CashGPT — Notice of Collection of Personal Information
(For California Residents Only)
Effective Date: [INSERT EFFECTIVE DATE]
If you are a California resident, you have the right to notice of our collection of Personal Information under the California Consumer Privacy Act of 2020, as amended by the California Privacy Rights Act (collectively, “CCPA/CPRA”). This Notice is provided by Mode Mobile, LLC (“Mode Mobile,” “we,” “us,” or “our”), the operator of CashGPT.
The table below sets forth the categories of Personal Information we collect through CashGPT, examples of the specific types of information within each category, whether we collect that category, and the business or commercial purposes for which we collect and use it.
| CCPA/CPRA Category | Examples Collected by CashGPT | Collected? | Business / Commercial Purpose |
| A. Identifiers | Name, email address, hashed email identifier, IP address, device ID, mobile advertising ID (IDFA/GAID), unique account identifier | Yes | Account creation; fraud prevention; advertising measurement; audience matching and suppression; identity resolution |
| B. Personal Information — Cal. Civ. Code §1798.80(e) | Name, email address | Yes (name and email only) | Account management; communications |
| C. Protected Classification Characteristics | None collected at registration | No | N/A |
| D. Commercial Information | CashGPT Points balance, earning history, redemption history, payout records | Yes | Rewards calculation; payout processing; fraud prevention; analytics |
| E. Biometric Information | Facial liveness scan / face map generated from video selfie at redemption | Yes (with express opt-in consent at redemption only) | Identity verification; account duplication and fraud detection. Not sold or shared. |
| F. Internet or Other Electronic Network Activity | App interactions and events, AI chat usage metadata (message counts, session duration, tokens), advertising engagement, attribution data. Future: AI chat content (see Privacy Policy Section 4). | Yes (metadata now; chat content in future update) | Service operation; Points calculation; fraud prevention; advertising delivery and measurement; analytics; personalization (future) |
| G. Geolocation Data | Approximate location derived from IP address (country/region). No precise GPS location collected. | Yes (approximate only) | US eligibility verification; fraud and VPN detection |
| H. Sensory Data | Video selfie captured during identity verification at redemption | Yes (with express opt-in consent at redemption only) | Facial liveness detection — see Category E |
| I. Professional or Employment-Related Information | None | No | N/A |
| J. Education Information (FERPA) | None | No | N/A |
| K. Inferences | Profiles reflecting user preferences, AI chat topic interests, and behavioral and engagement patterns. Future: topic-based interest profiles derived from chat content. | Yes (basic inferences now; topic inferences in future update) | Offer personalization; advertising targeting and measurement; analytics |
| L. Sensitive Personal Information (CPRA) | Biometric data (facial liveness / face map) — see Category E above | Yes (with express opt-in consent at redemption only) | Identity verification and fraud prevention only. Use limited to purposes permitted under CCPA/CPRA §1798.121. |
How We Use the Personal Information We Collect
Service Operation. To establish and maintain your CashGPT account, calculate and credit CashGPT Points, process redemptions and payouts, and provide customer support.
AI Chat. To process your chat inputs and generate responses via Google Gemini. Currently only usage metadata is retained. In a future update we intend to store chat content for chat memory and topic-based advertising personalization. We will update this Notice and obtain consent before that change takes effect.
Identity Verification and Fraud Prevention. To verify your identity at redemption (including biometric liveness verification with your consent), detect fraudulent activity, and enforce one-account-per-person controls.
Advertising and Analytics. To serve, measure, and improve advertising through third-party advertising SDKs; to measure app attribution through Singular; and to analyze usage trends through Mixpanel.
Legal and Compliance. To enforce our Terms of Service, comply with legal obligations, and defend legal claims.
Categories of Third Parties With Whom We Share Personal Information
Service Providers: Google Gemini (AI chat), Verisoul (identity verification and fraud detection), PayPal (payouts), Mixpanel (analytics), Singular (attribution), advertising SDK providers, customer support providers, and cloud infrastructure providers.
Advertising and Identity-Resolution Partners: Third parties that receive identifiers (including advertising IDs, hashed email identifiers, and IP addresses), app activity data, and inferences for advertising, audience matching, and measurement. These disclosures may constitute a “sale” or “sharing” of Personal Information under the CCPA/CPRA. California residents may opt out as described in our Notice of Right to Opt Out.
Affiliates and Business Transfer Recipients: Other Mode Mobile entities and potential acquirers in connection with a merger or sale of assets.
Legal and Governmental Authorities: Courts, regulators, and law enforcement where required by law or to protect our rights.
Special Notice Regarding Biometric Information
CashGPT collects facial liveness scan data only from users who provide express opt-in consent via a separate consent screen before any capture. This data is used solely for identity verification and fraud prevention at the time of a Points redemption, is stored encrypted on servers operated by our verification provider Verisoul, and is not sold or shared except to Verisoul acting on our behalf. We retain biometric data only until the earlier of 30 days after an account deletion request or 1 year after the verification purpose is fulfilled.
Annual Statistical Data (California Residents)
Commencing with our first full calendar year of operation and updated annually thereafter, we will publish statistical data on California-resident consumer privacy requests received during the preceding calendar year, covering: (1) Requests to Know; (2) Requests to Delete; (3) Requests to Correct; (4) Requests to Opt Out of Sale or Sharing; and (5) Requests to Limit Use of Sensitive Personal Information, including the number received, complied with, denied, and median response time in each category.
Contact Us
For more information or to exercise your rights, see our Privacy Policy at https://cashgpt.chat/legal/privacy or contact us at privacy@modemobile.com (subject line: “California Privacy Rights”).
Mode Mobile, LLC One East Erie, Suite 525 Chicago, IL 60611