Last Modified: February 20, 2024
This Privacy Policy (“Policy“) is published by Send Crypto Holdings Ltd. (“Send Crypto” or “Company”), a company incorporated under the laws of Cyprus, in connection with the Send Crypto platform available on this website and any of its subdomains (the “Website“) or on any mobile application or interface (the “App(s)“). Send Crypto is dedicated to protecting your privacy rights and making our practices regarding your personal data transparent and fair. This Policy was designed to help you better understand the information we collect, store, use and share when you use, interact with or otherwise access our Services. This Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time.
This Policy is integrated into and forms part of our Terms which are currently available at https://www.sendcrypto.com/terms-and-conditions/.
Depending on your interaction with us, we may collect two types of data from you:
“Non-Personal Data” means aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services. We are not aware of the identity of the user from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data.
“Personal Data” (as defined under the GDPR) or “Personal Information” (as defined under the CCPA or other US privacy legislations) means individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.
For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
Please note that the Company does not collect and process Personal Data you share directly with your Third-Party Services for the purposes of KYC verification and legal compliance (if applicable). However, we do collect public on-chain data such as your public address, transaction details, balance amounts and type of assets and wallets accessible through Third-Party Services you integrate with our Services.
The table below details the types of Personal Data we collect, the methods and purpose of such collection, and our lawful basis for processing such Personal Data (where the GDPR applies):
| DATA TYPE | METHODS AND PURPOSE | LAWFUL BASIS |
|---|---|---|
| Account Information | When you create an account with us, we will collect information associated with your account, including your name, contact information, phone number, date of birth, email address, and any other information provided by you when opening your account (collectively, “Account Information”). | Account Information is required for the proper and basic operation of the Website and offering of Services. Further processing may be subject to our legitimate interest, for example for internal documentation, and improvement of service purposes by training our models. |
| Website Interaction and Marketing | When you interact with our Website, we may collect your online identifiers, such as Internet Protocol (IP) address, device identifiers, Cookie ID and tracking technologies and other unique identifiers (“Online Identifiers”). Online Identifiers are used in particular to operate the Website and enable its proper functionality, for example, to automatically recognize you by the next time you enter the Website or to confirm you are a real person. | Strictly necessary cookies are required for the proper and basic operation of the Website and will be processed in our legitimate interests, where such cookies collect Personal Data on our behalf. Other cookies, to the extent these collect your Personal Data, will be based on your consent which we will obtain through our cookie notice and consent mechanism. |
| Image Collection | Users have the option to upload an image of their choice as their profile picture. We do not store the specific images selected by users for their profiles. Users retain full control over their profile images and can modify or delete them at any time within the settings. In addition, for enhanced security and identity verification purposes, users may be asked to upload specific documents and provide a selfie. | Access to user images is requested for two distinct purposes: allowing users to set a profile image and facilitating identity verification. We do not employ user images for any other use except for these specified purposes. |
| Publicly Available Blockchain Data | We collect publicly available on-chain blockchain data such as your public address, transaction details and history, balance amounts and type of assets and wallets accessible through Third-Party Services you integrate with our Services. | This information is required to reflect the actual data pertaining to your accounts with Third-Party Services which is necessary for the proper operation of the Services. |
| User Content | When you use our Services, we collect Personal Information that is included in the input, texts, prompts, questions, comments, interactions, links, file uploads, or feedback that you provide to our Services (“Content”). You are not required (and we recommend you not) to include any Personal Data in your Content. | User Content is required for the proper and basic operation of the Website and App and offering of Services. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of our Services. |
| Contact Information and Newsletters | If you voluntarily contact us, through any means of communications we make available for support or other general inquiries you may be required to provide us with certain information such as your email address or any additional information you decide to share with us (“Contact Information”) or to receive updates and newsletter from us from which you unsubscribe at any time. We process Contact Information to respond to your inquiries, and provide you with the support, materials, updates and information you requested. The correspondence and its contents with you may be processed and stored by us in order to improve our customer service and in the event we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable). | We process Contact Information subject to your consent. Further processing may be subject to our legitimate interest, for example for internal documentation and improvement of service purposes. |
| Legal Matters | We may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, to enforce our legal terms and conditions, to protect the security or integrity of our databases, and to take precautions against legal liability. | Such processing is based on our legitimate interests, which in this case are protecting our Services and data, exercising our legal rights, and complying with our legal obligations. |
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. The transfer of Personal Data to third party countries as further detailed in the Data Transfer Section is based on the same lawful basis as stipulated in the table above.
Also, please note our Services incorporate Multi-Party Computation (MPC) technology to generate encryption keys. As a component of our backup and recovery strategy, we offer the option to securely store an encrypted (and unidentified) portion of your key in your cloud storage. This measure is designed to simplify the process of recovering your account, should the need arise. To enable this feature, SendCrypto will request your permission to store and manage its encrypted key share within your cloud account, along with access to the associated email address for verification and recovery purposes. This process is fully compliant with privacy standards, ensuring your data remains protected and under your control at all times.
As further described in our Terms, we may integrate or provide access to platforms, applications, services, interfaces, software programs, protocols, and other various products that are not operated or maintained by the Company (“Third-Party Services“) (e.g., crypto wallets, exchanges and data providers). When you interact with Third-Party Services, these parties may independently collect information about you and solicit information from you (including, for instance, information pertaining to KYC, verification and legal compliance purposes). The collection and processing of such personal data is carried solely and directly between the user and the Third-Party Service. SendCrypto plays no role in this process and does not have access to, nor does it store, any personal information shared between you and Third-Party Services. The collection and processing of personal data by Third-Party Services is subject to their privacy policies and other terms.
We share your Personal Data with third parties, including our service providers that help us maintain our Services. More information about the categories of such third-party recipients is described below:
| CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
|---|---|---|
| Service Providers | All types of Personal Data collected by us | We may disclose Personal Data to our service providers, contractors and third parties, including, but not limited to, our cloud and hosting provider, analytics and marketing providers, payment processors (for paying customers), CRM systems etc. |
| Affiliated Companies | All types of Personal Data collected by us | We share Personal Data with our affiliated companies in accordance with the terms of this Policy. We share such Personal Data for the purpose of providing and improving our Services, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience. |
| Consent Manager (“CMP”) | Online Identifiers and the user’s preference. | When you browse our Website for the first time, depending on your location, a CMP may appear, where you will be able to choose if you allow us and our partners to implement tracking technologies, and where applicable, to share Personal Data (e.g., Online Identifiers) with third parties for one or all of the aforesaid purposes (“Preference”). These Preference are different depending on your jurisdiction. The CMP receives the Online Identifiers from us. |
| Any acquirer of our business | All types of Personal Data | We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy. |
| Legal and law enforcement | Subject to law enforcement authority request. | We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose. |
We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
When we share information with service providers, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Data they receive and to use the Data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).
We retain the data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable laws, or until you express your preference to opt-out, where applicable.
The retention periods are determined according to the following criteria:
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice. However, retention periods will be determined by taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time and in a way that prevents the Data from being restored or reconstructed.
In order to exercise any of your rights (e.g., right to erasure) under applicable data protection laws, please contact us through the following email address .Please include your full name, and email address so we are able to handle your request properly. Subject to applicable laws, we may require that you provide additional information to verify your identity before allowing you to exercise certain rights.
We use reasonable organizational, technical, and administrative measures to protect your Personal Data. However, while we work hard to protect the Personal Data we process from unauthorized access or disclosure, we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty that we will always be able to prevent such access.
Please contact us via the methods available below if you feel that your privacy was not managed properly, or if you become aware of an attempt by a third party to gain unauthorized access to your Personal Data. We will make a reasonable effort to notify you and the relevant authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
The Website is not intended for use by individuals under the age of majority, as defined by the applicable law in such individual’s jurisdiction of residence (“Minor“). We do not knowingly process Minor’s information and will discard any data we receive from a user that we find or reasonably suspect to be a Minor immediately upon discovery. Please contact us via the details available below if you have reason to believe that a Minor has shared any data with us.
The updated date of this Policy will be reflected in the “Last Modified” heading, indicated at the header of the Policy. Where required by applicable law, we will obtain your consent. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices
If you have any question, inquiry or concern related to this Policy or the processing of your Personal Data, you may contact our privacy team as follows: [email protected].
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