Privacy Policy

Last Updated June 29, 2021

PLEASE REVIEW THIS PRIVACY POLICY FOR THE COIN CLOUD SERVICES CAREFULLY. BY ACCESSING THE COIN CLOUD WEBSITE, ANY COIN CLOUD KIOSK, OR THE COIN CLOUD WALLET APPLICATION, YOU SIGNIFY ACCEPTANCE OF THIS PRIVACY POLICY.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE SITE, ANY KIOSK, OR THE WALLET APP.

This policy describes the ways Cash Cloud Inc. doing business as Coin Cloud ("Coin Cloud", "we", "our" or "us") collects, stores, uses and protects your ("User," or "customer") personal information (collectively, the "Privacy Policy" or "Policy"). The purpose of this Privacy Policy is to ensure that Coin Cloud complies with applicable United States federal and state regulations and governs the Coin Cloud website, hosted at www.coin.cloud (the "Site"), any Coin Cloud Kiosk (the "Kiosks" and each a "Kiosk"), or the Coin Cloud wallet application (the "Wallet App", and collectively with the Site and Kiosks, the "Services").

Changes To This Privacy Policy

We may, in our sole discretion, modify this Privacy Policy from time to time by posting a revised version at https://coin.cloud/legal/privacy. If we make any material change to this Privacy Policy, we will notify you by posting a notice on https://coin.cloud/legal/privacy prior to the change becoming effective and may also elect to send you a text message or an email notifying you of the policy modifications.

Personal Information We Collect

Personal information is generally defined as data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Coin Cloud may collect the following information from you:

  • Personal Identification Information: Name, Social Security Number, Date of Birth, Address, Phone Number, Email
  • Government Identification Information: Government issued identity documents such as a passport, driver's license, and/or state identification card.
  • Correspondence: Information that you provide to Coin Cloud when interacting with Coin Cloud Support via phone, email, online form, or other correspondence.
  • Internet Activity: IP Address, Geolocation, Type of Device, Operating System, Browser, and similar data.
  • Information From Third Parties: We may also obtain information about our customers from third parties such as credit bureaus and identity verification services. We ensure that such third parties adhere to the same data protection principles as Coin Cloud.
  • Usage Data: Coin Cloud uses analytics software to allow us to better understand the functionality of our Site. This software may record information such as how often you use the Site, the events that occur with such use, aggregated usage, and performance data. We may combine this automatically collected log information with other information we collect about you in order to provide and improve Coin Cloud's Site and Services.

We may collect additional information as necessary to comply with all applicable laws, statutes, regulations or other requirements imposed by any governmental authority having jurisdiction over us. Should you have questions about the personal information collected by us, please contact Coin Cloud Support at Support@Coin.Cloud.

Children's Personal Information

Coin Cloud's website is a general audience website and is not designed for persons under the age of 18. We do not knowingly collect personal information or provide Services to any person under the age of 18. If a user submits personal information and is suspected of being younger than the age of 18, Coin Cloud will terminate Services to that user and take steps to delete the information as soon as possible.

Why We Collect Personal Information

Our primary purpose for collecting personal information is to provide you with a secure, smooth, efficient, and customized experience.

We may use personal information in the following ways:

  • To maintain legal and regulatory compliance. Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. This includes collection and storage of your photo identification. In addition, we use third parties to verify your identity by comparing the personal information you provide against third party databases and public records. For example, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we may have to discontinue Services for you and/or close your account.
  • To enforce our Terms of Service and other agreements. Coin Cloud handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.
  • To detect and prevent fraud and/or funds loss. We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services and to protect you against account compromise or funds loss.
  • To provide Coin Cloud's Services. We process your personal information to provide the Services to you. For example, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.
  • To provide Service communications. We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
  • To provide Client Support. We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems.
  • To ensure quality control. We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
  • To ensure network and information security. We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services.
  • For research and development purposes. We process your personal information to better understand the way you use and interact with our Services. In addition, we use such information to customize, measure, and improve our Services and the content and layout of our website and applications, and to develop new services.
  • To enhance your experience. We process your personal information to provide a personalized experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties.
  • To engage in marketing activities. Based on your communication preferences, we may send you marketing communications (e.g., emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising and marketing preferences and as permitted by applicable law.
  • For any purpose. We may disclose your personal information for any purpose you consent to.

Ultimately, without Coin Cloud's processing of personal information as outlined above, we cannot ensure your continued secure and uninterrupted enjoyment of our Services.

How We Protect and Store Information Securely

We take security of data very seriously. While no data transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure, we have security measures in place to protect your personal information, including the use of industry-standard safeguards such as firewalls and data encryption, physical access controls, and limiting access to personal information only for those employees who require it to fulfill their job responsibilities.

Data Retention

Coin Cloud retains information for as long as is necessary to accomplish the business purpose for which it was collected and to comply with our legal and contractual obligations. We are a FinCEN registered Money Services Business (MSB) in the United States and per the applicable Bank Secrecy Act (BSA) provisions, we must retain personal information that has been obtained as a part of our customer identification and verification processes for, at minimum, a period of five (5) years after an account has been closed or became dormant.

How We Share Personal Information

We may share your personal information with:

  • Other Coin Cloud entities, in order to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
  • Service providers under contract who help with our business operations; and/or
  • Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Coin Cloud; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary to report suspected illegal activity or to investigate violations of our Terms of Use.

We will make sure that these third parties have appropriate internal controls in place to protect any personal information that might be transferred. In cases of suspected fraud or in connection with an ongoing investigation, we may share certain user information with our third-party affiliates. Please note that these third parties may be in other countries where the laws on processing personal information may be more or less stringent than in your country.

Marketing

Unless otherwise prohibited by law, we may sell your personal information to third parties for marketing purposes. We may combine your information with information we collect from other companies and use it to improve and personalize the Coin Cloud Services, content and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, you can send an email to Support@Coin.Cloud.

Residents of Vermont, please refer to "Vermont Privacy Rights" below.

How We Use Cookies

When you access our website, we, or companies we hire to track how our website is used, may place small data files called "cookies" on your computer. We and our service providers also use cookies to customize the Coin Cloud Services, content and advertising; measure promotional effectiveness, and promote trust and safety.

  • What are cookies? A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to "remember" your actions or preferences over time. Most browsers support cookies, but you can set your browser to decline them and can delete them whenever you like.
  • What type of cookies do we use? We send a "session cookie" to your computer when you log in to your account or otherwise use the Coin Cloud Services. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we do not need to ask you for your password on each page. Once you logout or close your browser, this cookie expires and no longer has any effect. We also use longer-lasting cookies for other purposes such as to display your email address on our login page, so that you don't need to retype the email address each time you login to your account. We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes. You may encounter cookies from third parties when using the Coin Cloud Services on websites that we do not control (for example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application.)
  • Managing your cookie settings: You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Please note that, if you choose to delete Coin Cloud cookies, your access to some functionalities and areas of our website may be degraded or restricted.

Coin Cloud SMS Communications

  • By submitting your phone number in a Coin Cloud web form, you consent to receive one or more automated texts at the phone number from which you texted or at the phone number you entered in the form.
  • We will not be liable for any delays in the receipt of any SMS messages as delivery is subject to effective transmission from your mobile service operator. SMS MESSAGE SERVICES ARE PROVIDED ON AN "AS IS" BASIS, AND WE MAKE NO WARRANTY, EXPRESS OR IMPLIED, AND ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR ANY PARTICULAR PURPOSE, ARE HEREBY EXPRESSLY DISCLAIMED.
  • Data obtained from you in connection with this SMS service may include your cell phone number, your carrier's name, and the date, time and content of your messages, as well as other information that you provide. We may use this information to contact you and to provide the services you request from us.
  • By subscribing, you consent to receive two-factor authentication texts to confirm your identity at our DCM network and transaction receipts
  • By subscribing or otherwise using the service, you acknowledge and agree that we will have the right to change and/or terminate the service at any time, with or without cause and/or advance notice.
  • To cancel your SMS subscriptions, text STOP to 768723 in reply to a text message you receive. You may receive a subsequent message confirming your opt-out request.
  • For additional help, text HELP to 768723 in reply to a text message you receive.
  • Message and Data Rates May Apply
  • T-Mobile® is not liable for delayed or undelivered messages.
  • United States Participating Carriers Include AT&T, T-Mobile®, Verizon Wireless, Sprint, Boost, U.S. Cellular®, MetroPCS®, InterOp, Cellcom, C Spire Wireless, Cricket, Virgin Mobile and others.

California Privacy Rights

In addition to the rights provided for above, if you are a California resident, you have the right to request disclosure of the categories and/or specific pieces of personal information that Coin Cloud may have collected regarding you. California residents also have the right to request deletion of personal information that Coin Cloud may have collected regarding you.

Coin Cloud does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.

Coin Cloud will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.

In order to request a copy of personal information or to request deletion of personal information, California residents can send verifiable consumer requests to Coin Cloud at Support@Coin.Cloud.

Only you, or someone registered with the California Secretary of State in order to act upon your behalf, may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for data access, transport, or deletion twice within a twelve-month period.

In order to submit a verifiable consumer request to Coin Cloud, the request must both provide sufficient detail for Coin Cloud to be able to appropriately ascertain your identity and give sufficient clarity for Coin Cloud to understand the nature of the request. Coin Cloud will determine the criteria for a verifiable consumer request based upon the nature of the request and account.

If you have submitted a verifiable consumer request to Coin Cloud, Coin Cloud will respond in a timely manner consistent with applicable law. If Coin Cloud is unable to verify your request, or if Coin Cloud is unable to ascertain that you are a California resident subject to the rights in this Section, Coin Cloud will submit an appropriate response.

Vermont Privacy Rights

In addition to the rights provided for above, if you are a Vermont resident, you have additional rights regarding restrictions on Coin Cloud's sharing of personal information with non-affiliated third parties.

Coin Cloud will not share Vermont consumers' personal information with a nonaffiliated third party except as necessary to effect, administer, or enforce a transaction that you have requested or authorized. Notice and consumer consent will be required for any other form of disclosure outside established exceptions pursuant to the Vermont Privacy of Consumer Financial and Health Information Regulation.

Neither Coin Cloud nor its affiliates will obtain information about a Vermont consumer's creditworthiness without first obtaining that consumer's consent.

Contact Us

If you have questions concerning this Privacy Policy, please feel free to send us an email at Support@Coin.Cloud.