Collection of Personal Information

You can use the Services without telling us who you are or disclosing any information allowing someone to identify you as a specific, identifiable individual. However, if you wish to use some of the Services' features, you may be required to provide certain Personal Information (for example, your name and e-mail address).

Any information you knowingly give us when you register for an account or fill out a form on the Services is received and stored by us. The following details could be included if necessary:

  • Account details (such as user name, unique user ID, password, etc)
  • Contact information (such as email address, phone number, etc)
  • Basic personal information (such as name, country of residence, etc)
  • Geolocation data of your device (such as latitude and longitude)
  • Any other materials you willingly submit to us (such as articles, images, feedback, etc)

You can opt not to give us your Personal Information, but in that case, you might not be able to use some of the Services' features. Users are welcome to get in touch with us as they decide which information is required.

Use and Processing of Personal Information

Unless we have a data processing agreement in place with you, in which case you would be the data controller and we would be the processor, we act as both a data controller and a data processor when handling personal information.

If we do not have a data processing agreement in place with you, in which case you would be the data controller and we would be the processor, we will act as both a data controller and a processor when handling personal data.

When you submit Personal Information through the Services, we act as a data processor in those circumstances. The provided personal information is processed solely as per your instructions; we do not own, control, or make decisions regarding it. In these situations, the User who is providing the Personal Information serves as the data controller.

We might need to gather and use specific Personal Information to provide the Services to you or to comply with a legal requirement. We might not be able to give you the requested products or services if you do not provide the information we ask for. Any information we learn about you may be applied to the following things:

  • Create and Manage User Accounts;
  • Send Administrative Information;
  • Respond to inquiries and offer support;
  • Request User Feedback;
  • Enforms Terms and Conditions and Policies;
  • Protect from abuse and Malicious Users;
  • Respond to legal requests and prevent Harm;
  • Run and Operate the Services.

Depending on how you use the Services, where you are in the world, and whether one of the following situations applies, we may process your personal information.

  • You have consented to the use of your information for one or more specific purposes;
  • You must provide the information for us to carry out a contract with you or fulfill any pre-contractual obligations;
  • You must comply with a legal obligation to which you are subject;
  • You must provide the information for us to carry out a task that is carried out in the public interest or the exercise of official authority vested in us; and
  • the processing is required to further one of our or another party's legitimate interests. We may also combine or aggregate some of your Personal Information to better serve you and to improve and update our Services.

Note that in some cases, we may be permitted to process your information up until you exercise your right to object by choosing not to, and we may be able to do so without needing your consent or any other legal justification. In any case, we will be happy to explain the specific legal basis that applies to the processing, including whether providing Personal Information is required by law, or contract, or is necessary to enter into a contract.

First E Cash will not advertise, promote, or sell other services to you by renting, selling, or otherwise disclosing your information to third parties or other unaffiliated parties. However, whether or not you use the First E Cash service, First E Cash may collaborate with outside parties to analyze the data we collect about you when you visit us online, including our website, Facebook page, and Facebook advertisements, where and to the extent permitted by law. To advertise and promote First E Cash services to you and others, First E Cash may use the information it collects there along with the information it receives from your use of our service, which may include Personally Identifiable Information.

For instance, First E Cash contributes information to Facebook's Ad Manager account and SDK programs, which informs us about how customers and other visitors access, view, and use the First E Cash website and application. These advertisements and promotions may show up in your Facebook feed or on other websites owned or run by Facebook, like Instagram, using the data we use to create them. Our ability to tailor our marketing and promotional messages to you will depend on how you use our service, the information you give us or that we learn about you in other ways, and algorithms created to help us predict your needs based on your information and the information of other First E Cash service users.

According to First E Cash, these programs offer useful information and advantages to our current and potential users. If you live in a country where consent is required for the use of your data for marketing and promotional purposes, First E Cash will not use your data for these uses unless you "opt-in" to them.

Your Access to Information

Subject to applicable laws, applicable data protection regulations, and First E Cash's policies intended to prevent fraud and other abuses of financial services, you have the right to access your personal information that is kept by First E Cash. You can reach us at compliance@abc.com to do this. You have the right to ask First E Cash to correct any incorrect, insufficient, or otherwise inaccurate information they may have about you, or you may choose to update the information yourself directly in the App.

Managing Information

You can remove some of the Personal Information we may have about you. The Personal Information you can delete might change as the Services evolve. However, even after you delete Personal Information, we might keep a copy of it in our files for as long as is necessary to meet our obligations to our partners and affiliates as well as for the purposes listed below. On the settings page of your account on the Services, you have the option to delete your Personal Information or your account permanently.

Disclosure of Information

Depending on the Services you have requested, or as required to complete any transaction or provide any Service you have requested, we may share your information with our affiliates, contracted businesses, and service providers (collectively, "Service Providers") we rely on to support the operation of the Services made available to you and whose privacy policies are consistent with ours or who agree to abide by our policies concerning Personal Information. We won't divulge any personally identifying information to third parties or divulge any information to unrelated third parties.

Service Providers are not permitted to use or disclose your information other than as required to carry out tasks on our behalf or under legal obligations. We only provide Service Providers with the information necessary for them to carry out their assigned tasks; we do not permit them to use or disclose any of the provided information for their marketing or other purposes.

If required or permitted by law, such as to comply with a subpoena or other legal process, we may also disclose any Personal Information we collect, use, or receive. Additionally, we may disclose Personal Information when we have a good-faith belief that doing so is necessary to protect our rights, ensure our safety or the safety of others, stop fraud, or comply with a government request.

Retention of Information

As long as your user account is active, we will keep your personal information on file for as long as is necessary to comply with legal obligations, enforce our agreements, handle disputes, and unless a longer retention period is mandated or permitted by law.

Following your updates or deletion, we may still use any aggregated data derived from or incorporating your personal information, but not in a way that would allow us to identify you specifically. Personal Information shall be deleted after the retention period has passed. As a result, following the end of the retention period, the rights of access, erasure, rectification, and data portability cannot be enforced.

Deletion of Information

First E Cash typically keeps records of every transaction for five years. Such information may be destroyed by First E Cash after that time, at which point neither you nor anyone else will have access to it. However, if required by law or regulation, there may be instances where First E Cash is required to keep information for longer periods.

Cookie Policy

To improve your online experience with our Services, "cookies" are used. On your hard drive, a web page server will store a text file called a cookie. Cookies can't be used to launch programs or spread malware on your computer. Only a web server in the domain that issued the cookie to you can read the unique identifier that is assigned to you by cookies.

Cookies may be used by us to gather, store, and track data for security, personalization, and statistical purposes. Please be aware that you have the choice to accept or decline cookies. The majority of web browsers accept cookies by default, but you can change your browser's settings to reject cookies if you'd prefer.

Do Not Track Signals

Some browsers have a "Do Not Track" function that tells websites you visit that you do not want your online activity to be tracked. Tracking is not the same as using or gathering data related to a website. For these purposes, tracking is the process of gathering personally identifiable data from users or visitors to a website or online service throughout their activity on various websites. The Do Not Track signal is not yet uniformly communicated by browsers. The Services are therefore not yet configured to recognize or act upon signals from your browser's Do Not Track feature. However, we only use and collect as much of your Personal Information as is necessary, as explained in more detail elsewhere in this Policy.

E-Mail Marketing

You can voluntarily sign up for our electronic newsletters at any time. Your email address will be kept private by us, and we won't share it with anyone unless expressly permitted in the section on information use and processing. Under any relevant laws and regulations, we will keep the email-sent information on file.

All emails sent from us will identify who the email is from and include information on how to get in touch with the sender, under the CAN-SPAM Act. By following the unsubscribe instructions provided in these emails or by contacting us, you can decide whether to continue receiving our newsletter or marketing emails. You will still get important transactional emails though.

Information Security

Your information is protected from unauthorized access, use, or disclosure by being stored on computer servers in a secure, monitored environment. To guard against unauthorized access, use, modification, and disclosure of Personal Information under our control and custody, we maintain reasonable administrative, technical, and physical safeguards. However, there is no guarantee that data will be transmitted over the Internet or a wireless network.

Because of this, you acknowledge that, despite our best efforts to protect your Personal Information,

  • there are security and privacy limitations of the Internet that are outside of our control;
  • the security, integrity, and privacy of any information and data exchanged between you and the Services cannot be guaranteed; and
  • any such information and data may be viewed or altered in transit by a third party.

Please take the necessary precautions to safeguard this information because the security of Personal Information is largely dependent upon the security of the device you use to communicate with us and the security you employ to safeguard your login credentials.

Information for California Users Only

The California Consumer Privacy Act, also known as the "CCPA," and the rights it grants California residents are both covered in more detail in this section. Please refer to the "Collection of Information" section above for more information on the specific data we gather from our users. Please read the "Use of Information" section above for more information on how the information is used for our business needs. As described in the "Collection of Information" section, we may share and disclose personal user information with third-party partners.

SALE OF YOUR PERSONAL INFORMATION: First E Cash does not sell (as that term is defined in the CCPA), rent, or otherwise make your information available to third-party marketers or other parties who are not affiliated with First E Cash for advertising, promoting, or selling other services to you. However, we may allow affiliated companies to use your information; if you would prefer to opt out of such sharing, which may be viewed as a "sale" under the CCPA, just get in touch with us at compliance@abc.com.

Subject to some restrictions, the CCPA gives California residents the right to request more information about the categories or particular pieces of personal information we collect (as well as how we use and disclose this information), to have their personal information deleted, to opt out of any potential "sales," and to be protected from retaliation for exercising these rights.

California residents may make requests under their CCPA rights by getting in touch with us at compliance@abc.com. We will use the details linked to your account, including your email address, to verify your request. Identification from the government might be needed. Customers may also appoint a qualified agent to act as their representative in the exercise of these rights.

Data Breach

We reserve the right to take reasonable appropriate measures, including but not limited to, investigation and reporting, as well as notification of and cooperation with law enforcement authorities, if we become aware that the security of the Services has been compromised or Users' Personal Information has been disclosed to unrelated third parties as a result of external activity, including but not limited to security attacks or fraud. If we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law, we will use commercially reasonable efforts to notify affected individuals in the event of a data breach. When we do, we will post a notice on the Services, and send you an email.

Changes and Amendments

We reserve the right, in our sole discretion, to change this Policy or its terms about the Services at any time. We'll email you to let you know when we do so. At our discretion, we may also notify you in other ways, such as through the contact details you have provided.

Unless otherwise specified, a revised version of this Policy will take effect right away after being posted. You will be deemed to have agreed to the changes if you continue to use the Services after the revised Policy goes into effect (or take any other action that may be specified at that time). However, unless you permit us, we won't use your personal information in a way that materially deviates from the stated purpose for which it was collected.

Accepting these Policies

You declare that you have read this Policy and that you accept all of its guidelines. You agree to be bound by this Policy by accessing and using the Services and submitting your information. You are not permitted to access or use the Services if you do not agree to abide by the terms of this Policy.

Contacting Us

If you have any questions, concerns, or complaints regarding this Policy or the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us via our e-mail, i.e., support@abc.com.

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

This Privacy Policy represents the way First E Cash (collectively "First E Cash", "we", "our", or "us") does business through our mobile application and the way First E Cash obtains, uses, manages, stores, and disposes of specific user information that, as a user of our services, you provide to us through our mobile application. Please see the "collection of personal data" section given below in the article for details regarding the information we collect from our users. To know how we use that information for our business purposes and share it with third parties, check out the "Use of personal data" and "Storage and sharing of personal data outside of the EEA" sections mentioned below. Details regarding your rights as a user, including the right to access and correct your personal information, are described in the "User Rights" section. First E Cash will not sell, rent, or disclose your data to third-party marketers or firms unaffiliated with First E Cash to promote, advertise, or sell other services to you.

First E-Cash collects information about you and the person to whom you are sending money (your "Beneficiary") from the data you provide to us through the First E Cash mobile application ("App"). When you provide the information to us, through our app or otherwise, you warrant that all the information you provide is accurate and complete. In giving the personal data of any other person to us during the transaction or use of our service, you agree that you have obtained consent from that person to disclose their personal information to us, as well as their consent to our collection, use, and disclosure of such personal information for our business purposes as stated in this Privacy Policy. First E Cash relies on your warranty when we provide the service to you. The information you provide to First E Cash includes personal data, which can be used on its own or with other information to identify you or your Beneficiary.

In addition to your information, First E Cash may obtain information about you or your Beneficiary from third parties. This information from third parties may also include personal data. More information about these third parties is given below in this privacy policy. First E Cash uses this information to provide services to the user and to protect the user's information, the Beneficiary, our services, and the general public from fraud, mistakes, money laundering, and other serious problems.

Data Controller

For the relevant data protection regulations, the "Data controller" of your personal data depends on where you live as a user of First E Cashs' services.

If you live in the EU, the data controller is First E Cash, an EU company registered at . If you have any queries regarding how we use or protect your data, email us at .

Collection of personal data

The primary data we collect from the user is the data that the user provides us through the First E Cash App. This data includes information about the user, such as full legal name, address, date of birth, telephone number, and email address, along with other data and documentation that allows First E Cash to verify the user's identity. The user has to provide us with information about an approved payment source, like a debit card, and information about their Beneficiary, which may include sensitive personal data like the Beneficiary's name, address, mobile number, and bank account information. When you give us permission to access your contacts stored on your device at the time of registration, we only use that information to auto-populate fields when you add a new recipient as a Beneficiary. We do not upload your contacts to our server or anywhere else. We may also collect information from the device through which you access the First E Cash Application. This device information includes your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the First E Cash Application. We may also collect information about the websites you have visited before accessing our services. First E Cash may store such information and associate it with your use of our services to help us identify you and facilitate your use of our services in the future. First E Cash may also need some additional information from a user in the case of high-value or high-volume transactions or as required to comply with our anti-money laundering obligations under the country's applicable law.

First E Cash may verify and confirm all of the information that the user provides to us or that we collect otherwise from user access to the First E Cash App with third parties, including the financial institution that issued the payment card (credit card, debit card, etc.), you propose to use, and the telecommunication company or a financial institution through which your money is sent to your Beneficiary. First E Cash may also verify such information with identity verification services, electronic databases, social media companies, and credit reporting agencies. We may share your information with the banks, telecommunications providers, and other financial services companies that facilitate payments to your Beneficiary. To confirm your identity and your eligibility to use our service, First E Cash may require you and your Beneficiary to provide us with additional information and documentation from time to time.

First E Cash may collect and store information regarding your use of the Application and the service when you access the First E Cash app. It includes information about the way you move through the site, the time you spend there, the frequency with which you access the Application, your transfer history, and details regarding the amount of money you transfer to your Beneficiaries.

If you contact us for any reason, whether by email, telephone, text, or otherwise, First E Cash will record and store communications that the user has with us for evidence and quality assurance. You agree to our phone conversation recording by contacting us by telephone.

Use of personal data

First E Cash may store and use all of the information and documentation you provide, as well as information that we derive from your device through your use of our service and information that we obtain from third parties, to provide you with better service. First E Cash uses your personal information to comply with the applicable laws and regulations of the country, including those intended to prevent fraud, money laundering, and other financial system abuses. First E Cash may use your contact information to contact you as needed to confirm or complete a transaction and allow our agents, partners, and service providers to fulfill their obligations in providing the First E Cash service to you. We may also use your information to fix bugs, improve our service, develop new or updated products and services, and create advertising, marketing, and promotional campaigns. We ask for your consent before sending you marketing communications about other products and services offered by First E Cash. More information regarding our use of your personal data for marketing and promotion is given below. We may disclose your information to third parties when we reasonably determine that such disclosure is required by law, such as in responses to subpoenas and information requests by law enforcement. These third parties may include government agencies, financial services regulators, or national security authorities.

First E Cash will not sell, rent or disclose your data to third-party marketers or firms not affiliated with First E Cash to advertise, promote, or sell other products or services to our users. However, First E Cash may work with third parties (where and to the extent allowed by the applicable law) to analyze the information that we gather from you when you visit us online, including our website, Facebook page, and Facebook advertisements, whether or not you use the First E Cash service. We may use this collected information and the information we obtain from your use of our service. This information may include personal data to advertise and promote First E Cash services to you and others. For example, First E Cash provides data to Facebook's Ad Manager Account and SDK programs, which provide information about how customers and other visitors view, access, and use our website and application. We use that information to create advertisements and promotions. These advertisements and promotions may appear in your Facebook feed or on other sites or apps owned or operated by Facebook, such as Instagram, WhatsApp, and so on.

We may customize the marketing and promotional messages for you on the basis of your use of the service, the information you provide or otherwise obtain from you, algorithms designed to help us predict your potential needs and the information of others who use our services. Such strategies provide valuable information and excellent benefits in terms of experience to our current and potential users. However, First E Cash will only use your personal information for marketing and promotional purposes if you permit us to do so. You are allowed to withdraw this permission at any time. You have the right to ask First E Cash not to contact you for marketing purposes by contacting us at .

Our legal bases for using your personal information

First E Cash must have a legal basis to use your personal information for specific purposes. Your personal information may be used for each of the following legal bases:

Performance of a contract: This includes providing you with one of our products or services; sending you a notification regarding any changes to our services, application, or website; or changes to our terms and conditions or privacy policy; enabling third parties to perform technical, logistical, or other required functions for First E Cash, and responding to and resolving any complaints you may have.

Consent: You have permitted us to process and use your personal information for a specific purpose, such as sending you marketing and promotional communications through email, SMS, and push notifications; sending you surveys and engaging with you to gain your views on our services, sites, or mobile application; or where otherwise required by applicable law.

For our legitimate interests (to the extent that your interests do not override such interests): This includes using personal data needed to fulfill, our legal and regulatory obligations related to anti-money laundering and counter-terrorist financing; establishing, exercising, protecting or defending our legal rights and interests; detection, prevention, and prosecution of fraud and theft as well as preventing illicit or prohibited use of our services or other illegal activity; conducting surveys, satisfaction reports and market research; promoting and conducting our business; developing new products and services; contacting you to for progress your use of our Services including any issues you may have encountered within completing your transaction, subject always to compliance with applicable law of the country; and Managing and operating the financial and commercial affairs of our business. Whenever First E Cash uses legitimate interest as the ground for processing your personal data, you can object to our use.

For compliance with our legal obligation: This includes the use of your personal information to accomplish legal and regulatory duties related to anti-money laundering, terrorist financing, detection, prevention, and prosecution of theft and fraud, and preventing the illegal use of our services or any other illegal or wrongful activity; comply with Data Protection constitution and any other applicable laws; requests from the Information Commissioner's Office; the Financial Conduct Authority or other governmental or regulatory agency with supervisory authority over us; complying with the court orders, disclosures to law enforcement or tax agencies; and the maintenance of records to comply with the legal, audit, regulatory and tax requirements.

Protection of personal data

Our practices and leading security experts help ensure your personal information is secure and safe. All such critical information is stored on servers with state-of-the-art data protection technology. This data is accessible only to our trusted employees who need to access it for business purposes. We use 128-bit encryption and encode your payment card or other sensitive information as soon as you enter the First E Cash application. This process overwrites your details with cryptic code so that they are unreadable by unauthorized or illegal parties.

However, no method of transmission over the Internet or method of electronic storage is fully secured. Although First E Cash uses powerful and secure methods and technology to protect personal user data and conducts regular tests of our information protection practices and technology, First E Cash cannot guarantee its safety and security. However, we will notify you of any breach or other compromise that affects your personal information promptly and in compliance with applicable law.

Storage and personal data Sharing outside of the EEA

First E Cash transfers and stores your personal information at a destination outside the European Economic Area ("EEA"). Your personal information will also be processed by staff outside the EEA who work for our company. Such staff is engaged in payment process details and the provision of support services. You accept this transfer, storage, or processing by submitting your data to us. First E Cash will take all the necessary and reasonable steps to ensure that your data is transmitted or treated securely and follows this privacy policy.

To provide our services to the user, we also need to transfer the personal data to financial or telecommunication counter-parties in the country of your Beneficiary (for the processing of your payment details and the execution of transactions) and other selected third parties (analytics providers that assist us in the optimization of our Application and our communication to you; for details, see the "Use of personal data" section mentioned above) based outside the EEA. We ensure that our partners and we take sufficient and appropriate technical, physical, and organizational security measures to protect your personal information. We also ensure we have appropriate contractual protections with these authorized third parties.

Use of cookies and other tracking devices

To recognize you, remember your preferences, and make your future transactions and other interactions with us smoother and more accessible, First E Cash uses "cookies" and other tracking devices. We also use such tracking devices to help us understand customer behavior on our Application; it helps us improve our services and make them easier for future use. You may disable your device's use of cookies. However, it may slow down or prevent your ability to use our service. For more information on the use of cookies, please visit.

User rights

Your rights to access your personal information on the First E Cash application are subject to applicable law, relevant data protection regulations, and First E Cash's policies intended to prevent fraud and other abuses of financial services. To learn more about it, you can contact us at . Suppose the information we have maintained about you needs to be corrected, complete, or accurate. In that case, you have the right to require First E Cash to correct it or correct it yourself through our Mobile Application.

Under certain conditions, the user also has the right to request that we transfer the personal information we have collected to another organization. Apart from that, the user also has the right to ask First E Cash to delete their data when it is no longer necessary or subject to a legal obligation to which First E Cash is subject.

As described in the "Use of personal data" section mentioned above, you have the right to ask us not to contact you for marketing purposes by writing us at

Destruction of personal data

Generally, First E Cash maintains information about each transaction for a minimum of five years and a maximum of ten years. After that period, we will destroy such data, and it will no longer be available to you or anyone else. However, there may be situations where First E Cash must maintain data for longer periods if required by law or regulation.

Privacy Policy changes

First E Cash's privacy policy may change in the future. In that case, the revised version of the First E Cash privacy policy will be posted on our website, . It will also be sent to current users via the email addresses associated with their First E Cash App registrations.

This Privacy Policy describes the way FIRST E CASH (collectively "FIRST E CASH", "we", "our", or "us") obtains, uses, manages, stores, and disposes of certain information you, as a user of our services, provide to us through our mobile application. Please see the "collection of personal data" section below for details regarding the information we collect from our users. To know how we use that information for our business purposes and share it with third parties, review the "Use of personal data" and "Storage and sharing of personal data outside of the EEA" sections. Details regarding your rights, including the right to access your data and correct your personal data, are described in the "User Rights" section. We will not sell, rent, or disclose your personal information to third-party marketers or others unaffiliated with FIRST E CASH to promote, advertise, or sell other services to you.

FIRST E CASH collects information about you and the person to whom you are sending money (your "Beneficiary") from the data you provide to us through the FIRST E CASH application ("App"). When you provide the information to us, through our Application or otherwise, you warrant to FIRST E CASH that all the information provided by you is accurate and complete. In giving the personal data of any other person to us during the use of our services, you agree that you have obtained consent from that person to disclose their personal information to us, as well as their consent to our collection, use, and disclosure of such personal information, for the business purposes as stated in this Privacy Policy. We are relying on your warranty when we provide the service to you. The information you provide to FIRST E CASH includes personal data, which can be used on its own or with other information to identify you or your Beneficiary.

In addition to the information provided by the user, FIRST E CASH may obtain information about you or your Beneficiary from third parties. This information from third parties may contain personal data. More information about these third parties is given below. FIRST E CASH uses this information to provide their services to the user and to protect the user, the FIRST E CASH service, the Beneficiary, and the general public from fraud, mistakes, money laundering, and other problems.

Data Controller

For the relevant data protection regulations, the "Data controller" of your personal data depends on where you live as a user of our services.

If you live in the UK, the data controller is FIRST E CASH, a UK company registered at . If you have any queries regarding how we use or protect your personal data, email us at.

Collection of personal data

The basic information we collect from the user is the information the user provides us on the FIRST E CASH app. This information includes information about the user, such as full legal name, address, date of birth, telephone number, and email address, along with other data and documentation that allows FIRST E CASH to verify the user's identity. The user must provide us with information about an approved payment source, like a debit card, and information about their Beneficiary, which may include sensitive personal data such as the Beneficiary's name, address, mobile number, and bank account information. When you give FIRST E CASH permission to access your contacts stored on your device, we only use that information to auto-populate fields when you add a new recipient as a Beneficiary. We do not upload your contacts or personal data to our server. We may also collect information from the device from which you access the FIRST E CASH Application. This information includes your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the Application. We may also collect information about the website you visited before accessing FIRST E CASH services. To help FIRST E CASH identify you and facilitate your use of our services in the future, FIRST E CASH may store such information and associate it with your use. We may also need additional information from a user in the case of high-value or high-volume transactions or as required to comply with our anti-money laundering obligations under the country's applicable law.

FIRST E CASH may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the FIRST E CASH App) with third parties, including the financial institution that issued the payment card you propose to use and the telecommunication company or a financial institution through which your money is sent to your Beneficiary. We may also verify such information with identity verification services, electronic databases, social media companies, and credit reporting agencies. We may share your information with the banks, telecommunications providers, and other financial services firms that facilitate payments to your Beneficiary. FIRST E CASH may require you and your Beneficiary to provide us with additional information and documentation to confirm your identity and your eligibility to use our service from time to time.

FIRST E CASH may collect and store information regarding your use of the App and the service when you access the FIRST E CASH app. It includes information about the frequency with which you access the App, the way you move through the site, the time you spend there, your transfer history, and details regarding the amount of money you transfer to your Beneficiaries.

If the user contacts us for any reason, whether by telephone, email, text, or otherwise, FIRST E CASH will record and store communications that the user has with us for evidence and quality assurance. By contacting us by telephone, you agree to our phone conversation recording.

Use of personal data

FIRST E CASH may maintain and use all of the information and documentation you provide, as well as information that we derive from your use of the service and information that we obtain from third parties, to provide the FIRST E CASH service to you. We use your personal data to enable FIRST E CASH to comply with applicable laws and regulations, including those intended to prevent fraud, money laundering, and other financial system abuses. FIRST E CASH may use your information to contact you as required to confirm or complete a transaction and allow our agents, partners, and service providers to fulfill their obligations in providing the FIRST E CASH service. We may also use your information to fix problems, improve our service, develop new or updated products and services, and create marketing, advertising, and promotional campaigns. We will ask for your consent to send you marketing communications about products and services offered by FIRST E CASH. More information about FIRST E CASH's use of your personal data for marketing and promotion is given below. FIRST E CASH may disclose your information to third parties when FIRST E CASH reasonably determines that such disclosure is required by law, such as in responses to subpoenas and information requests by law enforcement. These third parties may include government agencies, financial services regulators, or national security authorities.

FIRST E CASH will not sell, rent, or otherwise disclose your personal information to third-party marketers or others unaffiliated with FIRST E CASH to advertise, promote, or sell other products or services to you. However, FIRST E CASH may work with third parties (where and to the extent allowed by law) to analyze the information that we gather from you when you visit us online, including our website, Facebook page, and Facebook advertisements, whether or not you use the FIRST E CASH service. We may use this information we gather and the information we obtain from your use of our service, which may include personal data, to advertise and promote FIRST E CASH services to you and others. For example, FIRST E CASH provides data to Facebook's Ad Manager Account and SDK programs, which provide information about how customers and other visitors view, access, and use our website and application. We use that information to create advertisements and promotions. These advertisements and promotions may appear in your Facebook feed or on other sites or apps owned or operated by Facebook, such as Instagram.

We may customize our marketing and promotional messages to you based on your use of our service, the information you provide or that we otherwise obtain from you, algorithms designed to help us predict your potential needs and the information of others who use our services. FIRST E CASH believes that such strategies provide valuable information and benefits to our current and potential users. However, FIRST E CASH will only use your personal data for marketing and promotional purposes if you "opt-in" to such uses. You are allowed to withdraw this permission at any time. The user has the right to ask us not to contact you for marketing purposes by contacting us at.

Our legal bases for using your personal information

First E Cash must have a legal basis to use your personal information for specific purposes. Your personal information may be used for each of the following legal bases:

Performance of a contract: This includes providing you with one of our products or services; sending you a notification regarding any changes to our services, application, or website; or changes to our terms and conditions or privacy policy; enabling third parties to perform technical, logistical, or other required functions for First E Cash, and responding to and resolving any complaints you may have.

Consent: You have permitted us to process and use your personal information for a specific purpose, such as sending you marketing and promotional communications through email, SMS, and push notifications; sending you surveys and engaging with you to gain your views on our services, sites, or mobile application; or where otherwise required by applicable law.

For our legitimate interests (to the extent that your interests do not override such interests): This includes using personal data needed to fulfill, our legal and regulatory obligations related to anti-money laundering and counter-terrorist financing; establishing, exercising, protecting or defending our legal rights and interests; detection, prevention, and prosecution of fraud and theft as well as preventing illicit or prohibited use of our services or other illegal activity; conducting surveys, satisfaction reports and market research; promoting and conducting our business; developing new products and services; contacting you to for progress your use of our Services including any issues you may have encountered within completing your transaction, subject always to compliance with applicable law of the country; and Managing and operating the financial and commercial affairs of our business. Whenever First E Cash uses legitimate interest as the ground for processing your personal data, you can object to our use.

For compliance with our legal obligation: This includes the use of your personal information to accomplish legal and regulatory duties related to anti-money laundering, terrorist financing, detection, prevention, and prosecution of theft and fraud, and preventing the illegal use of our services or any other illegal or wrongful activity; comply with Data Protection constitution and any other applicable laws; requests from the Information Commissioner's Office; the Financial Conduct Authority or other governmental or regulatory agency with supervisory authority over us; complying with the court orders, disclosures to law enforcement or tax agencies; and the maintenance of records to comply with the legal, audit, regulatory and tax requirements.

Protection of personal data

FIRST E CASH's leading security experts and practices help ensure that your data is secure and safe. All such information is stored on servers with state-of-the-art data protection technology. This data is accessible only to our employees who need to access it for business purposes. We use 128-bit encryption and encode your debit card or other sensitive information as soon as it is entered into the FIRST E CASH app. This process overwrites your details so that they are unreadable by unauthorized parties.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Although FIRST E CASH uses robust methods and technology to protect the data that you provide to us, and we regularly test our information protection practices and technology, we cannot absolutely guarantee its security. However, FIRST E CASH will notify you of any breach or other compromise that affects your personal data promptly and in compliance with applicable law.

Storage and personal data Sharing outside of the EEA

FIRST E CASH transfers and stores your personal data at a destination outside the European Economic Area ("EEA"). Your personal data will also be processed by staff outside the EEA who work for our company. Such staff is engaged in payment process details and the provision of support services. By submitting your data, you acknowledge this transfer, storage, or processing. We will take all the necessary and reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

To provide our services to you, we also need to transfer your personal data to financial and telecom counter-parties in the country of your Beneficiary (for the processing of your payment details and the execution of transactions) and to other, selected third parties (analytics providers that assist us in the optimisation of our App and our communication to you, for details, see the "Use of personal data" section above) based outside the EEA. We ensure that our partners and we take adequate and appropriate technical, physical and organisational security measures to protect your personal data. We also ensure we have appropriate contractual protections in place with these third parties.

Use of cookies and other tracking devices

FIRST E CASH uses "cookies" and other tracking devices to help us recognize you, remember your preferences, and make your future transactions and other interactions with us smoother and more accessible. We also use such tracking devices to help us understand consumer behavior on our app, to help us improve it, and to make it easier for future use. You may disable your device's use of cookies, but that might slow or prevent your ability to use our service. For more information, please visit.

User rights

Users rights to access their personal information on the FIRST E CASH app are subject to applicable laws and in accordance with relevant data protection regulations and FIRST E CASH's policies intended to prevent fraud and other abuses of financial services. To do so, you can contact us at . If the information we have maintained about you is wrong, incomplete, or inaccurate, you have the right to require FIRST E CASH to correct it or correct it yourself directly in the App.

You also have the right to request that we transfer the personal data we have collected to another organization under certain conditions. Apart from that, you also have the right to ask us to delete your data when it is no longer necessary or subject to a legal obligation to which FIRST E CASH is subject.

Destruction of personal data

Generally, we maintain information about each transaction for a minimum of five years and a maximum of ten years. After that period, we will destroy such information, and it will no longer be available to you or anyone else. However, there may be circumstances where FIRST E CASH must maintain data for longer periods if required by law or regulation.

Privacy Policy changes

FIRST E CASH's privacy policy may change in the future. In that case, the revised version will be posted on our website, , and will be sent to current users via the email addresses associated with their FIRST E CASH App registrations.