January 31th, 2023, Version 3
Espresso Cash is an online service operated by Espresso Cash Inc., an American company registered in the New Jersey under the number 0450913896.
Article 1 - Foreword
Espresso Cash (hereinafter referred to as “Espresso Cash” or the “Company”) is an online wallet service, allowing its users (the “Users” or “You”) to receive, send and store crypto assets (the “Service”).
Article 2 - Subject
The protection of your data and privacy are our Company’s priority, and it implements all appropriate measures to ensure their respect.
Article 3 - Update
By registering on the Service Website, You are consenting to the version in force and available on the Website at that time.
Article 4 - Data collected and Purposes
When You register on our Website, our Company processes Personal Data for particular purposes, each duly legitimate on a valid legal basis.
Please find a summary table of the information collected, the purposes and the legal basis for each of them according to the General Data Protection Regulation (“GDPR”):
|From Cookies, as above described in Article 10, which qualify as Personal Data.
|Discussions or comments
You are under no obligation to provide the requested Personal Data. Nevertheless, our Company draws to Your attention that, in such a case, access to the Website may be altered, if not impossible.
In any event, and disregarding the processing purpose at stake, please note that our Company will comply with a strict data minimization principle and thus only collect and process Personal Data necessary for the above purposes.
Article 5 - Data recipients
The service providers and suppliers may have access to Personal Data for the sole and exclusive purpose of carrying out the missions assigned to them. Our Company ensures that the service providers and suppliers have sufficient legal and technical guarantees for the performance of the task and comply with the applicable laws and regulations.
Furthermore, as the case may be, our Company shares your Personal Data with competent courts and any other governmental and public authorities requesting access to your Personal Data, within the extent legally permitted.
In any event, our Company communicates your Personal Data to the above recipients on a strictly need-to-know basis and only as necessary for fulfilling duly identified processing purposes.
Article 6 - Storage period
Personal identification. The maximum storage period of your Personal Data collecting to comply with the AML/KYC Procedure is five (5) years from the termination of the business relationship.
Browsing information. The maximum storage period for Cookies is thirteen (13) months from the time they are placed on your browser or Equipment. At the end of this period, new consent is required.
Other information. Concerning your other Personal Data, as described in the summary table above, our Company will not retain your Personal Data for more than one (1) year following your last action on the Website or the last contact from you.
If our Company considers it does not need to retain your Data in its active database, it will archive it and will ensure that access to it is restricted to a limited number of persons who have an actual need to access your Personal Data.
Article 7 - Data transfer
Personal Data may be processed outside the European Union territory. In that situation, Company shall take all necessary precautions and alternatively or cumulatively ensure that (i) an adequacy decision has been taken by the European Commission regarding the country of destination; (ii) contractual clauses adopted by the European Commission or the supervisory authority have been signed with the recipient; (iii) the recipient adheres to an approved code of conduct or certification mechanism.
Article 8 - User’s rights
As a data subject, You benefit from various rights regarding the processing of your Personal Data. These are as follows:
- request from Company access to and rectification or erasure of your Personal Data;
- request from Company restriction of the processing concerning You;
- object to the processing of your Personal Data;
- portability of your Personal Data;
- give guidelines regarding the use of your Personal Data after your death; and
- complaint with the French Data Protection Authority (CNIL), the competent supervisory authority.
To exercise your rights or for any question on Personal Data protection, You shall make a request accompanied by proof of identity to the Company according to Article 11 (Contact).
Company shall strive to reply without undue delay and at the latest within one (1) month after receiving the request. Company reserves the right to extend this period to three (3) months in the case of a complex request.
Company protects your Personal Data and complies with the applicable data protection legal framework. To this end, the Company may require your assistance. Thus, You commit to informing Company if the Personal Data You shared with us becomes obsolete or inaccurate.
Article 9 - Security
Company undertakes to take all appropriate technical and organizational measures to ensure the security and confidentiality of the Personal Data processed.
Article 10 - Cookies
You are informed that information may be transmitted to Your browser or Equipment while using the Website (“Cookies”). When You browse the Website for the first time, a Cookie banner may be displayed requesting You to accept, refuse or configure Cookies.
- functionality (language, location, etc.);
You may accept, refuse, and delete specific or all Cookies. You may also contact us if You have any questions about our Company’s cookies, as described in Article 11 (Contact).
You are informed that certain cookies’ refusal may affect the delivery of the Service provided and the navigation on the Website.
Article 11 - Contact
You may also consult our Platform for further information.