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Last Updated: June 11, 2024

1. Introduction

At SendMoney360.com ("we," "us," "our," or "SendMoney360"), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, disclose, store, and protect your personal data when you use our global money transfer services through our website, sendmoney360.com, mobile applications, or related services (collectively, the "Services"). Our mission is to provide fast, secure, and cost-effective international money transfers, and we handle your data with the utmost care to maintain your trust.

This Privacy Policy is designed to comply with global privacy laws and regulations, including but not limited to the General Data Protection Regulation (GDPR) in the European Union, the UK GDPR, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable data protection frameworks. It explains what data we collect, how we use it, your rights, and how you can contact us with privacy-related inquiries.

By using our Services, you acknowledge that your personal data will be processed as described in this Privacy Policy. If you do not agree with this policy, please do not use our Services. For additional details on our use of cookies, please refer to our separate Cookie Policy.

2. Who We Are

SendMoney360 is a global fintech platform offering secure and efficient international money transfer services to individuals and businesses worldwide. We are dedicated to providing transparent, user-friendly financial solutions while adhering to strict regulatory standards, including anti-money laundering (AML) and know-your-customer (KYC) requirements.

Data Controller Details

For the purposes of GDPR and UK GDPR, the data controller is:
SendMoney360 Limited
123 Global Street, Suite 456, London, UK, EC2N 1AR
Email: privacy@sendmoney360.com
Phone: +44 20 1234 5678

For inquiries related to data protection in other jurisdictions, please contact our Data Protection Officer using the details in Section 16.

3. What Data We Collect

We collect various types of personal data to provide our Services, ensure compliance with legal obligations, and enhance your user experience. The categories of data we collect include:

3.1 Personal Information

  • Identity Data: Full name, date of birth, nationality, government-issued identification (e.g., passport, driver’s license, or national ID number for KYC purposes).
  • Contact Data: Email address, phone number, billing address, and delivery address (if applicable).
  • Profile Data: Username, password, security questions, and account preferences (e.g., language, currency).

3.2 Financial Information

  • Payment Data: Bank account details, credit/debit card information, or other payment method details (processed securely via our payment partners).
  • Transaction Data: Details of money transfers, including recipient information, amounts, currencies, dates, and transaction references.
  • Tax Information: Tax identification numbers or residency details, where required for regulatory reporting.

3.3 Device and Browser Data

  • Technical Data: IP address, browser type and version, operating system, device type, and other identifiers.
  • Usage Data: Information about how you interact with our Services, such as pages visited, links clicked, and time spent on the website.

3.4 Location Data

  • Geolocation Data: Approximate location based on your IP address or precise location (with your consent) to comply with regional regulations, detect fraud, or provide location-specific services.

3.5 Cookies and Tracking Data

  • Cookie Data: Information collected via cookies and similar technologies (e.g., web beacons, tracking pixels) to enhance functionality, analyze performance, or deliver personalized ads. See our Cookie Policy for details.

3.6 Other Data

  • Customer Support Data: Communications with our support team, including emails, chat logs, or call recordings (where permitted by law).
  • KYC/AML Data: Information collected during identity verification, such as ID documents, proof of address, or source-of-funds documentation.
  • Marketing Data: Preferences for receiving promotional materials or newsletters, where you have opted in.

We do not collect sensitive personal data (e.g., racial or ethnic origins, political opinions, health data) unless strictly necessary for legal compliance or with your explicit consent.

4. How We Collect Data

We collect your personal data through various methods to provide and improve our Services:

4.1 Through Website Forms

  • Account registration forms (e.g., name, email, password).
  • Transaction forms for initiating money transfers (e.g., recipient details, payment information).
  • Contact or support request forms.

4.2 Through Transactions

  • Data provided during money transfers, such as bank account details or recipient information.
  • Information collected during KYC/AML verification processes, including ID uploads or proof of address.

4.3 Through Cookies and Analytics Tools

  • Cookies, web beacons, and tracking pixels collect usage and technical data (e.g., IP address, page visits). See our Cookie Policy for details.
  • Third-party analytics tools (e.g., Google Analytics, Hotjar) provide anonymized insights into user behavior.

4.4 From Third Parties

  • KYC/AML Providers: We partner with third-party services (e.g., Onfido, Trulioo) to verify your identity and comply with regulatory requirements.
  • Payment Processors: Partners like Stripe or PayPal provide payment-related data to process transactions securely.
  • Marketing Partners: If you opt in, we may receive data from advertising networks or social media platforms to deliver personalized ads.
  • Public Sources: We may collect data from public records or government databases for compliance purposes (e.g., sanctions lists).

We ensure that all data collection methods comply with applicable privacy laws and that third-party providers adhere to equivalent standards.

5. How We Use Your Data

We use your personal data to deliver our Services, comply with legal obligations, and enhance your experience. Specific purposes include:

5.1 To Process Transactions

  • Facilitate international money transfers, including currency conversion and payment processing.
  • Verify recipient details and ensure accurate delivery of funds.

5.2 To Verify Identity (KYC/AML Compliance)

  • Conduct know-your-customer (KYC) and anti-money laundering (AML) checks to prevent fraud, money laundering, or terrorist financing.
  • Verify your identity using government-issued IDs or other documentation.

5.3 To Detect Fraud and Ensure Security

  • Monitor transactions and account activity for suspicious behavior.
  • Use device and location data to prevent unauthorized access.

5.4 To Improve Website Performance and Services

  • Analyze usage data to optimize website functionality, user experience, and service offerings.
  • Conduct A/B testing or user surveys to enhance our platform.

5.5 For Customer Support and Communication

  • Respond to inquiries, provide transaction updates, or resolve issues via email, phone, or live chat.
  • Send transactional emails, such as transfer confirmations or account alerts.

5.6 For Marketing (Where Legally Permitted)

  • Send promotional emails, newsletters, or offers, where you have provided consent or where permitted under applicable laws (e.g., soft opt-in under GDPR).
  • Deliver personalized ads via third-party platforms (e.g., Meta, Google Ads) based on your interests.

We process your data only for the purposes outlined above and in accordance with the legal bases described in Section 6.

6. Legal Basis for Processing Data

We process personal data in compliance with applicable laws, relying on the following legal bases under GDPR, UK GDPR, and other regulations:

6.1 Consent

  • We rely on your explicit consent for non-essential processing, such as marketing communications or certain cookies (see Cookie Policy).
  • You may withdraw consent at any time via our Cookie Preference Center, account settings, or by contacting us (see Section 16).

6.2 Contractual Necessity

  • Processing is necessary to fulfill our contract with you, such as:
    • Processing money transfers and delivering funds to recipients.
    • Managing your account and providing access to our Services.

6.3 Legal Obligations

  • We process data to comply with regulatory requirements, including:
    • KYC/AML checks to prevent financial crimes.
    • Tax reporting or sanctions screening obligations.
    • Responding to lawful requests from government or regulatory authorities.

6.4 Legitimate Interests

  • We process data for legitimate business interests, provided they do not override your rights and freedoms, such as:
    • Detecting and preventing fraud or unauthorized access.
    • Improving our Services through analytics and performance monitoring.
    • Sending transactional or service-related communications.

For CCPA and PIPEDA compliance, we ensure transparency in data processing and provide opt-out options for data sharing (e.g., for advertising purposes). California residents can exercise their “Do Not Sell or Share My Personal Information” rights via our website footer or by contacting us.

7. How We Share Data

We may share your personal data with trusted third parties to provide our Services, comply with legal obligations, or improve user experience. Categories of recipients include:

7.1 Service Providers

  • Payment Processors: Partners like Stripe, PayPal, or local banking institutions process payments securely.
  • Cloud Storage Providers: We use secure cloud services (e.g., AWS, Microsoft Azure) to store and manage data.
  • Analytics Providers: Tools like Google Analytics or Hotjar provide insights into website usage (anonymized where possible).
  • Customer Support Platforms: Services like Zendesk manage support tickets and communications.

7.2 Compliance Partners

  • KYC/AML Providers: Companies like Onfido or Trulioo verify identities and perform compliance checks.
  • Regulatory Bodies: We may share data with financial regulators, tax authorities, or law enforcement when required by law.

7.3 Affiliates and Partners

  • We may share data with affiliated entities within the SendMoney360 group for operational purposes.
  • Marketing partners may receive data for targeted advertising, subject to your consent or opt-out preferences.

7.4 Other Disclosures

  • In the event of a merger, acquisition, or business transfer, your data may be shared with relevant parties, subject to confidentiality agreements.
  • We may share anonymized or aggregated data for research or statistical purposes, ensuring it cannot be linked to you.

All third parties are contractually obligated to comply with applicable privacy laws and maintain equivalent data protection standards. We do not sell your personal data unless explicitly authorized by you, in accordance with CCPA/CPRA requirements.

8. International Data Transfers

As a global money transfer platform, we may transfer your personal data across borders to provide our Services or comply with legal obligations. For example, data may be processed in the EU, UK, U.S., Canada, or other jurisdictions where our servers or partners are located.

To ensure compliance with GDPR, UK GDPR, and other regulations, we implement the following safeguards for international data transfers:

  • Standard Contractual Clauses (SCCs): Approved by the European Commission to ensure adequate protection for data transferred outside the EU/EEA.
  • Data Protection Framework (DPF): For transfers to the U.S., we rely on the EU-U.S. Data Privacy Framework or equivalent mechanisms, where applicable.
  • Binding Corporate Rules (BCRs): For intra-group transfers within the SendMoney360 family.
  • Adequacy Decisions: We rely on adequacy decisions for jurisdictions recognized by the EU or UK as providing equivalent data protection (e.g., Canada under PIPEDA).

We regularly assess our data transfer mechanisms to ensure compliance with evolving regulations and court rulings.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, or resolve disputes. Retention periods vary by data type:

  • Account Data: Retained for the duration of your account and up to 7 years after account closure to comply with tax and AML regulations.
  • Transaction Data: Retained for 7 years to meet financial reporting and auditing requirements.
  • KYC/AML Data: Retained for 5–7 years, as required by anti-money laundering laws.
  • Cookie Data: Retained as described in our Cookie Policy, typically ranging from session duration to 2 years for analytics cookies.
  • Customer Support Data: Retained for up to 3 years to address future inquiries or disputes.
  • Marketing Data: Retained until you unsubscribe or withdraw consent.

Once retention periods expire, we securely delete or anonymize your data. Archival systems may retain limited data for legal or auditing purposes, stored securely with restricted access.

10. Your Rights Under Privacy Laws

You have specific rights regarding your personal data, depending on your jurisdiction. These include:

10.1 GDPR and UK GDPR Rights

  • Access: Request a copy of the personal data we hold about you.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure (Right to Be Forgotten): Request deletion of your data, subject to legal retention requirements.
  • Restriction: Restrict processing of your data in certain circumstances (e.g., while we verify its accuracy).
  • Data Portability: Receive your data in a structured, machine-readable format or have it transferred to another controller.
  • Objection: Object to processing based on legitimate interests, including for direct marketing.
  • Withdraw Consent: Revoke consent for non-essential processing at any time.

10.2 CCPA/CPRA Rights

  • Know: Request details about the personal information we collect, use, or share.
  • Delete: Request deletion of your personal information, subject to exemptions (e.g., legal obligations).
  • Opt-Out of Sale/Sharing: Prevent the sharing of your data for advertising purposes.
  • Non-Discrimination: We will not discriminate against you for exercising your rights.

10.3 PIPEDA and Other Jurisdictions

  • Access and correct personal information.
  • Challenge our compliance with privacy laws.
  • Withdraw consent, subject to legal or contractual restrictions.

10.4 Exercising Your Rights

To exercise your rights, contact our Data Protection Officer at privacy@sendmoney360.com or use the “Privacy Rights” form in your account dashboard. We will respond within 30 days (or 45 days for complex CCPA requests), subject to verification of your identity. If you are unsatisfied with our response, you may lodge a complaint with your local data protection authority (e.g., ICO in the UK, CNIL in France, or OPC in Canada).

11. How We Protect Your Data

We implement robust technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse:

  • Encryption: All data transmitted via our Services is encrypted using TLS 1.3. Sensitive data (e.g., payment details) is encrypted at rest using AES-256.
  • Access Controls: Only authorized personnel with a legitimate need can access your data, protected by multi-factor authentication and role-based permissions.
  • Firewalls and Monitoring: We use advanced firewalls and intrusion detection systems to protect our servers and monitor for suspicious activity.
  • Regular Audits: We conduct regular security audits and penetration testing to identify and address vulnerabilities.
  • Compliance Certifications: Our infrastructure complies with industry standards, such as PCI DSS for payment processing and ISO 27001 for information security.

Despite our efforts, no system is completely secure. If we detect a data breach, we will notify affected users and relevant authorities within 72 hours, as required by GDPR and other laws.

12. Children’s Privacy

SendMoney360’s Services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that a child has provided personal information, we will delete it promptly in accordance with laws like the Children’s Online Privacy Protection Act (COPPA). If you believe a child has used our Services, please contact us immediately (see Section 16).

13. Cookies and Tracking Technologies

We use cookies and similar technologies (e.g., web beacons, tracking pixels) to enhance functionality, analyze usage, and deliver personalized ads. For detailed information, including types of cookies, third-party services, and how to manage your preferences, please refer to our Cookie Policy. You can manage cookie settings via our Cookie Preference Center, accessible through the website footer.

14. Links to Third-Party Sites

Our Services may contain links to third-party websites, such as payment processors or partner platforms. We are not responsible for the privacy practices or content of these sites. We encourage you to review the privacy policies of any third-party sites you visit.

15. Policy Updates

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or Services. Updates will be posted on this page with a revised “Last Updated” date. Significant changes will be communicated via email or a prominent notice on our website, where required by law.

Version History:

  • June 11, 2024: Initial publication of the Privacy Policy.
  • Future versions will be logged here with summaries of changes.

We encourage you to review this policy periodically to stay informed about our data practices.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

  • Email: privacy@sendmoney360.com
  • Mailing Address: SendMoney360 Limited, 123 Global Street, Suite 456, London, UK, EC2N 1AR
  • Phone: +44 20 1234 5678

For GDPR or UK GDPR inquiries, you may also contact your local data protection authority. A list of EU supervisory authorities is available at edpb.europa.eu. In Canada, contact the Office of the Privacy Commissioner at priv.gc.ca.

Thank you for trusting SendMoney360 with your international money transfer needs. We are committed to safeguarding your privacy and delivering secure, reliable services.

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