Privacy Policy

SENDFUNDS

Last Updated: February 01, 2024

Privacy Policy

SENDFUNDS (“SENDFUNDS,” ‘we,” ‘our,” and/or “us”) values the privacy of individuals who use our applications or services that link to this Privacy Policy (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal information from users of our Services.

Applicability

By using our applications and services (“Services”), you voluntarily are providing your personally identifiable information to us and consent to the collection and use of such personally identifiable information as set for in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service.

If you do not agree to the terms of this Privacy Policy or our Terms of Service, then do not provide us with any information and do not utilize our Services.

Modification

We may modify this Privacy Policy at any time so please review this policy from time to time. If you have questions regarding this Privacy Policy, please contact us at compliance at [email protected].

Information We and /or Vendors and Service Providers Collect

We and/or Vendors and Service Providers retained in connection with the provision of our Services may collect a variety of personally identifiable information from or about you or your devices from various sources, as described below.

A – Information You Provide to Us

Registration and Profile Information. When you register for an account to use our Services, we ask you for your personally identifiable information, including your name, email address, phone number, residential address, SENDFUNDS password, date of birth, social security number, employment status, employer name, job description, annual income, net worth, any identify documents(e.g., driver’s license, etc.), information on your trusted contacts (name and phone number, email, address, relationship), affiliations with companies and/or brokerage, and information on whether you or a family member are a senior military, governmental, or political official.

Communications. If you contact us directly, we may receive personal information about you. For example, when you contact us to learn more about our Services or for support, we will receive your name, email address, and the contents of your message. If you subscribe to our marketing communications, we will receive your name and email address.

Careers. If you decide to apply for a job with us, we will collect the personal information you provide to us as part of your job application, such as your contact information and other information you submit with your application and/or include it on your resume. If you apply for a job with us through a third-party platform , we will collect the personal information you make available to us through such third-party platform.

B – Information We Collect When You Use Our Services

Use of our Services. When you use our Services, we collect the personal information you provide to us. For example, when you make a trade through SENDFUNDS we will collect information regarding your trade, such as the date and amount of the trade. We will also collect information regarding your trade history, such as a record of your orders, positions, and related information, and any other information you provide to us.

Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and so􀅌ware you use to access our Services, including internet protocol (IP) address, device type, and operating system version.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with them, such as the length of time you spend on a page, objects you click on, and the dates, times, and lengths of your sessions. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to htps://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at htps://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both “Session” cookies, which disappear after you close your browser, and “Persistent” cookies which remain after you close your browser and may be used by your browser on subsequent visits to our Services. Cookies enable a website to recognize you on your return, remember your preferences and provide tailored services to you. Cookies will not contain information that will enable us to contact you via telephone, e-mail, or other means. To manage the Cookies that apply to our site, please review the settings. In addition to the above uses, we may use your information for the purpose of conducting business with you and managing our relationship with you. The information collected is also used to provide a record of communications between SENDFUNDS and visitors to our site and to comply with any applicable legal and/or regulatory requirements.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

C – Personal Information We Receive from Third Parties

Partners. We may receive personal information about you from third parties and combine it with other personal information we have about you.

How We Use the Personal Information We Collect

We use the personal information we collect:

• To provide, maintain, debug, improve, and enhance our Services.
• To understand and analyze how you use our Services, and develop new products, services, features, and functionality.
• To understand and analyze usage patterns.
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
• To send you push notifications and/or text messages.
• To generate de-identified and aggregated data for any lawful purpose.
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
• To find and prevent fraud and respond to trust and safety issues that may arise.
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the personal information is collected.

How We Share the Personal Information We Collect

We do not share or otherwise disclose personal information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may share personal information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any personal information we receive with vendors and service providers retained in connection with the provision of our Services.

Digital Asset Securities Trading. We will provide information regarding your trade or other account information as required to settle your trade.

Marketing. We do not rent, sell, or share personal information about you with non- affiliated companies for their direct marketing purposes unless we have your permission.

Analytics Partners. We may use analytics services such as Google Analytics. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to htps://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at htps://tools.google.com/dlpage/gaoptout.

As Required by Law and Applicable Regulations. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Aggregate Information. We may share in aggregate, statistical form, non-personal information regarding the visitors to the Site, traffic patterns, and site usage with our partners and affiliates.

Merger, Sale, or Other Asset Transfers. We may transfer your personal information to service providers, advisors, potential transactional partners, or other third partes in connection with the consideration,

negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.

Consent. We may also disclose your personal information with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Third Parties. Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any personal information you disclose to these third parties. We encourage you to read their privacy policies before providing any personal information to them.

Safeguards

SENDFUNDS is aware that customer information and records can be compromised in a variety of ways. Intrusions are generally accomplished through the theft of the login credentials of a customer or firm employee. Accounts can also be breached through fake electronic instructions (e.g., email requests for funds transmittals). SENDFUNDS Vendors and Service Providers have technical controls to protect Firm software and hardware that stores and processes data, as well as the data itself. They have a defense in depth strategy, this concept involves multiple layers of security controls that are placed throughout the firm’s Information Technology system. Access to the Firm’s network is restricted to authorized users only.

Associated persons are granted access to the Firm’s systems based on the individual’s function with the Firm. Infrastructure and network level access and changes are logged and monitored by SENDFUNDS staff. SENDFUNDS also has a system of alerts and notifications for issues that may arise and maintains logs for Incident Management. Only the CEO or CTO or his/her designee can cause changes to network devices. Access to administrative functions is controlled by the CTO. The trading system components can only be updated by the CTO or his/her designee.

Security

We and our Vendors and Service Providers make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain. However, the security of this information depends in part on the security of the computer you use to communicate with us, the security you use to protect User IDs and passwords, and the security provided by your internet access services provider. We are not responsible for the security of your internet access services provider; you should review the security and privacy policies of your internet access services provider carefully. Informa􀆟on that you access via this Site may be stored on your computer during your session for your convenience. If others have access to your computer or your User ID and password, they may be able to access this information. We are not responsible for the security or privacy of information communicated to or from such a computer.

Finally, you should keep any correspondence you receive relating to this Site or the Services (including, but not limited to registration information, emails, or any other information) confidential and in a safe place.

International Visitors

Our Services are hosted in the United States. We may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing. If you choose to use our Services, please note that you are transferring your personal information to the United States for storage and processing.

Depending on where you live, you may be able to exercise certain privacy rights related to your personal information under certain conditions.

• The right to access – You have the right to request copies of your personal data. 
• The right to rectification – You have the right to request that SENDFUNDS correct any information you believe is inaccurate. You also have the right to request SENDFUNDS to complete the information you believe is incomplete.
• The right to erasure – You have the right to request that SENDFUNDS erase your personal data, under certain conditions. (Applicable rules may prevent SENDFUNDS from honoring your request).
• The right to restrict processing – You have the right to request that SENDFUNDS restrict the processing of your personal data, under certain conditions. (Applicable rules may prevent SENDFUNDS from honoring your request).
• The right to object to processing – You have the right to object to SENDFUNDS processing of your personal data, under certain conditions. (Applicable rules may prevent SENDFUNDS from honoring your request).
• The right to data portability – You have the right to request that SENDFUNDS transfer the data that we have collected to another organization, or directly to you, under certain conditions.

(Applicable rules may prevent SENDFUNDS from honoring your request).

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected]

California Residence

• The right to know: You can request that SENDFUNDS disclose to you: (1) the categories and/or specific pieces of personal information they have collected about you, (2) the categories of sources for that personal information, (3) the purposes for which the business uses that information, (4) the categories of third par􀆟es with whom the business discloses the information, and (5) the categories of information that the business sells or discloses to third parties. You can make a request to know up to twice a year, free of charge.
• The right to delete: You can request that SENDFUNDS delete personal information we collected from you and tell our service providers to do the same, subject to certain exceptions (such as if SENDFUNDS or our service providers are legally required to keep the information).

• The right to opt-out of sale or sharing: You may request that SENDFUNDS stop selling or sharing your personal Information (“opt-out”), including via a user-enabled global privacy control. SENDFUNDS cannot sell or share your personal information after we receive your opt-out request unless you later authorize us to do so again.
• The right to correct: You may ask SENDFUNDS to correct inaccurate information that we have about you.
• The right to limit use and disclosure of sensitive personal information: You can direct SENDFUNDS to only use your sensitive personal information (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested. If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected]

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].