CiNKO ("we", "us", "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, share, and protect information related to the use of the CiNKO Mobile App and Digital Wallet Services.
By using our Services, you consent to the practices described in this Privacy Policy, as well as the CiNKO Digital Wallet Terms and Conditions, and any other applicable policies, including but not limited to the Cookie Policy, Website Terms of Use, and Mobile App Terms. These documents collectively govern the use of your personal data in relation to your CiNKO User Account and Mobile App Transactions. Please ensure that you review these policies regularly to stay informed about how we collect, use, and protect your information.
We collect various types of information, including:
Personal Information: Information provided when creating your CiNKO User Account, such as your name, email address, telephone number, and other identifying data.
Sensitive Information: This may include biometric data, such as biometric templates (e.g., a photo of your face for identity verification purposes) or any photos you upload to our applications for authentication and security purposes. Sensitive data will only be collected with your explicit consent and used in compliance with relevant regulations.
Transaction Data: Information related to your use of the Digital Wallet Services, such as Mobile App Transactions, payments, transfers, and transaction history.
Location Data: If permitted, we collect precise location data when the CiNKO Mobile App is running in the foreground or background. You may opt out of location tracking through your device settings.
Device and Usage Data: We collect technical information related to your mobile device and interaction with our Mobile App, which may include:
- Technical Data: The internet protocol (IP) address used to connect your device to the internet, your log-in information, browser type and version, time-zone setting, device language, operating system and platform, and whether your device uses a virtual private network (VPN).
- Device Information: The type of device you use, including a unique device identifier (such as your device’s IMEI number or mobile phone number), mobile network information, and your mobile operating system.
- Mobile App Interaction: Information about your interactions with our Mobile App, such as pages or services you viewed, links you clicked, page response times, and errors encountered.
- Transaction-Related Data: Information about transactions performed through the Mobile App, such as the date, time, amount, currency, beneficiary details, and the IP addresses of both sender and receiver. We may also collect data on the payment method and the device used for the transaction.
- Stored Information: If you grant permission, we may access information stored on your device, such as your address book, log-in information, photos, or other digital content, to facilitate certain app features.
We use your data for the following purposes:
To provide, maintain, and improve the CiNKO Mobile App and Digital Wallet Services.
To verify your identity and authenticate your CiNKO User Account.
To facilitate Mobile App Transactions and manage your CiNKO User Account.
To detect, prevent, and investigate fraud, security breaches, and other suspicious activities in compliance with anti-money laundering (AML) regulations.
To communicate with you about service updates, account-related matters, or policy changes.
To respond to requests and inquiries you have made through the CiNKO Mobile App and/or to maintain contact with you, address your comments, complaints and suggestions and provide you with support.
To improve our Services through statistical research and analytics, as well as to monitor how CiNKO Users interact with the Services.
To fulfil any legal obligations and requirements. Please note that, in addition to the regulations specific to the sector and activity, other rules related to: Prevention of Money Laundering and Financing of Terrorism, general informative regimes, tax collection regimes, and requirements of administrative and/or judicial authorities, among others, also apply here
We will only use the personal data collected for the specific, intended purposes that you have consented to. If your data needs to be used for any purpose other than those initially disclosed to you, we will notify you in advance, and where required or applicable, we will seek your explicit consent before proceeding.
We may share your information in the following circumstances:
With Service Providers: We work with trusted third parties who provide services on our behalf, such as processing Mobile App Transactions, cloud service providers, call centre or customer support, compliance and regulatory services, and IT services. These third parties are bound by strict confidentiality agreements.
Legal and Compliance Requirements: We may disclose your information to comply with applicable laws or regulations, judicial or administrative proceedings, or to protect and defend the rights or property of CiNKO. For example, we may share your personal data with any competent state authority, government agency, financial institution, or court, where disclosure is necessary to comply with the law, to exercise, establish or defend our rights, or to protect your vital interests or those of another individual.
With Affiliates and Partners: We may share information with our partners, affiliates, agents, and suppliers to process transactions or for research and development purposes.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transition.
We recognize the importance of protecting and managing your personal information. Any personal information we use will be treated with the utmost care and security. We implement a combination of physical, technical, and administrative security measures to protect your data, including:
Encryption: Data is encrypted during transmission and at rest.
Access Controls: Access to your information is limited to authorized personnel only.
Monitoring: We regularly monitor for unauthorized access or suspicious activities.
Although we take reasonable precautions to protect your data, no system is entirely secure, and we cannot guarantee absolute security.
If you use a password, PIN or generated authorisation code to access your CiNKO Account or use the Digital Wallet Services you will be responsible for keeping this information confidential. Please do not share it, we will never ask you for this information.
Blockchain technology operates as a decentralized and immutable ledger that records and tracks transactions. Each transaction is securely stored in a "block" and linked to a preceding block, creating a chain of information that is virtually impossible to alter once confirmed. Blockchain’s immutability is a key feature, ensuring that once data is recorded, it cannot be modified or deleted without affecting the integrity of the entire chain.
Transactions conducted using blockchain involve the storage of data, which may include personal information. Once a transaction is recorded on a blockchain, CiNKO has no control over that data, and we cannot assist in modifying or erasing it. Blockchain technology is decentralized, meaning that no single entity, including CiNKO, can alter or delete data once it is confirmed on the blockchain.
When you conduct a transaction on a blockchain network through CiNKO’s platform, certain personal information may be recorded on the blockchain, including:
The source wallet address.
The destination wallet address.
The transaction amount.
The time and date of the transaction.
Due to the inherent design of blockchain, this information will become part of a public, immutable ledger. This could limit your ability to exercise certain data rights, such as the right to erasure or rectification. While some technologies may offer features to limit third-party access to personal information, the data will still remain permanently stored on the blockchain and cannot be fully deleted.
If you are using CiNKO’s Mobile App Services where blockchain technology applies, we encourage you to consult our FAQ section for additional resources and information about how blockchain transactions work. We also strongly recommend that you conduct your own research before engaging in blockchain-based transactions, especially if you are concerned about how this technology may impact your ability to exercise your data privacy rights.
As a CiNKO User, you have certain rights over your personal information, including:
Access and Correction: You can access or update your personal information directly through your CiNKO User Account.
Data Portability: You may request a copy of your personal information in a commonly used format.
Data Deletion: You can request deletion of your data, subject to legal requirements (e.g., AML laws).
Opt-Out of Marketing: You can opt out of receiving promotional communications through the Mobile App or by contacting us.
To exercise any of the above rights you can contact us at privacy@cinko.io.
In the event of a data breach, we will notify the relevant supervisory authority and inform affected CiNKO Users where the breach presents a high risk to your personal information.
We collect precise location data to provide and enhance the Services. You can opt out of location tracking through the CiNKO Mobile App. However, certain features may be affected if you disable location services.
CiNKO complies with AML regulations and relevant legislation in all jurisdictions where we operate. We may be required to report suspicious transactions or user activities to the appropriate authorities. Your data may be used and disclosed in accordance with these legal obligations.
Since CiNKO operates globally, your information may be transferred across borders. When we transfer data to other countries, we ensure that the data is protected under applicable data protection laws and legal mechanisms such as standard contractual clauses.
We retain your personal information for as long as it is necessary to provide our Services and to comply with legal obligations. Transaction data may be retained for regulatory purposes, including AML compliance.
We reserve the right to modify this Privacy Policy at any time. If significant changes are made, we will notify you via the CiNKO Mobile App, email, or other prominent methods. Please check this policy regularly for updates.
If you have any questions or concerns regarding this Privacy Policy, please contact us at privacy@cinko.io.
