Dear Customer,
Please review the following document before using our app to send money.

Privacy Policy Your privacy is very important to us

SENDINR LIMITED ("SENDINR")

These Terms and Conditions ("the T&Cs") and the Privacy Statement govern your use of SENDINR's Payment Services offered through its Website/Mobile application. You must accept and agree to abide by the T&Cs and acknowledge the content of the Privacy Statement before sending funds via the Website/mobile application.

1. What data do we collect?

Like most companies, we collect various types of data about our customers. Some of it may be considered personal data, which means data that make you identifiable as an individual.
As a regulated financial institution, we are bound by the legal requirement to collect, verify and record certain data about you or recipients of your transactions. All types of data we gather may be used to prevent or detect crime.

We may collect and use the following data:
Basic personal data, such as (but not limited to):

• Date of birth
• Address
• Phone number
• E-mail address

This data is necessary for SendINR to provide the Service to you. We will request this data when you sign up, before the Service is provided.
Data for ‘Know Your Customer’ (KYC) regulations, such as (but not limited to):

• Proof of your identity, like a passport, driving licence, national ID card or residence permit
• Proof of your address, like a utility bill or bank statement
• Additional details on the the source of funds being sent, like a payslip, credit card statement, tax rebate receipt or bank loan agreement

This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary.
Data about your recipient, such as (but not limited to):

• Name
• Date of birth
• Occupation
• Phone number
• Proof of their identity, such as a passport, driving licence, national ID card or residence permit

This data will sometimes be needed to conduct Know Your Customer (KYC), Customer Due Diligence (CDD) and security checks, as required by local and international regulations. This helps us keep your money safe, and we will only request these details when necessary. All data about your recipients will be treated in line with this Privacy Policy.
Data from other third party sources, such as (but not limited to):

• Facebook, Twitter or Google profile images and names
• Banks and payment service providers used to transfer money to us
• Advertising networks
• Search engines providers (such as Yahoo.com or Google)
• Credit reference agencies

SendINR collects this data only when you provide the relevant permission to social media sites.
Technical data, such as (but not limited to):

• Page views
• App downloads
• Operating system
• Browser type

This data is used to help us to understand how you use our Service, so that we can improve it.

2. Why do we collect your data?

We collect your data to personalise and improve our Service for you. The specific purposes for which we collect your data include:
Transactional purposes
We need to collect data in order to process your transactions. Without data such as you and your beneficiaries bank account details or full name and address, we would be unable to transfer money for you.
Regulatory purposes
As regulated financial institutions, SendINR and our partners are required to conduct Know Your Customer (KYC) and Customer Due Diligence (CDD) checks to comply with our legal and regulatory requirements.
These include our requirements under Anti Money Laundering (AML) and Counter Terrorist Financing (CTF) legislation. All of this helps us keep our Service safe and secure.

Marketing purposes
We may process your personal data to provide you with certain types of marketing communication that we believe will be relevant and of interest to you. This helps us provide you with a more personalised Service. This kind of activity is permitted by our ‘legitimate interest’ (for more information on legitimate interest, please see Section 8 of this Policy). We will always endeavour to make these communications relevant and unintrusive, and you are able to object to marketing communication from us at any time.
Analytical purposes
We may collect and analyse data such as website or app visit logs in order to improve the quality of our Service.
You do not have to disclose any of the above data to us. However, if you choose to withhold certain data, we may not be able to provide you with our Service.

3. How do we keep your data safe and secure?

All the data that you provide to us is encrypted on our secure servers. We restrict access to your data to specific employees of SendINR who have an important business-related reason for handling it.
All of the data we collect from you or from other sources will always be stored in accordance with this Privacy Policy.

4. How long do we keep your data?

Depending on what purpose your data is used for, the length of time we keep it may vary. Either way, we will only hold your data as long as necessary to serve the purpose it is used for.
Regulatory
We are legally required to keep the data obtained for Know Your Customer (KYC), Customer Due Diligence (CDD) and security purposes (including transaction records and our communications with you) for at least five years after the most recent transaction.
Legitimate Interest
When the five years’ retention period and/or legitimate interest no longer apply, we will remove your data from our system. For more information on legitimate interest, please see Section 8 of this Policy.
Consent
In situations where you give us specific consent to process certain kinds of data, you are able to withdraw that consent at any time. We will then stop processing your data and, if the five years’ retention period and/or legitimate interest retention period does not apply, we will also erase your data from our system.
We may retain any data mentioned above for a longer period, if required to protect the rights, property or safety of the Service provided by us or our partners.

5. Who do we share your data with?

We share your personal data with third parties only when it is necessary for the fulfilment of the Service or to comply with applicable laws.
We will never sell your personal data to other organisations.
We work with partners who help us to complete your transactions. If they are based outside the EEA, we will share your personal data with them only when they apply essential safeguards, or if it has been established by EU institutions that the relevant country has an appropriate data protection regime in place, or when we otherwise ensure that the appropriate level of protection is applied for data processing.
The following are some purposes for which we may share your data with third parties:
To fulfil the contract between you and SendINR
We may share your data with third parties, such as our partners and intermediaries, when they are necessary for the fulfilment of the Service.
When required by law
We may share your data when required by law, for example for the purposes of security, taxation and criminal investigations.
For marketing and communication
We may share your data with third parties such as providers of customer service tools, marketing campaign tools, email communication tools, analytics software (for marketing purposes) and data visualisation tools (for analytical purposes).
If we sell or buy any business or assets, we may be obliged to share your personal data with the prospective seller or buyer.

6. What are your rights?

The law gives you a number of important rights in relation to your personal data, which are listed below.
There are certain exceptions where these rights may be superseded by laws and other requirements applicable to regulated financial institutions like SendINR. An example of this would be the obligatory retention period (seen Section 5), which supersedes the right to data erasure.
Your rights are:

• The right to be informed: the right to be informed about how we use your personal data
• The right of access and data portability: the right to request access to the data that we have about you, to obtain the data within a month of asking for it, and to use it for your own purposes
• The right to rectification: the right to correct, amend or update your personal data if it is wrong or has changed (this can usually be done using the settings provided on your account)
• The right to erasure: the right to ask us to remove the data we hold about you from our records
• The right to be forgotten: the right to request erasure of any links to your personal data, or of any copy or replication of any public personal data
• The right to restrict processing: the right to ask us to stop processing your personal data
• The right to object: the right to object to data processing, if you believe that our legitimate interest might infringe upon your rights
• Rights related to automated decision-making and profiling: the right not be subject to individual decisions made solely by automated means.
• The right to notification in the event of breach: the right to be immediately informed if we identify a data breach
• The right to raise a complaint: the right to contact our Data Protection Officer if you are not happy with how we have handled your personal data
• The right to lodge a complaint with a supervisory authority: the right to submit a complaint to the Information Commissioner’s Office (ICO) if you are not satisfied with our Data Protection Officer’s response, or if you believe that we are not processing your personal data in a lawful way (For more details please refer to the Commissioner’s Officewebsite.

• Legitimate interest

Legitimate interest is a specific legal justification for the collection and processing of your personal data. It applies when we have reasonable grounds to collect and/or process your personal data to improve our Service, as long as this does not infringe on your rights.
Our legitimate interest may justify some examples of automated decision-making. One of those is our estimated transaction timing, which we use to determine the time in which the transfer will reach your beneficiary.
We believe that if you are an active customer of SendINR, it is in your interest to receive occasional information about our Service. We may therefore send you communications about offers or promotions that we believe are relevant for you based on your previous use of the Service. If we notice that you are having problems using our Service, we may on our own initiative decide to contact you, in some cases by phone, to offer help.
We may also process your data to help develop new product features that we believe will improve the Service. We may contact you occasionally to assess your satisfaction with the Service. We may also use your data to determine the effectiveness of marketing or promotional campaigns. We may also contact you with information about any changes in the Service, and/ or other important updates.
We will only share anonymised or encrypted data with the third parties. We may also provide our partners with anonymous aggregated data about our customers for marketing and analytical purposes, to help optimise our marketing communications.
You can object to data processing based on our legitimate interest at any time by contacting us at website.privacy@sendinr.com or by changing the settings on your SendINR account.

7. Cookies Policy

Cookies are small text files which are stored on your device when you access SendINR. They allow us to recognise you and store data about your past activity and your preferences so that we can personalise and improve the Service for you.
Cookies and other similar technologies may collect data such as language preference, country and previously viewed pages.
We use the following cookies:

• Necessary cookies: these cookies enable the basic use of our Service
  e.g. enabling content reserved for registered users
• Personalisation cookies: these cookies allow our Service to be personalised for you
  e.g. remembering your preferred language or sending country
• Analytical cookies: these cookies allow us to see how people use our Service so that we can understand how to improve it
  e.g. seeing how many people are logged in at a given time of day

By using our Service, you agree to place the cookies described above on your device. You have the right to withdraw your consent at any time. If you would like to delete our cookies, you can do so by changing the settings of your browser.
Blocking or deleting cookies may mean that some features of the Service may not be available to you.

• Changes in Privacy Policy

SendINR may change this Privacy Policy from time to time. Any changes will be effective immediately unless stated otherwise. The date of the most recent update is displayed at the top of the page.

Any dispute or claim arising in connection with this Privacy Policy will be considered in relation to the English version only.

• Contact details

You can contact SendINR:

• By email: At Your Service.
• Via our website, www.sendinr.com