PRIVACY POLICY

Effective as of [4/18/2023].

This Privacy Policy describes how Send Holdings North America LLC dba Send ("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 Privacy 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.

Send provides a mobile app that enables individuals to easily send and receive USDC. This Privacy Policy applies to personal information we collect from users of the Send app.

Our App and related services are designed for use by individuals for their personal, family or household purposes.

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Personal information we collect Information you provide to us.

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

• Contact data, such as your first and last name, email address, mailing address, and phone number.
• Financial data, such as your bank account, payment card details or other payment information.
• Identity data, such as your date of birth, social security number, taxpayer identification number, driver's license number and a copy of your government-issued identification.
• Communications that we exchange with you, including when you contact us through the App, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

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.

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, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Location data when you authorize the App to access your device's location.

Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies:

• Cookies are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. The App and our website use both "session cookies" that are deleted when a session ends, and "persistent cookies" that remain longer.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

App delivery and operations. We may use your personal information to:

• provide, operate and improve the App and our business;
• enable security features of the App, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the App, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the App and our communications; and
• provide support for the App, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the App and our business.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the App;
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the App and promote our business.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Service providers. Companies and individuals that provide services on our behalf or help us operate the App or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Send or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your choices

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at send@send.it. You may continue to receive service-related and other non-marketing emails.

Legal rights in some regions. Some privacy laws give individuals certain rights regarding their personal information. For example, you may have the right to request access, corrections, or deletion of your data. Please contact us at send@send.it to exercise your legal rights under applicable laws. We may verify your identity before fulfilling your request.

Declining to provide information. We need to collect personal information to provide services through the App. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third-party platforms or social media networks. If you choose to connect to the App or share your information through a third-party platform or social media network, the collection, use, and sharing of your data will be subject to that service's privacy policies and your settings on that service.

Other sites and services

The App may contain links to websites and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites or online services, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The App is not intended for use by children under 13 years of age. If we learn that we have collected personal information through the App from a child under 13 without the consent of the child's parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it in the App. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the App after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

• Email: send@send.it
• Mail: 1712 Pioneer Avenue, Suite 2636, Cheyenne, WY 82001
• Phone: +1 (626) 392-3000