Privacy Policy — MewCash

AT A GLANCE

Scope of This Privacy Policy

This chapter explains what data We collect, why, how We protect it, and what rights You have. It applies to all personal information collected through the Platform. Identity verification data collected by Stripe Connect is governed by Stripe's own Privacy Policy.

This Privacy Policy applies to all personal information collected by MewCash LLC through the Platform, including the website, mobile application, and APIs. It does not apply to data collected by third-party services that You access through the Platform (such as Stripe Connect or affiliate merchant websites), which are governed by their own privacy policies.

If You are a California resident, You have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), as described in Section 1.6.

AT A GLANCE

Information We Collect

We collect account info (email, phone), transaction data from merchants, device and session data for security, and engagement data (check-ins, referrals). We do NOT collect biometric data—Stripe handles identity verification separately.

Information You Provide

• Account Registration Data: Email address, phone number, name, and any additional information You voluntarily provide during registration or profile setup. • Communications: Messages You send to Our Customer Success team, dispute form submissions, and feedback. • Family Declarations: If You participate in the Family Fast-Track Program, the family relationship declaration You provide during invite onboarding.

Information We Collect Automatically

• Transaction Data: Purchase details, merchant identifiers, commission amounts, timestamps, order status, chargebacks, and reversals received from affiliate networks via merchant webhooks. • Device & Session Data: IP address, device fingerprint, browser type and version, operating system, session duration, referring URLs, and approximate geolocation (derived from IP address). • Engagement Data: Check-in timestamps, streak status, referral activity (referrer/recruit relationships), tier progression, and gifting activity. • Coin Ledger Data: The complete history of MewCoin issuance, state transitions, cashout requests, and expirations associated with Your account.

Information We Do NOT Collect

• We do not collect or store biometric data (fingerprints, facial scans, retinal scans, voiceprints). All identity verification is delegated to Stripe Connect. • We do not collect or store Your bank account numbers, routing numbers, debit card numbers, or government-issued identification documents. These are collected and stored by Stripe under its own Privacy Policy. • We do not collect information from children under 18 years of age.

AT A GLANCE

How We Use Your Information

We use Your data to run the Platform, calculate rewards, detect fraud, comply with tax and legal obligations, and improve Your experience. We do not sell Your personal information.

We use the information We collect for the following purposes:

Platform Operations: To provide, maintain, and improve the Platform; to create and manage Your account; and to process Your cashout requests.
Reward Calculation & Verification: To calculate, issue, and verify MewCoin rewards; to apply tier multipliers; and to reconcile commission data from merchants.
Fraud Detection & Prevention: To detect, investigate, and prevent Cashback Gaming, Pattern Inconsistency, synthetic identity creation, bot activity, and other violations of the Fair Play Rules.
Legal & Tax Compliance: To comply with applicable laws, regulations, and legal processes, including IRS 1099-MISC reporting, FinCEN AML obligations, UDAAP requirements, and responses to lawful government requests.
Communications: To send transactional notifications (cashout confirmations, hold notices, expiry warnings), service updates, and policy change notices.
Analytics & Improvement: To analyze usage patterns in aggregate to improve Platform features, optimize reward personalization, and enhance system performance.
ADMT Operations: To power Automated Decision-Making Technology as described in Chapter 1, Section 1.9.

AT A GLANCE

How We Share Your Information

We share data only as needed to run the Platform: with our Payment Processor (Stripe), affiliate networks (to verify transactions), and when required by law. We do NOT sell Your personal information. We do NOT share it for cross-context behavioral advertising.

We may share Your information with the following categories of recipients, solely for the purposes described:

Payment Processor (Stripe Connect): To process cashout disbursements and verify identity for KYC compliance. Stripe acts as an independent data controller for identity verification data and as a service provider for payment processing.
Affiliate Networks: To verify transactions, reconcile commissions, and detect fraud. We share only the minimum data necessary (typically a hashed Member identifier and transaction reference).
Tax Reporting Providers: To generate and file IRS Form 1099-MISC where required by law.
Legal Compliance: To comply with applicable laws, regulations, subpoenas, court orders, or lawful government requests. We will notify You of such disclosures where legally permitted.
Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, Your information may be transferred. You will be notified of any such change and any choices You may have.
With Your Consent: We may share Your information for other purposes with Your explicit consent.

Do Not Sell / Do Not Share

MewCash does not sell Your personal information to third parties for monetary or other valuable consideration. MewCash does not share Your personal information with third parties for cross-context behavioral advertising as defined under the California Privacy Rights Act (CPRA). This commitment applies to all Members, regardless of jurisdiction.

AT A GLANCE

System Intelligence & the Identity Graph

You own Your personal data and any inferences that identify You individually. We own the aggregate models, de-identified patterns, and platform-wide algorithms that power fraud detection and reward optimization. If You submit a valid deletion request, We delete Your personal data and individual-level inferences—but We retain truly de-identified and aggregate system models that cannot identify You.

What Is System Intelligence?

MewCash's AI and data infrastructure generates two distinct categories of derived data: • Individual-Level Inferences: Predictions, scores, or classifications that are linked to Your specific account—for example, Your personal fraud risk score, Your personalized merchant recommendations, or Your individual behavioral profile. Under the CCPA/CPRA, individual-level inferences drawn from personal information are themselves personal information (Cal. Civ. Code § 1798.140(v)(1)(K)), and We treat them accordingly. • Aggregate System Models ("System Intelligence"): De-identified, aggregated, and platform-wide models, algorithms, statistical patterns, and analytical outputs that do not identify, and cannot reasonably be used to identify, any individual Member.

Ownership & Intellectual Property

We draw a clear line between Your data and Our models: • Your Data: You own Your personal information (name, email, phone number, transaction history) and any individual-level inferences linked to Your account. These are subject to Your full CCPA/CPRA rights, including the Right to Know, Right to Delete, and Right to Correct (see Section 1.6). • Our Models: Aggregate System Intelligence—the de-identified models, algorithms, platform-wide statistical patterns, and analytical methods described in Section 1.5.1—is the Intellectual Property of MewCash LLC.

How This Works in Practice

Here is how We handle data requests in relation to System Intelligence: (a) If You submit a Right to Delete request, We will delete Your personal information and all individual-level inferences linked to Your account, subject to the statutory exceptions described in Section 1.6.1. (b) If You submit a Right to Know request, We will disclose the categories and specific pieces of personal information We hold about You, including individual-level inferences. (c) You agree not to reverse-engineer, attempt to reconstruct, or derive the aggregate System Intelligence. (d) MewCash's ownership of de-identified, aggregate System Intelligence survives termination of Your account. (e) We commit to good-faith compliance with the spirit and letter of applicable privacy laws.

AT A GLANCE

Your Privacy Rights

California residents have specific rights: access, deletion, correction, opt-out of sale (We don't sell), and non-discrimination. We respond to verified requests within 45 days.

California Residents (CCPA/CPRA)

If You are a California resident, You have the following rights under the California Consumer Privacy Act and the California Privacy Rights Act: • Right to Know: Request disclosure of the categories and specific pieces of personal information We have collected about You. • Right to Delete: Request deletion of Your personal information and individual-level inferences, subject to statutory exceptions. • Right to Correct: Request correction of inaccurate personal information We maintain about You. • Right to Opt-Out of Sale or Sharing: We do not sell Your personal information. No opt-out action is required. • Right to Limit Use of Sensitive Personal Information. • Right to Non-Discrimination.

How to Exercise Your Rights

To exercise any privacy right, contact Us at [email protected]. We will verify Your identity using information associated with Your account and respond within 45 calendar days of receiving Your verified request. If We require additional time, We will notify You and may extend by an additional 45 days. You may designate an authorized agent to submit a request on Your behalf.

Other Jurisdictions

If You are located in a jurisdiction with applicable data protection laws (such as the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, or similar state laws), You may have similar rights. Contact [email protected] to exercise them.

AT A GLANCE

Data Retention

We keep Your personal data (including individual-level inferences) while Your account is active, plus 7 years after termination for tax and legal compliance. De-identified, aggregate System Intelligence is retained indefinitely.

We retain Your personal information for as long as Your account is active. Following account termination, We retain Your personal information for 7 years to satisfy tax reporting (IRS 1099-MISC filing obligations), legal compliance, law enforcement requests, and fraud prevention obligations.

De-identified, aggregate System Intelligence (Section 1.5) is retained indefinitely, as it does not constitute personal information. Individual-level inferences linked to Your account are subject to the same retention and deletion rules as Your personal information.

Coin ledger records, transaction history, and audit logs are retained for the full retention period to support financial reconciliation and dispute resolution.

AT A GLANCE

Data Security

We implement industry-standard security safeguards. No system is 100% secure, and We cannot guarantee absolute security. You use the Platform at Your own risk.

We implement reasonable administrative, technical, and physical safeguards designed to protect Your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and incident response procedures.

However, no method of electronic transmission or storage is perfectly secure. We cannot guarantee the absolute security of Your information. You acknowledge that You provide Your information at Your own risk.

AT A GLANCE

Children's Privacy

MewCash is for adults only (18+). We do not knowingly collect data from anyone under 18.

The Platform is not directed at individuals under 18 years of age. We do not knowingly collect personal information from anyone under 18. If We learn that We have collected personal information from a child under 18, We will take steps to promptly delete it. If You believe a child under 18 has provided Us with personal information, please contact [email protected].

AT A GLANCE

Third-Party Links & Services

The Platform contains links to merchant websites and third-party services. We are not responsible for their privacy practices.

The Platform contains links to third-party websites, including affiliate merchant sites and the Stripe Connect onboarding flow. This Privacy Policy does not apply to those third-party services. We encourage You to review the privacy policies of any third-party site You visit. MewCash is not responsible for the content, privacy practices, or security of any third-party website or service.

AT A GLANCE

International Data Transfers

MewCash is based in the United States. By using the Platform, You consent to the transfer and processing of Your data in the U.S.

MewCash LLC is based in the State of Wyoming, United States. If You access the Platform from outside the United States, Your information may be transferred to, stored, and processed in the United States where Our servers are located and Our central database operates. By using the Platform, You consent to the transfer of Your information to the United States and acknowledge that data protection laws in the United States may differ from those in Your country of residence.

AT A GLANCE

Changes to This Privacy Policy

We may update this Privacy Policy with advance notice. Material changes are communicated via email and in-app notification.

We may update this Privacy Policy from time to time. Material changes will be communicated via email and in-app notification with advance written notice. Non-material changes (clarifications, formatting) may be posted to the Platform. Your continued use of the Platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy.

AT A GLANCE

Contact Information

Reach us at [email protected] for privacy requests, [email protected] for general inquiries, or [email protected] for legal notices.

Mailing Address

MewCash LLC 30 N Gould St # 31872 Sheridan, Wyoming, United States 82801

Email Contacts

• General Inquiries & Customer Success: [email protected] • Privacy Requests & Data Rights: [email protected] • Legal Notices & Arbitration Opt-Out: [email protected]

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