SendSpend Privacy Policy 

1. Overview

 

SendSpend has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you download and install our App or use our Services. This Privacy Policy applies to your Personal Data when you download and install our App or use Services, and does not apply to online websites, apps or services that we do not own or control, including websites, apps or services of other SendSpend Users.

 

This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our App and Services. Please note that our Service offerings may vary by region.

 

We have defined some terms that we use throughout the Privacy Policy.  You can find the meaning of a capitalized term in the Definitions section.

 

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Policy.

 

2. What Personal Data Do We Collect?

 

We may collect information about you when you visit our Apps or use our Services, including the following:

 

  • Registration and use information – When you register to use our Services by establishing an e-Wallet, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an e-Wallet. We may require you to provide us with additional Personal Data as you use our Services.

  • Transaction and experience information – When you use our Services or access our App, for example, to make purchases from merchants, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.

  • Participant information – When you use our Services or access our App, we collect Personal Data you provide us about the other participants associated with the transaction.

    • Send or request money:  When you send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial e-Wallet information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money. 

    • Pay or request someone else to pay a bill:  If you use our Services to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we collect Personal Data from you about the e-Wallet holder such as name, postal address, telephone number, email address, and e-Wallet number of the bill that you intend to pay or request to be paid.

    • Add value to your e-Wallets: If you use our Services to add value to your E-Wallet or any other e-Wallet you may have, or if you ask a User to add value to any of these e-Wallets, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, if you use our Services to reload a mobile phone, or to request value be added to your mobile e-Wallet, we may collect Personal Data and other information including mobile e-Wallet number from the other participant.

  • Information about your friends and contacts – It may be easier for us to help you transact with your friends and contacts if you provide Personal Data such as name, email address and telephone number about your friends and contacts while using a Service or if you connect your contact list or friend list to your E-Wallet.  If you choose to connect your contact list information on your device with your E-Wallet and/or establish an e-Wallet connection between a social media platform and your E-Wallet, we will collect and use your contact list or friend list information to improve your experience when you use the Services.

  • Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional App feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection if the use of that information differs from the uses disclosed in this Privacy Policy. 

  • Information about you if you transact as a guest – Certain limited Services are available without being required to log in to or establish an E-Wallet, also referred to as Feature Phone Transactions. We will collect Personal Data, information about any funding instrument used to complete a Feature Phone Transaction, Device Information, Technical Usage Data, and Geolocation Information as necessary to provide the requested Feature Phone Transactions. If you are an E-Wallet holder and choose to make a Feature Phone Transaction, we will collect information about the transaction and may associate it with your E-Wallet. If you are not an E-Wallet holder and choose to make a Feature Phone Transaction, we will collect and store all information you provide and use and share such information in accordance with this Privacy Policy.

  • Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

  • Other information we collect related to your use of our Apps or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

 

 

3. Why Do We Retain Personal Data?

 

We retain Personal Data to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your E-Wallet is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

 

 

4. How Do We Process Personal Data?

 

We may Process your information for the following reasons:

 

  • To operate the Apps and provide the Services, including to:

    • initiate a payment, send or request money, add value to an e-Wallet, or pay a bill;

    • authenticate your access to an E-Wallet;

    • communicate with you about your E-Wallet, the Apps, the Services, or SendSpend;

    • create an e-Wallet connection between your E-Wallet and a third-party platform; and

    • perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes.

  • To manage our business needs, such as monitoring, analysing and improving the Services and the Apps’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services.

  • To manage risk and protect the Apps, the Services and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Apps or Services.

  • To market to you by delivering marketing materials about SendSpend products and online Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor certain Services or App experiences to better match our understanding of your interests.

  • To provide personalized Services offered by SendSpend on third-party websites, Apps and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites or apps. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.

  • To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services.  We will use this information to enhance the security of the Apps and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.

  • To comply with our obligations and to enforce the terms of our Apps and  Services, including to comply with all applicable laws and regulations.

  • To make it easier for you to find and connect with others, we may use the information you have shared with the Service to suggest connections between you and people you may know. For example, we may associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service.

  • To respond to your requests, for example, to contact you about a question you submitted to our customer service team.

 

 

5. Do We Share Personal Data?

 

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

 

We may share your Personal Data or other information for the following reasons:

 

  • With other members of SendSpend: We may share your Personal Data with other members of SendSpend to, among other things, provide the Services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of SendSpend products, Services, and communications.

  • With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.

  • With other financial institutions that we have partnered with to jointly create and offer a product or service: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer products.  These financial institutions may only use this information to market and offer SendSpend-related products unless you have given consent for other uses.

  • With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information with the other participants to your transactions, including other Users you are sending or receiving funds from, and merchants or their service providers when you use the Services to pay for goods or services. The information includes:

    • Personal Data necessary to facilitate the transaction;

    • information to help other participant(s) resolve disputes and detect and prevent fraud; and

    • aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.

  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for SendSpend’s business purposes or as permitted or required by law, including:​

    • if we need to do so to comply with a law, legal process or regulations;

    • law enforcement, regulators, government officials, or other third parties in relation to a subpoena, court order, or other legal process or requirement under any law or regulation of any jurisdictions that are applicable to SendSpend or one of its affiliates; when we need to do so to comply with such law or banking rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;

    • to protect the vital interests of a person;

    • to protect our property, Services and legal rights;

    • to facilitate a purchase or sale of all or part of SendSpend’s business;

    • in connection with shipping and related services for purchases made using a Service;

    • to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Apps or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;

    • to banking partners as required by card association rules for inclusion on their list of terminated merchants;

    • to credit reporting and collection agencies;

    • to companies that we plan to merge with or be acquired by; and

    • to support our audit, compliance, and corporate governance functions.

  • With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an e-Wallet connection with a third-party e-Wallet or platform.

 

In addition, SendSpend may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Apps and use our Services.  This data will not personally identify you or provide information about your use of the Apps or Services.  We do not share your Personal Data with third parties for their marketing purposes without your consent.

 

 

6. How Do We Use Cookies and Tracking Technologies?

 

When you visit our Apps, use our Services, or visit a third-party website or app for which we provide Online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Apps and Services.  Certain aspects and features of our Services and Apps are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Apps and Services may be limited or not possible.

 

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties.  We do not respond to DNT signals.

 

 

7. What Privacy Choices Are Available To You?

 

You have choices when it comes to the privacy practices and communications described in this Privacy Policy.  Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of an App.  You may be provided with instructions and prompts within the experiences as you navigate the Services. 

 

  • Choices Relating to the Personal Data We Collect

    • Personal Data. You may decline to provide Personal Data when it is requested by SendSpend, but certain Services or all of the Services may be unavailable to you.

    • Location and other device-level information. The device you use to access the Apps or Services may collect information about you, including Geolocation Information and User usage data that SendSpend may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.

 

  • Choices Relating to Our Use of Your Personal Data

    • Personalised Services offered by SendSpend on third-party websites, apps and services. You may manage your preferences for other SendSpend Services that are personalised and offered to you on third-party websites and apps from your E-Wallet. We may also provide you with instructions and prompts on how to manage your preferences within the Service experience.

    • Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your e-Wallet of the Service you use.

 

  • Choices Relating to Cookies

    • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or App.

    • You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of an App. For example, you may be asked if you want the Service or App to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.

    • You can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page.

 

  • Choices Relating to Your Registration and E-Wallet Information

    • If you have an E-Wallet, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if you have questions about your E-Wallet information or other Personal Data.

 

  • Choices Relating to Communication

    • Notices, Alerts and Updates from Us: 

      • Marketing: We may send you marketing content about our Apps, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt-out of these marketing communications by following the instructions in the communications you receive. If you have an E-Wallet with us, you may also adjust your communication preferences in your E-Wallet settings. For messages sent via push notifications, you may manage your preferences in your device.

      • Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt-out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

 

8. How Do We Protect Your Personal Data?

 

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s), Personal Identification Number (PIN) and E-Wallet/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

 

9. Can Children Use Our Services?

 

The Apps and Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Apps and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

 

10. What Else Should You Know?

 

Changes to This Privacy Policy.

 

We may revise this Privacy Policy from time to time to reflect changes to our business, the Apps or Services, or applicable laws.  The revised Privacy Policy will be effective as of the published effective date.

 

If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” section of our App or page of our website. We also may notify Users of the change using SMS, email or other means.

 

Transfers of Your Personal Data to Other Jurisdictions

 

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the United Kingdom, European Union, United States of America, Republic of South Africa and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other jurisdictions. By using our Apps and Services, you consent to your Personal Data being transferred to other jurisdictions, including jurisdictions that have different data protection rules than your jurisdiction.  We do not represent that our Apps and Services are appropriate or available in any particular jurisdiction.

 

11. Contact Us

 

You may contact us if you have general questions about our Privacy Policy and practices or questions about your E-Wallet information or Personal Data.

 

We want to make sure your questions go to the right place:

  • Click here to contact us about your SendSpend e-Wallet

 

 

12. Definitions

 

  • E-Wallet means a SendSpend e-Wallet.

  • Device Information means data that can be automatically collected from any device used to access the Apps or Services.  Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the App or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).

  • Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell-phone triangulation. Some of our Services may ask you for permission to share your current location. Some of the Apps and Services require this information to provide a specific product or online Service. If you do not agree with our collection of the geolocation information, our Apps or Services may not function properly when you try to use them.

  • SendSpend means SendSpend Limited and subsidiaries or affiliates. In this Privacy Policy, SendSpend is sometimes referred to as “we,” “us,” or “our,” depending on the context.

  • Personal Data means personal information that can be associated with an identified or identifiable person.  “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial e-Wallet information, e-Wallet number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID).  Personal Data does not include information that does not identify a specific User.

  • Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

  • Services mean any products, services, content, features, technologies, or functions, and all related applications, websites and services offered to you by SendSpend in connection with an E-Wallet.

  • APPs mean the SendSpend mobile App, website, official social media platforms, or other online properties through which SendSpend offers the Services and which has posted or linked to this Privacy Policy.

  • Technical Usage Data means information we collect from your phone, computer or other devices that you use to access the Apps or Services. Technical Usage Data tells us how you use the Apps and Services, such as what you have searched for and viewed on the Apps and the way you use our Services, including your IP address, IMEI number, device ID, statistics regarding how pages are loaded or viewed, the websites you have viewed and other usage and browsing information collected through Cookies.

  • User means an individual who uses the Services or accesses the Apps and has established a relationship with SendSpend (for example, by opening an E-Wallet and agreeing to the SendSpend User Agreement) or otherwise uses the Services as a buyer, seller or other types of participants to a transaction.

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