1. 1. Introduction

   This Privacy Policy (the “Policy”) explains how we collect, use, and process your personal data when you use our website www.broadsend.co (the “Website”); our mobile application (the “Application”); and any communication with those who enroll for the Services of the Company (“Clients”), collectively as “Users”. The Website and the Application together with the Services (as defined below) and all content contained therein are referred to collectively as the “Resources” as further described in the User Agreement. By continuing your interactions with us, or by using the Resources and the Service, you confirm that you understand, accept, and consent to the practices described in this Policy.

2. 2. What data do we collect?

   Personal data, or personal information, means any information about an identified or identifiable individual. It does not include anonymous data, which cannot be linked back to the individual. The Company collects the following data from all Users:

   Information you give us.

   1. To access the Services, you may provide us information about yourself when you sign up to use our Services. Such personal details may include your as name, date of birth, email, address, and phone number; government-issued identity documents, taxpayer identification number or national insurance number, and employment information.
   2. This also includes information you provide through your continued use of our Services, your participation in discussion boards or other social media functions on our Website or App, through entering a competition, promotion or survey, and by reporting problems with our Services. Additional information you give us for security, identification and verification purposes may include financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security/insurance number, national identification number, personal description, photograph, tax reference number, proof of address, proof of residency, and government-issued identity documents,. If you fail to provide any of this information, it might affect our ability to provide our Services to you.
   3. We may require additional information In some cases, including when you send or receive high value or high volume transactions, or where we need to comply with anti-money laundering regulations, we may also need more identification information from you, including a copy of your bank account statements.
   4. Please ensure that your personal data is current, complete and accurate by logging onto your account and updating it whenever necessary.

   Information we collect about you.

   1. We may collect technical information on your browser, IP address, location, and device; information on your behavior on our website, including pages viewed, links clicked, keystrokes, and actions taken including copy/paste functions; demographic information; Information about your internet connection, the equipment you use to access our Resources, and usage details; information on your personal calendar, Communications data, including messages, comments, or file transmissions and Location data, including User location searches;
   2. We also gather transaction information, including information related to the use of the Services, types of Services requested, dates and times of such requests, payment methods, the name of the sender, the name of the recipient, and other similar information; and any additional information required by the Company (in its sole discretion) to verify a User's identity, which may include utility bills (for example, for proof of residency).(c) Information from your social networks.
   If you log into our Services using your social network account (including Apple ID, Facebook or Google) we will receive relevant information that is necessary for us to enable our Services to authenticate your access. The social network will provide us with access to certain information that you have provided to them, including your name, profile image and email address, in accordance with the social network service provider's privacy policy. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social network account

3. 3. Children's data. 

   Our products and services are directed at adults, and are not intended for children. We therefore do not knowingly collect data from children. Any data collected from a child before their age is determined will be deleted.

4. 4. How do we protect the date we collect?

   Safeguarding your information is our priority. Any transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. However, when we receive your information, we use strict procedures and security features to ensure it stays secure, including: (i) encryption of any communications over the Internet between you and us, using strong asymmetric encryption. (ii) Updating our servers in a timely manner; (iii) proactively monitors for abnormal and malicious activity in our servers and services;

5. 5. Ways we use your data

   • 1. Lawful basis: We will only use your personal data when the law allows us to. Depending on the country in which you are in, we rely on the following legal bases to process your personal data: (i) your consent, (ii) necessary legitimate interests; (iii) when there we have a legal obligation to process your personal data to comply with laws, regulations or court orders; (iv) when it is necessary to fulfill our obligations under a contract with you; (v) as required to protect the vital interests of yourself or other individuals.
   • 2. Purposes for which we will use your personal data: The Company collects data from Users, which may include personal data:
     1. To provide the Services and the other Resources to Users
     2. To enhance the safety and security of our Users and Services, including by protecting you and the Company from errors, misrepresentations, fraud, financial crime and/or contraventions of laws For customer support
     3. To enable communications between users and The Company
     4. To allow a third party or a financial institution that sent money to recover money received by you in error or due to fraud
     5. To verify information you provide to us and to enforce our user Agreement with you
     6. To send marketing and non-marketing communications to users
     7. In connection with legal proceedings
     8. For research and development
     9. To carry out the Company's obligations and enforce its rights arising from any contracts with a User, including for billing and collection or to comply with legal requirements
     10. To administer our Services and for internal operational, planning, audit, troubleshooting, data analysis, testing, research, statistical and survey purposes To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you To provide Users with information, products, or services that a User requests from the Company. To fulfill the purposes for which a User has provided the information or that were described when it was collected, or any other purpose for which a User provides it For any other purpose with a User's consent
     The Company provides software Services as defined in the User Agreement. The Company may collect data from its Clients in order to perform such services (the “Services”). You acknowledge, accept, and agree that without the data collected as set forth above, the Company may not be able to provide the Services and most functionality of the Application.

   • 6. Sharing and storing your personal data

     The security of your personal data is very important to us. The Company stores all information Users provide to it behind firewalls on our secure servers. Any payment transactions will be encrypted (using SSL technology).The Company securely stores User data on servers leased from a reputable third-party hosting service located in the United States and Canada. The Company may process, store, and transfer Users' personal data in and to a foreign country which does not offer an equivalent level of protection to your country. In such cases, we ensure that appropriate safeguards, including Standard Contractual Clauses and/or International Data Transfer Agreements, are in place.  The safety and security of User data also depends on each User. Where a User has chosen a password for access to certain parts of the Resources, each User is responsible for keeping its password confidential. The Company asks each User not to share its password with anyone. Any transmission of personal data is at each User's own risk. The Company is not responsible for circumvention of any privacy settings or security measures contained on the Resources.

   • 7. Access to your contact list

     With your express consent, we may access your contact list on your mobile device so that you can identify your contacts on Broadsend to facilitate sending money to friends and family on Broadsend through their phone number, email address or username. We only access your contact list information with your explicit permission. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services so you can send money to them for free and quicker. We will not send messages to your contacts or make use of the data for any other purpose.

   • 8. Data retention and deletion

     We will retain your personal data only for as long as is necessary to fulfil the purposes for which we collected it. We may be required by law to store some of your personal and transactional data beyond the closure of your account with us for regulatory, tax, insurance, litigation, or other legal requirements.. We only access your data internally on a need-to-know basis, and we'll only access or process it if absolutely necessary. Users may request deletion of their account at any time. We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate. We do this automatically, so you don't need to contact us to ask us to delete your data. Deletion methods include shredding, destruction and secure disposal of hardware and hard-copy records, and deletion or over-writing of digital data Under some circumstances the Company may anonymize Users' personal information so that it can no longer be associated with a particular User. The Company reserves the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to the relevant User or its consent.

   • 9. Data sharing and disclosure of your personal information

     The Company may share your data, with the following third parties; our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. our vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include: Payment processors and facilitators; Background check and identity verification providers (as applicable); Cloud storage providers; Marketing partners and marketing platform providers, including social media advertising services; Data analytics providers; Research partners, including those performing surveys or research projects in partnership with the Company or on the Company's behalf; Consultants, lawyers, accountants, and other professional service providers; Insurance and financing partners; Vehicle solution vendors or third-party vehicle suppliers; to  a fraud prevention agency to prevent and detect fraud or crime and to assist us in conducting or co-operating with investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so. Please note that if we, or a fraud prevention agency, determine that a fraud or money laundering risk is posed, we may refuse to provide the Services requested or we may stop providing existing products and services to a customer. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services. in response to a subpoena, warrant, court order, properly constituted police request or as otherwise required by law; to recover debt or in relation to your insolvency or to allow a party or a financial institution that sent money to recover money received by you in error or due to fraud; to develop customer relationships, services and systems; and if you consent, to share your details when using our Services To know more about the information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to privacy@broadsend.co

   • 10. Your rights

     Applicable laws in your jurisdiction may grant each User certain rights regarding the personal data that the Company holds about such User and you may be entitled to the following: Right to erasure - You may have the right to request that the Company erase your personal data, under certain conditions. Right to access - You may have the right to request from the Company copies of your personal data. We may charge you a small fee for this service. Right to rectification - You may have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete information you believe is incomplete. Right to restrict processing - You may have the right to request that the Company restrict the processing of your personal data, under certain conditions. Right to object to processing - You may have the right to object to the Company's processing of your personal data, under certain conditions. Right to data portability - You may have the right to request that the Company transfer the data collected to another organization, or directly to you, under certain conditions. Users who use our Services voluntarily provide their personal data in order for the Company to provide Services do so pursuant to the Company's User Agreement. The retention, return, transfer, and destruction of personal data provided for such purposes is subject to the Policy and to the terms of our User Agreement. If you make a request, the Company will respond to you within the period prescribed by applicable privacy law. If you would like to exercise any of these rights, please contact us.

6. 11. Your California privacy rights

   California residents may have rights pursuant to the California Consumer Privacy Act (“CCPA”) regarding your personal data, including: The right to be informed of the personal data we collect, use, and process for purposes listed in section 5.  The right to request the specific pieces of personal data that we have collected about you in the twelve (12) months preceding your request; The right to request deletion of your personal data that we collected; The right to correct any inaccurate information that we hold about you; The right to limit the use of your sensitive personal information to only that which is necessary for providing products or services; The right to opt-out of the sale or sharing of personal information, however please note that The Company does not engage in the sale of personal information as contemplated by the CCPA. As detailed in this Privacy Policy, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information; and The right not to be discriminated against for exercising any of these rights. If you would like to make a request pursuant to these rights, please contact us.

7. 12. Sensitive data, for identity verification.

   The Company may request specific information from a User to help the Company confirm its identity and its right to access. As part of our identity verification process we collect, use and store biometric data. We extract face scan information from photos and videos to compare pictures of you on identity documents with each other and with a selfie that you provide to verify your identity and for anti-fraud checks, and to improve these processes. We may ask you to specifically consent to the collection, use and storage of your biometric data during the verification process, where privacy regulations require it in your jurisdiction. If you do not consent, we offer alternate methods to verify your identity which may take longer. The same documents and photos are required for both processes. We will not disclose or disseminate any biometric data to anyone other than our identity verification providers, or when required by applicable laws and regulations, or pursuant to a valid order from a court. We never sell, lease, trade or otherwise benefit from your biometric data. We will retain biometric data for the period necessary to complete the identity verification process, and in any case no longer than 1 year after collection, unless required by law or legal process to keep it longer. Applicable privacy law may allow or require the Company to refuse to provide a User with access to some or all of the personal data that the Company holds about such User, or the Company may have destroyed, erased, or made such User's personal information anonymous in accordance with the Company's record retention obligations and practices. We further reserve the right, if considered appropriate at our sole discretion, to provide relevant information regarding you and your transactions to law enforcement agencies..

8. 12.Cookies.

   We use small files known as cookies to distinguish you from other users and see how you use our site and products while providing you with the best experience. They also enable us to improve our services. For detailed information on cookies and other technologies we use, and the purposes for which we use them. visit allaboutcookies.org to learn more.

9. 13. How do we use cookies?.

   The Company uses cookies and similar technologies for purposes such as: Authenticating Users; Remembering User preferences and settings; Determining the popularity of content; Delivering and measuring the effectiveness of advertising campaigns; Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services. To allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those

10. 14. How to manage your cookies?

    You can set your browser not to accept cookies, and you can remove cookies from your browser. However, in a few cases, some of the Site features may not function as a result.

11. 15. Privacy policies of other websites

    The Site and our Application may contain links to other websites. This Policy applies only to the Site. If you navigate to any other website from a link on the Site, you should review the privacy policy of such website.

12. 16. Updates to our privacy policy

    We reserve the right to update our policy from time to time and post any changes we make on this page. If we make material changes, you'll be informed through a notice on the Website home page or in the Application. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Resources and this Policy to check for any changes.

13. 17. Data security breach notifications

    Broadsend ensures that it appropriately manages any actual or suspected incidents relating to information systems and information within the custody of the organization.In the event of a data security breach that requires us to notify customers, Broadsend will send notifications by email. Customers are therefore obliged to keep a registered email address current. Customers are required to promptly notify us of any change in their email address on record by contacting help@Broadsend.com and providing an updated email address and contact information. A customer's continued use of Broadsend products and services constitutes consent to receive electronic notice in the event of such a breach.

14. 18. How to reach us

    If you have any questions about this Policy, the data we hold on you, or you would like to exercise one of your data protection rights provided for under applicable privacy laws, please do not hesitate to contact our Data Privacy Officer at privacy@broadsend.co. The Company will respond within 30 calendar days unless circumstances out of the Company's control prevent us from doing so.

Should you wish to report a complaint or if you feel that the Company has not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authority.