Version 1.0 • Effective Date: December 9, 2025 • Jurisdiction: Antigua and Barbuda

1. Introduction

ClicCash Limited ("ClicCash", "we", "us") values your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the ClicCash mobile application ("App"), our website, or our payment services (collectively, the "Services").

This Policy applies to:

• Consumers: Individuals using the App to send/receive money.
• Merchants & Agents: Sole proprietors, partners, and authorized signatories of businesses using ClicCash Business services.

By registering for an Account, you consent to the data practices described in this Policy.

Data Controller:

ClicCash Limited
Unit #16, Royal Palm Place,
Friar's Hill Road, St. John's,
Antigua & Barbuda
ONDCP Registration #: PSP-0001

2. Information We Collect

We collect information necessary to provide the Services while strictly adhering to our regulatory obligations.

2.1 Information You Provide

• Identity Data: Name, date of birth, nationality, gender, occupation, employer information, government-issued ID numbers (Passport, Driver's License, National Identity Card), documents, files, images, data and any other content you allow us to access.
• Contact Data: Residential/Business address, email address, and mobile phone number.
• Biometric Data: If you enable biometric login (FaceID/TouchID), we process this data for authentication.
• Financial Data: Bank account details (for withdrawals) and debit/credit card details (for funding).
• Business Data (Merchants only): Business registration documents, beneficial owner details, and proof of address for directors/partners.

2.2 Information Collected Automatically

• Transaction Data: Details of payments sent and received, timestamps, merchant names, and amounts.
• Device Data: Device model, operating system, unique device identifiers (IMEI/UUID), and IP address.
• Location Data: Geo-location data to prevent fraud and ensure you are operating within authorized jurisdictions.
• Cookies: We use cookies and similar technologies, such as pixel and local storage technology, (collectively, "cookies") to collect information.

2.3 Information from Third Parties

• Verification Services: We receive data from identity verification partners and fraud prevention agencies to confirm your identity and perform "Know Your Customer" (KYC) and "Know Your Business" (KYB) checks.
• Sanctions Lists: We screen names against global sanctions lists (e.g., Office of Foreign Assets Control (OFAC), United Nations Security Council Consolidated List (UN)) as required by the Money Laundering (Prevention) Act, 1996.

3. How We Use Your Information

We use your data for the following specific purposes:

• Service Delivery: To process transactions, maintain your balance of electronic representations of money, and provide customer support.
• Identity Verification: To verify who you are and determine your Account Tier (e.g., Lite vs. Standard) in compliance with Office of National Drug and Money Laundering Control Policy (ONDCP) regulations.
• Security & Fraud Prevention: To detect suspicious activity, prevent unauthorized access, and protect your Account.
• Legal Compliance: To comply with orders from the ONDCP, the Eastern Caribbean Central Bank (ECCB), or court order.
• Communications: To send you transaction receipts, security alerts, and updates to our Terms (e.g., fee changes).
• Service Improvement: To analyze usage trends and improve our App functionality (using anonymized data where possible).

4. Disclosure of Your Information

We are transparent about how we share data. We do not sell your personal data to third-party advertisers. We only share data with:

• Service Providers: Trusted third-party vendors who assist with identity verification and background checks, cloud hosting and data storage, and transaction processing and banking settlements.
• ClicCash Technologies Canada Ltd.: Our parent company, for technical support, software development, and centralized compliance monitoring.
• Regulatory Authorities: The ONDCP, ECCB, Financial Intelligence Unit (FIU), or law enforcement agencies, only when required by law or to report suspicious activity.
• Other Users: When you send money, the recipient (Consumer or Merchant) will see your registered name and/or phone number to identify the source of funds.
• Third parties in the event of the transfer of our business or assets: If we are involved in a merger, acquisition, bankruptcy, receivership, purchase or sale of some or all of our assets, or another situation involving the transfer of some or all of our business assets, then we may share your information with business entities or people involved in the negotiations or transfer as part of such a transaction, as permitted by law.

5. International Data Transfers

As a modern fintech, we utilize global infrastructure. Your personal data may be transferred to, and processed in, jurisdictions outside of Antigua and Barbuda, specifically:

• Canada: Where our parent company and core engineering teams are located.
• United States/Other: Where our secure cloud service providers and other vendors operate.

We ensure that these international transfers are protected by adequate legal safeguards, including strict data processing agreements and standard contractual clauses, to ensure your data remains secure.

6. Data Retention

How long do we keep your data? We retain your personal data for as long as your Account is active to provide the Services.

Post-Termination Retention:

Even after you close your Account, we are legally required by the Money Laundering (Prevention) Act, 1996 to retain your transaction and identity records for a minimum period (typically six (6) years).

• During this period, data is archived securely and accessed only for legal or regulatory purposes.
• After the statutory retention period expires, your data will be securely deleted or anonymized.

7. Security of Your Data

We implement strict technical and organizational measures to protect your data, including:

• Encryption: Data is encrypted in transit (SSL/TLS) and at rest.
• Access Controls: Strict limitation of access to personal data to authorized employees only.

8. Biometric Data

If you use Biometric Authentication (e.g., FaceID, TouchID, Fingerprint) to log in or authorize transactions:

• You acknowledge that this is considered Sensitive Personal Data under the Data Protection Act 2013.
• By enabling this feature in the App, you provide explicit consent for the use of Biometric Authentication for security purposes. Your raw biometric data is processed and stored locally on your device by the device's operating system, and ClicCash does not access or store this data.
• You may withdraw this consent at any time by disabling biometric login in your device or App settings.

9. Children's Privacy

Our Services are not directed to children under the age of 16. We do not knowingly collect personal data from anyone under 16. If we become aware that we have collected data from a child under 16 without parental consent, we will delete it immediately.

10. Your Rights

Under the Data Protection Act 2013, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct inaccurate or incomplete data.
• Objection: Object to the processing of your data for direct marketing purposes.

To exercise these rights, please contact our Data Protection Officer at the email below. Please note that some rights may be limited by our legal obligations to retain data for AML/CFT purposes.

You also have the right to:

• Control cookies and similar technologies: You can use your controls in your internet browser to limit how the websites you visit use cookies or withdraw your consent by clearing and blocking cookies.
• Unsubscribe from marketing emails: You can unsubscribe from our marketing emails.

11. Refusing or Withdrawing Consent

Subject to legal, regulatory and contractual requirements you may refuse to consent to our collection, use or disclosure of information about you and you may withdraw your consent to our further collection use or disclosure of your information at any time in the future by giving us a reasonable notice.

However, depending on the circumstances, withdrawal of your consent may prevent us from providing you or continuing to provide you with our services and means of access to our services and there may be certain uses of your information that we may not be able to stop immediately.

You cannot refuse our collection, use and disclosure of information required by third-party service providers essential for the provision of the services or required by Regulatory Authorities.

12. Accuracy of Information

To ensure your account is secure and your transactions are processed correctly, it is your responsibility to provide information that is true, accurate, and complete. You therefore acknowledge that all the information provided by you will be, at any time, true and complete.

If any of your personal details change (such as your name, address, or contact information), please update your account information promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time by publishing an updated version to reflect changes in law or our operations. We will notify you of material changes through the App or via email. The "Effective Date" at the top of this page indicates when the latest changes took effect.

Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us:

ClicCash Support

Mailing Address

ClicCash Limited
Unit #16, Royal Palm Place, Friar's Hill Road
St. John's, Antigua & Barbuda