User Agreement

1. General provisions

1.1. This Agreement (hereinafter, the "Agreement”) is a contract between you and CASHOFF LIMITED (hereinafter, CASHOFF) and applies to your use of the CASHOFF Services (hereinafter, the “Services” or the “Service”) provided at the yepy.com website. This User Agreement describes the terms and conditions applicable to your access to and use of the CASHOFF Services.

1.2. These Terms and Conditions of the User Agreement govern the use of Services and the Website delivered as part of the services provided by the CASHOFF limited company, registered under English law, namely the Companies Act 2006 and The Companies and Limited Liability Partnerships Regulations 2016, with registered address Level39, One Canada Square, Canary Wharf, London, United Kingdom, E14 5AB, e-mail: help@yepy.com.

1.3. This Agreement and the relationship between us shall be governed by the laws of England subject to your local mandatory rights.

1.4. We may amend this Agreement at any time by posting the amended terms on our website; all amended terms shall automatically become effective 7 days after they are initially posted on our site.

2. Entering into this agreement

2.1. By registering for the Services, you must read, agree with and accept all of the terms and conditions contained in this Agreement (including the CASHOFF Privacy Policy and Cookie Policy referred to below). This Agreement takes effect upon the User’s registration on the Website.

2.2. The terms of the CASHOFF’s Privacy Policy and Cookie Policy are incorporated by reference into this Agreement and provide additional terms and conditions related to the Services. The above-mentioned documents are “Ancillary Documents” for the purpose of this Agreement.

2.3. All future changes set out in the Privacy Policy published on the yepy.com at the time you register for the Services are incorporated by reference into this Agreement and will take effect as specified in that Policy Update.

2.4. This Agreement together with other legal terms and legally required disclosures relating to your use of the CASHOFF Service will be provided to you, at all times on the CASHOFF website.

2.5. This Agreement is provided to you and is concluded in English, other versions of this Agreement are translations of this Agreement. You agree that any use of the Services shall constitute your acceptance of the Agreement and we recommend that you store or print off a copy of the Agreement (including all policies) for your records.

3. Definitions and interpretations

“Account” means a User Account.

“Agreement” means this agreement including all subsequent amendments.

CASHOFF,” “we,” “us” or “our” means CASHOFF as specified in point 1.2. of this Agreement.

“Content” means any information, data, texts, messages or other materials posted on the Site.

Data Protection Laws” means 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, and repealing Directive 95/46/EC (General Data Protection Regulation), and Data Protection Act 2018.

“Login” means a name of the User account in any form.

“Password” means an element of the account, a secret set of symbols intended to confirm the User’s identity or authority, used to protect information from unauthorised access.

“YEPY Mobile App“ means an application on a mobile device that enables a User to perform certain actions with CASHOFF Account using that mobile device.

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

“User,” “you” or “your” means any person registered on the yepy.com website or using the Service who has entered into this Agreement and has the Internet access.

“Website (site)” means the URL such as https://yepy.com/.

4. Services and data usage

4.1. CASHOFF provides You with the opportunity to participate in loyalty programmes, receive cashback remuneration and manage your money in banking applications. Your Account provides You with access to these services through CASHOFF Services ( The provision of the Services and the data necessary for their use will be described in more detail in separate subsequent Agreements ).

4.2. CASHOFF will not sell or disclose your data to any third party for any purpose other than set in this Agreement.

5. Compliance with data protection laws

5.1. CASHOFF processes your data in order to provide its services, including personalised (targeted) advertising, as well as to check, research and analyze data allowing us to develop, maintain and improve the Services and the website sections. CASHOFF is committed to take all necessary precautions to protect your data from unauthorised access, modification, disclosure or destruction. CASHOFF provides access to the data only to those employees and contractors who need this information to ensure the functioning of the Services and proper provision of the services.

5.2.With regard to any personal data processing by CASHOFF in connection with this Agreement, it complies with the requirements of the Data Protection Laws in respect of the provision of services and otherwise in connection with this Agreement. In complying with the Data Protection Laws, without limitation, CASHOFF:

- implements and maintains at all times all appropriate security measures as to the processing of personal data;

- maintains a record of all processing activities carried out under this Agreement.

6. Security and privacy

6.1. CASHOFF will make all reasonable efforts to safeguard Your data against unauthorised access or misuse. In case of a system breach or if the system is compromised or the data is inadvertently exposed to unauthorised third parties, you will be promptly notified of such a breach or exposure including root cause, remediation steps, and compensating controls to ensure such a breach does not occur in the future.

6.2. CASHOFF aims to obtain your explicit consent in connection with any use of the Services. This consent must be compliant with all applicable data protection legislation and other privacy laws, rules, and regulations.

6.3. Additionally, on your request, CASHOFF will provide you with information about data and other information we may collect from you , how it will be used and/or shared, as well as obtain necessary consent. CASHOFF will provide and adhere to the Privacy Policy for its services that: (i) complies with all applicable laws, rules, and regulations, (ii) is conspicuously displayed to all end users of the Services, and (iii) clearly and accurately describes to end users of the Services what data and user information it collects and how CASHOFF uses and shares such information.

6.4. If You request CASHOFF to delete your data it stores, CASHOFF agrees to promptly honour your request and to delete all such data and information from its servers.

7. Your account and access

7.1. To be eligible for our Services, you must have full legal capacity to enter into a contract; be at least 18 years old. You further represent and warrant to us in opening an Account with us that you are not acting on behalf of, or for the benefit of, anyone else.

7.2. In order to use the Services, you will need to register for a CASHOFF Account by providing your name, e-mail address, password, and accepting the terms of this Agreement and our Privacy Policy. The registration is free of charge and voluntary. You will receive the registration confirmation upon completion of the registration process on the e-mail specified. After successful registration CASHOFF assumes the obligation to observe your rights and fulfil the obligations under this Agreement.

7.3. If your information changes at any time, please ensure you promptly update your Account to reflect those changes.

7.4. You agree to provide us with the information we request for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information.

8. Registration obligations

8.1. 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.

8.2. 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. The Services can also be accessed directly through the CASHOFF website.

8.3. Mobile Device Terms

8.3.1. If you are accessing the Site or Services through a mobile application, the Mobile App is for your personal non-commercial use only.

8.3.2. CASHOFF owns or is the licensee to, all right, title, and interest in and to its application, including all rights under patent, copyright, trade secret, trademark, unfair competition law, or any other proprietary rights, including all applications, renewals, extensions, and restorations thereof. You must not modify, adapt, translate, prepare derivative works from, decompile, reverse-engineer, disassemble, or otherwise attempt to derive source code from the whole or any part of the Mobile App and you must 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 the Mobile App.

8.3.3. Device Specific Additional Terms

iOS – Apple

These Mobile Device Terms are an agreement between you and CASHOFF, and not with Apple. Apple is not responsible for the Mobile App and the content thereof.

CASHOFF grants you the right to use the Mobile 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 an agreement between you and CASHOFF and not with Google. Google is not responsible for the Mobile App and the content thereof.

CASHOFF grants you the right to use the Mobile App only on an Android product that you own or control and as permitted by the Google Play Terms of Service.

8.4. User ID, Password and Security

8.4.1. As part of the registration and account creation process, You will select a User ID and a password. Your CASHOFF account and User ID shall not be transferred or sold to another party and You are solely responsible for maintaining the confidentiality of Your User ID and password and for all activities that occur under Your User ID and password. For the subsequent automatic authorization on the Site, You can store the login and password (as cookies) on the used hardware-software.

8.4.2. You are solely responsible for maintaining the confidentiality of your Account information, password and any activity relating to your Account. Your Account is not transferable to another party.

8.4.3. You agree to (a) immediately notify CASHOFF of any unauthorised use of Your User ID or password or any other breach of security and (b) ensure that You properly exit the Services at the end of each session. CASHOFF cannot and will not be liable for any loss or damage arising from Your failure to comply with this point.

9. Website and CASHOFF services status

9.1. The yepy.com site is an Internet resource. All the Site rights and rights to use of a network address (domain name), yepy.com in particular, belong to CASHOFF. This Agreement does not contain any provisions granting the right to use the company name, trademarks, domain names and other distinctive CASHOFF signs. This right to use the company name, trademarks, domain names and other distinctive signs can only be granted with the written agreement of CASHOFF.

9.2. The Service Functionality

9.2.1. CASHOFF provides the technical possibility of Services use, it does not participate in the formation of the account content, nor does it control or should be held responsible for the action/inaction of any person regarding the use of the Site and/or the Service, or the formation and use of the account content on the Site.

9.2.2. CASHOFF ensures the Site and/or Service functionality and operation, undertakes to recover the Site and/or Service promptly in the event of technical failures and interruptions. CASHOFF is not liable for temporary and other interruptions in the Services operation as well as for the loss of information caused by them.

9.2.3. CASHOFF is not liable for any damage caused to your or somebody else’s personal computer, mobile device, any other equipment or software caused or associated with downloading materials from the Site or from links posted on the Site.

9.2.4. CASHOFF has the right to disclose statistical information related to the Site and/or the Service functionality, as well as the Users’ information to ensure the targeted display of advertising information to different audiences of the Site and/or the Service Users.

9.2.5. By using our website and services you give CASHOFF permission to collect, use and process the data to provide and send you the information about the Site and/or the Service development, as well as to advertise its own activities and services.

9.3. Site changes and availability

CASHOFF reserves the right to modify or discontinue, temporarily or permanently, the Site, the Services or any part of the Site or Services, any Services applications with or without notice for any reason at any time. CASHOFF performs regularly-scheduled maintenance. While we do our best to avoid customer impact, the Site or our Services may be temporarily unavailable during maintenance periods.

9.4. Links

9.4.1. CASHOFF may provide, or third parties may provide, links to other World Wide Web sites or resources. 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, goods or services available on or through any such site or resource.

9.4.2. The links or manuals on downloading the files and/or installing third-party programs on the Site do not mean CASHOFF supports or approves of these actions.

9.4.3. Where we offer a link to any site, product, service, commercial or non-commercial information posted on the Site and/or the Service, it does not mean CASHOFF approves or recommends these products (services).

9.4.4. If You decide to leave the Site and access any third-party website, use or install third-party programmes, You do so at Your own risk, and from that time You should be aware that our terms and policies 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 the Site.

9.5. Advertising on the Service

CASHOFF is responsible for advertisement posted on the Service within the limits imposed by the current legislation.

10. Intellectual property rights

10.1. The Website's services and all the necessary programmes associated with them contain confidential information that is protected by intellectual property laws. You acknowledge that the domain name, configurations, displays, screens, software, code, algorithms, scripts, inventions, trade secrets, images, graphics, text, and all information appearing on or displayed in connection with or contained by CASHOFF on its Website and/or the Service is subject to CASHOFF’s exclusive rights and covered by various intellectual property right protections, including domestic and international copyright, trademark, and trade secrecy laws.

10.2. You acknowledge that CASHOFF is the sole owner of the information on its Website and You do not acquire any of those ownership rights by printing or downloading any of the information or making use of the Service. You shall take no action to decompile, reverse-engineer, infringe, or misappropriate any of the 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.

10.3. CASHOFF grants You a personal non-exclusive and non-transferable right to use the Service, provided that neither You nor any other person with your assistance will:

- copy or modify the software;

- create programmes derived from the software;

- penetrate into the software in order to obtain programme 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.

10.4. Except as expressly provided in this Agreement and the applicable law, 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.

11. CASHOFF rights and obligations

11.1. CASHOFF shall:

- maintain the proper Services and the Site operation;

- protect data provided.

11.2. CASHOFF has the right to:

- post advertising information or any other information for public distribution without Site and Service content prejudice on the user’s account page;

- send information messages to users;

- terminate the login and password operation and remove any Content without prior authorisation in the event of access use suspension or in violation of this Agreement.

12. Your rights and obligations

12.1. You shall:

- comply with the provisions of this Agreement;

- not disrupt the normal Site and its Services operation;

- provide real and complete data, keep this information accurate and truthful.

- inform CASHOFF about unauthorised access to the account and/or unauthorised use of login and password;

- not provide access to your account or to any particular information contained therein to other Users;

- take appropriate measures to ensure the login (e-mail address) and password security, specify the real email in the appropriate field of the registration 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 all information, data, text, messages and other materials (Content) you transmit via the Site and/or the Service;

- not use the Site and/or Service in any manner in violation of any applicable law or regulation and not post links to web resources contrary to applicable law on the website;

- not use the Site and/or Service 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 the Site and/or Service;

- 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.

12.2. You have the right to:

- be provided free of charge access to your information by uploading the data on the Site and/or the Service using a login and password;

- make changes and corrections to your information in the Account ensuring the reliability of such information;

- delete your information from the Account;

- delete your Account and by doing so all information regarding the User’s data will automatically be erased;

- enquire CASHOFF about the data processing;

- forward to CASHOFF appeals, proposals and claims on the implementation of this Agreement, as well as on all matters related to the Site functioning, third-party rights and interests violation concerning Services use (these complaints can be sent to the mailing address specified in point 1.2. of this Agreement).

13. Violations

13.1. We may investigate any potential or suspected violations of the User Agreement, Additional Policies, 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 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 if the user is responsible for the misconduct.

13.2. 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 substantially similar legal procedure) from local and foreign law enforcement or regulatory agencies, other government officials or authorized third-parties.

13.3. 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.

14. Disclaimer of warranties; limitation of liability

14.1. You understand and agree that you are making use of the site and services on an ‘as is’ and ‘as available’ basis. You use the Service at your own risk. CASHOFF does not take any responsibility for the compliance of the Service with your purposes.

14.2. CASHOFF is not responsible for the Content you created, but it has right to refuse to post or remove any Content that is available through the Site. It also has the right to change the form, order and volume of information being posted.

14.3. 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 site or services; (ii) viruses or other malicious software obtained by accessing our site or services or those of any site, services, or tools linked to our site or services; (iii) any user content or content of third parties.

15. 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.

16. No warranties

The information set forth on and the description of services offered through the website 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 (in particular, the terms of the user's participation in a loyalty programme sales promotion) set forth in the website (in particular, in the framework for the Service of Data collection from loyalty programmes of distributing facilities).

17. Term and termination

17.1. This Agreement shall remain valid and applicable to You for so long as You remain a user in good standing of CASHOFF.

17.2. 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.

17.3. This User Agreement shall commence on the date that you register an Account with CASHOFF and will continue for an indefinite period unless terminated in accordance with these provisions.

17.4. You may terminate this User Agreement at any time by contacting Customer Service. In the event that you request that CASHOFF closes your Account, it will treat your request as termination of this User Agreement. CASHOFF may terminate this User Agreement at any time by giving at least thirty (30) days’ notice via email to your registered email address. We will then close your Account.

18. Final provisions

18.1. This Agreement shall be governed by and construed in accordance with English law.

18.2. In the event of any dispute or disagreement, you have to make an effort to resolve them through negotiation. In the event that disputes are not resolved through negotiation, the disputes shall be resolved in accordance with the procedure established by applicable law.

18.3. 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.

18.4. This Agreement is concluded in English only. We will communicate with you in English only (if the request was submitted to the headquarters). You may also contact our local call centres in your region (you can find the contact details on the relevant section of the website).

18.5. You agree that CASHOFF may provide notice or other information to you by posting it on the CASHOFF website, emailing it to the email address listed in your Account, calling you by phone, or sending you a text/SMS message. You must have internet access and an e-mail account to receive communications and information relating to the Services.

18.6. With the exception of amendments to this Agreement, such notice shall be considered to be received by you within 24 hours of the time it is posted to the CASHOFF website or emailed to you. If the notice is sent by mail, we will consider it to have been received by you three Business Days after it is sent. You may request a copy of any legally required disclosures (including this Agreement) from us and we will provide this to you in a form which allows you to store and reproduce the information (for example, by e-mail) and you may terminate your consent to receive required disclosures through electronic communications by contacting CASHOFF to its email specified in point 1.2. of this Agreement. CASHOFF reserves the right to close your Account if you violateу the terms of this Agreement or the CASHOFF’s Privacy policy.

Privacy Policy

General provisions

CASHOFF LIMITED (hereinafter, CASHOFF) is a legal entity registered under English law, namely Companies Act 2006 and The Companies and Limited Liability Partnerships Regulations 2016. CASHOFF is located at Level39, One Canada Square, Canary Wharf, London, United Kingdom, E14 5AB, e-mail: help@yepy.com(our contacts).

When we refer to our name “CASHOFF” or “we”, “us” or “our” in this Policy, we are referring to the CASHOFF LIMITED.

“User,” “you”, “your” or a “ data subject” means any person who is registered on the website yepy.com or is using the Service, entered into User agreement and who has the Internet access.

Our service is provided at yepy.com and associated mobile applications. We provide You with the ability to participate in loyalty programmes, receive cashback remuneration and manage your purchase details and to analyze your banking information.

DEFINITIONS AND INTERPRETATIONS

“Account” means a User Account.

“Content” means any information, data, texts, messages and other materials posted on the Site.

“Login” means the name of the User account in any form.

“Password” means an element of the account, a secret set of symbols intended to confirm the User identity or authority, used to protect information from unauthorized access.

“Mobile App” means the application on a mobile device that enables a User to undertake certain activities under CASHOFF Account using that mobile device.

“Services” mean a set of software and hardware and its updates determined by CASHOFF.

“Website (site)” means the URL such as https://yepy.com/.

1. Purpose of this privacy policy

1.1. The Privacy Policy describes the information collected by CASHOFF (hereinafter, CASHOFF), purposes, ways of data collection, use and transfer thereof, rights and obligations of Users’ providing information to CASHOFF. This Privacy Policy applies when individuals (hereinafter, Users) provide CASHOFF with personal data using the CASHOFF website: yepy.com (hereinafter, the Site), CASHOFF mobile applications (hereinafter, mobile applications), CASHOFF Services (hereinafter, the Services) and other online products and services where Users communicate with CASHOFF. CASHOFF provides its services to eligible persons aged 18 years old and above only. CASHOFF does not collect or use any information from children.

1.2. By using CASHOFF Services, the User agrees to this Privacy Policy and its conditions on processing of personal data and other information; if you disagree with these terms and conditions or any part of these terms and conditions, you must not use our Service.

1.3. CASHOFF’s websites or mobile applications may contain links to websites operated by other organizations that have their own privacy policies. Users shall get through the terms and provisions of their privacy policies before providing personal data as CASHOFF shall not be held responsible for the websites of other organizations.

1.4. From time to time, we may change the provisions of this Privacy Policy. We encourage you to review the Privacy Policy regularly to stay informed about our information practices and the ways you can help protect your privacy.

2. Legal basis

2.1. This Privacy Policy (hereinafter, the Policy) is the basis for the personal data process. It is based on the rules of current legislation on the protection of personal data, in particular 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, Regulation (EU) 2016/679) and Data Protection Act 2018.

3. Information which we may collect:

3.1. This section tells you what personal data we may collect from you when you use our Services. You may provide us with:

- Registration Information: the information required for the registration on the Website provided by the Users: email address and password;

- Account and Transactional Information: When you add accounts to our service, we may access, store and process your Account Information held by your account provider. Account Information includes, for example, your account details, account transaction information, account features;

- Technical Information: when you browse our website, we automatically collect some technical information about your visit to our website, including, but not limited to, the IP address used to connect your computer to the internet, your browser type and version and your browser plug-in types and version. The data is automatically received by the http server during the Services access and subsequent User’s actions (the type of the User's operating system, the Site pages visited by the User);

- Information obtained automatically: Information obtained automatically when you access the Services (cookies: see our Cookie Policy);

- Customer Testimonials: this could include your name, social media handle and/or any testimonial, review or other comment on our products or services that you choose to provide to us;

- Information provided by Users using the editing section of their Website Account;

- Additional information provided by the Users at the request of the CASHOFF in order to fulfil the CASHOFF’s obligations to the Users.

3.2. All the types of data mentioned in this section are depersonalised and kept in anonymized form according to the requirements of the current legislation. The data provided by the User is stored until the goals for which such data were collected are fulfilled. The data is removed if its storage is not required to meet legal or regulatory requirements, and to protect the interests of CASHOFF.

3.3. The above mentioned data will not be retained by CASHOFF for longer than necessary in accordance with applicable laws. In any case, our Policy is to remove all inactive contacts after 3 (three) years of no contact. An email is sent to the inactive contact to ensure the contact doesn’t exist anymore or doesn’t reply. If no reply within two weeks, CASHOFF removes all information about this individual from its database.

3.4. Where we anonymise your personal data (i.e. so that it can no longer be associated with you) for further research or statistical purposes, we may use this information indefinitely without further notice to you.

4. The data process

4.1. CASHOFF guarantees that the personal data provided by the Users is processed lawfully, fairly and in a transparent manner. The data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; kept in a form which is necessary for the purposes for which the personal data are processed for the period necessary for the purposes regarding their processed.

4.2. User consent and Purposes of the data process

4.2.1. The data process is based on the User consent, registration on the Site and an account creation at yepy.com websites or mobile applications, which means the consent and acceptance of the Privacy Policy terms.

4.2.2. 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 withdraw your consent.

4.3. How We Use Your Data

We use the Personal Data that we collect to operate, improve, and personalize the Website and services including to provide customer service, customize our marketing, to detect, prevent and mitigate fraudulent or illegal activities. You agree that we may use your Personal Data as follows:

- to fulfil the contract’s obligations (to provide you with the services described in the User Agreement, for details see the User Agreement );

- to improve the quality of the Services, to develop new Services;

- to provide users with advertising and direct marketing that is more relevant to you;

- to hold statistical and other studies based on the Users impersonal data;

- to provide Users with information of potential interest (on 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, the provision of services, as well as to process requests from Users;

- to communicate with you, either via email, telephone, or otherwise as authorized by you to inform you about the Services, Conferences, Events, etc..

- to comply with legal obligations;

- to protect the vital interests of the data subject or another individual;

- to perform the tasks in the state interests;

- for the purposes of ensuring the CASHOFF legitimate interests or of 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, or and for archival and backup purposes in connection with the provision of the Services;

- to operate, improve and personalize the services we offer, and to give each user a more consistent and personalized experience when interacting with us;

- for any other purpose with your consent.

4.4. If the purposes for which CASHOFF processes personal data do not require data identification, it is not obliged to save, receive or process additional information to establish the identity of the data subject. Information on data analysis and statistical information are in anonymous form.

4.5. CASHOFF may place relevant advertising targeted in accordance with non-identifying information, such as browser type, region, which is determined based on information about the User’s network address on the Internet, as well as Services use.

4.6. The CASHOFF may use Your email address to contact for changes regarding your account and the Services.

4.7. How is your personal data collected?

We use different methods to collect data from and about you including through:

- Direct interactions. You may give us your personal data by email, by phone, by post or otherwise. This includes personal data you provide when registering to use our service.

- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy.

- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, for example, analytics providers such as Google.

4.8. Terms of the User Information Process

4.8.1. User data is collected on the site or by means of the mobile application at the User’s registration, and later when the User adds the information about himself/herself using the Services. Data listed in article 3.1. of this Privacy Policy concerning Registration Information is the minimum data required.

4.8.2. User data is kept on electronic media and processed automatically, except the cases where non-automated data processing is necessary in accordance with the requirements of the current legislation.

4.8.3. User data is not transferred to any third parties except as expressly provided for in this Privacy Policy or in the current legislation. Having the User’s consent or specification it is possible to transfer user data to the third parties who are counterparties of CASHOFF if such counterparties assume obligations to ensure the confidentiality of this information.

4.8.4. User data is removed:

- when the User deletes his/her data from the Account;

- when the Administration of the Service removes the User’s information as well as the User account in the cases established by the User Agreement.

4.8.5. In case of User’s self-deletion of the Account, the CASHOFF keeps the User’s data on its electronic media for 210 days from the moment the account deletion. The data are removed after 210 days from the date of the account deletion. The User has the right to restore their account before the expiration of the specified period.

4.9. How do we share information with the third-parties?

4.9.1. CASHOFF has the right to transfer User’s information to the third parties in the following cases:

- the User has given their consent to such actions;

- the transfer is necessary to perform contract obligations;

- the transfer is necessary for the conclusion or performance of a contract in the interests of the data subject;

- the transfer is required for Services use or for the provision of services;

- 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 stipulated by the current legislation in the framework of the procedure established by law, including court orders or other procedural documents;

- the transfer takes place within the framework of negotiating on sale or other business transfer (in whole or in part) and all this Privacy Policy obligations are transferred to the host party;

- in order to ensure the CASHOFF’s rights or third parties interests in case of User violation the User Agreement;

- in order to provide access to internal systems containing the data to improve the quality of the Services, including, but not limited to, third-party service providers, contractors and vendors.

4.9.2. CASHOFF will not sell your data or disclose your data to any third party for any purpose other than as set forth above.

5. Data protection measures

5.1. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and 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 password(s) and Account/profile registration information and verifying that the Personal 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.

5.2. Technical security measures

5.2.1. 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. The CASHOFF implements:

- the development of the personal data protection system based on the threat model for the corresponding class of information systems;

- the performance verification use of the information security tools;

- the permissive system implementation for the access to information resources;

- the registration and records of actions of personal data information systems Users;

- the implementation of antivirus control, preventing the introduction into the corporate network of malicious programmes (virus programmes) and software bookmarks;

- the accounting of the information protection means, operational and the accounting of technical documentation.

5.2.2. CASHOFF uses a login (email address) and password to provide User with an authorized access to the Services. The User shall not transfer his own login and password to the third parties and is also obliged to take measures to ensure their confidentiality.

5.2.3. Using his/her Account and providing the data, the User agrees that CASHOFF may send him/her emails regarding security, confidentiality and other administrative requests.

5.2.4. CASHOFF uses TLS to protect data transmission, encrypts and pseudonymizes personal data, it ensures and maintains confidentiality, integrity, availability and stability of the data process.

5.2.5. CASHOFF ensures timely access restoration to personal data in case of loss, conducts testing and evaluates performance on security processing, Server security checks and updates.

5.2.6. If any breaches of the security system are discovered, CASHOFF shall notify the Users via e-mail so that the Users can take the necessary safeguarding measures.

5.2.7. The User may send CASHOFF their comments and questions as to the service and security provision to the e-mail stipulated in this Policy General Provisions.

5.3. Internal control

5.3.1. CASHOFF analyses data processing activities against good faith criteria and provides additional guarantees on personal data processing.

5.3.2. CASHOFF will:

- inform the User on personal data breach as well as on altering or erasure of personal data or suspension of its processing.

- provide the User with information relating to them as a data subject;

- confirm personal data processing and grant the corresponding admission;

- amend the data accordingly if required by the data subject;

- remove personal data due to the absence of demand and upon expiration of the retention period.

6. Rights of the data subject and website terms and conditions

6.1. When providing the services at the Website, CASHOFF, acting reasonably and in good faith, shall assume that the User:

- has all the rights necessary to register and use the Services;

- delivers the reliable information about themselves in the amounts necessary for the Service usage;

- is aware that the personal data in the Services posted by the User is only available for the User and cannot be looked through, copied and spread among other Users and/or third parties;

- has duly read this Policy, agrees to it and accepts the rights and responsibilities stated therein.

6.2. CASHOFF does not verify the correctness of the data received (aggregated) about Users, apart from cases when such verification is necessary for CASHOFF to fulfil its obligations to the User.

6.3. CASHOFF neither control nor is liable for websites of third parties available in the service that the user may follow the link to. Such websites may gather or request other personal information or perform any other actions.

6.4. CASHOFF does not verify the correctness of the data provided by Users, nor does it control their legal capability. Nevertheless, the CASHOFF presumes that the User provides reliable and sufficient information when filling in the registration form and keeps it up-to-date.

6.5. The data subject is liable to:

- access their personal data subject to processing.

- request for personal data erasure (the right to be forgotten);

- request for personal data rectification;

- request for confirmation of personal data processing;

- lodge a complaint with a supervisory authority (the Information Commissioner's Office - the ICO - in the 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.

6.6. The User is eligible to submit their requests to CASHOFF, including requests about their data usage in writing to the following address: Level39, One Canada Square, Canary Wharf, London, United Kingdom, E14 5AB, or a soft copy to the e-mail below: help@yepy.com. You can also complain about our processing of your personal information to the relevant data protection authority.

6.7. CASHOFF will consider and reply to the request received from the User within 30 days from receiving the request.

6.8. All the correspondence received from users (hard or soft copies of the requests) is treated confidentially and will not be disclosed without the User's consent.

7. Termination

7.1. If the User violates any of the CASHOFF's terms or standards, the CASHOFF reserves the right to terminate access to the services provided by CASHOFF, suspend or delete the personal account as well as all the corresponding information and files in the personal account and/or block access to any of those files or services.

7.2. If and when CASHOFF considers necessary to protect its Service security or welfare, the Administration is eligible to terminate the User's account.

8. Privacy policy Amendment

8.1. CASHOFF may change this Privacy Policy. If amended or updated, the latest version will be dated accordingly. The updated Privacy Policy shall take effect when posted unless otherwise provided by the updated Privacy Policy. The latest version thereof is always on our website.