SpringCash Privacy Notice

1. Welcome to the SpringCash Privacy Notice

1.1 SpringCash LLC (including companies which are controlled by, or under common control with SpringCash LLC, collectively referred to as the "SpringCash Group") respects your privacy and is committed to protecting your personal data. This Privacy Notice explains how we look after your personal data and outlines your privacy rights and legal protections.

1.2 This Notice explains how we collect and process your data 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 in conjunction with 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 we ask you to contact us first.

2.4 Third-party links: Our site may link to third parties. We don’t 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. We collect:

  • 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

We process your data 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 you.

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:

We may send tailored offers and updates. You can opt out at any time.

6.3 Cookies:

Manage cookies in your browser or via our cookie preference center. Disabling may affect functionality.

6.4 Purpose Limitation:

We use your data only for the purposes described unless a compatible reason arises.

7. Disclosures of Your Personal Data

We may share your data 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 our instructions.

8. International Data Transfers

We ensure protection when transferring data outside the U.S., using appropriate safeguards like Standard Contractual Clauses.

9. Data Security

We implement strong security measures, access controls, and breach response protocols to protect your data.

10. Data Retention

We retain data only as long as necessary, per our internal policies and legal requirements.

  • Basic data is kept for 7 years
  • You can request deletion (subject to exceptions)
  • We may anonymize data 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. We may need ID verification. 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: our 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

We may update this notice. Please review periodically.
Effective Date: June 3, 2025