Privacy Policy

1. Who are we and how can you contact us if you have any concern?

The organization responsible for ensuring that your Personal Data is processed in compliance with applicable regulations is:

SendiCash [legal entity name], [registered address placeholder], [country placeholder].

If you have any concern or question, or if you would like to exercise any of your rights with respect to your Personal Data, you may contact our Data Protection Officer ("DPO") at info@sendicash.com.

2. What data do we collect about you and how do we collect it?

We collect your Personal Data through a variety of methods: either you provide it to us directly, we collect it from external sources, or we collect it by using automated means.

Information you may provide to us

You may give us information about you by filling in forms on our Sites or through our app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services and when you report a problem with the Sites or with our app.

Information we collect about you

With regard to each of your visits to our Sites or our app we automatically collect, for example:

• Login information: technical information about your use of the Services, including browser type and version, wallet identifier, last access time of your wallet, IP address used to create the wallet and the most recent IP address used to access the wallet.
• Device information: details about the device you use to access your account, including hardware model, operating system and version, and unique device identifiers, in anonymised form not tied to any particular person.
• Transaction information: information relating to transactions you effect using the SendiCash wallet (for example, converting one virtual currency to another or purchasing virtual currencies).

Information we collect because we are required to by law, rule, or regulation

Depending on the Service, we may collect information from you in order to meet regulatory obligations around know-your-customer ("KYC") and anti-money laundering ("AML") requirements. This may include your full name, residential address, contact details, date and place of birth, citizenship, bank account or card details, status as a politically exposed person, source of funds and proof of address, government identification documents, as well as transaction history and account balances.

Information we collect from external sources

We also receive information from other sources and combine that with the information we collect through our Services. For instance, we may:

• Use cookies to help personalise your online experience. Cookies provide us with information about your use of the Sites that can help us improve the Sites and your experience with them. We process Personal Data collected through cookies in accordance with this Privacy Policy and our separate Cookie Policy.
• Analyse public blockchain data to ensure that parties using our Services are not engaged in illegal or prohibited activity and to analyse transaction trends for research and development purposes.
• Use co-branded third-party services (clearly identified as such) that may collect information as determined by their own privacy policies.
• Receive basic Personal Data such as your name, address and bank account information from banks or payment processors that you use to transfer fiat currency.
• Receive anonymised information from advertising or analytics providers, including how you found our website.

3. On what basis do we collect your data?

We only use your Personal Data where we have a legal basis to do so. Depending on the context, we rely on:

• Consent: for certain processing (for example some direct marketing under the GDPR). You can withdraw your consent at any time by contacting us.
• Performance of a contract: where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legal obligation: where we must process Personal Data to comply with legal obligations, including those applicable to financial services institutions (for example KYC and AML requirements).
• Legitimate interest: where processing is necessary for our legitimate interests in conducting our business (for example preventing fraud, enhancing security, and statistical analysis) and where such interests are not overridden by your rights and freedoms.

4. For what purposes do we collect your data?

We collect and use your Personal Data to:

• Provide our Services, including customer support.
• Process transactions and send notices about your transactions.
• Resolve disputes, collect fees, and troubleshoot problems.
• Communicate with you about our Services and business, respond to questions or requests, and handle complaints.
• Comply with applicable laws and regulations and establish, exercise and defend claims.
• Monitor and report compliance issues.
• Customise, measure, and improve our business, Services, and the content and layout of our sites and apps (including developing new products and services).
• Perform data analysis and internal technical operations.
• Deliver targeted marketing, service updates and promotional offers (where permitted) and measure their effectiveness.
• Perform risk management and protect against, identify and prevent fraud, prohibited or illegal activity, claims and other liabilities.
• Enforce our contractual terms.

5. How long do we keep your data?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including satisfying legal, accounting or reporting obligations or resolving disputes. Retention periods vary by jurisdiction and context.

For example, Personal Data collected to comply with financial or anti-money laundering laws may be retained after account closure for as long as required under such laws. Contact information used for marketing is retained until you unsubscribe, after which we add your details to a suppression list.

6. Who do we share your Personal Data with?

We may share your information with selected recipients to perform functions required to provide certain Services and to prevent and investigate fraud or other criminal activity. All such third parties are contractually bound to protect data in line with this Privacy Policy.

These recipients may include:

• Other SendiCash entities.
• Service providers who support our operations (for example cloud infrastructure, identity verification, analytics, customer service and marketing tools).
• Law enforcement, regulators, banks and other third parties where required by law or when we believe disclosure is necessary to report suspected illegal or fraudulent activity or to enforce our terms.
• Buyers or successors in the event of a merger, restructuring or similar corporate transaction.

7. Is your data transferred outside of the European Union?

Where Personal Data is transferred from the European Economic Area to countries outside the EEA, we ensure appropriate safeguards are in place, such as standard contractual clauses or other mechanisms recognised by applicable data protection laws.

8. What are your rights?

Under applicable data protection laws (such as the GDPR), you may have rights in relation to your Personal Data, including:

• The right to withdraw consent where processing is based on consent.
• The right of access to the Personal Data we hold about you.
• The right to rectification of inaccurate or incomplete Personal Data.
• The right to erasure of your Personal Data in certain circumstances (the "right to be forgotten").
• The right to restrict processing in certain circumstances.
• The right to data portability in some cases, allowing you to receive your Personal Data in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
• The right to object to processing based on legitimate interests, particularly where processing relates to direct marketing.

You can exercise these rights free of charge by contacting us at info@sendicash.com. Before responding, we may need to verify your identity and may request additional information where necessary. We will respond within the timeframes set by law.

9. How about children's privacy?

Our Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under 18. If you are a parent or guardian and you become aware that your child has provided us with Personal Data, please contact us at info@sendicash.com. If we learn that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our systems.

10. What happens if we make changes to this Privacy Policy?

We may update this Privacy Policy from time to time to reflect changes to our information practices. We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes on this page and, if the changes are significant, we will provide a more prominent notice.

11. Contact information

You may contact us with questions or concerns about our privacy policies or practices at info@sendicash.com.