Privacy Notice for Cash App

For Cash users in the United States, click here for the privacy notice which applies to you.

Effective Date: 3 April 2018

This Privacy Notice describes how Squareup International Ltd., with its office at Fumbally Square, Fumbally Lane, Dublin 8, Ireland, and its affiliates (collectively, “Square,” “we,” and “us”) collect, use, disclose, transfer and store your information when you (“you,” “your”) apply or sign up for a Cash App account through a relevant app store or online at https://cash.me and other services (collectively, “Services”).

This Privacy Notice applies to your use of our Services, and covers only information collected in connection with your access to and use of our Services. Please read this Privacy Notice carefully.

Our Privacy Notice explains: Scope Information We Collect From You How We Use Your Information How We Share Your Information How Long We Retain Your Information Cookies and Similar Technologies Your Rights International Data Transfers Changes to this Privacy Notice Contact


SCOPE

Cash offers the ability to make, accept, request or record payments between individuals. The Additional Cash Terms of Service and General Terms of Service (Terms of Service) set the terms under which we supply the Services to you. Square will collect, use, disclose, retain or otherwise process your information as described in this notice when you apply or sign up for and use a Cash App account.


INFORMATION WE COLLECT FROM YOU

We need to collect information about you to provide you with the Services or the support you request. The type of information we collect can vary depending on the country from which you access our Services. Additionally, you can choose to voluntarily provide information to us.

Information You Provide to Access our Services

We collect information you provide when you apply or sign up for a Cash App account, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, participate in contests or promotions offered by us or our partners, or otherwise use our Services.

We collect the following information about you when you use our Services. This information is necessary for us to provide the Services to you and to allow us comply with applicable laws and regulations, including, but not limited to anti-money laundering laws. Without it, we will not be able to provide you with the Services:

  • Identification Information. Your name, email address, postal code, phone number and Cashtag, signature, and authentication credentials (for example, information you use to login to your Cash account), including IP address.

  • Financial Information. Bank account and payment card numbers.

  • Additional Identification Information for Verified User. Your full postal address, date of birth, government-issued identification including passport and driving licence if you choose to share such information in order to send and receive larger payment amounts.

  • Contacts Information. In order to provide you with the Cash Service, we will also need to collect information from you about the intended recipient of the payment you request us to make. We will therefore ask you to provide contact details of your intended recipient. You can do this by: (a) manually entering a phone number or email address into the Cash App; or, (b) as described below (under Information You Provide to Enhance Your Experience), you can choose to give us access to your phone contacts to facilitate the entry of recipient information. You can update your settings to stop sharing your phone contacts with us at any time, although we will always need a recipient’s phone number or email address to send money to them as requested by you.

  • Transaction Information. When you use our Services to make, accept, request, or record payments, we collect information about when and where the transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.

Information You Provide to Enhance Your Experience

You can choose to provide us with additional information in order to obtain a better user experience when using our Services. This additional information will be processed with your consent:

  • Contacts Information. We collect the telephone numbers of all your phone contacts if you choose to give us access to your phone contacts. You can update your settings to share your phone contacts with us at any time although we will always need a recipient’s phone or email address to send money to them as requested by you.

  • Social Media Information. Any social media account details you give us express permission to collect, if you choose to share such information.

  • Other Information You Provide. We collect information that you voluntarily provide to us, including your photograph, if you choose to upload a picture to the Services; survey responses; participation in contests, or other marketing lead forms or devices; suggestions for improvements; referrals; or any other actions performed on the Services.

Information We Automatically Collect from Your Use of our Services

We automatically collect information about you and the devices you use to access the Services such as your computer, mobile phone, or tablet to pursue our legitimate business interest, in particular:

  • To improve and protect our content, services and applications;

  • To personalise our website, products and Services for you;

  • To use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud; and

  • To monitor accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable laws.

The information we collect includes:

  • Geolocation Information. The location of your device including your IP address, device language, and location of your network provider. For more information and to learn how to disable collection of location information, please see below.

  • Device Information. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services. If you use an iOS device, we also automatically detect if you have downloaded Chrome, so we can ask you which browser you prefer to use to open links from your Cash App.

  • Use Information. Information about how you use our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, the website you visited before you visited or used the Services, data about how you interact with our Services, and other clickstream data.

Information We Collect From Other Sources

We also collect information about you from third parties. We do not have control over how these third parties process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties. The information we collect from third parties about you includes:

  • Identity Verification. We collect information from third-party verification services (e.g., identity verification agencies, social media companies (if you authorise us to do so), and through companies which provide third party analytics (see Cookies section)), and publicly available sources. In some circumstances, where lawful, this information can include your government-issued identification number. Where we engage identity verification agencies, these agencies will access your personal details that they maintain, such as by using credit files, to verify your name, date of birth, and address. Such identity verification is not the same as a credit check. A footprint will be left on your credit file that a search was carried out by the agency for identity verification purposes, which you can see if you check your credit file, but this record will not show up in a credit search and will not affect your ability to obtain credit. The verification agency can also separately retain a record of its search and can share the fact of that past search with other companies that use its services. This search record can show that an unnamed payment processor (or similar industry term) had requested an identity check. We do this identity verification check for the purpose of anti-money laundering, identity verification and fraud prevention.

  • Credit, Compliance and Fraud. By applying or signing up for a Cash App account or Services, you acknowledge that we can obtain and disclose to third parties relevant information about you in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure or as may otherwise be required by applicable law.

Minors’ Information

Our Services are general audience services not directed at individuals under the age of 18. If we obtain actual knowledge that any information we collect has been provided by an individual under the age of 18, we will promptly delete that information.


HOW WE USE YOUR INFORMATION

We collect and can use information about you when you request to engage with our Services. For example, we need some of the information we collect from you to deliver the Services to you, sometimes we are required by law and regulations to collect and process this information about you, at other times, we consider it is in our legitimate business interests to collect and process this information, taking into consideration your privacy right. We use information about you in the following ways:

Providing, Improving and Developing our Services

  • Determining whether the Services are available in your country. We process Location Information where you have requested use of the Services, but before you agree to the Terms of Service we have to verify if we are able to process your request. Without this information, we cannot confirm whether we are able to offer the Services to you under the Terms of Service.

  • Processing or recording payment transactions or money transfers (as both the recipient or instigator of the payment). We need this information in order to fulfil our obligations arising out of the Terms of Service entered into between you and us. Without this information we would not be able to provide the Services requested by you. Information required for these reasons include:
    • Identification Information;
    • Cash Account Information;
    • Transaction Information; and
    • Contact Information.
  • Providing you with the Cash product and features you choose to use. You have the choice to use certain features of the Services, for example, linking your social media account, or providing a photo and government identification information where you have qualified to become a Verified User.

    If you choose to use these features of the product we will need to collect associated information from you either with your consent, for compliance with the law, or where it is in our legitimate business interests to further process your information as described above. You can update your choice to share this information with us at any time.

  • Displaying historical transaction information. As set out in our Terms of Service, we will provide information regarding your transaction history, including monthly account statements. We therefore need to collect and process this information to satisfy our obligations under these terms.

  • Connecting you with people you already know. For example, you can choose to upload contact information from your device’s address book through the Cash App. With your consent, we will match the contact information you choose to upload this way to the information provided by other users of Cash App in order to provide and improve the Services, including making it easier to find contacts to whom you may send or request payments.

  • Providing, maintaining and improving our Services. It is in our legitimate business interests to continue to maintain our product and service offering to individuals in order to keep running our business

  • Developing new products and services. It is in our legitimate business interests to continue to improve our product and service offering to individuals in order to develop and grow our business.

  • Delivering the information and support you request through the use of our Services. This includes push-notification messages, technical notices, security alerts and support and administrative messages including to resolve disputes, collect fees and provide assistance for problems with our Services or your Cash App account.

    We may need to communicate with you in our legitimate business interests, or to fulfil our own obligations or meet your requests that arise from the Terms of Service between you and us and we need your Identification Information in order to deliver this information to you. If you do not provide this information, we will not be able to fulfil our obligations or meet your requests under the Terms of Service.

  • Improving, personalising and facilitating your use of our Services. For example, when you sign up for a Cash App account, we can associate certain information with your new account, such as information about other Cash App accounts you had or currently have, and prior transactions you made using our Services. We do this in order to ensure in our legitimate interests that content from our Services is presented in the most effective manner for you.

  • Measuring, tracking and analysing trends and usage in connection with your use or the performance of our Services. We want to understand how current products and services are used in order to develop and enhance our products in our legitimate interests. In order to ensure that our legitimate business interests of striving to deliver a consistent, secure and continuous service are met, we need to carry out certain analytics on the performance of our Services.

Communicating with You About our Services

  • Sending you promotional information we think you may find useful or which you have requested from us about our products and services, including future marketing of our Services.

    We will only send you push notifications regarding promotional information where we have your consent to do so, by selecting your choice in the Notifications section of the App. Please see Your Rights section for further information.

  • Conducting surveys and collecting feedback about our Services.

    We do this to pursue our legitimate interests to understand if the Services are helpful to you and to evaluate the effectiveness of any updates we provide.

Protecting our Services and Maintaining a Trusted Environment

  • Investigating, detecting, and preventing fraud, security breaches, other potentially prohibited or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf.

    We do this as we are required by law to ensure effective fraud prevention processes are in place. We also do this to prevent out Services being misused for fraudulent activities which is in our legitimate interests as a provider of the Services and other payment processing services.

  • Protecting our customers’ rights or property, or the security or integrity of our Services.

  • Enforcing our Terms of Service or other applicable agreements or policies.

    This is necessary in order to fulfil the obligations between you and us under the Terms of Service.

  • Verifying your identity (e.g., through government-issued identification numbers).

    We need to verify your identity to comply with our contractual obligations, applicable law, and / or for our legitimate interest in protecting the security and integrity of our Services and your account.

  • Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process.

  • Fulfilling any other purpose disclosed to you in connection with our Services.

  • Contacting you to resolve disputes, collect fees and provide assistance with our Services.

    We process this information given our legitimate interest to provide you with our Services, to measure the adequate performance of our contract with you and to comply with applicable laws.

Advertising and Marketing

  • Marketing of our Services.

  • Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys and rewards offered by us and select partners.

    If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications. We will only process your information for these purposes where we have your consent to do so.

Other Uses

  • For any other purpose disclosed to you in connection with our Services from time to time.

    If we intend to process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing, and will obtain your consent where necessary.

Some of our processes for how we use your information may involve automated processing and automated decisions. We need to do this to meet our own contractual obligations, to comply with applicable law and as it is in our legitimate business interests to carry out such checks for fraud prevention purposes or where we are under a legal or regulatory obligation to do so (or we believe we are required to do so under such legal or regulatory obligation). For example:

  • Identity verification processing. We use third party identification verification services to automatically verify your identity, so we know you are who you say you are. We set out more information on this above and how this affects you. If we cannot identify you, we may not be able to provide the Services to you. This identity verification check will be based on the information you provide to us and the results we get for the third party verification services (which is limited to the result of the check).

  • Fraud and crime prevention processing. We have developed processes, for the purposes set out above, to check that our Services are not being used for fraudulent purposes. We will consider information you provide to access our Services, information you provide to enhance your experience, information we automatically collect from your use of our Services and information we collect from other sources. We regularly check that our processes are up to date and implemented robustly and fairly to ensure that we can deliver the Services to you and that they are safe to use. If we feel that our fraud and crime prevention processing detects activities or use of our Services which could be used for fraudulent or criminal activities, we may not be able to provide the Services to you.

  • Product development and creation. We can process the information you provide to us, the information we collect from your use of our Services and the information we obtain from third parties automatically to improve our product and develop new products. The information we use will help us to understand what is important to our users, and how we can create better products and services.

  • Product marketing. With your consent, we can process the information you provide to us, the information we collect from your use of our Services and the information we obtain from third parties automatically to market new products to you by delivering notifications in our applications or on our websites.


HOW WE SHARE YOUR INFORMATION

We can share information about you as follows:

With Other Users of Our Services with Whom You Interact

  • With other users of our Services with whom you interact through your own use of our Services. This is necessary to provide our Services to you and to fulfil our obligations in our Terms of Service. For example, we can share information when you make or accept a payment or money transfer using our Services.

With our Affiliates

  • With our group companies, including our parent company, Square, Inc., and other affiliates, for the purposes outlined above, and as it is necessary to provide our Services to you and fulfil our obligations in our Terms of Service.

With Third Parties

  • With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus and other entities (including First Data) in connection with the payment or money transfer process;

  • With third parties that run advertising campaigns, contests, special offers or other events or activities in connection with our Services.

Business Transfers and Corporate Changes

  • To a subsequent owner, co-owner or operator of one or more of the Services; or

  • In connection with (including, without limitation, during the negotiation or due diligence process of) a corporate merger, consolidation or restructuring; the sale of substantially all of our stock and/or assets; financing, acquisition, divestiture or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

  • If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from tax authorities, law enforcement agencies, etc.); (ii) to enforce or comply with our General Terms or other applicable agreements or policies; (iii) to protect our rights or property, or the security or integrity of our Services; or (iv) to protect us, users of our Services or the public from harm, fraud or potentially prohibited or illegal activities.
  • With your consent. For example:
    • At your direction or as described at the time of sharing;
    • When you authorise a third party application or website to access your information.

Aggregated Information

  • We also can share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

HOW LONG WE RETAIN YOUR INFORMATION

We generally retain your information only as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your Cash App account (see below for more information), we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our General Terms or other applicable agreements or policies, or to take any other actions consistent with applicable law.


COOKIES AND OTHER SIMILAR TECHNOLOGIES

We use various technologies to collect information when you access or use our Services, including placing a piece of data, commonly referred to as a “cookie,” or similar technology on your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We will begin collecting information about you or from activity on devices you use as soon as you use our Services. By using our Services, you permit us to collect and use your information from activity on devices you use in accordance with this Privacy Notice. For more information and to learn how to block or delete cookies used in the Services, please see below.

Certain cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to use the Services and, as such, will last longer.

We use cookies to:

  • Remember that you have visited us or used the Services before. This means we can identify the number of unique visitors we receive, which allows us to make sure we have enough capacity to accommodate all of our users.
  • Customise elements of the promotional layout and/or content of our Services.
  • Collect data about the way you interact with our Services (e.g., when you use certain features or upload attachments).
  • Collect anonymous statistical information about how you use the Services (including the length of your application session) and the location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.

Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf.

Most web and mobile device browsers are set to automatically accept cookies by default. However, you can change your browser settings to prevent automatic acceptance of cookies, or to notify you each time a cookie is set.

You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

Type of Cookies Description and further information
Essential Cookies Essential cookies are cookies that enable you to navigate and use all the features in the Services provided by us. For example, without these, you would not be able to navigate between pages on the website.
Functionality Cookies These cookies enable us to remember you have used our Services before, preferences you may have indicated and information you have provided to us to give you a customised experience. For example, this would include ensuring the continuity of your registration process.
Performance and Analytical Cookies This information is used to make sure our Services can cope with the volume of users, to help us correct errors in the Services and to measure use across our Services. These cookies help us understand if you have used our Services before so we can identify the number of unique users we receive. They also help us understand how long you spend using our Services and from where you have accessed the Services, so that we can improve the Services and learn about the most popular aspects of the Services. We use third parties, for example, Google Analytics, to analyse statistical information from users of the Site. We might be able to associate such information with other information which we collect from you once we receive it from a third party.
Retargeting or advertising Cookies These cookies collect information about the pages you visit and also other information about other websites you visit. This information is only collected by reference to the cookie identifier that you are using. For more information visit http://www.youronlinechoices.com/uk/.

We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We use web beacons to deliver cookies, track the number of visits to our website, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.

Third-Party Advertising and Analytics

We can use third-party service providers to provide site metrics and other analytics services. These third parties can use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into). This information can be used by Square and third-party service providers on behalf of Square to analyse and track usage of our Services, determine the popularity of certain content, and better understand how you use our Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Notice does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

Examples of our third-party service providers to help deliver our Services or to connect to our Services include:

  • Google:

    We use Google Places API to help you fill out the form collecting your address on our Services.

    We use Google Analytics to understand how our Services perform and how you use them. To understand more about Google Analytics and update your preferences in relation to Google’s analytics tools please see here https://support.google.com/analytics/answer/6004245?hl=en-GB and to opt out of Google Analytics please click here https://tools.google.com/dlpage/gaoptout.

    To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/.

  • Facebook:

    We use Facebook Connect API to allow you to connect your Facebook account to your Square account. To learn more about how Facebook uses your data please visit https://en-gb.facebook.com/help/325807937506242/ or log on to you Facebook account and access your settings.

    To understand more about Facebook advertising please see here https://www.facebook.com/about/ads.

  • BugSnag and Crashlytics:

    We use Bugsnag and Crashlytics monitoring apps to monitor errors that impact customers and report diagnostic data to us so we can improve our Service and help to make sure they work when you need to use them. Please visit https://docs.bugsnag.com/legal/privacy-policy/ to learn more about how Bugsnag processes your data and https://fabric.io/terms to learn more about how Crashlytics processes your data.

These third party service providers make use of cookies to implement their services.


YOUR RIGHTS

Personal Information

If you reside in the UK or another member state of the European Union, you have the right under certain circumstances:

Before the 25th May 2018:

  • To be provided with access to your personal data held by us;
  • To request the rectification or erasure of your personal data held by us;
  • To request that we cease processing your data;
  • To object to profiling activities based on our own legitimate interests;
  • To object to solely automated processing; and
  • In addition, where you have provided your consent to our processing of your personal data you can withdraw this at any time.

In order to exercise any of these rights (including the right to withdraw your consent), please email privacy-eu@squareup.com. We may need to verify your identity before granting access or otherwise changing or correcting your information.

After the 25th May 2018:

In addition to the rights listed above, you have the right under certain circumstances:

  • To request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • To request that your data be transferred to a third party (data portability).

In order to exercise your GDPR rights after 25 May 2018 (including the right to withdraw your consent), you can go to http://Cash.me/support. We may need to verify your identity before granting access or otherwise changing or correcting your information.

Deactivating Your Account

If you wish to deactivate your Cash App account, you can do so at any time by logging into your Cash App account and visiting cash.me/support.

If you would like to have your account closed permanently, please contact us at cash.me/support.

Promotional Communications

You can opt out of receiving in-app push notifications containing promotional messages from Square at the time we collect your information by following the instructions on screen or by following the instructions in those messages. If you decide to opt out, we can still send you non-promotional communications in-app, via email and text, such as transaction receipts and messages about your account or our processing of your information in accordance with the provision of our Services.


INTERNATIONAL DATA TRANSFERS

Square operates internationally and many of our systems are based in the United States which has different data protection standards to the European Union. When we transfer your personal data to our affiliates outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. For a list of the countries in which we operate, please see https://squareup.com/gb/about.

We also use standard contractual clauses when we transfer your personal data to third parties outside the EEA or we adopt other means to ensure that adequate safeguards are applied to your personal data, such as a relevant third party’s Privacy Shield certification or binding corporate rules (approved by EU data protection authorities and put in place to protect your personal data). First Data (https://www.firstdata.com/en_gb/privacy/binding-corporate-rules.html) and Master Card (https://www.mastercard.co.uk/en-gb/about-mastercard/what-we-do/privacy.html) have implemented binding corporate rules.

You may obtain a copy of any of the documents we use to protect your personal data when it is transferred outside the EEA by contacting us at privacy-eu@squareup.com.


CHANGES TO THIS PRIVACY NOTICE

We change this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective at the time we post it. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email, if you have provided an email address. If you disagree with these changes, you can cancel your account at any time. Your continued use of our Services constitutes your consent to any amendment of this Privacy Notice.


CONTACT

Please contact our Privacy Department with any questions or concerns regarding this Privacy Notice. Please mark your questions or concerns, FAO: Data Protection Officer.

Squareup International Ltd. Fumbally Square Fumbally Lane Dublin 8, Ireland privacy-eu@squareup.com

If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with our Privacy Department listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We can request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

If your request or concern is not satisfactorily resolved by us, you can approach your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).