We at TONCA$H respect the privacy and confidentiality of the personal data of our clients, customers, visitors, and all others whom we interact with in the course of providing our services. While we are driven by the goal of enhancing customers’ shopping and cashback experiences, we also understand that a key concern may be the safety of personal information. We are committed to ensuring that all personal data provided to us remains secure and is only used for purposes that our customers have consented to.To begin with, we only collect the personal information necessary to provide you with the services you’ve requested, understand your needs, and serve you better. We collect the least information possible and provide our merchant partners only with what is needed to verify and track your rewards.

TONCA$H takes privacy and security seriously and is receptive to any feedback on these issues. If you have any queries, comments, or concerns or otherwise require any assistance, please feel free to contact us at support@toncash.network.

This Privacy Policy (“Privacy Policy”) explains how TONCA$H (Terracotta Warriors Limited) (“TONCA$H”, “we”, “us”, and “our”) collects, uses, discloses, and shares information when you interact with us. This Privacy Policy applies to all users of TONCA$H’s mobile device applications, websites, Telegram, TONCA$H’s browser extension, and any other sites and/or platforms of applications that are branded “TONCA$H” and link to or reference this Privacy Policy (collectively, the “Services”).  

To the extent that TONCA$H has links to other websites, please note that we do not own, operate, or control them, and they have their own controlling privacy policies that you should review. 

Please read this Privacy Policy carefully. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT REGISTER, SUBSCRIBE, CREATE AN ACCOUNT, OR OTHERWISE INTERACT WITH THE SERVICES. BY SIGNING UP FOR, USING, OR CONTINUING TO USE THE SERVICES, YOU CONSENT TO THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

 (1) What data do we collect and why

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

The Personal Data that TONCA$H may collect from you will depend on the Services that you use or subscribe to. TONCA$H collects this data to enable our Services and platforms to function correctly and to help us understand their performance on different devices and browsers. TONCA$H will collect Personal Data in an indicative but not limiting manner when you:

• Create a TONCA$H account by using the Telegram app.

• Register for our Services and use our Services (such as by placing an order on or through our online platforms).

• Leave your contact details with us after attending our events or visiting our telegram app, social media platforms, and website.

• Sign up for alerts or newsletters or respond to our marketing materials (e.g., advertisements or flyers).

• Contact us with inquiries or requests for assistance or interact with us or our employees via our online interface, email, or other communication methods.

• Participate in competitions, surveys, or other such events.

• Submit a job application, either directly to us or through recruitment firms.

We do not knowingly collect, maintain, or use information from children under 18 years of age, and no part of the Services are directed to children. If you are a child under 18, please do not attempt to use our Services or send any personal information to us. If you learn that a child has provided us with their information in violation of this Privacy Policy, please alert us to the concern via support@toncash.network. 

The Personal Data collected may include, among others, information relating to your:

• Identity: This may include your full name, e-mail address, date of birth, phone number, photographs, local device ID, local identification number, contact information such as your address or telephone number, nationality, gender, date of birth, location, IP address, and payment-related information (e.g. bank account details or details of your account with a payment service provider such as PayPal, or your credit card/debit card information), depending on the type of Service you use. 

• Interactions with us: This includes recordings of your phone calls with us, emails you sent, and other records of any contact you have with us.

• Device information: We may collect device information such as device metadata connected with device characteristics, configuration, and other data describing device information. We collect this information to protect our customers and systems and to prevent fraudulent transactions.

• Device clipboard: We may access content found in your device’s clpboard, with your permission. For example, if you choose to paste content from the clipboard into our application or opt to use our clipboard-sharing function, we will access the information stored in your clipboard in order to track your redirects to our merchant partners. We only detect item links and never store any text, images, video or personal data in your device’s clipboard.

• Account: Details relating to your TONCA$H account.

• Preferences: This includes details that you have shared with us as to how you would like to be contacted and your preferred products and brands.

• Location: Some of the Services we provide depend on your location. In order to work, those Services need to know your location. Whenever you open and use or interact with our platforms (including our app) on your mobile device or otherwise, we use the location information to tailor our Services to your location. The Services use your various devices ‘background location’, including sending you notifications of offers/plans/interesting things near you. If you have ‘background location’ turned on, our platforms, will from time, to time tell us about your device’s location even if you are not directly interacting with our platforms.

• Use of our Services: This includes using cookies, our web extension or other browser-related methods to track information relating to your interaction with our and our merchants’ websites (e.g. the pages within our website that you visit, the time spent on those pages, items and information searched on our site, access time and dates, webpages you were visiting prior to our site, and information relating to clicks and redirects), as well as data related to your transactions with our merchants and partners (Including any Order Reference / Order ID).

(2) Cookies

TONCA$H uses “cookies,” small data files sent to your browser, to store and track information when you enter our website. The cookie is used to track some of the information mentioned above relating to the use of our Services. Most browsers allow you to turn off the processing of cookies, but doing so may restrict your use of the website and its functionalities.

(3) Accuracy of Information and Third-Party Consent

You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with the products and services that you have requested.

(4) Security of Personal Data

TONCA$H ensures that all Personal Data collected will be safely and securely stored, and it has implemented stringent measures to secure and protect your information. These include, among others:

• Utilising industry-standard encryption by using a secure, encrypted TSL connection on all our web pages where you transmit Personl Data, and encrypt data at rest.

• Ensuring that Personal Data relating to you is only stored on servers with proper safeguards to prevent security breaches.

• Limiting access to the information in our systems.

• Implementing strict verification processes to prevent unauthorised access to Personal Data.

• Securely destroying your Personal Data when it’s no longer needed for our business or legal processes.

(5) Why we collect your data 

TONCA$H does not sell or trade Personal Data collected online with third parties. We may use Personal Data relating to you to, among others:

• Administer the services we provide you:
  Primarily, we use your Personal Data to fulfil and process your orders and cashback. This would include using Personal Data relating to you to track your transactions with our merchant partners, credit cashback rewards into your TONCA$H account, and process the necessary payments associated with such transactions, as well as payments, factoring or credit transactions made through and to us. It would also include using Personal Data relating to you to activate or deactivate services, provide you with additional products, services, and benefits (such as promotions, loyalty programmes, or reward programmes), administer (at times in conjunction with our preferred partners) promotional events, contests, competitions, and corporate social responsibility projects, and where necessary collecting and satisfying any debt owed by you and enforcing or defending our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration or other legal process.

• Enhance the services we provide you:
  We use your Personal Data to investigate complaints, claims and disputes. We also use your Personal Data to improve site and service performance and the delivery of our services, such as when you make inquiries into and provide feedback on our quality of service. We may also use Personal Data relating to you to understand your preferences, develop new products and servipersonalisesonalize or otherwise improve the products and services we offer you. It would also include using Personal Data relating to you to deliver relevant advertising (such as that involving details of our or our preferred partners’ products, services, special offers, and rewards), either to our customers gnerally, or which we have identified may be of interest to you in particular, to deliver periodic newsletters to you with your prior consent or if otherwise permitted under local laws and regulations, or to promote benefits and offer rewards and promotions that you qualify for.

• Customer Service:
  This would include using Personal Data relating to you to respond to requests and enquiries made by you (or persons authorised by you), providing you with directory assistance, and providing you with updates relating to our products, services, or policies.

• Security and Compliance:
  This would include using Personal Data relating to you to detect and prevent fraud and other crimes (e.g. by verifying your identity, conducting checks against money laundering, terrorism financing, credit and fraud risk, and other related risks), conducting internal audits, or otherwise meeting legal, regulatory and other requirements (including providing assistance to law enforcement, judicial, and other government agencies, responding to regulatory complaints, making relevant disclosures to regulatory bodies, conducting audit checks, due diligence and investigations, and taking steps which TONCA$H considers necessary in the event of a lawsuit or potential lawsuit). It would also include the use of Personal Data relating to you for the purposes of security, credit and fraud and risk management and to ensure the safety and security of our properties and systems.

• Job applications
  This would include processing job applications, recruitment and selection and processing and administering employment records.

We will not use Personal Data relating to you for purposes other than what we have infored you, or which we are permitted or required under local law and regulations.

We will only retain Personal Data relating to you for only as long as there is a business or legal need to.

(6) Sharing of Personal Data

We may share Personal Data with:

• Companies partially or entirely owned by TONCA$H.

• Our business/Services partners, vendors, agents, and service providers are essential for delivering our services. This encompasses merchant partners, payment service providers, and third-party service providers involved in marketing promotions and services offered by TONCA$H or its preferred partners.  

• Third-party service providers delivering operational services to TONCA$H (such as telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre or other services to TONCA$H, credit or debit card companies, payment gateways, payment processors, third-party payment providers, debt collection agencies, credit bureaus, and fraud and credit risk monitoring and assessment providers). It also includes our professional advisers such as auditors and lawyers and any credit bureau or agency where necessary and appropriate. 

• In the event of an actual or prospective business asset transaction (such as any merger, acquisition or asset sale), any business partner, investor, assignee, or transferee to facilitate such a transaction.

• Relevant regulators, statutory boards or authorities, or law enforcement agencies as required by any laws, rules, guidelines, and regulations or schemes.

(7) Transferring your data outside of the EEA

We work with third-party businesses in the European Economic Area (EEA) and countries outside of the EEA. If we transfer your Personal Data outside the EEA to a country that does not provide adequate levels of personal data protection as determined by the European Commission, we’ll put in place legally appropriate safeguards as stated under English law to require the protection of your personal data, for example by using the international data-transfer agreement, or the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers as approved by the United Kingdom government. You can request details of those safeguards by emailing support@toncash.network. 

(8) Your legal rights

You have the following rights regarding your personal information:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of new data you provide to us.

• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be in a position to comply with your request of erasure for specific legal reasons, which will be noted to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your info,rmation which override your rights and freedoms.

• Request restriction on processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by email at support@toncash.network. You will not have to pay a fee to exercise any of your legal rights as specified above. 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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the relevant personal data (or to exercise any of your other legal rights). This is a security measure we take to help avoid your personal data being disclosed to a person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to help speed up our response.

We try 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 updated.

(9) Changes to the Personal Data Protection Policy

TONCA$H reserves the right to modify and update this Privacy Policy at any time. Any changes will be published on our website, and by continuing to use our services, you agree to be bound by the updated terms. The date of the most recent revision will appear on this page. If you do not agree with any changes, please do not continue to use TONCA$H.