Privacy Policy

1. Who We Are

CacaoCash is a product of DEKSxyz, Inc., a company incorporated in the United States. We provide digital payment services that allow users to pay at local QR codes across Latin America using foreign currencies.

For privacy-related questions, contact us at privacy@cacaocash.com.

2. Information We Collect

Information you provide directly:

• Full name, email address, phone number, and date of birth when you create an account
• Government-issued ID document, ID number and selfie for identity verification (KYC)
• Payment method details (bank account numbers, card information processed through our payment partners)
• Messages and communications you send to our support team

Information collected automatically:

• Device information (model, operating system, unique device identifiers)
• Advertising identifiers (Apple’s IDFA, only if you allow tracking, and Google’s advertising ID on Android)
• IP address and approximate location
• App usage data (screens visited, features used, session duration)
• Transaction data (amount, recipient, timestamp, QR code scanned)
• Cookies and similar tracking technologies on our website

Information from third parties:

• Identity verification results from our KYC/AML compliance partners
• Fraud signals from financial crime detection services
• Exchange rate data from financial data providers

3. How We Use Your Information

We use your information to:

• Create and manage your CacaoCash account
• Process payments and transfers
• Verify your identity and comply with anti-money laundering (AML) and Know Your Customer (KYC) regulations
• Detect, prevent, and investigate fraud and unauthorized transactions
• Communicate with you about your account, transactions, and service updates
• Provide customer support
• Improve our products and services through analytics
• Measure how well our advertising works (see Section 6)
• Comply with legal obligations and respond to lawful requests from authorities
• Send you marketing communications (only with your consent, and you can opt out at any time)

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contract performance — processing necessary to provide the services you requested
• Legal obligation — compliance with financial regulations, AML/KYC requirements, and tax laws
• Legitimate interests — fraud prevention, security, improving our services, and measuring our advertising
• Consent — marketing communications, non-essential cookies, and, on iOS, sharing your advertising identifier with Meta (you can withdraw consent at any time)

5. How We Share Your Information

We do not sell your personal information. We may share it with:

• Payment processors and banking partners — to execute transactions
• Identity verification providers — Persona, which checks your ID document and selfie, to fulfill KYC/AML requirements
• Manteca — our local payments partner in Latin America, which receives your name, ID number and a copy of your ID document to verify your identity (KYC) and settle your local payments
• Cloud infrastructure providers — to store and process data securely
• Analytics providers — Vercel Analytics and PostHog, to understand app usage
• Sentry — crash reporting and error diagnostics, which receives technical details such as device model, operating system, app version and the error that occurred
• Privy — sign-in (email, Google or Apple) and the wallet infrastructure that secures your account
• Advertising partners — Meta, to measure and improve our ads (see Section 6)
• Legal authorities — when required by law, court order, or to protect our rights
• Acquirers or successors — in the event of a merger, acquisition, or sale of assets

All third-party service providers are contractually required to handle your data securely and only for the purposes we specify.

6. Advertising Measurement (Meta)

Our mobile app includes the Meta SDK, provided by Meta Platforms, Inc. (“Meta”). We use it to measure which of our ads on Facebook and Instagram lead people to install and use CacaoCash, and to show our ads to people who are more likely to find CacaoCash useful.

What the app shares with Meta:

• App events: installing and opening the app, creating an account, starting and completing identity verification, making your first deposit, and completing a QR payment (including the payment amount in USD)
• Your device’s advertising identifier (on iOS, only if you allow tracking; on Android, the Google advertising ID)
• Device and app information, such as device model, operating system, app version, language, and IP address
• Your CacaoCash user ID and your email address, which the SDK hashes on your device before sending, so Meta can match events to a Meta account

What we never share with Meta: your name, identity documents or selfie, bank or card details, account balances, wallet addresses, or who you pay and which QR codes you scan.

How to opt out:

• iOS — the app asks for your permission before sharing your advertising identifier. You can change your choice at any time in Settings → Privacy & Security → Tracking. If you don’t allow tracking, we don’t share your advertising identifier.
• Android — you can delete or reset your advertising ID in your device’s ad settings (usually Settings → Google → Ads, or Settings → Privacy → Ads).
• On Meta — you can review and disconnect activity that apps share with Meta under “Your activity off Meta technologies” in Meta’s Accounts Center, and control which ads you see in Ad preferences.

Meta processes this information under its own terms and its Privacy Policy. The Meta SDK runs only in our mobile app; our website does not use it.

7. International Data Transfers

CacaoCash operates globally. Your information may be transferred to and processed in countries other than your own, including the United States. When we transfer data internationally, we use standard contractual clauses or other appropriate safeguards to protect your information in accordance with applicable law.

8. Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Specifically:

• Account and identity verification records (such as your name, phone number, ID number and verification results): while your account is open, and afterwards for as long as applicable financial and anti-money laundering laws require, typically 5 to 10 years after your account is closed
• Transaction records: for as long as financial, tax and anti-money laundering laws require, typically 5 to 10 years
• Crash and error reports: up to 90 days
• Marketing preferences: until you withdraw consent

Deleting your account: in the app, tap your profile picture on the Home screen, then Settings → Delete account. If you can’t open the app, email privacy@cacaocash.com from the email address on your account. Deleting your account immediately removes your sign-in account and your email address; other records are kept as described above. Full steps are at cacaocash.com/delete-account.

9. Your Rights

Depending on your location, you may have the right to:

• Access — request a copy of the personal data we hold about you
• Correction — ask us to correct inaccurate or incomplete data
• Deletion — request deletion of your data (subject to legal retention requirements)
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Restriction — request that we restrict processing of your data
• Opt out of marketing — unsubscribe from marketing emails at any time

To exercise any of these rights, contact us at privacy@cacaocash.com. We will respond within 30 days.

10. Security

We implement industry-standard security measures including encryption in transit (TLS) and at rest, access controls, and regular security audits. However, no system is 100% secure. If you believe your account has been compromised, contact us immediately at info@cacaocash.com.

11. Children's Privacy

CacaoCash is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal data, contact us and we will delete it promptly.

12. Cookies

We use cookies and similar technologies on our website. For full details, see our Cookie Policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through a prominent notice in the app. The "Last updated" date at the top of this page indicates when the policy was last revised. Continued use of CacaoCash after changes constitutes acceptance of the updated policy.

14. Contact Us

For privacy-related questions, requests, or complaints:

• Email: privacy@cacaocash.com
• General inquiries: info@cacaocash.com
• Company: DEKSxyz, Inc.