Privacy Policy

SEND FOUNDATION

T&F Chambers, Nikao, Avarua, Rarotonga, Cook Islands


DocumentPrivacy Policy
Version2.0
Effective DateJune 28, 2023
Last RevisedJanuary 13, 2026
Document OwnerCompliance Department

This Privacy Policy ("Policy") describes how Send Foundation ("Send," "we," "us," or "our") handles personal information that we collect through our mobile application (the "App"), website, social media, marketing activities, live events, and other activities described in this Policy.

Send may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. Our App and related services are designed for use by individuals for their personal, family, or household purposes.


Article 1. Personal Information We Collect

Section 1.1 Information You Provide

Personal information you may provide to us through the App or otherwise includes:

(a) Contact data: your first and last name, email address, mailing address, and phone number.

(b) Financial data: your bank account, payment card details, or other payment information.

(c) Identity data: your date of birth, social security number, taxpayer identification number, driver's license number, and a copy of your government-issued identification.

(d) Communications: messages we exchange with you, including when you contact us through the App, social media, or otherwise.

(e) Marketing data: your preferences for receiving our marketing communications and details about your engagement with them.

Section 1.2 Third-Party Sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

(a) Public sources, such as government agencies, public records, and social media platforms.

(b) Data providers, such as information services and data licensors.

Section 1.3 Automatic Data Collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the App, our communications, and other online services, such as:

(a) Device data: your device's operating system, browser type, IP address, unique identifiers, language settings, and general location information.

(b) Online activity data: pages or screens you viewed, navigation paths, access times, and duration of access.

(c) Location data: when you authorize the App to access your device's location.


Article 2. How We Use Your Personal Information

We may use your personal information for the following purposes:

(a) Service delivery: provide, operate, and improve the App; enable security features; communicate with you about the App; and respond to your requests and feedback.

(b) Research and development: analyze and improve the App and our business.

(c) Compliance and protection: comply with applicable laws; protect rights, privacy, safety, or property; prevent fraud and illegal activity.

(d) With your consent: in cases where we specifically ask for your consent to collect, use, or share your personal information.


Article 3. How We Share Your Personal Information

We may share your personal information with:

(a) Service providers: companies that provide services on our behalf (hosting, customer support, email delivery, analytics).

(b) Professional advisors: lawyers, auditors, bankers, and insurers where necessary.

(c) Authorities: law enforcement and government authorities as required by law.

(d) Business transferees: in connection with mergers, acquisitions, or other business transactions.


Article 4. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

Data TypeRetention Period
Account dataLifetime of account; deleted upon account deletion
Financial and transaction recordsMinimum seven (7) years per tax, AML, and regulatory requirements
KYC and identity verification dataMinimum seven (7) years per FinCEN and AML regulations
Activity logsThree (3) years for security and audit purposes
Marketing dataUntil opt-out or deletion request

Note: Blockchain transaction data is immutable and cannot be deleted from the blockchain. We can only remove off-chain references to such data.


Article 5. Your Choices and Rights

(a) Opt-out of marketing: You may opt out of marketing emails by following the unsubscribe instructions or contacting us.

(b) Access, correction, and deletion: You may request access to, correction of, or deletion of your personal information by contacting us. We will verify your identity before fulfilling your request.

(c) Account deletion: You may delete your account through the App settings. This will remove all associated personal data, subject to our legal retention obligations.

(d) Do Not Track: We currently do not respond to "Do Not Track" signals.


Article 6. Security

We employ technical, organizational, and physical safeguards designed to protect your personal information, including encryption of data in transit and at rest, multi-factor authentication, and access controls. However, no method of transmission over the Internet or electronic storage is 100% secure.


Article 7. International Data Transfer

We are headquartered in the United States and may use service providers in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may differ from those in your jurisdiction.


Article 8. Children

The App is not intended for use by children under thirteen (13) years of age. If we learn that we have collected personal information from a child under 13 without parental consent, we will delete it.


Article 9. Changes to This Policy

We reserve the right to modify this Policy at any time. If we make material changes, we will notify you by updating the date of this Policy and posting it in the App. Your continued use of the App after changes indicates your acceptance of the modified Policy.


Article 10. Contact Information

For questions regarding this Policy or to exercise your rights, please contact:

Send Foundation — Compliance Department

Email: privacy@send.it

Address: T&F Chambers, Nikao, Avarua, Rarotonga, Cook Islands


End of Document

Privacy Policy v2.0 — Send Foundation