User Agreement

Please read these terms and conditions of the User Agreement carefully as they set out our respective legal rights and obligations as well as remedies. By using Yepy you agree to comply with this User Agreement.

  1. GENERAL
    1. This User Agreement (hereinafter, the “Agreement”) is an agreement between you (hereinafter, the “Yepy User” and/or “User”) and CASHOFF LIMITED (the company incorporated under the English law; VAT number: 280267306; registration number: 10995366; registration address: The Shipping Building, The Old Vinyl Factory, Blyth Road, Hayes, London, Greater London, United Kingdom, UB3 1HA, business address: Level39, One Canada Square, Canary Wharf, London, United Kingdom, E14 5AB, email: help@yepy.com, phone: +44 330 010 16 39, +44 800 310 10 17), collectively referred to as the Parties, and individually as the Party. Hereby the Parties warrant that they each have the right, authority and capacity to enter into and be bound by the terms of this Agreement.
    2. This Agreement together with its Annexes governs the use of the yepy.com website and the Yepy mobile application (hereinafter, “Yepy”) that offer reference and analytical information on the range, prices, discounts, offers for consumer goods of the relevant region (the User selects the region when installing the application or at the beginning of the Yepy use), the opportunity to take part in promotions, receive analytics, reports of your income and expenses, as well as recommendations on budget planning.
    3. For users around the world to enjoy the whole range of the Yepy services as listed in Clause 1.2., CASHOFF engages with its Partners from various regions to support Yepy functioning therein. If you are based in APAC, the Russian Federation, Eurasia or CIS countries, the Yepy functioning is backed by the companies below respectively:
      • CASHOFF LIMITED, Hong Kong, with the registered address: Flexi-Space, 123, Smart-Space 2, Units 1205-1208, Level 12, Cyberport 2, 100 Cyberport Road, Hong Kong, email address: help@yepy.com, Phone number: +852 800 906 459, +852 580 301 66.
      • CASHOFF LLC, the Russian Federation, with the registered address: Suite 253, 17, Varshavskoye shosse, 117105, Moscow, Russia, email address: help@yepy.com, Phone number: 8 800 511 31 06, +7 495 747 59 97.
    4. This Agreement and the relationship between us shall be governed by the laws of England and Wales and subject to the exclusive jurisdiction of the Courts of England and Wales.
    5. This Agreement is provided to you and concluded in English, other versions of this Agreement are translations of this Agreement. If there is any inconsistency or conflict between the English and other versions, the English version shall prevail.
  2. SCOPE OF THE AGREEMENT
    1. This Agreement applies to all Yepy Users who visit Yepy, use its Services and the paid subscription. In this regard, the Agreement contains general provisions for Yepy and its paid subscription use and specific terms of use for the Yepy Services. General and specific terms may vary depending on Your region.
    2. The general terms for Yepy use govern the following:
      • getting free access to reference information on the range, prices, discounts, offers for consumer goods and services (viewing an offer list for the specific region);
      • accessing Yepy content, its databases within the framework of its functionality for the dedicated region;
      • viewing a list of previously downloaded receipts and their details;
      • viewing analytics and reports on income and expenses, recommendations on budget planning (Yepy paid subscription), see related details in Annex III.
    3. The specific terms set in Annex I, Annex II and Annex III of this User Agreement govern the use of the Yepy Services. These Services ensure data aggregation of the User's payment templates from personal accounts and the display thereof; data gathering across user bank accounts and making it available from one screen; having Users’ data analyzed to help them manage their money wisely; Users' taking part in promotions and receiving cashback. There are the following Yepy Services:
    4. The use of Yepy or any of its Services shall determine the data set (data capacity) necessary for its adequate rendering (see Clause 6 of the Privacy Policy). The User gives their consent to the processing of the data received by CASHOFF within the framework of the described Services.
  3. ACCEPTANCE OF TERMS
    1. To use Yepy you must have full legal capacity (the User has to be at least eighteen (18) years old or of the legal age of majority within the jurisdiction where the User resides) to enter into this Agreement. Accepting the terms of this Agreement explicitly or confirming them in Yepy or concluding an implied-in-fact contract which testifies to the consent shall be deemed as acceptance of all of the Agreement terms and conditions including its Annexes. By accepting the Agreement, the User is deemed to have agreed that they have fully read and agreed to these terms and conditions. The acceptance is not subject to any time restriction, the Terms have been concluded for an indefinite term. By purchasing Yepy subscription, the User agrees with the procedure, scope (see Annex III) and conditions of the subscription. Unless specified otherwise, Yepy subscription is deemed active as of the moment of its acquisition by the User (by clicking the “Buy” button).
    2. Revocation of Acceptance.The User may withdraw from the User Agreement. User’s revocation of acceptance by withdrawing from the Agreement terms and conditions shall serve as the basis for the termination of the contractual relationship between the Company and the User (termination of this Agreement).
  4. DEFINITIONS AND INTERPRETATIONS

    Agreementmeans this agreement including all subsequent changes thereto.

    CASHOFF,the Company, we, us or ourmeans CASHOFF as specified in Clause 1.1. of this Agreement.

    Authorizationmeans certifying the User's right to access the Account by successfully entering the User credentials in Yepy.

    Affiliatesmean entities directly or indirectly controlling, being controlled by, or under common control with CASHOFF.

    Partnersare service vendors, subcontractors, affiliates or payment processors that help CASHOFF render its services in regions, and who are the data operators. In order to render the scope of services in Yepy, CASHOFF may rely on various third-party vendors. The vendors may be based inside as well as outside the EEA, including Asia and Russia. CASHOFF may rely on its partners for the following:

    1. rendering customer or payment processing services;
    2. verifying the information against publicly available databases;
    3. providing technical framework;
    4. ensuring product functioning and debugging;
    5. providing services through third-party platforms and software (e.g. via API integration)

    Contentmeans any information, data, texts, messages and other materials posted on the website or in the mobile application.

    Loginmeans the name (ID) of the Personal Account with Yepy.

    Passworddenotes a user account element, a set of secret characters used to authenticate Users and to protect data from unauthorised access.

    Personal Accountor Account means a User data set stored in the computer system which is used to identify (authenticate) them and provide them with access to their data and settings. The User is eligible for one Personal Account only, in case of the customer's bad faith/fraudulent conduct regarding their Personal Account, or one user signing up for the Offers from multiple accounts, the Company may recognize such a user account breaching the Terms and renege its obligations.

    Yepymobile applicationmeans an application on a mobile device which enables the User to perform specific actions with the Personal Account on the mobile device.

    Servicesmean a set of software and hardware and its updates determined by CASHOFF and provided to the User through the Yepy mobile application and at the yepy.com website.

    Regionmeans the region selected by the User at the beginning of Yepy use.

    User, you or yourmeans any person who is registered at the yepy.com website / Yepy mobile application or uses the Services, entered into this Agreement and who has the Internet access.

    Website (site)means a URL address such as https://yepy.com.

  5. YOUR ACCOUNT AND ACCESS
    1. In order to use Yepy and its Services, you will need to create a Personal Account by providing your e-mail or mobile phone number, a password, and accepting the terms and conditions of this Agreement and our Privacy Policy. By creating a Personal Account, you warrant to us that you are not acting on behalf of, or for the benefit of anyone else.
    2. When logging in the Personal Account you must provide complete and accurate information for participating in loyalty programs, receiving cashback remuneration and managing your money in online banking. When providing us with this or any other information that may be required, you hereby confirm that the information is accurate and authentic. If your information changes at any time, please ensure you promptly update your Personal Account to reflect those changes.
    3. Yepy Subscription
      1. The use of Yepy paid subscription is determined by the provisions of this Agreement and its Annex III. To become a Yepy subscriber, the User must pay the cost of a weekly, monthly, annual or unlimited subscription. The cost of the subscription shall be paid by the User at the beginning of the period. The user can also pay the maximum cost of service on a nonrecurring basis.
      2. The subscription fees are set in currency of the region selected by the user and indicated by CASHOFF in the dedicated section of the Yepy app while their validity period is displayed in the Personal Account.
      3. We reserve the right to change, amend, modify or vary the price, package and/or functionality of Yepy paid features. If we change the price and package, we will give you notice in advance of these changes.
      4. The User guarantees that they have the right to use the means chosen by them to pay for the subscription without violating the governing law. The company shall not be liable for possible loss to third parties arising from the use of payment funds not belonging to the User.
      5. The User shall follow the payment instructions for the procedure and manner of payment, including the rules of input of the message and the procedure for the input of capital and lowercase letters, figures and input language.
      6. You are responsible for paying any other charges that you may incur by transferring the subscription cost to the Company, including fees, commissions and other types of payments, at your own expense. You expressly agree that CASHOFF shall not for any reason whatsoever be liable to refund the full amount or any part of fees, charges and taxes paid by you.
      7. The money deposited by the User shall not be subject to return if the User's actions that violate this Agreement have led to the termination of the Yepy paid features rendering, and also if the Yepy paid features rendering has become impossible upon the User's fault.
  6. REGISTERED USER’S OBLIGATIONS
    1. You agree to (a) provide true, accurate, current and complete information about yourself; (b) maintain and promptly update the information to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or if CASHOFF has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, CASHOFF has the right to suspend or terminate your registration and deny any current or future use of the Services.
    2. Access

      Provided that the account assigned is duly filled, you acquire full rights to use the Services. To access the Services, you must have the necessary equipment (such as a smartphone or tablet) and associated telecommunication service subscriptions to access the Internet.

    3. Mobile Device Terms
      1. If you use the mobile application to access the Services, this mobile application is intended solely for your personal non-commercial use.
      2. CASHOFF is the holder of the rights to Yepy and Services as well as of the trademark rights or any other property rights, including all applications, updates, extensions and restored versions of the application. You hereby undertake not to modify, adapt, translate, decompile, reverse engineer, decompress, or otherwise try to detect the source code of the whole or a part of the Application, and you shall not remove, obscure, or alter CASHOFF's copyright notice, trademarks or other proprietary rights notices affixed to, contained within, or accessed in conjunction with or by Yepy.
      3. Device Specific Additional Terms

        iOS – Apple

        These mobile device Terms are not an agreement between you and Apple. Apple is not responsible for the application and the content thereof.

        CASHOFF grants you the right to use the app only on an iOS Product that you own or control and as permitted by the App Store Terms of Service.

        Android – Google

        These mobile device Terms are not an agreement between you and Google. Google is not responsible for the App and the content thereof.

        CASHOFF grants you the right to use the application only on an iOS Product that you own or control and as permitted by the App Store Terms of Service.

    4. Login, Password and Security
      1. As part of the registration and account creation process, you will select a login and a password valid only for the region you specified. Your Personal Account and Login shall not be transferred or sold to another party and you are solely responsible for maintaining the confidentiality of your credentials and for all activities that occur under your Login and Password. For the subsequent automatic authorization in Yepy, you can store the Login and Password (as cookies) on the hardware or software you use.
      2. You are solely responsible for maintaining the security and confidentiality of your Personal Account data, password and any activity relating to your Personal Account. Your Personal Account is not transferable to another party.
      3. You agree to (a) immediately notify CASHOFF of any unauthorised use of your Login or Password or any other breach of security and (b) ensure that you properly log out of Yepy at the end of each session. CASHOFF can’t and will not be liable for any loss or damage arising from your failure to comply with this clause.
  7. ACCOUNT MANAGEMENT
    1. Updates to your Personal Account

      You agree to keep your Personal Account data current, complete and accurate by periodically updating the information through Yepy. You must be logged in Yepy and enter your password to change your account data. You may check your account status and a transaction history at any time via the application. You shall maintain the confidentiality of your account data, including login and password which you use to access Yepy. Any use of your login and password will be deemed to be you, and the Company is entitled to act on the instructions received under your Password. If there is a breach of security through your Account, you shall immediately change your password and notify us of such a breach. You agree that, unless you have first notified us immediately of any such breach, we should assume that any instruction transmitted using your login and password is yours and has been authorized by you, and we will have no obligation to inquire into the propriety of such instruction.

    2. Active Personal Account

      An Active Personal Account means you have been engaged in one of the following activities within the last twelve (12) months: (i) have updated your Personal Account data, (ii) have accrued cashback or (iii) have logged in your account. If your Personal Account remains inactive for more than twelve (12) consecutive months and the balance in your inactive account is or becomes zero, the Company reserves the right to close the account permanently and cease to maintain your Personal Account records and access to Yepy.

  8. INTELLECTUAL PROPERTY RIGHTS
    1. All rights, titles and interests in Yepy and the Services belong to the Company or its licensors. The Company labels may not be used in connection with any product or service that is not in the Company’s possession or in any manner that is likely to cause confusion among customers, or in any manner that disparages or discredits the Company.
    2. Yepy and its Services as well as all the necessary programs related to them, contain confidential information and are protected by the intellectual property legislation on CASHOFF's side.
    3. You hereby acknowledge that the domain name, configurations, design elements, visualization, software, codes, algorithms, scripts, developments, trade secrets, pictures, graphics, text, and all information displayed on the website / in the mobile application are the objects of CASHOFF's exclusive rights in accordance with the laws on the protection of intellectual property rights, including domestic and international copyright laws, on the protection of trademark rights, as well as on the maintenance of trade secrets.
    4. You acknowledge that CASHOFF is the sole owner of the information presented in Yepy and you do not acquire any of those ownership rights by printing or downloading any of the information from or by using Yepy. You shall take no action to decompile, reverse-engineer, infringe, or misappropriate any of CASHOFF’s Intellectual Property, nor shall you register or attempt to register in your own name anywhere in the world any of the CASHOFF Intellectual Property or elements thereof.
    5. CASHOFF grants you a personal non-exclusive and non-transferable right to use Yepy, provided that neither you nor any other person with your assistance will:
      • copy or alter the software;
      • create programs derived from the software;
      • penetrate into the software in order to obtain program codes.
      • sell, assign, lease, transfer to third parties in any other form the rights with respect to the software of the services provided under the Agreement;
      • modify services, as well as obtain unauthorised access to them.
    6. Except as expressly provided in this Agreement and the applicable laws, no Content may be copied, reproduced, processed, distributed, published, downloaded, transmitted, sold or otherwise used in whole or in part without the prior permission of the copyright owner or unless the copyright holder directly expressed his consent to the free use of the Content by any other person.
  9. CASHOFF'S RIGHTS AND OBLIGATIONS
    1. CASHOFF shall:
      • maintain the proper operation of the Services;
      • protect the information provided;
    2. CASHOFF has the right to:
      • post advertising information or any other information for public distribution without Yepy and Service content prejudice on the user’s account page;
      • send informational messages to users;
      • terminate the Personal Account and remove any Content without prior authorisation in the event of access use suspension or violation of this Agreement.
    3. Changes to Yepy and the Services, their availability
      1. CASHOFF reserves the right to change or suspend, temporarily or indefinitely, the operation of the Services at any time (should the Services updates be related to the need to obtain additional User data, CASHOFF notifies the User thereof and receives the consent), as well as the dedicated components of the website/application with or without notice to the User.
      2. Maintenance work is done by CASHOFF on a regular basis and in accordance with the schedule. For our part, we will do our best so that the maintenance does not in any way affect the functionality of the services for users, however, periods of temporary unavailability of the service are possible.
    4. Advertising in Yepy

      CASHOFF is responsible for advertisements placed on the Service within the limits established by the applicable laws.

  10. USER'S RIGHTS, LIABILITIES AND WARRANTIES
    1. You shall:
      • comply with the provisions of this Agreement;
      • not disrupt the normal operation of Yepy and its Services;
      • provide real and complete data, keep it accurate and truthful;
      • inform CASHOFF about unauthorised access to the Services through the Personal Account and/or unauthorised use of the Login and Password;
      • not provide access to your Personal Account or to any particular information contained therein to third parties;
      • take appropriate measures to ensure the login (e-mail) and password security, specify the real email in the appropriate field of the signup page, bear full responsibility for any actions committed with the account as well as for any consequences that could entail or entailed such use;
      • be responsible for any information, data, text, messages and other materials (Content) you publish in Yepy;
      • not use Yepy in violation of any applicable law or regulation and not post links to web resources contrary to applicable law on the website;
      • not use Yepy to download, send, transmit or otherwise post Content that is unlawful or violates the legal rights of others;
      • not pretend that you are, or that you represent someone else, including the CASHOFF employees;
      • not publish any advertisement or related materials on Yepy;
      • not compromise (unauthorised penetration) any technological Services’ components, databases and other Site components;
      • not transfer any information or software that contains viruses or other malicious components.
    2. You have the right to:
      • be provided with access to your information by uploading the data on Yepy using your login and password;
      • make changes and corrections to your information in the Personal Account providing the reliability of such information;
      • enquire CASHOFF about the data processing;
      • delete your information from the Account;
      • delete your Account and by doing so all information regarding the User’s data will automatically be erased;
      • send appeals, proposals and claims on the implementation of this Agreement, as well as on all matters related to the site/mobile app functioning, rights and third parties' interest violation concerning Services use to CASHOFF (these complaints can be sent to the mailing address specified in Clause 1.2. of this Agreement).
    3. YOUR WARRANTIES
      • The User undertakes to take all reasonable measures to prevent any unauthorised access of third parties to the data related to the Service.
      • The User shall be liable for maintaining control over their personal account and keeping any third parties away from undertaking any activities therein. Any action with regard to the User Account after the authorisation has been successfully completed is deemed taken by the User personally.
      • The User should notify the Company of any change in their data by updating personal records in the Personal Account accordingly. Adverse consequences caused by failure to notify of the changes in the data are the User's liability.
      • The User warrants that the Personal Account has not been deleted, blocked and/or deactivated on account of fraudulent acts; and/or breach of this Terms by the User; and/or breach of the applicable laws by the User. In case the User violates the warranties, stipulated hereto, the Company reserves the right to refuse the User's registration and/or delete the User's Account.
  11. VIOLATIONS
    1. We may investigate any potential or suspected violations of the User Agreement, security protocols or best practices, third-party rights or applicable law; any actions or any other misconduct or potential abuse on or through the Services or such attempts. When assessing whether and which measure(s) to take against a user, we will take the legitimate interests of the user into account, and shall, in particular, consider whether the User is responsible for the misconduct.
    2. We reserve the right to report any activity that we believe to be illegal or otherwise in contravention of this User Agreement and we will respond to any verified requests relating to a criminal investigation (i.e. a subpoena, court order or a substantially similar legal procedure) from local and foreign law enforcement or regulatory agencies, other government officials or authorized third-parties.
    3. CASHOFF reserves the right not only to report that there is or has been a reasonable likelihood of a security breach of the website or systems that could result in the unauthorised disclosure of customer information but also to take any other actions deemed necessary and/or require you to provide us with information related to any such breach.
  12. LIABILITY
    1. You understand and agree that you are using Yepy (free or paid subscription) and its Services on an ‘as is’ and ‘as available’ basis. User discretion is advised. CASHOFF does not take any responsibility for the compliance of the Service with your purposes. The Yepy subscription features are offered by the Company for acquisition in the form in which they are available and are provided by the Company at the time of the acquisition, with no direct or indirect guarantees provided.
    2. CASHOFF is not liable for the Content you post in Yepy, however we have the right to refuse to post or remove any Content that is available in Yepy. We also have the right to change the form, order and size of the information being posted.
    3. The information, materials and opinions contained in Yepy are for general information purposes only, should not be construed as legal, accounting, financial or tax advice or opinion on any specific facts or circumstances and should not be relied upon in that regard. The Company reserves the right to correct any errors or omissions in the Services.
    4. In addition, to the maximum extent permitted by law, CASHOFF is not liable for: (a) any special, indirect, or consequential damages; (b) loss of profits, goodwill or reputation, or other intangible losses; (c) damages relating to (i) your access to, use of, or inability to access or use the Services; (ii) viruses or other malicious software obtained by accessing Yepy or our Services or those of any site, services, or tools linked to Yepy or the Services; (iii) any user content or content of third parties.
    5. CASHOFF ensures the Service functionality and operation, undertakes to promptly restore its operability in the event of technical failures and interruptions. CASHOFF is not liable for temporary interruptions and interruptions in the Services operation as well as for the loss of information caused by them. The Company is obliged to take measures within its competence to eliminate as soon as possible any technical failures and errors in the provision of a paid features in the event of their occurrence, regardless of the reasons for their occurrence. At the same time, the Company does not guarantee complete absence of technical errors and failures.
    6. CASHOFF is not liable for any damage caused to your or somebody else’s personal computer, mobile device, any other equipment or software caused by or associated with downloading materials from Yepy or from links posted in it.
    7. Links
      1. Yepy or third parties may provide links or access to other websites or resources on the Internet. Because CASHOFF has no control over such sites and resources, you acknowledge and agree that CASHOFF is not responsible for the availability of such external sites or resources and does not endorse and is not responsible or liable for any content, advertising, products or other materials on or available from such sites or resources. You further acknowledge and agree that CASHOFF shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of, or reliance on, any such content, consumer goods or services available on or through any such site or resource.
      2. The links or manuals on downloading files and/or installing third-party programs in Yepy do not mean CASHOFF supports or approves of these actions.
      3. If you decide to leave the Site and access any third-party website, use or install third-party programs, you do so at your own risk, and from that time you should be aware that the terms and policies of this Agreement no longer govern. Further on, you should review the applicable terms and policies including privacy and data gathering practices of any site to which you navigate from Yepy.
    8. CASHOFF does not bear responsibility for the User's compliance with the terms of payment for the Yepy subscription, including any financial losses that occurred due to circumstances beyond the control of the Company.
    9. CASHOFF does not bear responsibility for the inability to provide paid features to the User for any reasons beyond its control, including disruption of communication lines, equipment malfunctions, non-fulfilment of obligations of suppliers of certain services, etc.
    10. The total liability of the Company within the framework of the paid features is, in any case, limited to the funds deposited on the Company's account by the User.
    11. CASHOFF is exempted from liability for violation of the terms of the User Agreement, if such violation is caused by force majeure circumstances, including actions of public authorities, fire, flood, earthquake other spontaneous actions, lack of electricity and/or computer network failures, strikes, civil unrest, unrest, any other circumstances, not limited to those listed, which may affect the provision of the paid service.
    12. The limitation of liability contained in these Terms of Use will apply to the fullest extent permitted by applicable laws.
    13. The User hereby releases CASHOFF from any liability arising from any Company's delay in performance or non-performance under this Agreement caused by an event of force majeure. Force majeure includes any circumstances that could not be reasonably foreseen or are caused by events beyond Company's reasonable control, including without limitation acts of God, normative acts issued by state or government institutions, strikes, war or any kind of military operations, blockade, epidemics, acts or threats of terrorism, etc.
  13. WARRANTIES

    CASHOFF hereby warrants that:

    • its’ issuance of this Agreement does not and will not breach any other agreement or terms and conditions to which it is a party; and
    • it has the necessary authority to issue this Agreement.
    • You hereby warrant to CASHOFF that:
    • Your acceptance of this Agreement does not breach any other agreement or terms and conditions to which You are a party; and
    • you will provide all the information required for the provision of the Services in good faith and will not knowingly, recklessly or carelessly make any misrepresentations or incorrect statements; and
    • you will comply with any additional terms and conditions published by CASHOFF from time to time.
  14. DISCLAIMER
    1. The information set forth on and the description of the Yepy Services were believed by CASHOFF to be accurate at the time of preparation or obtained from sources believed to be reliable. CASHOFF makes no express or implied warranties, either of merchantability, fitness for a particular purpose or of any other nature regarding the information or services descriptions set forth in Yepy.
    2. The Company shall not be held liable for suspensions or failures that cause User's inability to use the Service if such non-compliance or failure took place on account of Force Majeure, i.e. exceptional and unavoidable emergencies, including technical malfunction, software errors, or other circumstances going beyond the will of the parties, which could not have been forecasted or avoided.
    3. The Company reserves the right to cease, alter or temporarily stop Yepy work unilaterally if any of its functionality cannot be used as planned, including any reason uncontrolled by the Company which distorts or influences the implementation, security, integrity and proper functioning of the website/application.
    4. The Company may carry out maintenance with a temporary suspension of Service without prior notice to the User.
    5. The Company shall not be held liable for any hacker activity aimed at disrupting Yepy's normal functioning, while also taking reasonable steps to eliminate errors and vulnerabilities of the service.
    6. The Company shall not be held liable for the connection quality, quality of the internet, as well as for the malfunction of the User's internet provider, equipment or software, or other causes beyond reasonable control of the Company as well as for all related negative consequences.
    7. The Company hereby excludes any liability for the User's loss arising out of virus malware or other malicious software in the hardware and the software that the User utilises to access the system.
  15. TERM AND TERMINATION
    1. This Agreement shall remain valid and applicable to you for so long as you remain a user in good standing of CASHOFF.
    2. You may terminate this Agreement by closing your Account at any time. To do so, open the settings of your Personal Account, select “delete my account” and cease to use Yepy or contact our support team. If you request CASHOFF to close your Account, this request will be equated to the request to terminate this User Agreement.
    3. We may terminate this Agreement by giving you 30 days' notice (via Yepy or by e-mail). CASHOFF reserves the right, at any time and without prior notice to You, to terminate its relationship with you in the event that you are in breach of any of your warranties or obligations under this Agreement and, in particular, your undertaking to not misuse or misrepresent the scope and validity of the Services to third parties, particularly where the name and reputation of CASHOFF and/or any of its Affiliates is or is liable to be harmed or tarnished as a result.

      All provisions of the Terms which by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity and limitations of liability.

  16. CHANGES TO THIS AGREEMENT
    1. CASHOFF reserves the right to change this Agreement at any time and to reflect changes in the applicable laws, technical or security requirements, or the Yepy functionality from time to time. Any non-material change to this User Agreement will become effective on the date the change is posted and any material changes will become effective thirty (30) days from their posting on Yepy.
    2. You may terminate the Agreement as set out in Clause 15.2 if any change proposed does not suit you. You acknowledge and agree that your continued use of Yepy following the posting of changes to this Agreement constitutes your agreement to such changes.
  17. CLAIMS MANAGEMENT
    1. This Agreement shall be governed by and construed under the laws of England and Wales. The Company and the User will be liable for failure to perform their obligations in accordance with English law.
    2. Any disputes arising from the execution of the Terms shall be considered in mandatory compliance with the claims management procedure. In case of failure to reach agreement and inability to settle the dispute through negotiations the Parties submit to the exclusive jurisdiction of the Courts of England and Wales.
    3. If you are a resident of the Russian Federation, one of the Eurasian or CIS countries, should you have any dispute, you can send your claim to our Partners in the relevant region as stated in Clause 1.3 of this User Agreement.
    4. In case the User files a claim occasioned by Bonus rewarding/writing off as well as with any other claim arising out of the Annex I to the Company, the latter one undertakes to use its best endeavours to pursue the investigation into the claims soonest. In any case and in case of any claim, the Company and Partners or banks' liability under the terms to the User is limited to the Cashback amount or the Subscription cost given the dispute is arising therefrom.
  18. FINAL PROVISIONS
    1. Any disputes and disagreements arising from or in connection with this Agreement shall be amicably resolved by the Parties to the maximum extent. In the event that disputes are not resolved through negotiation, the disputes shall be resolved in accordance with the procedure established by applicable law.
    2. If any provision of this Agreement is found to be invalid, the invalidity of such provision will not affect the validity of the remaining provisions of this Agreement or any Service-specific terms and conditions.
    3. You agree that CASHOFF may provide notice or other information to you by posting it in Yepy or sending it to the email address listed in your Account. You need to specify your email in the Personal Account to be able to receive communications and information relating to the Services.
    4. You may terminate your consent to receive required disclosures through email by contacting CASHOFF via its email specified in Clause 1.5. of this Agreement.
    5. CASHOFF reserves the right to close your Account if you violate the terms of this Agreement or other additional agreements or the CASHOFF’s Privacy Policy.

ANNEX I – CASHBACK PER ITEM SPECIFIC TERMS OF USE

  1. SCOPE
    1. This Annex I contains specific terms governing your use of Cashback per Item (hereinafter in this Annex I, the Service) in Yepy.
    2. The Cashback per Item Service makes a certain set of features available for the User.
      • If you are based in the European Union or the EEA, the list of Cashback per Item features for you is as follows:

        • Viewing and signing up for Offers to qualify for cashback per eligible item on a receipt.
        • Reward issuing for purchasing an offered item;
        • Purchase itemization (based on receipt or loyalty program data) from retail stores;
        • Data on cashback rewarded for eligible items which match the Offers in the receipts uploaded by the User, as well as viewing the list of previously uploaded receipts and their details;
        • Withdrawing the reward to a user's banking card or an e-wallet.
      • If you are based in the APAC region the list of Cashback per Item features for you is as follows:

        • Viewing and signing up for Offers to qualify for cashback per eligible item on a receipt.
        • Reward issuing for purchasing an offered item;
        • Purchase itemization (based on receipt or loyalty program data) from retail stores;
        • Data on cashback rewarded for eligible items which match the Offers in the receipts uploaded by the User, as well as viewing the list of previously uploaded receipts and their details;
        • Withdrawing the reward to a user's banking card or an e-wallet.
      • If you are based in the Russian Federation or one of the Eurasian or CIS countries, the list of Cashback per Item features for you is as follows:

        • Viewing and signing up for Offers to qualify for cashback per eligible item on a receipt.
        • Reward issuing for purchasing an offered item;
        • Purchase itemization (based on receipt or loyalty program data) from retail stores;
        • Receiving purchase itemisation data from the Federal Tax Service:
        • Data on cashback rewarded for eligible items which match the Offers in the receipts uploaded by the User, as well as viewing the list of previously uploaded receipts and their details;
        • Withdrawing the reward to a user's banking card or an e-wallet.
  2. DEFINITIONS AND INTERPRETATIONS

    Cashbackmeans Bonuses (bonus points) rewarded by the Company to Users for Purchases they make which are recorded in the Account and paid in cash equivalent according to the procedure described in the Offer Terms and Conditions that are published in Yepy. Cashback is paid to consumers who purchased an item/service for personal, family, household or other use unless those related to entrepreneurial activity. Unless rewarding a Bonus to the consumer for a purchase made, any other use of the website or the mobile application shall constitute a breach of these Terms. The assessment thereof shall be at the Company's discretion.

    User Profilemeans a Yepy Interface that enables the User to access their data and work with them.

    Offersmean campaigns aimed at encouraging User engagement with purchasing items eligible for a reward for reasons contemplated by the Offer Terms and Conditions, with the latest Offers posted in Yepy.

    Offer Terms and Conditionsmean terms and conditions published in the Offers tab in Yepy which set forth Offer details, a list of items (services) eligible to participate in the Offer, Offer timescale, Cashback amount to be rewarded and paid for purchasing an item (a service), maximum Cashback amount to be distributed across the Offer and other details on the Offer procedure and prerequisites if any.

    Consumer's Balancemeans an overall result of all Bonus transactions as of now.

    A Bonus Transactionmeans depositing or withdrawal transactions, including bonus direct debits from the User's account which affects the Consumer's Balance.

    Bonus Direct Debitmeans withdrawal of bonuses which have been previously rewarded to the User Account without reward payment.

    A Refundable Transactionmeans withdrawal and/or depositing Bonuses to the User Account if the User returns the item, given such purchase was eligible for withdrawal and/or depositing the User's Bonuses.

    Bonus Rewardmeans transactions which result in an increase of Bonuses in the User Account.

    Bonus Withdrawalmeans transactions that result in a decrease of Bonuses in the User Account upon the following: a Bonus Direct Debit, Bonus Withdrawal with reward payment by transferring money to the User's bank card account or e-wallet.

    Bonusesmean relative value units rewarded to the User Account for purchasing items from retail business establishments. Bonuses are for recordkeeping purposes only and shall not serve as a means of payment.

    An Itemmeans a good of the Company Partners which are participating in the Offers in Yepy. The Company shall not be held liable for the quality of consumer goods or services purchased by the User.

    Company Partnersmean legal entities and entrepreneurs who have signed relevant agreements with the Company to promote their goods in Yepy by running Offer campaigns for goods/services.

    A Purchasemeans the act of User's purchasing an item on offer which is published in the Offers section in Yepy and serves as a ground for rewarding and paying Cashback pursuant to the Offer Terms and Conditions.

    Retailers/retail stores stand for legal entities(or individuals - entrepreneurs) who sell their products or services.

    Bad faithstands for User's actions resulting in abuse of their rights under the terms and conditions hereto as well as abuse of the Offer terms and conditions. In particular, such actions shall include: purchasing an item for other than consumer purposes, claiming Cashback without making a purchase (including returns of goods after the cashback has been rewarded), creating multiple User Accounts which belong to a single individual, an attempt of repeated cashback claim with the same Receipt.

    Means of verifying the purchase of an offered item:

    1. Receipt verification:verifies that something of value has been transferred from one party to another; is issued by a store on paper or electronically and is used to verify a dedicated purchase made by the User (may be provided as a photo of a paper receipt or an e-receipt). If you are based in the Russian Federation, for you can use either a Receipt (a photo of a paper receipt, e-receipt) or its data (a scanned QR code or ID identifiers, Federal Tax Service or Fiscal data Operators data) to verify the purchase of the offered item.
    2. Retailer Loyalty Programstands for a reward system for the Retailer's regular customers which requires signup (by creating a personal account in the loyalty program) and issuance of a loyalty card to identify User's transactions and items purchased from the Retailer, and to provide rewards. If you are based in Russia, the Loyalty program data (including receipts) can be used by the Company to verify the Purchase of the offered item.
  3. OFFERS ELIGIBILITY / CASHBACK REWARDING
    1. User participation in the Yepy Offers is free of charge.
    2. A Participant can be any natural person with full legal capacity who has agreed to the Terms and Conditions and purchased an item matching the Offer.
    3. Given the Purchase of an offered item is verified, the User who has signed up for the Offer can receive and use accrued bonuses, transfer them to get a reward in cash only as set forth in Clause 3.4. of this Annex I.
    4. General Provisions for bonus rewarding and its withdrawal in cash
      1. Having purchased an item at a store, paid for it and received a receipt with the Purchase details, the User uploads a Receipt (e-receipt, a photo of a receipt, loyalty program data – in most regions; purchase verification with the Federal Tax Sevice and Fiscal Data Operators, QR code scanning – for the Russian region) in Yepy, enters its details or the credentials of the loyalty program to verify that the offered item has been purchased for the price stated which defines the bonus quantity to be paid and the data (on receipt contents and a Purchase transaction) to be shown in the Personal Account. The number of Bonuses to be rewarded for a Purchase of an item is subject to the Offer Terms and Conditions. The Terms for Bonus reward when purchasing an item may vary between Users regions and Vendors i.e. Cashback amounts vary by regions of Yepy use, store and product category, however the Offer terms and Conditions may contain some exclusions. Please read the terms of use carefully. Cashback is earned on your purchase amount, which excludes taxes, fees, shipping, gift-wrapping, discounts or credits, returns or cancellations, and extended warranties.
      2. The User qualifies for cashback if they have completed the following:
        • Authorisation (before or after the Purchase).
        • Purchase verification for an offered item by means of providing a Receipt (receipt scanning, e-receipt, a photo of a receipt) or receipt details or loyalty program data. The data shall be provided within the term of the relevant Offer. If you are based in the Russian Federation, and have chosen the Federal Tax Service or the Fiscal Data Operators as means of verifying the data, but we failed to receive the data from those sources within 30 days, the receipt is deemed unprovided.
        • The Item should match the Offer Terms and Conditions.
        • The promotion timescale is subject to the terms of each Offer.
        • The product must be purchased within the region selected at the signup.
      3. Cashback is rewarded if the Company has successfully verified the issuance of the Receipt and its compliance with the Terms and Conditions. The means of the dedicated verification are subject to the Company's discretion. The Offers are not available on any second-hand, refurbished or reconditioned stock.
      4. Proof of purchase should be a legible copy of the retail receipt clearly showing the retailer name, date of purchase, product name and purchase price. In case the data on the Receipt is unreadable or fails to identify whether the purchased item meets the Offer Terms and Conditions (e.g. if the Receipt data does not clearly reflect the item name or category), the Company is entitled to request/clarify the identifiers to ensure that the item meets the Offer terms and conditions and was purchased in good faith by the User.
      5. For each of the Receipts, the Bonus points can be only awarded once. In case several Users have claimed the same Receipt to the Company, the Cashback will be rewarded to the User who was the first to upload the Receipt.
      6. Cashback is rewarded within 5 (five) business days; however, it may take longer if the Company is dubious about the User's bad faith. Cashback rewarding is exercised by the Company Partner (payment processing company (payments platform)/bank).
      7. The successfully rewarded cashback details will be displayed in the User's Personal Account.
      8. Accrued Bonuses can be paid to the User in cash by writing off Bonuses and paying the reward in the Personal Account in the currency of the region you selected at the signup to any bank account or e-wallet stipulated in the Personal Account. Bonus conversion rate (conversion of bonuses into the currency of the region you selected at the signup) is indicated in the application whenever the Bonuses are withdrawn. The transaction is conducted within 5 (five) business days (the timescale is subject to the geographical area).
      9. The cashback rewarded cannot be exchanged for cash.
      10. Where the cashback payment constitutes a taxable benefit, the tax liability lies with the recipient. Accordingly, if your bank charges you, such charges will be deducted by your bank from the cashback amount. In case of a termination, you are still liable to us for any financial obligation incurred by you through your use of the Services prior to the termination.
      11. Should the purchaser return the product to the seller, the Participant will not be entitled to claim cashback and any claim will be thereafter dismissed. For the avoidance of doubt, this clause does not prohibit in any way the purchaser’s right to exercise their applicable statutory or warranty rights.
  4. RIGHTS AND LIABILITIES OF THE COMPANY
    1. The Company may cease Bonus reward or exchange to cash as well as write off the User's accrued Bonuses without notice in the following cases:
      1. If the User breaches any terms of the User Agreement or its Annexes including this Annex I;
      2. if the Company receives claims by other Users, the Company Partners and/or third parties about the User's breaching the Terms;
      3. if any activities prohibited by the applicable legislation are discovered;
      4. In case of any suspicions of and/or information testifying to fraud commitment.
    2. The Company may not reward or may write off Bonuses for Receipts without notice if the item has been returned or the payment has been cancelled; the purchase for the Receipt does not exist; the receipt has been uploaded by a User who abuses their job position, including those who work as a cashier, an employee of a retail enterprise or a shopping unit. This list is not exhaustive and applies to any Purchase if there is any suspicion about the User's bad faith which is to be determined at the Company's discretion.
    3. Bad faith can also serve as the basis for restricting the use of the Yepy for the User, deleting their Personal Account. In case the Personal Account is deleted due to the User's breaching the Terms, the User may not claim compensation from the Company.
    4. The Company may write off Bonuses without notice provided they were wrongly rewarded and if the reward does not meet the Terms and Conditions. In case the Company Partner's Liquidation or Bankruptcy Process has started, the Company may also write off all Bonuses rewarded for purchasing their item without notice.
    5. The Company may terminate the Offer early without prior notice to the User as well as may not reward Bonuses for Receipts provided after its termination. The User should check the Offer terms and conditions before submitting the Receipt.
    6. In case the Offer is terminated either due to the Company Partner's violation of the Agreement signed by the Partner and the Company, the Bonuses received for this Partner's items and registered on the Consumer's Balance shall be written off without notice.
    7. The Company shall not pay Cashback for the following Purchases:
      • from stores where wholesale is the major or one of the business activities;
      • from online shops which allow online purchase discard after the payment without the item or before the item has been received;
      • in amounts exceeding personal consumption;
      • other Purchases that violate the Terms and are aimed at unjust enrichment.
    8. The Company reserves the right to verify the eligibility of participants and/or to exclude participants at its sole discretion at any time for any reason. Resellers may not submit claims on behalf of their customers.
    9. Fraudulent Activity. Any failure to comply with this Agreement and its Annexes, any fraud or abuse relating to the accrual or withdrawal of cashback or other rewards and bonuses, or any misrepresentation of any information furnished to the Company by you or anyone acting on your behalf may result in the closure of your Personal Account and forfeiture of any accrued cashback rewards. If the Company has any reason to suspect fraudulent activity is associated with your Personal Account, the Company reserves the right to delay or withhold any cashback payment. Any suspected or actual cases of fraud will be escalated and reviewed in accordance with our fraud procedure. Company decisions are final.
  5. RIGHTS, LIABILITIES AND WARRANTIES OF THE USER
    1. The User represents and warrants that they have the legal capacity and are at least 18 years of age.
    2. The User shall be liable for maintaining control over their personal account and keeping any third parties away from undertaking any activities therein. Any action with regard to the User Account after the authorisation has been successfully completed is deemed taken by the User personally.
    3. The User shall pay themselves for the expenses caused by signup or authorisation in the service, including Internet access, paying for the purchases to accrue Bonuses.
    4. In case of any claims or issues, related to bonus accrual or withdrawal, subject to the geographical area, the User is welcome to send their claims to the email stipulated in Clauses 1.1. or 1.3. of the User Agreement.
    5. By using Yepy, the User warrants that the information the User provides is reliable, accurate, correct and up-to-date. In case of a breach of the warranty, the User is fully liable for providing unreliable, inaccurate, incorrect and/or outdated information.
    6. CASHOFF shall not be held liable for incorrect, false or unreliable data entered by the User at the signup. The User who entered incorrect, wrong or unreliable data at the signup may be restricted from receiving Bonuses.
    7. The User agrees that the Company shall not be held liable if the User was not rewarded or was wrongly rewarded with Bonuses or the User received an incorrect or untimely money transfer due to inaccurate and/or unreliable information provided by the User.
    8. The User should notify the Company of any change in their data by updating personal records in the User Account accordingly. Adverse consequences caused by failure to notify of the changes in the data are the User's liability. The Company shall not be held liable for the User's failure to comply with the undertakings stipulated in the Terms.
    9. The User warrants that the Personal Account has not been deleted, blocked and/or deactivated on account of fraudulent acts; and/or breach of this Terms by the User; and/or breach of the applicable laws by the User before. In case the User violates the warranties, stipulated hereto, the Company reserves the right to refuse the User's registration and/or delete the User's Account.
    10. The User shall not:
      • provide incorrect, misleading, fraudulent or forged information on purchasing or paying for the goods.
      • use receipts for Items and services which were not purchased by the User or were returned to the seller to receive Bonuses;
      • use Receipts for the Items which have signs of wholesale purchases as a means of receiving Bonuses;
      • upload Receipts which have been uploaded before by the User or any other party;
      • create numerous Personal Accounts to sign up for the Offers;
      • pretend to be someone else or try to get access to the Personal Account of another individual.
      • harm the Yepy functionality or any User by any means, including upload or spread of viruses, advertising software, malicious software, worms or any other malicious codes;
      • use Yepy in violation of the law.
    11. The burden of proof that the Bad faith was not taking place lays with the User.
  6. DISCLAIMER
    1. The Company shall not be held liable for any delays regarding the Bonus exchange due to the fault of the Company Partners or the User themselves, including incorrect Receipt upload or receipt data upload to the system. User's claims as to Bonus reward shall be reviewed by the Company upon the provision of the original receipt only.
    2. Upon the Company Partner's failure to perform or non-performance of its obligations under the agreement with the Company, the Bonuses accrued for purchasing an item of this Partner will be written off without notice.
    3. The Company reserves the right to cease, alter or temporarily stop Yepy work unilaterally if any of its functionality cannot be used as planned, including any reason uncontrolled by the Company which distorts or influences the implementation, security, integrity and proper functioning of the website/application.
    4. In case of suspension or termination of the Service, the Company will not reimburse the remaining points which were rewarded to their internal account by the time of suspension or termination to the Users. The User may not demand any reimbursement from the Company, including in cash.
    5. The Company may carry out maintenance with a temporary suspension of Service without prior notice to the User.
    6. The company does not sell or deliver any consumer goods or services. All transactions for purchasing goods or services are done by the User in Retail stores directly. The Company is no party to the process of buying and paying for the goods by the User and is not responsible for it.
    7. The Company is not a lending institution (a bank) nor a payment gateway and shall not be liable for acts (omissions) of the lending institutions (banks), payment gateways or payment services which carry out money transfers to the Users.
    8. The Company shall not be held liable for the quality of consumer goods or services purchased by the User. The quality of goods or services is the full responsibility of the dedicated goods producer or the service provider.
    9. The Company does not offer warranties for the items (works, services) purchased within the offer period to the User and does not set the guaranteed shelf life (expiry dates) either. The warranties are provided and the guaranteed shelf life (expiry date) is set by the relevant goods supplier or service/works provider.
    10. The Company shall not be held liable for any hacker activity aimed at disrupting Yepy's normal functioning while also taking reasonable steps to eliminate errors and vulnerabilities of the service.
    11. The Company shall not accept any liability for any financial or non-financial loss suffered by the User as a result of using Yepy and Service for any technical malfunctions.
    12. The Company shall not be held liable for defects, errors and failures of the software ensuring the functioning of the system as well as in case the User faces a temporary lack of access to the software and/or hardware on causes beyond the reasonable control of the Company as well as further losses.
    13. The Company hereby excludes any and all liability for the User's loss arising out of virus malware or other malicious software in the hardware and the software that the User utilises to access the system.
    14. The Company shall not be held liable for the User for suspension or termination of the Offers as well as for any change in the Offer terms and conditions introduced by the Company Partners.
    15. The company shall not be liable for any indirect loss, consequential loss or lost opportunity of the User, or third-party claims occasioned by signing up for the Offers, the Service usage.
    16. The Company's liability to you arising out of any infringement of this Terms and Conditions shall be limited to rewarding the number of Bonuses necessary in case of any claim occasioned by cashback reward.
    17. The Company's inaction in the face of the User's (or Users') violation of any of the Agreement provisions does not deprive the Company of the right to take reasonable action to protect its interests later nor does it mean that the Company waives its rights in case of similar or subsequent violations.
    18. The Company shall not be liable for any failure to fulfil this Terms where such failure is caused by any supervening circumstances amounting to force majeure (i.e. beyond Company’s reasonable control) and/or events which, without the fault of either party, render performance impossible or incapable of satisfactory execution.

ANNEX II – DATA AGGREGATION SPECIFIC TERMS OF USE

  1. SCOPE
    1. This Annex II contains specific conditions governing your use of the Data Aggregation in Yepy (hereinafter in this Annex II - the Service).
    2. Yepy's Data Aggregation makes a certain set of features available for the User.
      • If you are based in the European Union or the EEA, the list of Data Aggregation features for you is as follows:

        • Yepy's Data Aggregation connects to APIs offered by account information and payment service providers or other financial services providers, for the purposes of enabling Yepy Users to connect one or more of their accounts held with a payment service or other financial service providers to Yepy in order to offer Users the features specified below:
        • view the list of banking products
        • view the transaction history of banking products
      • If you are based in the APAC region the list of Data Aggregation features for you is as follows:

        • upload data from the Personal Account with a bank, a telecom provider, an e-wallet;
        • view the list of banking products
        • view the transaction history of banking products
      • If you are based in the Russian Federation or one of the Eurasian or CIS countries, the list of Data Aggregation features for you is as follows:

        • upload data from the User Profile with a bank, a telecom provider, an e-wallet, a pension fund:
        • View the list of banking products, pension savings;
        • View the transaction history for the banking products;
    3. The Data Aggregation ensures the qualitative rendering of the Data Analytics, Budget and Goals and Cashback per Item Services (a higher cashback opportunity, see Annex I and Annex III).
  2. DEFINITIONS AND INTERPRETATIONS

    Personal Account with a third partymeans a User data set stored in the software system and aimed to identify (authenticate) Users with a third party and give them access to their data and settings, which is used in Yepy to transfer the User's data with a third party to the Company.

    Lending institutionmeans a legal entity that engages in revenue-making as the main goal of its business and is qualified (licensed) to conduct banking transactions.

  3. USE OF THE DATA AGGREGATION
    1. In order to start using the Service, the User shall:
      1. Sign in their Personal Account with a third party through Yepy.
      2. Depending on your region, select one of the following:
        • If you are based in the EU or the EEA member state:

          • Select a lending institution from those suggested by the Company where the User has an account/card. Give this lending institution your consent to receive certain data through the Company via the API (API consent).
          • Choose other institutions (a telecom provider, an e-wallet), the transactions and data of which the User may need to test and utilize other Services of the Company.
        • If you are based in APAC, the Russian Federation, Eurasia or CIS countries:

          • Select a lending institution from those suggested by the Company where the User has an account/card. The Customer uses the website/application to authorise in their personal account with the selected lending institution by entering their authorisation credentials (the login and password from their personal account with the third-party lending institution) and, if necessary, an SMS code to allow the upload of financial data on the Customer's accounts and other products.
          • Choose other institutions (a telecom provider, an e-wallet), the transactions and data of which the User may need to test and utilize other Services of the Company.
          • You can use Yepy to authorise in your personal account with the account of the loyalty program by entering authorisation credentials (the login and password from their personal account with the third-party loyalty program institution).
    2. User Authorisation in the Personal Account of a third-party lending institution or API consent in Yepy will be deemed the User's consent to provide the information on User's Personal Accounts with third parties that is necessary to ensure proper service performance to the Company and the confirmation that the User has read the User Agreement and its Annex II and agreed to them.
  4. USER'S RIGHTS, LIABILITIES AND WARRANTIES
    1. The User shall be solely liable for the accuracy of the data entered when using the Service as well as for the data compliance with the applicable laws, including liability for third parties in case the User enters the data that does not relate to them directly (for example, third-party data) or violates the rights or the legitimate interests of third parties.
    2. The User shall be solely liable in the face of third parties for their actions regarding the use of the data obtained through the Service, including if such actions will lead to violation of rights and legitimate interests of third parties, as well as for compliance with the law when using the Service.
    3. The User undertakes to take all reasonable measures to prevent any unauthorised access of third parties to the data related to the Service.
    4. The User shall be liable for maintaining control over their personal account and keeping any third parties away from undertaking any activities therein. Any action with regard to the User Account after the authorisation has been successfully completed is deemed taken by the User personally.
    5. While using the Service, the User shall not:
      • use personal account credentials of others in a third-party lending institution without appropriate entitlement to do so;
      • unauthorizedly collect and store data including account data and personal data of other parties;
      • interfere with the normal operation of the Service;
      • assist actions aimed at violating limitations and prohibitions set by the Terms;
      • use any other means to breach the legislation, including the international law.

ANNEX III – DATA ANALYTICS, BUDGETS AND GOALS SPECIFIC TERMS OF USE

  1. SCOPE
    1. This Annex III contains some descriptive provisions about Yepy Data Analytics, Budgets, Goals Service (hereinafter in this Annex III - the Service) and its subscription as described in Clause 5.3. of the User Agreement.
    2. In order to start using the Service, the User shall:
      • sign in Yepy through their personal account by using their personal account credentials.
      • read through this Terms and the Privacy Policy beforehand.
      • pay the subscription fee as specified in Clause 5.3. of the User Agreement.
    3. Yepy's Data Analytics, Budget, Goals Service relies on the data provided by the User while using Yepy's Data Aggregation as well as Yepy's Cashback per item, and enables the User to view the analytics across data from the above-mentioned Services (purchases, expenses, finances), reports on expenses and income, budget planning suggestions. There are the following features:
      • If you are based in the European Union or the EEA, the list of Data Aggregation features for you is as follows:

        • Analytics and Reports: categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
        • Receive personal cashflow-based advice: suggestions on direct debit opportunities for services and goods;
        • Use money-flow management tools, budget and goals - calculations and indications upon completion;
        • View budget and goal reports, balance and payment source charts, categorised income, etc.
        • Receive personal cashflow-based suggestions:
        • View analytical reports/charts/graphs on balance/expense/income divided into categories varied by date, location, time and period;
        • View, create, delete, alter data on cash, budgets, financial goals.
      • If you are based in the APAC region the list of Data Aggregation features for you is as follows:

        • Analytics and Reports: categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
        • Receive personal cashflow-based advice: suggestions on direct debit opportunities for services and goods;
        • Use money-flow management tools, budget and goals - calculations and indications upon completion;
        • View budget and goal reports, balance and payment source charts, categorised income, etc.
        • Receive personal cashflow-based suggestions:
        • View analytical reports/charts/graphs on balance/expense/income divided into categories varied by date, location, time and period;
        • View, create, delete, alter data on cash, budgets, financial goals.
      • If you are based in the Russian Federation or one of the Eurasian or CIS countries, the list of Data Aggregation features for you is as follows:

        • Analytics and Reports: categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
        • Receive personal cashflow-based advice: suggestions on direct debit opportunities for services and goods;
        • Use money-flow management tools, budget and goals - calculations and indications upon completion;
        • View budget and goal reports, balance and payment source charts, categorised income, etc.
        • Receive personal cashflow-based suggestions:
        • View analytical reports/charts/graphs on balance/expense/income divided into categories varied by date, location, time and period;
        • View, create, delete, alter data on cash, budgets, financial goals.

Privacy Policy

  1. GENERAL PROVISIONS
    1. CASHOFF LIMITED (hereinafter, "CASHOFF", "we" or "us"), incorporated under the English law, namely the Companies Act 2006 and the Companies and Limited Liability Partnerships Regulations 2016, VAT number 280267306, registration number 10995366, registered address: the Shipping Building, The Old Vinyl Factory, Blyth Road, Hayes, London, Greater London, United Kingdom, UB3 1HA, business address: Level39, One Canada Square, Canary Wharf, London, United Kingdom, E14 5AB, email: help@yepy.com; phone: +44 330 010 16 39, +44 800 310 10 17) is committed to safeguarding the privacy of our customers when they are using the Yepy website/mobile application (hereinafter, “Yepy”) and its Services.
    2. This Policy applies where we are acting as a data controller with respect to the personal data of the Yepy Users; in other words, where we determine the purposes and means of personal data processing. Kindly note that the set of data, as well as means of the data exchange between the users and Yepy, may vary depending on your geographical area (see clause 6.4).
    3. This Privacy Policy relates to all of the information provided by the Yepy Users to CASHOFF. The Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.
    4. Yepy and the Services enable its users to participate in loyalty programs, receive cashback remuneration, view Users' purchase details, analyze user’s banking information, view analytics and reports on their income and expenses, receive advice on budget planning, provide us with access to and share their payment services account information.

      There are the following Yepy Services:

      • Cashback per Item (see Annex I of the User Agreement);
      • Data Aggregation (see Annex II of the User Agreement);
      • Data Analytics, Budget, Goals (see Annex III of the User Agreement).
    5. CASHOFF provides its services to eligible persons aged 18 years (or of the legal age of majority in the relevant jurisdiction) and over only; CASHOFF does not collect or use any information from children. This Privacy Policy relates to the Yepy visitors and customers who register for and use the Services (collectively referred to as "the Users").
    6. CASHOFF is committed to protecting and respecting your privacy. This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in accordance with applicable data protection laws. We are the data controller of any personal data that you provide to us as set out in this Privacy Policy and as described in data protection laws. Depending on your geographic area, there are several company partners who will be the data operators solely or jointly for the personal data you provide while using Yepy. Acting as a data processor, CASHOFF also processes personal data on behalf of our customers as described in this Policy.
    7. Contact us:

      If you have any questions or complaints about this Privacy Policy or the means of data processing at CASHOFF, please contact us via help@yepy.com or as specified in the relevant paragraph below:

      • If you are based in the European Union or the EEA - CASHOFF UK Data Protection Officer - Mr. Darren Andrew Hughes, at the address, set out in Clause 1.1. or by phone: +44 800 310 1017.
      • If you are based in the APAC region - Customer Service Department in Hong Kong, phone: +852 800 906 459 or mailing address: Flexi-Space, 123, Smart-Space 2, Units 1205-1208, Level 12, Cyberport 2, 100 Cyberport Road, Hong Kong.
      • If you are based in the Russian Federation or one of the member states in the Eurasian region or CIS – Customer Service Department in Russia, phone: 8 800 511 31 06, +7 495 747 59 97, or mailing address: Suite 253, 17, Varshavskoye shosse, 117105, Moscow.
  2. DEFINITIONS AND INTERPRETATIONS

    Affiliatesmean entities directly or indirectly controlling, being controlled by, or under common control with CASHOFF. In order to ensure proper Yepy international functioning, CASHOFF may provide data to the companies under common control.

    Partnersmean service providers, subcontractors or affiliates of the company who assist CASHOFF in rendering services across regions and who are data operators or payment processors. In order to render the scope of services in Yepy, CASHOFF may rely on various third-party vendors. The vendors may be based inside as well as outside the EEA, including Asia and Russia. If you are a resident of the EU or the EEA, your data operator is CASHOFF, for other regions - the companies in Hong Kong and the Russian Federation, their contacts are indicated in Clause 1.7.

    CASHOFF may rely on its partners for the following:

    • rendering customer or payment processing services;
    • verifying the information against publicly available databases;
    • providing technical framework;
    • ensuring product functioning and debugging;
    • providing services through third-party platforms and software (e.g. via API integration)

    The Partners are bound by contractual obligations on use and protection of personal data.

    Contentmeans any information, data, text, messages and other materials posted in Yepy.

    General Data Protection Regulation (GDPR) —the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the Regulation (EU) 2016/679).

    CASHOFF, the Company, we, us, ourmean CASHOFF LIMITED in accordance with Clause 1.1 of this Policy.

    Personal Accountmeans a User data set stored in the software system and used to identify (authenticate) Users in banks and payment systems in order to give them access to their data and settings in Yepy. The User is eligible for one Personal Account only, in case of the customer's bad faith/fraudulent conduct regarding their Personal Account, or one user signing up for the Offers from multiple accounts, the Company may recognize such a user account breaching the Terms and renege its obligations.

    Personal Account with a third partymeans a User data set stored in the software system and used to identify (authenticate) Users in banks and payment systems in order to give them access to their data and settings in Yepy.

    User Profilemeans a Yepy Interface that enables the User to access their data and work with them.

    Loginmeans the name (ID) of the User profile in Yepy.

    Yepy mobile applicationmeans an application on a mobile device which enables the User to perform specific actions with the User account on the mobile device.

    Passworddenotes a user account element, a set of secret characters used to authenticate Users and to protect data from unauthorised access.

    User, you, yourmeans an individual registered in Yepy who have agreed to the terms of the Policy and who has access to the Internet.

    Servicesmean a set of software and hardware and its updates determined by CASHOFF and provided to the User in the YEPY mobile application and at the yepy.com website.

    Website (site)means a URL_address such as https://yepy.com.

  3. PURPOSE
    1. This Privacy Policy explains how information about you or associated with you is collected by CASHOFF, the purposes, means of data collection, use and exchange thereof, rights and obligations of Users’ providing information to CASHOFF.
    2. By using Yepy, you commit to read and accept the terms of this Privacy Policy, Cookie Policy, as well as the User Agreement. By accepting the Policy and by agreeing to it in Yepy, the User is deemed to have fully and unconditionally accepted all the terms thereof without any exemption or limitation. If the User does not agree to the terms of this Policy, they should immediately cease to use Yepy.
  4. LEGAL BASIS
    1. This Privacy Policy (hereinafter, the “Policy”) is the basis for the personal data process. The Policy is based on the norms of the applicable laws on the protection of personal data, in particular, the Regulation (EU) 2016/679 and Data Protection Act 2018.
  5. OUR PRIVACY PRINCIPLES
    1. CASHOFF is committed to safeguarding the privacy and security of your personal data.
    2. We will only collect and use your personal data where we have legal authority to do so.
    3. We will not ask for more personal data than we need for the purposes for which we are collecting it.
    4. We will update our records when you inform us that your personal data has changed.
    5. We have implemented and adhered to the data retention policies relating to your personal data.
    6. We will ensure that your personal data is securely disposed of at the end of the appropriate retention period.
    7. We observe the rights granted to you under applicable data protection laws.
    8. We will ensure that queries relating to privacy issues are promptly and courteously dealt with.
    9. Our staff are trained in their privacy obligations.
    10. We will ensure the appropriate measures are in place to protect your personal data regardless of where it is held and ensure that safeguards are in place before transferring your information to countries outside the European Economic Area (“EEA”).
  6. DATA PROCESSING
    1. In this Section we have set out:
      • the general categories of personal data that we may process;
      • for personal data that we did not obtain directly from you, the source and specific categories of that data;
      • the purposes for which we may process personal data; and
      • the lawful basis for the processing.
    2. You may provide us with:
      • Contact Details — a minimum set of data provided by the Users as necessary for signing up with Yepy: email and password;
      • Account and Transactions Data — by connecting your Personal Accounts with other institutions to Yepy or giving API consent for exchanging your Transactions Data, you hereby authorize us to access, store and process the data held by your account provider. For example, that may include your account details, transaction history, account features;
      • Technical Data — automatically collected as you interact with our website/application, including the IP address used to connect your device to the Internet, your browser type and version, your browser plug-in types and version. These data alongside with the User's OS type and website pages visited by the User are automatically received by the HTTP server at the time of accessing the Services and the User’s subsequent actions;
      • The data collected automatically as you access the Services (see our Cookie Policy);
      • Customer Testimonials: these could include your name, social media handle and/or any testimonial, review or other comments on our products or services that you choose to provide to us;
      • The data provided by the user when editing their personal account with Yepy;
      • The data optionally uploaded by the Users at CASHOFF's request in order to fulfil CASHOFF’s obligations to the Users.
    3. Special Category Data

      We don’t collect any special category (or sensitive) data. Sensitive data is defined in the DPA as personal data revealing racial or ethnic origin, religious or philosophical beliefs, data concerning health. If we are about to collect sensitive data, we will obtain your explicit consent where required for the proposed use thereof at the time of collection.

    4. The type and quantity of data we collect and use depends on why you have provided it. Below is a more detailed list of types of data the Company processes when Yepy or its Services are utilised, as well as the objectives and the lawful basis for data collection and processing:

      All regions

      • Data Type

        • Automatically uploaded and technical information
        • Cookie Policy
      • Data collected

        • Cookie data that is automatically collected when Yepy is utilised.
        • Cookies are small text files that are stored on your computer or mobile device and accessed during further visits to the website or the application. Your use of our services means you have agreed to our using the cookies.
        • Technical data (automatically collected):
          • Yepy traffic data;
          • The IP address used for connecting to the Internet;
          • Browser type and version;
          • Plugin type and version;
          • OS version;
          • Websites visited by the User.
      • Objective

        • Yepy improvement;
        • Locating Yepy users;
        • Developing Yepy content strategy;
        • Number of visits;
        • Report on errors that affected Yepy users;
        • Notifications.
      • Lawful Basis

        • User Consent
      • Data Type

        • Personal Account Details
      • Data collected

        • Login details are a minimum set of credentials provided by the User which is necessary to register in Yepy: an email address and a password.
      • Objective

        • Sign-up for the premium use of the Company's services as well as for the discharge of the obligations to the User within Yepy framework (for example, for cases where you request personal account recovery).
      • Lawful Basis

        • Legitimate interests;
        • Contractual performance
      • Data Type

        • Other information provided at the User's discretion,
        • The data obtained from the device camera when scanning a QR code or uploading a receipt photo from the gallery.
      • Data collected

        • Receipt details specifying the items purchased by the User, data and time of purchase, name of a purchased item, the number of purchased items, price and total of a purchased item
      • Objective

        • Viewing the list of previously uploaded receipts and details thereof, as well as receive data whether the item on the receipt matches offered items and enables the User to receive bonus points.
      • Lawful Basis

        • Legitimate interests;
        • User Consent
      • Data Type

        • User Reviews
      • Data collected

        • These data may contain information on your account, name and any reviews, or other comments that you leave for us.
      • Objective

        • Yepy improvement;
        • Replies to requests.
      • Lawful Basis

        • Legitimate interests;
        • User Consent
      • Data Type

        • Extra data provided by Users on the Company's request
      • Objective

        • Company's fulfilment of its obligations for the Users.
      • Lawful Basis

        • Legitimate interests;
        • Contractual performance;
        • User Consent

      Data provided by the Users to utilise the Yepy Services

      If you are based in the European Union or the EEA, you are providing the following data to use Yepy:

      Cashback

      • Data collected
          • Data provided by the User:
            • Receipt fiscal data;
            • Loyalty program login and password;
            • Purchase transactions (added manually by the User);
            • Item-identifying details (a photo or video of an item purchased, barcodes)
          • The data received upon the User's Consent:
            • Receipt data (contents)
            • Purchase transactions (added automatically when the loyalty program has been connected).
      • Objective
          • purchase verification and item compliance with the Offer Terms and Conditions.
          • User's receipt verification;
          • confirmation of a bona fide item purchase;
          • bonus accrual and cashback redemption;
          • overview of purchases made and bonuses rewarded.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance
          • User Consent

      Data Aggregation

      • Data collected
          • The data received upon the User's Consent:
            • Data received upon your API consent:
            • Bank product details:
              • Accounts;
              • Cards;
              • Loans;
              • Deposits.
            • Transaction history on connected banking products
      • Objective
          • Allowing users to
          • view the list of banking products;
          • view the transaction history of banking products;
          • qualify for higher cashback rewards;
          • view User identifiable information;
          • utilise the data to provide more detailed reports and analytics across the Services.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance

      Data Analytics, Budget, Goals

      • Data collected
          • the Data provided by the User for using the Cashback per Item Service.
          • Data received upon your API consent:
          • Data provided by the User:
            • Financial transactions data added manually by the User to the Transaction section of Yepy’s User Profile;
            • Banking products:
              • Accounts;
              • Cards;
              • Loans;
              • Deposits.
      • Objective
          • Expense analytics across purchases made by the User;
          • User budget analysis against the goals set;
          • Bank transactions analytics;
          • offering advice on budget planning and expenses, places of shopping;
          • categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
          • User's cashflow-based recommendations;
          • money-flow, budget and goals management tools;
          • estimating completion times and indications upon completion;
          • reports, expense/income charts against categories, merchants, days, budget and goals reports, balance and payment source charts, categorised income, etc.
          • personal cashflow-based recommendations management;
          • income/expense analytics data.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance

      If you are based in the APAC region, these below are where you choose to provide your data to Yepy:

      Cashback

      • Data collected
          • Data provided by the User:
            • Phone number;
            • Receipt fiscal data;
            • Loyalty program login and password;
            • Purchase transactions (added manually by the User);
            • Item-identifying details (a photo or video of an item purchased, barcodes)
          • The data received upon the User's Consent:
            • Receipt data (contents)
            • Purchase transactions (added automatically after a loyalty program has been connected).
      • Objective
          • purchase verification and item compliance with the Offer Terms and Conditions;
          • User's receipt verification;
          • confirmation of a bona fide item purchase;
          • bonus accrual and cashback redemption;
          • overview of purchases made and bonuses rewarded.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance;
          • User Consent

      Data Aggregation

      • Data collected
          • The data received upon the User's Consent:
            • Login and password for the Bank Personal Account;
            • SMS code for the Bank Personal Account;
            • API for data exchange.
          • The data automatically uploaded from bank accounts.
          • Banking products:
            • Accounts;
            • Cards;
            • Loans;
            • Deposits.
          • Transaction history of uploaded banking products
      • Objective
          • Allowing users to:
            • view the list of banking products
            • view the transaction history of banking products
            • qualify for higher cashback rewards
            • view User identifiable information.
          • Utilise the data to provide more detailed reports and analytics across the Services.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance

      Data Analytics, Budget, Goals Service

      • Data collected
          • Data provided by the User for using the Cashback per Item Service.
          • Data received upon your API consent:
            • Aggregated data or the data received from banks under the User's API consent
          • Data provided by the User:
            • Financial transactions data added manually by the User to the Transaction section of Yepy’s User Profile;
            • Banking products:
              • Accounts;
              • Cards;
              • Loans;
              • Deposits.
      • Objective
          • expense analysis across the User's purchases;
          • User budget analysis against the goals set;
          • Bank transactions analytics;
          • offering recommendations on budget planning and expenses, places of shopping;
          • categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
          • User's cashflow-based recommendations;
          • money-flow management tools, budget and goals - estimation of completion times and indications upon completion;
          • reports, expense/income charts against categories, merchants, days, budget and goals reports, balance and payment source charts, categorised income, etc.
          • personal cashflow-based recommendations management;
          • income/expense analytics data;
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance

      If you are based in the Russian Federation or one of the Eurasian or CIS countries, these below are where you choose to provide your data to Yepy:

      Cashback

      • Data collected
          • Data provided by the User:
            • Phone number;
            • Receipt fiscal data;
            • Loyalty program login and password;
            • Purchase transactions (added manually by the User);
            • Item-identifying details (a photo or video of an item purchased, barcodes).
          • The data received upon the User's Consent:

            Federal Tax Authority and Fiscal Data Operator Data on receiving the receipt details on behalf of the Tax Service User.

            • Receipt data (contents)
            • Purchase transactions (added automatically after a loyalty program has been connected).
            • Data collected via the API Receipt Verification service to verify the record and authenticity of the fiscal attribute on the Russian Federal Tax Authority website,
      • Objective
          • purchase verification and item compliance with the Offer Terms and Conditions.
          • User's receipt verification;
          • confirmation of a bona fide item purchase;
          • bonus accrual and cashback redemption;
          • overview of purchases made and bonuses rewarded.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance;
          • User Consent

      Data Aggregation

      • Data collected
          • The data received upon the User's Consent:
            • Login and password for the Bank Personal Account;
            • SMS code for the Bank Personal Account;
            • API for data exchange;
            • Login and password for the Pension Fund Account, Telecom account, E-wallet account.
          • Automatically uploaded data from bank accounts.
            • Banking products:
              • Accounts;
              • Cards;
              • Loans;
              • Deposits.
            • Transaction history on connected banking products
      • Objective
          • allowing to
          • view the list of banking products;
          • view the transaction history of banking products;
          • qualify for higher cashback rewards;
          • User identification;
          • utilise the data to provide more detailed reports and analytics across the Services.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance.

      Data Analytics, Budget, Goals

      • Data collected
          • the Data provided by the User for using the Cashback per Item Service.
          • aggregated data or the data received from banks under the User's consent
          • Data provided by the User:
            • Financial transactions data added manually by the User to the Transaction section of Yepy’s User Profile;
            • Banking products:
              • Accounts;
              • Cards;
              • Loans;
              • Deposits.
      • Objective
          • expense analysis across the User's purchases;
          • User budget analysis against the goals set;
          • Bank transactions analytics;
          • offering recommendations on budget planning and expenses, places of shopping;
          • categorised charts for income and expense, merchants, days, automatic transaction break-down into categories and merchants;
          • User's cashflow-based recommendations;
          • money-flow management tools, budget and goals - estimation of completion times and indications upon completion;
          • reports, expense/income charts against categories, merchants, days, budget and goals reports, balance and payment source charts, categorised income, etc.
          • personal cashflow-based recommendations management;
          • income/expense analytics data;
          • pension calculations and accruement.
      • Lawful Basis
          • Legitimate interests;
          • Contractual performance.
    5. How do we collect your data?
      1. We collect data and process data when you:
        • sign up online or use Yepy.
        • voluntarily provide feedback on any of our message boards or via email.
        • Use or view our website via your browser’s cookies.
      2. Partner's commitment to data collection in Yepy

        If you are a resident of one of the European Union or the EEA memberstates, within the framework of the Data Aggregation, you provide the data to the Partner of the Company who is rendering the API integration services, otherwise, you directly provide Our Company with most of the data we collect.

        If you are a resident of the Russian Federation, one of the Eurasian or CIS countries, you provide data to our partners in the Russian Federation who facilitate the technical framework, perform maintenance and debugging.

        If you are a resident of the APAC country, our Partners in Asia who ensure the Yepy functioning in Hong Kong receive your data.

      3. The Company and our Partners may also receive your data indirectly from the following sources:
        • from a third party (such as your bank) acting on your behalf, where you have given your explicit consent for your information (API consent or data from the personal accounts with other institutions);
        • from other organisations where you have already explicitly consented to your information being shared from publicly available sources (such as Google).
        • from public databases (Federal Tax Office or Fiscal Data Operators Receipt Databases in the Russian Federation).
      4. Together with our Partners, we will only collect your information in line with relevant regulations and laws. This may relate to any of our services that you use or have used. You are responsible for making sure that you give us accurate and up to date information.
  7. DATA PROCESSING
    1. CASHOFF is compliant with our obligation to ensure that the Users’ data is processed lawfully, fairly and in a transparent manner. The data is collected for specified, explicit and legitimate purposes and is not further processed in a manner that is incompatible with those purposes; it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organisational measures.
    2. CASHOFF stores users’ data in accordance with internal regulations and the Information Security Policy. With regard to the User’s information, its confidentiality is maintained by CASHOFF, except in cases where the User voluntarily provides information about themselves for general access to an unlimited number of people.
    3. CASHOFF ensures that an appropriate data processing regime is in place by its internal regulations, including protection against unauthorized and illegal processing and inadvertent loss, destruction or damage by using the necessary technical and organizational measures. Data is stored for the period necessary for the purposes of its processing.
    4. CASHOFF's Partners are bound by contractual obligations on use and protection of users' personal data, and conduct data processing in strict compliance with applicable laws.
    5. User Consent and Purposes of the Data Processing
      1. The data processing is subject to the User Consent, signing up and creating an account with the yepy.com website or in the Yepy mobile application, which also means the consent to and acceptance of the Privacy Policy terms.
      2. Where we are relying on consent to process your personal data, you can withdraw your consent at any time. Please note that this will not affect the lawfulness of any processing carried out before you have withdrawn your consent.
    6. How Do We Use Your Data?
      1. We use the data collected from you to operate, improve, and personalize Yepy and the Services including to provide customer service, customize our marketing, to detect, prevent and mitigate fraudulent or illegal activities. You hereby agree that we may use your data as follows:
        • to fulfil the contract obligations (to provide you with the services as described in the User Agreement, for more details please see the User Agreement);
        • to enable normal management, operation, and maintenance of the programs;
        • to carry out data sorting and analysis for better understanding of your preferences;
        • to design new or improve the existing Yepy Services;
        • to provide users with advertising and direct marketing that is more relevant to them;
        • to hold statistical and other studies based on the Users’ impersonal data;
        • to provide Users with information of potential interest (on consumer goods or services);
        • to communicate with the User, including sending notifications, requests and information to the User’s email regarding the use of the Services, service rendering, as well as to process requests from Users;
        • to comply with legal obligations;
        • to protect the vital interests of the data subject or another individual;
        • to perform the tasks carried out in the public interest;
        • to ensure the legitimate interests of CASHOFF as a third party, unless such interests overlap with the interests or fundamental rights and freedoms of the data subject.
        • for customer service, security, to detect fraud or illegal activities, and/or for archival and backup purposes with regard to the service rendering;
        • to operate, improve and personalize the services we offer, and to give each user a more consistent and personalized experience with us;
        • for any other purpose with the User's consent.
      2. If the purposes of the User's data processing do not require CASHOFF to identify the data subject, it is not obliged to save, receive or process additional information to confirm the identity of the data subject. Analysis and statistics data are anonymous.
      3. CASHOFF may target contextually relevant advertising based on non-identifying information such as browser type or region, with the latter ones determined based on the User’s network address on the Internet, as well as the Service use.
      4. CASHOFF may use Your email address to contact you regarding changes to your account and the Services.
    7. Terms for the User Data Processing
      1. User data is collected on the website or in the mobile application at the time of signup, and later when the User adds the information about themselves using the Services.
      2. User data is kept on electronic media and processed automatically except cases where non-automated data processing is necessary as required by applicable laws.
      3. If you are a resident of one of the European Union or the EEA member states, your data is stored in Europe: The personal data we collect from you is stored in the secure information technology systems located in the European Economic Area (for example, Germany). At the date of this Privacy Policy, CASHOFF employs the following subcontractors:
        • Hetzner Online GmbH in Germany.

        The data received in Russia or the APAC region is stored with CASHOFF's local partners in accordance with applicable laws. Accordingly, the database in Russia is situated at 36/3, Berzarina street, Moscow.

      4. We do not share the User's personal data you shared with us with any third parties except as expressly provided for in this Privacy Policy. Such exceptions include Partners who are part of service rendering under the User Agreement, i.e. CASHOFF's licensors and contractors. The data sharing is limited to the purposes of the service rendering under the User Agreement as well as this Privacy Policy, and is governed by data processing agreements between CASHOFF and its contractors.
      5. Personal data is disclosed to the internal authorized staff and the Partners' staff as set by data processing agreements between CASHOFF and their Partners.
    8. International Data Transfers
      1. To ensure that Yepy is rendering its services worldwide, CASHOFF may transfer the data to its subcontractors and affiliates in Europe, Hong Kong and the Russian Federation.
      2. If you are a resident of the EU or EEA member state, please note that some of our external third-party subcontractors are based outside the European Economic Area (EEA). Their processing of your personal data will involve a transfer of data outside the EEA.
      3. Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
        • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
        • Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Europe.
      4. ATTENTION! PLEASE NOTE THAT BY GIVING CONSENT TO YOUR DATA PROCESSING UNDER THE AGREEMENT AND THE PRIVACY POLICY, YOU EXPRESSLY CONFIRM THAT YOU ARE FULLY AWARE OF AND ACCEPT THIS CLAUSE.
    9. How long do we keep your data?
      1. We are only allowed to keep your personal data for as long as it's still necessary for the purpose we initially required it. The retention period depends on the requirements of the applicable laws or regulations CASHOFF must comply with, the purposes of the collection and processing of Personal Data, and the legitimate interests of CASHOFF to establish, exercise or defend its legal rights.
      2. CASHOFF will delete Your personal data from its production server if you delete your Personal Account or invoke your right to be forgotten.
      3. CASHOFF will retain User's personal data or portions thereof:
        • in backup files on its backup servers for a period of up to one (1) month from the date of deletion from the production servers in order to ensure compliance with internal business continuity and disaster recovery procedures; and
        • in log files in order to: (i) comply with the requirements of the applicable laws or regulations; (ii) exercise or defend (ongoing) legal claims; and (iii) meet audit or statutory requirements. The retention period for the Personal Data retained in log files shall be a minimum of five (5) years from the date of deletion from the production servers, or any longer period as required by the applicable laws, unless subject to statutory or regulatory change.
      4. Backups and log files containing Personal Data are stored separately from the production servers. All Personal Data retained in backup files and log files will be treated in accordance with the terms of this Privacy Policy for as long as it is retained before being automatically deleted after the retention period has elapsed.
      5. Backup files are stored using strong asymmetric encryption. We will use feasible solutions to make it no longer directly available in our systems like archiving it. This means that in such case we will no longer process your data.
    10. How do we share information with third parties?
      1. CASHOFF has the right to transfer User’s information to third parties in the following cases:
        • The User has given their consent to such a transfer;
        • the transfer is necessary to perform contract obligations;
        • the transfer is necessary for the conclusion or performance of a contract concluded in the interests of the data subject;
        • the transfer is required for the Service use or for the service rendering;
        • the transfer is necessary for important reasons of public interest;
        • the transfer is necessary for the establishment, exercise or defence of legal claims;
        • the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
        • the transfer is provided for by the relevant legislation within the framework of the procedure established by law, including court orders or other procedural documents;
        • such a transfer takes place within the framework of negotiating on sale or other business transfer (in whole or in part) and all these Privacy Policy obligations as to the personal data received are transferred to the host party;
        • in order to ensure CASHOFF’s rights or a third party’s interests in case of the User violating the User Agreement;
        • in order to provide access to the internal systems containing the data to improve the quality of the Services, including, but not limited to, third-party service providers, contractors and vendors.
      2. CASHOFF will not sell your data or disclose your data to any third party for any purpose other than as set forth in the User Agreement and the Privacy Policy.
    11. Third-party Websites
      1. Yepy may include links to, or otherwise direct User's attention towards websites operated by third parties. Such links are provided solely for User's convenience and informational purposes. The inclusion of any link does not imply an association, support, endorsement, consent, examination, or approval by CASHOFF of such third party and third-party website (including without limitation of access to any content on such a website).
      2. CASHOFF shall not be liable for the information and content published on any third-party website or for the User's use of or incapacity to use such a website. Access to any third-party website is at the User's own risk, and the User must be aware of the fact that linked websites have terms and privacy policies different from those of CASHOFF, and CASHOFF does not control them. If the User elects to use any third-party website and/or provide any Personal Data when using such a website, User is solely responsible for evaluating the terms and the privacy policy that apply. CASHOFF will have no liability for any loss or damage that User may incur through providing any Personal Data on such third-party websites.
  8. DATA PROTECTION
    1. In this Privacy Policy, we take steps to ensure that your information is treated securely, including protection against unauthorised access and misuse. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorized access, disclosure, or alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your credentials such as password(s) and personal account/user profile, and verifying that the data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorized.
    2. Technical Safeguards
      1. CASHOFF takes all sufficient and necessary organizational and technical measures to protect the User’s information from illegal or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties. CASHOFF ensures:
        • the development of the personal data protection system based on the threat model for the relevant class of information systems;
        • performance verification of the information security tools;
        • permissive system implementation for the access to information resources;
        • registration and user activity records of personal data information systems;
        • the antivirus control preventing the introduction of malicious programs (virus programs) and software bookmarks into the corporate network;
        • central personal and technical data protection management.
      2. CASHOFF uses a login (an e-mail) and password to provide the User with authorized access to the Services. The User shall not transfer their login and password to third parties and is also obliged to take measures to ensure their confidentiality.
      3. By using their Account and providing the data, the User agrees that CASHOFF may send emails to them regarding security, confidentiality and other administrative requests.
      4. CASHOFF uses TLS cryptographic protocols to protect data transmission, encrypts and pseudonymizes the User’s data, ensures and maintains confidentiality, integrity, availability and stability of the data process.
      5. CASHOFF regularly invests in security audits. We test our systems, the Website and Services infrastructure for any failure points that might allow hacking. We routinely run security audits ourselves to ensure we meet necessary technical standards at all times. The data received under API consent is encrypted using the Secure Socket Layer technology (SSL) and processed accordingly. We will always use such encryption.
      6. CASHOFF ensures timely restoration of access to the User’s data in case of a physical or technical incident, conducts testing and evaluates performance on security processing, the server security checks and updates.
      7. If a security breach causes an unauthorized intrusion into our system, CASHOFF shall notify the Users via e-mail so that the Users can take the necessary safeguarding measures.
      8. The User may send CASHOFF their comments and questions as to the service and security to the e-mail stipulated in this Policy's general terms.
      9. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

        We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    3. Internal Control
      1. CASHOFF analyses data processing activities against good faith criteria and provides additional guarantees on personal data processing.
      2. CASHOFF:
        • informs the User on personal data breach as well as on altering or erasure of personal data or suspension of its processing.
        • provides the User with information relating to them as a data subject;
        • confirms personal data processing and grants the corresponding admission;
        • amends the data accordingly if required by the data subject;
        • removes personal data due to the absence of demand and upon expiration of the retention period.
  9. RIGHTS AND GUARANTEES OF THE PARTIES
    1. Rendering Yepy and its Services, CASHOFF, acting reasonably and in good faith, assumes that the User:
      • has all the rights necessary to sign up and use the Services;
      • delivers reliable information about themselves in the scope necessary for the Service usage;
      • is aware that the personal data posted by the User in the Service is only available to the User and cannot be looked through, copied or distributed by other Users and/or third parties;
      • has duly read this Policy, agrees to it and accepts the rights and responsibilities stated therein.
    2. CASHOFF does not verify the accuracy of the data provided by Users, nor does it assess their legal capacity. Nevertheless, CASHOFF presumes that the User provides reliable and sufficient information when signing up and keeps it up-to-date.
    3. The Data Subject has the right to:
      • access the data subject to processing.
      • request for data erasure (the right to be forgotten);
      • request for data rectification;
      • request for confirmation of data processing;
      • check whether we hold any of your data;
      • ascertain our policies and practices (from time to time) in relation to data and the type of data held by us;
      • opt-out from receiving direct marketing materials from us at any time.
    4. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
    5. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
    6. We try our best to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you posted.
    7. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, if you do have a complaint, we would appreciate the chance to deal with your concerns first, so please do contact us in the first instance.
  10. PERSONAL DATA BREACH NOTIFICATION
    1. If a security breach causes an unauthorized intrusion into our systems, software or networks or into systems of our contractors that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed, CASHOFF will notify the appropriate data protection authority unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the affected Users.
    2. CASHOFF will report the personal data breach to the appropriate data protection authority without undue delay after having become aware of it and in any case within the timeframe as provided for in the applicable data protection laws. When the personal data breach is likely to result in a higher risk to the rights and freedoms of the affected Users, or if required by the appropriate data protection authority, CASHOFF will also communicate the personal data breach to the affected Users without undue delay.
  11. CHANGES TO THIS PRIVACY POLICY
    1. CASHOFF reserves the right to change this Privacy Policy at any time and from time to time in order to reflect changes in the Services or the applicable laws.
    2. Any non-material change to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective thirty (30) days from their posting on Yepy. Unless stated otherwise, this Privacy Policy applies to all personal data collected and processed by CASHOFF in connection with Yepy and its Services. The User's continued Yepy use after the changes to this Privacy Policy become effective signifies the User's acceptance of any such changes.
    3. The latest version of the Policy is available from the Personal Account in the dedicated Yepy section.