CashGPT — Privacy Policy

Last Updated: [INSERT EFFECTIVE DATE]

At Mode Mobile, your privacy is important to us. This Privacy Policy explains how we collect, use, process, share, and safeguard Personal Information about you gathered through the CashGPT mobile application and related services (collectively, the “Services”). The terms “CashGPT,” “Mode Mobile,” “we,” and “us” include Mode Mobile, LLC and its affiliates and subsidiaries. By using the Services, you agree to the processing of your Personal Information as described in this Privacy Policy. Your use of the Services is also subject to our Terms of Service.

CashGPT is currently offered on [iOS/Android] only and is intended for users located in the United States who are at least 18 years old.

1. Information We Collect

For the purpose of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information about you from the sources described below.

2. Personal Information You Provide Us

Sign-In and Registration.

You create an Account by signing in with your Apple ID (“Sign in with Apple”) or your Google account (“Sign in with Google”). Through these sign-in methods, we receive your name and email address. Your email address serves as the primary identifier for your Account. We ask you to confirm your email address before you claim your first reward. A separate password is optional. We do not collect your phone number, home address, or date of birth at registration.

Redemption and Identity Verification.

When you redeem CashGPT Points for a cash payout, identity verification is required. Verification is performed using our third-party provider, Verisoul, and includes a facial liveness scan (a short video captured by your device camera from which a face map — a mathematical representation of your facial geometry — is generated). Under applicable laws, facial scan data may constitute “biometric data.”

We retain and use biometric data as follows:

• Purpose. We use biometric data solely to detect and prevent fraudulent redemptions and account duplication.

• Consent. We collect biometric data only from users who provide express opt-in consent via a separate in-app consent screen presented before any capture. Without express consent, no biometric data is collected.

• Storage. Biometric data is stored encrypted on Verisoul’s servers. Mode Mobile does not store raw biometric data on its own servers. We share biometric data only with Verisoul, acting on our behalf solely to perform identity verification. We do not sell, lease, trade, or otherwise profit from biometric data.

• Retention. We retain biometric data only until the earlier of: (1) within thirty (30) days of receiving notice of account deletion; or (2) within one (1) year of when the purpose for collection has been satisfied.

Communications.

If you contact us, we may receive your name, email address, and the contents of your message.

3. Personal Information Obtained From Third Parties

Apple and Google Sign-In.

When you sign in with your Apple ID or Google account, we receive the information you have authorized Apple or Google to share with us, currently limited to your name and email address. Please review Apple’s and Google’s privacy policies for information about what they share.

Analytics and Attribution Partners.

Our analytics and attribution partners (Mixpanel and Singular) may share data about your app activity and attribution with us as described in Section 4.

4. Personal Information We Collect Automatically From Your Use of the Services

Usage Metadata.

When you use the AI chat feature, we collect usage metadata, including message counts, session duration, token counts, and associated costs.

Current practice: We do not store the content of your chat messages or questions after your session ends. Only metadata is retained.

Future feature: We intend, in a future update to the Services, to begin storing your chat history for two purposes: (1) to enable the AI assistant to remember your past conversations (“chat memory”), allowing for more personalized and contextually aware responses; and (2) to analyze the topics you ask about (such as finance, insurance, or health) in order to deliver more relevant advertising. When this feature is introduced, we will update this Privacy Policy and notify you before chat content is stored or used for advertising. If you are a California resident, using chat content for advertising may constitute a “sale” or “sharing” of personal information under the CCPA/CPRA, and you will have the right to opt out.

Rewards and Points.

We track your CashGPT Points balance, earning history, and redemption history to operate the rewards program.

Device and Technical Information.

We collect your platform (iOS or Android), app version, IP address, and approximate location derived from IP address (country and region). We do not collect your precise GPS location. The Services are US-only, and we use your IP-derived country to confirm eligibility and detect VPN usage.

Advertising Identifiers.

The Service displays ads served by third-party advertising SDKs. These SDKs may collect your mobile advertising identifier (IDFA on iOS, GAID on Android) and related signals for ad delivery and measurement. On iOS, the App Tracking Transparency prompt will be displayed before any cross-app tracking occurs, and cross-app tracking will only proceed if you grant permission. You may limit ad tracking at any time through your device settings.

Analytics and Attribution.

We work with Mixpanel (analytics) and Singular (attribution) to collect and analyze in-app events, measure campaign performance, and understand how you use the Services. These providers use SDKs and similar technologies. Mixpanel’s privacy policy is available at mixpanel.com/legal/privacy-policy. Singular’s privacy policy is available at singular.net/privacy-policy.

Hashed Email Identifiers.

We may convert your email address into a hashed identifier for use in fraud prevention, audience matching, advertising measurement, and other purposes described in this Privacy Policy. We treat hashed email identifiers as Personal Information. Hashed email identifiers may be shared with advertising and identity-resolution partners for audience matching, measurement, and suppression. We retain hashed email identifiers for no longer than 24 months from collection or last interaction. You may exercise your rights with respect to hashed email identifiers by contacting us at privacy@modemobile.com.

5. How We Use Your Personal Information

• Service Operation. To create and maintain your Account, calculate and credit CashGPT Points, process redemptions and payouts, and provide customer support.

• Identity Verification and Fraud Prevention. To verify your identity at redemption, detect and prevent fraudulent activity and account duplication, and enforce one-account-per-person controls.

• AI Chat. To process your chat inputs and generate responses using Google Gemini. Your inputs are transmitted to Google’s servers for processing. Currently, chat content is not retained after your session; future storage and use of chat content for memory and advertising is described in Section 4.

• Advertising. To serve and measure advertisements delivered through third-party advertising SDKs, and to facilitate interest-based advertising based on your app activity and advertising identifiers.

• Analytics. To monitor and analyze usage of the Services, measure attribution, and improve the Services through Mixpanel and Singular.

• Communications. To contact you for customer-service and administrative purposes and to send push notifications.

• Legal. To enforce our Terms of Service, defend our legal rights, and comply with legal obligations.

6. How We Share Your Personal Information

• Affiliates. We may share Personal Information with our affiliates and subsidiaries.

• Google Gemini (AI Provider). Your chat inputs are transmitted to Google’s Gemini API for processing. Google’s use of data submitted through its API is governed by Google’s terms and policies.

• Verisoul (Identity Verification). When you redeem Points, we share the information necessary for identity verification with Verisoul, acting as our service provider solely to perform liveness and fraud detection.

• PayPal (Payouts). When you redeem Points for cash, we share the payout information necessary to process your payment with PayPal.

• Mixpanel and Singular (Analytics and Attribution). We share in-app event data and advertising attribution data with Mixpanel and Singular for analytics and campaign measurement.

• Advertising Partners. Third-party advertising SDKs embedded in the Service may receive your advertising identifier, approximate location, and app activity data for ad delivery 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 Section 13.

• Sale or Sharing for Commercial Purposes. We may sell or share certain Personal Information — including identifiers (such as email, hashed email identifiers, IP address, and advertising identifiers), app activity, approximate location, and inferences — with advertising partners, analytics providers, and identity-resolution platforms. If and when we begin storing and using chat content for advertising, that data may also be sold or shared as described in Section 4. California residents may opt out as described in Section 13.

• Business Transfers. We may share Personal Information in connection with a merger, acquisition, or sale of assets. We will use reasonable efforts to direct the recipient to process your information consistently with this Privacy Policy.

• Legal Requirements. We may disclose Personal Information if required by law or in the good-faith belief that disclosure is appropriate to comply with legal process, respond to governmental requests, or protect our rights or the rights of others.

7. Third Party Services and Links

This Privacy Policy applies only to Mode Mobile’s processing of your Personal Information. We are not responsible for the privacy practices of third parties, including Apple, Google, Verisoul, Mixpanel, Singular, PayPal, or any advertising partner. Please review their privacy policies.

8. Security

We maintain administrative, technical, and physical safeguards intended to protect Personal Information against accidental or unlawful destruction, loss, unauthorized disclosure or access, and other unlawful processing. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law. Specific retention periods:

• Account and profile data: retained for the duration of your account and deleted within 30 days of a confirmed account deletion request; banned accounts may be retained for up to 3 years to prevent re-registration.

• Points and redemption history: retained for the duration of your account and for 3 years following closure for legal and tax compliance.

• Chat metadata (message counts, tokens): retained for up to 12 months; anonymized analytics may be retained indefinitely.

• Chat content (future feature): once chat content storage is introduced, chat content will be retained until you delete it or delete your account, and for up to 30 days thereafter.

• Biometric data: retained until the earlier of 30 days after account deletion notice or 1 year after the verification purpose is fulfilled.

• Hashed email identifiers: retained for up to 24 months from collection or last interaction.

• Support and communications records: retained for up to 3 years from last interaction.

10. Your Rights and Choices

Marketing and Notifications.

You can manage push notifications in your device settings and opt out of marketing emails via the unsubscribe link or by contacting privacy@modemobile.com.

Account Deletion.

You may request deletion of your account through the in-app settings or by emailing cs@modemobile.com. Deletion is subject to the retention exceptions in Section 9.

Advertising Identifiers.

On iOS, you may limit ad tracking through Settings → Privacy & Security → Tracking. On Android, you may reset or delete your advertising ID through Settings → Privacy → Ads.

11. Use of Services By Children

The Services are intended for users who are at least 18 years old and are not directed to children. We do not knowingly collect Personal Information from children under 13. If a parent or guardian becomes aware that a child has provided us with Personal Information, please contact us at privacy@modemobile.com and we will take steps to delete it.

12. International Cross-Border Data Transfer

Mode Mobile is based in the United States. The Services are currently offered only to users in the United States. Your Personal Information is processed in the United States.

13. Your California Privacy Rights (California Residents Only)

If you are a California resident, you have the following rights under the CCPA/CPRA, subject to certain exceptions:

• Right to Know about the Personal Information we collect, use, disclose, sell, and share.

• Right to Delete Personal Information we collect or maintain.

• Right to Correct inaccurate Personal Information.

• Right to Opt Out of Sale or Sharing. To exercise this right, use the “Do Not Sell or Share My Personal Information” control in the app settings or contact us at privacy@modemobile.com.

• Right to Limit Use of Sensitive Personal Information. Sensitive Personal Information includes biometric data (facial liveness data). To exercise this right, contact us at privacy@modemobile.com or use the in-app controls.

• Right to Non-Discrimination for exercising your privacy rights.

How to Submit a Request.

You may submit requests by (i) using the in-app privacy controls; (ii) emailing privacy@modemobile.com (Attn: California Privacy Requests); or (iii) writing to Mode Mobile, LLC, One East Erie, Suite 525, Chicago, IL 60611. We will respond in accordance with the CCPA/CPRA.

14. Residents of Other U.S. States

If you are a resident of another U.S. state with a comprehensive privacy law, you may have rights to access, correct, delete, or opt out of certain processing of your Personal Information. To submit a request, contact us at privacy@modemobile.com. You may have the right to appeal a denial by contacting us at legal@modemobile.com.

15. Updates To This Privacy Policy

We may make changes to this Privacy Policy. The “Last Updated” date at the top indicates when it was last revised. If we make material changes — including introducing chat content storage and use for advertising as described in Section 4 — we will notify you through the Services or by other communication before those changes take effect. Your continued use of the Services following changes means you accept the revised Privacy Policy.

16. Contact Us

Mode Mobile, LLC is responsible for the processing of your Personal Information. If you have questions about this Privacy Policy or wish to exercise your rights, contact us at privacy@modemobile.com or write to:

Privacy Team (Attn: Justin M. Hines)

Mode Mobile, LLC

One East Erie, Suite 525

Chicago, IL 60611

United States of America