FlashCash App Privacy Policy

Last updated: May 20, 2018

Introduction

We at Greenwald Industries, a division of The Eastern Company (“Greenwald Industries”, “we”, “us”, and “our”) know that your privacy is important. This Privacy Policy (the “Policy”) is designed to assist you in understanding how we will process your personally identifiable information (“Personal Data”) in our FlashCash Laundry mobile application which allows you to pay for, start, and track the status of your laundry (the “App”).

Please read this Policy to learn more about the ways in which we collect, use, and otherwise process your Personal Data in our App. If we make any material changes to this Policy, we will notify you in accordance with the process described in the Changes to This Policy section below.

Data Controllership

In the context of this Policy, we act as a data controller for the Personal Data that we process.

Basis of Processing

Within the scope of this Policy, we process Personal Data based on the need to perform the services at your request.

Categories of Personal Data

Personal Data collected by us through the App could include:

  • contact information, such as e-mail address;
  • data related to laundry machine use (such as how much credit you add to your account);
  • data related to your PayPal account (note that no payment card or account information is processed in the App); and
  • geographical location of laundry machines you use.

How We Receive Personal Data

We may receive Personal Data directly from users of our App, including via the camera on your phone.

Purposes of Processing

We may process your Personal Data for the purposes of:

  • enabling you to use our App and provide our services, e.g., by allowing you to load funds to your account, etc.;
  • contacting you regarding your account and our App; and
  • improving our App.

Data Retention

Personal Data processed in our App is retained indefinitely. However, you may send a request to us to ask that we delete your Personal Data, subject to the limitations described in this Policy.

Sharing Personal Data with Third Parties

We may share your Personal Data with our service providers. Such third parties may include those providing:

  • cloud computing services;
  • project and issue tracking services;
  • email delivery services; and
  • software development services.

We may share your Personal Data with these third-party vendors, solely to enable them to perform the services for us. In providing such Personal Data, we require that those third-party vendors maintain at least the same level of protection that we maintain for such Personal Data.

If we would need to transfer your Personal Data to third countries, we will ensure that this will be subject to appropriate safeguards and other requirements, as stated in the applicable laws.

Other Disclosure of Your Personal Data

We may disclose your Personal Data:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary, in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
  • if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; and
  • to our subsidiaries or affiliates, only if necessary for business and operational purposes.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any Personal Data, about our App users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

If we must disclose your Personal Data, in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.

Data Integrity and Security

We have implemented and will maintain technical, organizational, and physical security measures that are reasonably designed to help protect your Personal Data from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction.

Access, Correction, and Deletion, Portability, Restriction and Objection to Processing

If you are a data subject about whom we store Personal Data, you may have the right to request access to, and the opportunity to update, correct, or delete such Personal Data. You may also have the right to ask that we limit our processing of your Personal Data, as well as the right to object to our processing of your Personal Data. You may also have the right to ask to have your Personal Data exported in a commonly used, machine-readable format.

Requests should be sent to Greenwald Industries using the information in the Contact Us section of this Policy.

Privacy of Children

Our App is not directed at, or intended for use by, children under the age of 13. We do not knowingly allow anyone under 18 to provide any Personal Data on our App. Children should always get permission from a parent or guardian, before sending personal information over the Internet. If you believe your child may have provided us with Personal Data, you can contact us using the information in the Contact Us section of this Policy and we will delete that Personal Data.

Regulatory Oversight

Greenwald Industries is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Changes to This Policy

We may update this Policy from time to time by posting a new version on this page. You should visit this page occasionally to ensure you agree with any changes. We will post our revised Policy on this page and update the “Last updated” date above to reflect the date of the changes. By continuing to use our App after we post any such changes, you agree that you accept the Policy as modified.

Contact Us

If you have a complaint, dispute, or questions regarding this Policy or our treatment of your Personal Data, please contact us at or via postal mail:

Director of Operations

212 Middlesex Avenue

Chester, CT 06412

United States

Please allow up to 10 working days for us to reply.

European Union Representative

VeraSafe has been appointed as Greenwald Industries’ representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Greenwald Industries only on matters related to the processing of Personal Data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative

Alternatively, VeraSafe can be contacted at:

Matthew Joseph

Zahradníčkova 1220/20A

Prague 15000

Czech Republic

 

VeraSafe Ireland Ltd

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

Supervisory Authority Oversight

If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union Member States.