SpringCash Privacy Notice
1. Welcome to the SpringCash Privacy Notice
1.1 SpringCash LLC (including companies controlled by or under common control with SpringCash LLC, collectively the "SpringCash Group") respects your privacy and is committed to protecting your personal data. This Privacy Notice explains how personal data is handled and outlines your rights and legal protections.
1.2 This Notice covers data collection and processing when you use SpringCash websites, mobile apps, or services (e.g., newsletter sign-up, online application, queries, job applications).
1.3 This Notice should be read alongside related SpringCash policies on Data Protection Laws.
1.4 SpringCash is committed not just to legal compliance but also to respectful and fair data handling.
1.5 SpringCash services are not intended for consumers.
1.6 This Notice supplements other specific notices and does not override them.
2. Our Role as Data Controller
2.1 SpringCash LLC (48 Bedford St. #5B, New York, NY, 10014, USA) is the data controller for the purposes of this Privacy Notice.
2.2 Questions? Contact us: privacy@springcash.com
2.3 You may complain to a data protection authority, but SpringCash asks to be contacted first.
2.4 Third-party links: The site may link to third parties. SpringCash does not control their privacy practices, so please review their privacy notices.
3. What Personal Data Do We Collect?
Personal data is any information that can identify an individual. Collected data includes:
- Identity Data: name, username, title, date of birth
- Contact Data: address, email, phone
- Financial Data: bank and payment info
- Access Data: credentials for third-party accounts
- Transaction Data: details of payments and services
- Technical Data: IP address, browser info, device usage
- Profile Data: preferences, feedback, history
- Usage Data: website interaction data
- Marketing Data: marketing preferences
- Recruitment Data: job application details
- Records of Discussions: communications and support logs
4. Purposes and Legal Bases of Data Processing
Data is processed for various purposes, including:
- To register customers
- To complete the Online Application Process
- To fulfill contractual obligations
- For communication and surveys
- For recruitment
- For marketing and performance analysis
- For legal compliance, fraud detection, audits
Aggregated Data is used for statistical purposes but is not considered personal unless linked back to an individual.
We do not collect special category data (race, health, etc.)
Identity verification is handled by Persona, who is an independent data controller.
5. How Is Your Personal Data Collected?
a. Direct interactions: via forms, emails, calls, applications, surveys, etc.
b. Automated technologies: via cookies, logs, and analytics tools
c. Third parties/public sources: e.g., LinkedIn, Plaid, Persona, Apollo, Lusha
6. How We Use Your Personal Data
6.1 Lawful Bases
- Contract performance
- Legitimate interests (balanced with your rights)
- Legal obligations
6.2 Marketing
Tailored offers and updates may be sent. You can opt out at any time.
6.3 Cookies
Manage cookies in your browser or via the cookie preference center. Disabling may affect functionality.
6.4 Purpose Limitation
Data is used only for the purposes described unless a compatible reason arises.
7. Disclosures of Your Personal Data
Data may be shared with:
- Internal SpringCash teams
- Approved external partners (e.g., Persona, Plaid)
- Parties involved in mergers, acquisitions, or sales
All third parties must comply with data protection laws and SpringCash's instructions.
8. International Data Transfers
Protection is ensured when transferring data outside the U.S., using appropriate safeguards like Standard Contractual Clauses.
9. Data Security
Strong security measures, access controls, and breach response protocols are implemented to protect your data.
10. Data Retention
Data is retained only as long as necessary, per internal policies and legal requirements.
- Basic data is kept for 7 years
- You can request deletion (subject to exceptions)
- Data may be anonymized for research
11. Your Legal Rights
You may:
- Request access, correction, or deletion of your data
- Object to or restrict processing
- Request data transfer
- Withdraw consent at any time
To exercise these rights, email privacy@springcash.com. Identity verification may be required. Most requests are fulfilled within one month.
12. Glossary
Data Protection Laws: includes GDPR, CCPA, and other U.S. state privacy laws.
Personal Data: info that identifies a person.
Legitimate Interest: business interest balanced with your rights.
Performance of Contract: required data processing to fulfill an agreement.
Legal Obligation: processing required by law.
Internal Third Parties: SpringCash Group entities.
External Third Parties: service providers, professional advisers, regulators.
13. Changes to This Privacy Notice
This notice may be updated. Please review periodically.
Effective Date: June 3, 2025