such parties for their use. ChaChing is not responsible for information that you or others choose to disclose on the Site, and neither ChaChing’s nor others’ use of such information is subject to this Privacy Policy.

The collection, further use, and/or disclosure of your information by Third-Party Providers or by other third parties is not the responsibility of ChaChing. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

Accuracy, Security, And Retention Of Your Information

Any personal information you provide to ChaChing is kept on secure servers. ChaChing uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. To help us protect your privacy, you should maintain the secrecy of the logon ID and password you may have set up in connection with your participation in the Site’s services. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or as permitted or required by applicable laws and regulations. However, despite our safeguards and efforts to keep information secure, no electronic transmission, storage technology or devices connected to the internet can be considered fully secure from the continually evolving threat and effort of hackers, cybercriminals, or other unauthorized third parties to defeat such security measures and improperly collect, access, steal, or modify such information. 

Transaction data is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or as permitted or required by applicable laws and regulations.

When we will not continue to process your relevant information, we will either delete or anonymize such information, where this is not possible (e.g., because such information has been stored on backup servers), we will securely store your personal information and isolate it from further processing until deletion is possible.

Rights With Respect To Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information covered by this Privacy Policy. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services, including the administration of cash back or other Rewards. 

For inquiries about your personal information, please contact us by clicking here. While ChaChing will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.

If you wish to at any time review or change the information in your account or terminate your account, you can log into your account settings and update your account, subject to this Privacy Policy and the Terms.

Your European Economic Area (“EEA”), Switzerland, and United Kingdom (“UK”) Privacy Rights

In addition, if you are a resident in the EEA or in the UK accessing the Site and Services lawfully and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: 

EEA: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

UK: Data protection - GOV.UK (www.gov.uk).

In addition, if you are a resident in Switzerland accessing the Site and Services lawfully the contact details for your data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Your California Privacy Rights

In addition, if you are a California resident, you may have the right, consistent with this Privacy Policy and applicable laws to request:

  • certain information about our collection, use, sale, or disclosure of your personal information
  • deletion of your personal information collected or maintained by us
  • to opt-out of the sale of your personal information

 You also have the right to not receive discriminatory treatment for exercising these rights.

If you choose to exercise these rights, we ask you to provide sufficient information, including the products and services you have used in the past, your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, additional information may be requested.

You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.

To exercise a right related to your personal information, please contact us by clicking here. Although the ChaChing Platform does not sell, or permit its Third Party Service Providers to sell, or otherwise profit from a transfer of your personal information (through, e.g., ‘downstream’ data sale) other than in the context of operating the Site, Platform or Services, ChaChing may share personal information related to tailored advertising, including online identifier, Internet Protocol address, device and Internet or other electronic network activity information, with third parties in the course of operating the Platform in ways that may be deemed to constitute a “sale” under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), to the extent the CCPA is applicable, for the purposes set out in this Privacy Policy. 

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure, if any, of your personal information by ChaChing to its affiliates and/or third parties for their direct marketing purposes.

To make such a request, please send an email with your first name, last name, mailing address, email address and telephone number to privacy@chaching.me. Please include “California Privacy Rights” in the Subject line of your email.

You may also make such a request by writing to us at:
Chaching Me, Inc.

1165 N Clark St #700

Chicago, IL 60610 USA

Transfer Of Your Personal Information To Other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information and transaction data to and in various countries that may have different levels of privacy protection than your country which levels may well be less comprehensive that those in your country. By using our Site, services and products, you acknowledge and agree to such transfers and processing, including, inter alia, within, to and from the United States. Our primary servers are currently located in the United States; however, we may at any time without notification or consent change the location of our primary servers and backup servers and our affiliates, services providers or other third parties provided for in this Privacy Policy or in the terms of service may not be located in, operate in or may not operate servers or personnel located in the United States. 

We implement appropriate safeguards, which may include, inter alia, European Commission standard data protection measures, to protect your personal information that is transferred between our group companies and between us and our third party service providers. ChaChing’s Intra-Group Personal Data Protection Statement provides additional information about the transfer (if any) of personal information from the EU, EEA and Switzerland (collectively, “EU”), or the United Kingdom, in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR, to the United States.

Links To Third-Party Sites And Services

ChaChing may provide links or access to third-party websites or other digital properties, including social networking websites. Since we do not control third-party digital properties and are not responsible for any information you may provide while on such digital properties, we encourage you to read the privacy policies on those websites before providing any of your information on such digital properties.

Questions Regarding This Privacy Policy

If you have questions regarding this Privacy Policy, or wish to contact our Data Protection Officer (“DPO”) please contact us at privacy@chaching.me. Please include “Privacy” or “Privacy DPO” (as the case may be) in the Subject line of your inquiry. If you have complaints about ChaChing’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

You can also contact us by post to:

Chaching Me, Inc.

1165 N Clark St #700

Chicago, IL 60610 USA

Modifications To This Privacy Policy

ChaChing reserves the right to update or change this Privacy Policy at any time. The updated version will be marked by a “Last Updated” date at the top of the Privacy Policy. Such changes will be effective upon posting without further consent or notice. We encourage you to review this Privacy Policy frequently. If we make material changes to this Privacy Policy we may in addition notify you by either posting a notice of such changes on the Site or by directly sending you a notification, such notices, for the avoidance of doubt, however, are effective irrespective of such notice being made, if any.

Riders for Submission Forms / Linked Pages Below:ChaChing Law Enforcement Data Request Statement

ChaChing will not disclose user data (which may include personal information, together “user data”) in response to requests from law enforcement, governmental, or regulatory agencies except where required to do so by law (for example, inter alia, in response to valid and properly-served legal process such as a subpoena or search warrant). ChaChing reviews the legality of all such requests prior to responding to ensure they are valid and that ChaChing is legally obligated to comply. ChaChing, at its sole discretion, may challenge requests, including, where necessary, through court challenges and exercise of available appellate rights, if, after careful assessment, ChaChing concludes that the request exceeds the relevant agency’s authority or is otherwise unlawful. When challenging requests, ChaChing may seek interim measures with a view to suspending the effects of the request until competent judicial authority has ruled on its merits.

ChaChing will notify its user about any legally binding request prior to disclosing user data in response to that request, and will notify the user if ChaChing becomes aware of any direct access by public authorities to user data, unless: (1) ChaChing is prohibited by applicable law from doing so, or (2) there are clear indications of unlawful conduct in connection with the user’s use of ChaChing’s Site or Services.

If ChaChing responds to a request for disclosure, ChaChing, at its discretion, may attempt to provide the minimum amount of information permissible, based on a reasonable interpretation of the request. Notwithstanding any of the foregoing, ChaChing reserves the right to respond to urgent law enforcement requests if ChaChing believes in good faith that an emergency, imminent danger of death or serious injury, or materially fraudulent, criminal or unethical activity, or the risk thereof, justifies such disclosure.

Personal Data Inquiry Form

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ChaChing Intra-Group Personal Data Protection Statement

April 1st  2022

The ChaChing Me Inc. and affiliates, if any, operating the Platform (“ChaChing”) are committed to compliance with their data protection obligations throughout the world. This Intra-Group Personal Data Protection Statement (“Statement”) sets out the privacy principles ChaChing follows with respect to personal information that it transfers from the European Union, European Economic Area, and Switzerland (collectively, “EU”) or the United Kingdom (“UK”), in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR.

ChaChing has implemented robust processes and protections to meet the requirements of transferring personal information and transaction data to third countries in accordance with applicable data protection laws. Accordingly, the relevant ChaChing group companies, if any, enter into Intra-Group Personal Data Protection Agreements (“IGAs”) to ensure that any such information transferred from the EU or UK is subject to appropriate safeguards, and to clearly identify the ChaChing group companies responsible for transfers of personal information from the EU or UK.

The IGAs incorporate unchanged EU Commission Standard Contractual Clauses (“SCCs”), which include specific obligations and rights around transfers of personal information and transaction data, and ensure that any such information leaving the EU and/ or UK will be transferred by ChaChing in compliance with applicable EU and UK data protection laws.  The IGAs include the operational procedures and security measures we use to maintain the accuracy and integrity of personal information and protect personal information.

Governance

We regularly review and update our governance framework, including roles and responsibilities of personnel, and maintain a working group to oversee data protection regulation compliance and document results and decisions as they relate to personal information management.

Accountability and Recordkeeping

We map the personal and transaction data life cycle and maintain a personal and transaction data map inventory, including documenting relevant data flows within ChaChing’s systems and any disclosures to third-party systems.

Security

We maintain organisational and technical safeguards intended to ensure the protection of personal information. We engage in ongoing monitoring and testing of the efficacy of these safeguards. Our data centres are dedicated solely to our products, services, and operations, and have secure and monitored access controls.

Privacy By Design

We seek to integrate personal data mapping and accountability into our product design processes, and operate personal data security in our development and product life cycles.

Administrative controls

We regularly review and update our policies, procedures, and controls to address our data protection obligations. We conduct data protection executive education and tailored training programs for data protection compliance.

The ChaChing group companies, if any, or any third party service provider involved in personal information or transaction data transfer and management are where applicable identified in the IGAs as Data Exporter(s) or Data Importer(s). With respect to specific products and services where ChaChing acts as a Data Processor to our users, we make available to our users additional data processing terms, including unchanged EU-Commission approved Controller-to-Processor SCCs. Products where ChaChing acts as data processor will be expressly stated here from time to time.

Contact information

Questions or comments regarding this Statement should be submitted to ChaChing’s privacy team at privacy@chaching.me or the following address:

Head of Legal

Chaching Me, Inc.

1165 N Clark St #700

Chicago, IL 60610 USA

This Statement may be amended from time to time, consistent with the requirements of applicable law, and will be effective immediately.