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:
3. Why Do We Retain Personal Data?
4. How Do We Process Personal Data?
We may Process your information for the following reasons:
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 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:
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:
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.
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?
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?
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
11. Contact Us
We want to make sure your questions go to the right place:
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 to our collection of the geolocation information, our Apps or Services may not function properly when you try to use them.
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 means 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.
Technical Usage Data means information we collect from your phone, computer or other device 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.