Privacy Policy

Overview

This privacy policy explains how and why SendFriend Inc. (“SendFriend”) collects, stores, uses, and shares personal data when you visit our websites or use our services. Reading it will help you understand your privacy rights and choices. “Personal data” in this policy means information about you, including your identity, finances, and online behavior.

Your Privacy Rights & Choices

You have the right to request a copy of the personal data we’ve collected about you in the past 12 months. You also have the right to ask us to delete your personal data we collected about you. If you want to see or delete your personal data, contact us at info@sendfriend.io. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.

If you request to see or delete your personal data, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request.

If you want to delete your personal data, you can (A) contact us at info@sendfriend.io, or (B) close your account. However, if you close your account or request that we delete personal data, we still need to keep some personal data so we can:

• Complete a transaction, provide goods or services you requested, or comply with our promises to you in the User Agreement [link] or other contract you have with us
• Detect and prevent malicious, fraudulent, or illegal activity
• Protect your (or another person’s) legal rights, including the right to free speech
• Manage our internal business processes that are reasonably related to your expectations when using our services
• Comply with laws

Depending on where you live and what type of account you use, you may have different rights and choices for managing your personal data. For example, certain State privacy laws do not apply to personal data collected, processed, or disclosed by a financial institution according to federal laws, such as the Gramm-Leach-Bliley Act. Consumers may read our Consumer Privacy Notice (see below) for more information about their rights under US federal law.

Our Communications With You

Your choices about how we communicate with you differ depending on the purpose of the message and how it is delivered. Some messages are considered optional, and some are necessary for you to manage your accounts with us. We use email, text messages, push notifications on your mobile device, and even paper mail depending on the situation and your preferences. Optional (marketing) communications will contain a link allowing you to unsubscribe from those communications. However, you won’t be able to opt out of messages that are considered necessary for you to manage your account, such as receipts and emails that alert you to changes in your account’s status that require your attention.

Collection & Use of Your Personal Data

We may collect your personal data when you register for or use our services, such as when you create an account or authorize a transaction. This may include:

• Information that identifies you, for example:
  1. First and last name
  2. Address
  3. Phone number
  4. Email
  5. IP address
  6. Device Information
  7. Information collected from cookies or other tracking technologies
• Records and financial information, for example:
  1. Social Security Number
  2. Government-issued identification
  3. Bank account and routing numbers
  4. Credit and debit card information
  5. Financial information
• Personal characteristics, for example:
  1. Age
  2. National origin
  3. Citizenship
• Geolocation data, for example:
  1. Global Positioning System (GPS) information when you give us permission through your device settings
  2. IP-based geolocation
• Audio, electronic, visual, biometric, or similar information, for example:
  1. Call recordings when you talk to customer service
  2. Voice identification, when you consent to this biometric method of authentication
  3. Photo IDs and profile pictures you provide
• Professional or employment information, for example:
  1. Business information, contact emails and phone numbers
  2. Tax IDs
• Information we infer based on your personal data, for example:
  1. Fraud and risk assessments
  2. Personalization preferences
  3. Where personal data comes from

We may collect personal information about you from various sources, for example from:

• You, when you use a SendFriend service
• Our payment partners, such as card networks and payment processors
• Financial institutions, such as banks
• Credit bureaus
• Service providers, such as companies that help us manage risk and fraud, deliver services to you, and market our services

If you have an account with SendFriend, we will associate information from all these sources with your account to improve your experience and for compliance and analytics purposes.

We do not knowingly collect personal information from people who are not allowed to use our sites and services. Contact us if you believe that we’ve mistakenly collected personal data from someone not allowed to use our services. We’ll delete it immediately, unless we’re legally required to keep it.

Use of Tracking Technologies

We or our authorized service providers may use cookies and similar tracking technologies to collect personal data whenever you use our services, visit our sites, or visit websites that offer our services. The information collected with these technologies helps us personalize your experience, measure the effect of our ads, prevent fraud and enhance the security of our sites and service.

You can disable or decline some cookies for our sites and services. But, since some parts of our service rely on cookies to work, those services could become difficult or impossible to use.

Some web browsers have an optional setting called “Do Not Track” (DNT) that lets you opt-out of being tracked by advertisers and some third parties. Some of our services may not function without tracking data; accordingly, we may not respond to DNT settings and/or the usage of DNT settings may impact the availability of the services.

Why We Collect Personal Data

We collect personal data for many reasons, including to improve your experience, and to run our business. Specific reasons why we collect your personal data include:

• Run our sites and provide better services, for example to help you send or request money, make purchases, show you your account information, verify access to your account, and keep your account and payment information up to date.
• Manage and improve our business. For example, we do user research to improve our products’ performance and abilities. We also monitor and analyze our sites to help ensure they work as expected.
• Protect our business and our customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and merchants.
• Send you marketing information about our products and services. We may use personal data to market about our partners. We use personal data to better understand and cater to your interests.
• Personalize your experience when you use our sites and services, as well as other third-party sites and services. In this case, we might use tracking technologies like cookies.
• Contact you when you need us, such as answering a question you sent to our customer service team.
• Comply with laws and enforce our agreements with you and other people who use our services.

How & Why We Share Personal Data

We do not sell your personal data. However, we may share personal data across our services and with other members of the SendFriend corporate family. Sometimes we share the personal data we collect with third parties to help us provide services, protect our customers from risk and fraud, market our products, and comply with legal obligations. We may share personal data with:

• Service providers that help us with processing payments, marketing, research, compliance, audits, corporate governance, communications, and security
• Card networks and payment processors
• Financial institutions, such as banks we partner with to offer joint products
• Credit reporting and collections agencies
• Courts, governments, regulators and law enforcement when accompanied by a subpoena or other legal documentation that requires SendFriend or members of our corporate family to respond
• People involved in a transaction, such as other users or merchants and their service providers
• Third parties that you asked us to connect with, such as other financial or social media apps
• Third-party tools used to help fight spam and abuse
• Other third parties to comply with laws, investigate or enforce violations of our user agreement, facilitate a merger, purchase, or sale of part or all of our business or to prevent or illegal activity

How We Protect Your Personal Data

Helping to keep your personal data safe against loss, misuse, unauthorized access, disclosure, and alteration is our top priority. To protect your personal data, we use technical, physical, and administrative security measures that include:

• Firewalls
• Data encryption
• Physical access controls at premises.

While we protect our systems and services, you’re responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date.

If your account is closed, we may keep your personal data and other information as required by law and according to our data retention policy. If we do, we’ll continue to handle it as we describe in this policy.

Updates To Our Privacy Policy

We’ll make changes to this privacy policy from time to time. This helps us stay up to date with changes to our business and the most current laws. After a new version is published, we’ll collect, store, use, and protect your personal data as we outline in that revised statement.

We’ll post any updates to this policy on the Privacy Policy page of our website prior to it becoming effective. We may also notify you about these changes through email or other communications.

Contact Us

If you have questions about this privacy policy or your personal data, contact us at info@sendfriend.io.

Consumer Privacy Notice

This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses SendFriend sites or services for your own personal, family or household purposes.