1. General

   1. We at Moon Cow Ltd., (the “Company”, “CashCow”, “Business”, “We”, “Us” or “Our”), are committed to securing your (“You”, “Your” or “User”) Personal Data (as defined below) and Your privacy. As part of this commitment, it is important for Us to be transparent about how We handle the information that We (or others on Our behalf) collect about Our users when We collect information about them, and how We use such information.
   2. This privacy policy (the “Policy”) provides information regarding the use of information that We collect about the users of Our website www.cashcow.com (the “Website”), and various services offered through the Website and the services offered by the Company (the “Platform” and collectively, the “Services”).
   3. This Policy is part of and should be read in conjunction with Our Platform Terms of Service: https://docs.cashcow.com/privacy/terms-of-use
   4. In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable living natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that We have or that We may have access to.

2. When do We collect Personal Data about You?

   1. We may collect Personal Data about You in the following circumstances:
      1. When You access or use the Website;
      2. When You register as a Users and use the Platform;
      3. When You participate in the Company’s Play & Earn Program;
      4. When You redeem coins for rewards; and
      5. When You interact with Us in any manner, including by sending Us messages through third party messaging applications or in any other manner.

3. No Obligation to Provide Personal Data to the Company and Its Implications

You are not obligated to provide Us with any Personal Data about You. However, in some instances, not providing such Personal Data will prevent Us from providing You with the Services You requested Us to provide You with and will prevent Your use of the Services or a part thereof.

4. What Types of Personal Data do We collect?

   1. We (or others on Our behalf) may collect the following types of Personal Data about You:
      1. Registration to the Services – upon creation of an account with Us as an authorized player, You may provide Us with your email address, as well as any other information that the Company may deem necessary to collect at the point of registration. While some of the details mentioned above are required fields in the registration pages, others are not required. However, We recommend that You complete all fields to ensure We can provide You with the best experience.
         1. Platform Usage Information. This information includes the online activity log, traffic information (including, without limitation, IP address, time of access, date of access, web and mobile page(s) visited, language used, crash reports and type of browser used), and information regarding the device You used. Some of this information may not identify You personally, and therefore does not constitute Personal Data.
         2. Platform Activity Information. Whenever You use the Website, We monitor Your use of the Website and record Your activity. The information that We gather about You in this context includes any activity that You perform on the Website, such as dates and times on which You use the Website, the length of time You spend watching content on the Website, Your interaction with content on the Website, etc.
         3. Play and Earn Program Activity. Whenever You participate in the Play and Earn Program, we will have knowledge regarding the number of coins you have earned and if You have redeemed them and the Redemption Reward You have received.
         4. Aggregate Information. We may also create statistical, aggregated and anonymized data relating to Our Users and the Service for analytical purposes, including business development and Services improvements. We may share this aggregate information with Our third-party partners. Aggregated data is derived from personal information and user data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand Our customer base and to develop, improve, and market Our Services.
         5. Communication Information. When You contact Us, through any channel whatsoever, when You subscribe to Our Newsletter on the Website or social media networks, You may provide Us with Your full name, e-mail address, telephone number and the content of Your communication with Us.

5. The Purposes of the Processing of Personal Data The Company processes Your Personal Data for one or more of the purposes outlined in this section and according to the appropriate legal basis.

   The Company will not process Personal Data about You unless there is a legal basis for such processing.

   The legal bases according to which the Company may process Personal Data about You are as follows:

   1. Processing is necessary for the purposes of provision of the Services, or any other legitimate interests pursued by the Company or by a third party. By way of example, for the purpose of improving Our Services We will use the data collected during Your use of the Services to improve Our Website or Platform, or for the exercise or defense of legal claims.
   2. Your consent that the Company will process Personal Data about You for one or more specific purposes. By way of example, for providing the Services.

6. How do We Use Personal Data?

   1. We may use Personal Data about You for the following purposes:
      1. To operate the Website or the Platform and provide the Services;
      2. To operate the Play and Earn Program and the related Redemption Rewards;
      3. To contact You for the purpose of operational requirements;
      4. To personalize content and/or offers to You;
      5. To respond to Your queries, requests, and/or complaints;
      6. To send You materials regarding the Services, events, and other information We think will be of interest to You, subject to Your consent;
      7. To analyze and improve the Services, as well as to develop and offer new ones;
      8. To analyze and track usage to determine the usefulness or popularity of certain content and to better understand the online activity of the Website users;
      9. To monitor and analyze trends, usage, and activities in connection with the Platform and the Services;
      10. To perform and maintain various activities supporting the offering and provision of the Platform, including, but not limited to, the Platform (such activities include back-office functions, business development activities, strategic decision making, financing management, third party services integration etc.);
      11. To protect Our and third parties’ interests, rights and assets, including detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities and initiation or exercise or defense of legal claims; and
      12. To fulfill Our legal or regulatory requirements.

7. Sharing of Personal Data with Third Parties

   1. We will not disclose Personal Data about You to third parties except as detailed in this Policy.
   2. We may transfer Personal Data under the following circumstances:
      1. To entities that control Us, entities that are under Our control and/or to entities under common control or ownership with Us, as may exist from time to time (collectively, the “Group”). Such entities may use the Personal Data to support the needs of the Group;
      2. Upon Your consent or instruction;
      3. In the event that We sell, assign, or transfer some or all of Our business or assets to a successor or acquirer, or if We are acquired by or merge with a third party, or if We apply for winding-up or become insolvent, or any other situation where Personal Data may be sold, assigned or transferred to a successor or acquirer;
      4. In the event that We will be subject to an audit or a due diligence process;
      5. To protect Our rights, property, and interest or those of third parties; and
      6. To fulfill Our legal or regulatory requirements or to comply with a national authority request or a court order.
   3. The Company may also share Personal Data about You with third parties that provide Us with the following services:
      1. Storage and hosting providers, including cloud computing services and data security services;
      2. Reward exchange platforms;
      3. IP address information;
      4. Analysis of user experience;
      5. Games providers;
      6. Customer support;
      7. Marketing;
      8. CRM data management;
      9. Third party services and integrations;
      10. Accounting and legal services; and
      11. Research, analytical, technical, and diagnostic services.
   4. We may share aggregate information with Our third-party partners. Such aggregated information does not relate to or identify any particular User.

8. Retention

We will retain Personal Data about You only for as long as necessary for the fulfillment of the purposes for which such Personal Data is collected. We may retain Personal Data about You for longer periods if We find it necessary to comply with legal requirements applicable to Us.

9. Security

We have implemented suitable security policies, rules, and technical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improper use or disclosure, unauthorized modification, or unlawful destruction.

10. Links to Other Websites

    1. The Website may contain links to websites and/or applications of third parties including the games that You will choose to play provided by third parties. Other websites and applications may also reference or link to Our Website. We do not control such websites and applications, nor the collection and/or processing of Personal Data about You by such websites and applications, and thus We are not responsible for the privacy practices. This Policy does not apply to any actions taken via such websites and/or applications.
    2. Whenever You access such third parties’ websites and/or applications, We recommend that You carefully review their privacy policies prior to using such websites and/or applications and prior to disclosing any Personal Data about You.

11. Your Rights in Respect of the Personal Data

    1. Generally, You have the right to request that We provide You with confirmation as to whether Personal Data about You is being collected by Us, to ask to review such data, to rectify the content if applicable and to erase the Personal Data no longer required by Us. You may also restrict Your consent to certain processing of Your Personal Data.
    2. Where the legal basis for the processing of the Personal Data about You is consent, You may at any time withdraw Your consent for the purposes for which You provided Your consent by sending a notice free of charge to the following email address: [email protected].
    3. Where You withdraw Your consent for the processing of Personal Data about You, We might not be able to provide You with some or all of the Services You requested or in the form intended to be provided to You, and You will have no claim in respect of that.
    4. At any time, You may approach Us by sending a notice to the email address [email protected] in order to receive information concerning the review performed by Us. This is so You can conclude that We may process the Personal Data about You on account of such processing being necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
    5. The Company may provide You with offers that are tailored for You specifically, in order to connect You to brands, products and services in ways that are important to You. This may include ads, offers and other sponsored content related to products and services of Ours or of third parties. This is done following the processing of Personal Data about You in order to adjust the materials presented to You, on the basis of Your preferences, behaviour, characteristics, and interests.
    6. Similar analysis and conclusions are used to the extent that You agreed to receive marketing materials from Us, as such materials are tailored to offer You products and services which We think may be of more interest to You.
    7. In addition, You may withdraw Your consent from receiving marketing materials via email at any time, by sending an email free of charge with the title “unsubscribe” to the following email address: [email protected] or by clicking the unsubscribe option in the profile page in any marketing material sent to You. You can withdraw Your consent from receiving marketing materials via push notifications in Your mobile device’s settings page.
    8. Please note that if You opt out of receiving marketing communications from Us, We may still communicate with You from time to time if We need to provide You with non-marketing information about Our services or for other legitimate non-marketing reasons.

If You reside in the U.S.A, please read below with respect to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), and the Colorado Privacy Act (CPA) rights You might have:

In order to exercise Your rights, please contact us using the following details: [email protected].

12. Transfer of Personal Data

    1. Personal Data about You may be transferred to a third country (i.e. jurisdictions other than the one You reside in) or to international organizations. In such circumstances, the Company shall take appropriate safeguards to ensure the protection of Personal Data about You and to provide that enforceable data subject rights and effective legal remedies for data subjects are available.

13. Changes to the Policy

    1. We may amend the terms of this Policy, from time to time. Whenever We amend this Policy, We will notify You of such amendments by publishing the updated Policy on the Website. In addition, when We make significant amendments to this Policy, We will strive to inform You about such amendments via means of communication We believe are reasonably appropriate to inform You of such amendments and by publishing a notice about such amendments on the Platform. Unless stated otherwise, all amendments will enter into force upon publication of the updated Policy on Our website or the designated page on the Website.

14. Contact Us

    1. For any queries relating to this Policy and data protection, please contact Us at [email protected].