SEND, INC.
101 N. Indian Hill Blvd., Suite 206, Claremont, CA 91711
Version: 2.1
Effective Date: July 16, 2025
Last Revised: September 3, 2026
Document Owner: Compliance Department
This Privacy Policy ("Policy") describes how Send, Inc. ("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 notices for specific products or services 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.
If you apply for or use a Send Card, please also read Article 11. Card Services are provided by Wirex, not by Send. Wirex processes personal information for Card Services under its own privacy notice.
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:
Contact data: your first and last name, email address, mailing address, and phone number.
Financial data: your bank account and other payment information you provide to fund or withdraw from your Send account.
Identity data: your date of birth, social security number or taxpayer identification number, driver's license number, and a copy of your government-issued identification.
Communications: messages we exchange with you, including when you contact us through the App, social media, or otherwise.
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:
Public sources, such as government agencies, public records, and social media platforms.
Data providers, such as information services and data licensors.
Identity-verification, fraud-prevention, and screening providers.
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:
Device data: your device's operating system, browser type, IP address, unique identifiers, language settings, and general location information.
Online activity data: pages or screens you viewed, navigation paths, access times, and duration of access.
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:
Service delivery: provide, operate, and improve the App; enable security features; communicate with you about the App; and respond to your requests and feedback.
Research and development: analyze and improve the App and our business.
Compliance and protection: comply with applicable laws; protect rights, privacy, safety, or property; prevent fraud and illegal activity; and perform identity, KYC, sanctions, and similar screening.
With your consent: in cases where we specifically ask for your consent to collect, use, or share your personal information.
Additional uses that apply if you apply for or use a Send Card are described in Article 11.
Article 3. How We Share Your Personal Information
We may share your personal information with:
Service providers: companies that provide services on our behalf (hosting, customer support, email delivery, analytics, identity verification, and fraud prevention).
Professional advisors: lawyers, auditors, bankers, and insurers where necessary.
Authorities: law enforcement and government authorities as required by law.
Business transferees: in connection with mergers, acquisitions, or other business transactions.
Card program partners: Wirex and related parties, as described in Article 11, if you apply for or use a Send Card.
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:
Account data: retained for the lifetime of your account and deleted upon account deletion, subject to the retention periods below.
Financial and transaction records: retained for a minimum of seven (7) years to comply with tax, AML, and regulatory requirements.
KYC and identity verification data: retained for a minimum of seven (7) years as required by FinCEN and AML regulations.
Activity logs: retained for three (3) years for security and audit purposes.
Marketing data: retained until you opt out or request deletion.
Card-related records: retained for at least five (5) years after the end of your Card relationship where required for contractual, compliance, fraud-prevention, or legal purposes, as described in Article 11.
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
Opt-out of marketing: You may opt out of marketing emails by following the unsubscribe instructions or contacting us.
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.
Account deletion: You may delete your account through the App settings. This will remove associated personal data we control, subject to our legal and contractual retention obligations.
Do Not Track: We currently do not respond to "Do Not Track" signals.
Closing your Send account does not require Wirex or another regulated provider to immediately delete information that it must retain by law. Requests about Card Services data held by Wirex should be directed to Wirex under its privacy notice.
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. If you use Card Services, information may also be processed in the United Kingdom, the European Economic Area, or other locations where Wirex and its service providers operate.
Article 8. Children
The App is not intended for use by children under 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
If you have questions about this Policy or wish to exercise your rights, please contact us at:
Email: [email protected]
Address: Send, Inc., 101 N. Indian Hill Blvd., Suite 206, Claremont, CA 91711
Article 11. Information Shared for Card Services
The Send Card is issued and provided by WIREX Limited and/or one or more of its affiliates ("Wirex"). Send refers you to Wirex and provides the technical interface. Send does not provide the regulated payment or electronic-money services associated with the Card.
If you apply for or use a Send Card, Send may collect and provide Wirex with information relating to your application and use, including:
identification and contact information;
government identification and verification results;
residency, nationality, tax, and occupation information;
source-of-funds and transaction information;
KYC, sanctions, and screening information;
information concerning suspected fraud or unlawful activity;
Card funding and transaction information;
device and authentication information; and
customer-support, complaint, and dispute records.
This information may be used to evaluate your eligibility, provide Card Services, process transactions and instructions, prevent fraud, perform KYC and sanctions screening, investigate complaints, and comply with legal or regulatory requirements. Send may also notify Wirex of negative information that later comes to Send's attention about an active Card user.
We may share this information with Wirex, its affiliates, identity-verification providers, payment processors, the applicable card network, fraud-prevention providers, and regulatory or law-enforcement authorities where required or permitted by law.
Wirex processes personal information for Card Services under its own privacy notice and legal obligations. You should review the Wirex privacy notice presented during Card enrollment. Wirex independently decides whether to accept you as a customer.
Send may retain Card-related records for at least five (5) years following the end of your Card relationship where required for contractual, compliance, fraud-prevention, or legal purposes. Wirex and its service providers may apply different retention periods under their respective legal obligations.
Closing your Send account may not require Wirex or another regulated provider to immediately delete information that it must retain by law.