Paysend Group Privacy Policy, updated on March 2025

PAYSEND

GLOBAL PRIVACY POLICY

Introduction

Our group company known as Paysend ("Paysend," "we," "our," or "us") values your privacy and is committed to protecting your personal data. The company with whom you contract when you become our customer (“Data Controller”) is the company responsible for looking after the personal information that you provide to us. You can find out more about each Data Controller in the section further down.

This Global Privacy Policy is designed for global users and complements regional policies where required by law.  For country-specific policies, please refer to the relevant policies at paysend.com/rules.

This Global Privacy Policy explains how we collect, use, store, and share your personal information, including biometric data, in compliance with applicable privacy laws. For details specific to biometric data collection, please refer to the country-specific Facial Scan Notice by visiting: paysend.com/rules.

This Global Privacy Policy does not apply to users in Australia, Canada, the EEA, El Salvador, Guatemala, Honduras, Jamaica, and the United States. Please refer to the appropriate local privacy policy at paysend.com/rules.

1. What Personal Information Do We Collect?

Depending on our relationship and interactions with you, the categories of Personal Information we collect may include:

• Personal contact information: Name, email address, home address, phone number, date of birth.
• ID information and biometric data: Facial scan images, and government-issued identification, document type, issuing country, ID number, expiry date, MRZ, barcodes, security features; PoA document data, as further described in our Facial Scan Notice.
• Financial, reference, and credit information: Banking details (cardholder name, expiry date, first 6 and last 4 digits of the card number), payment details, transaction history, creditworthiness verification, card numbers, bank statements, employment information (e.g., employer name and employment status), government-issued ID numbers, and pictures of your ID, utility bills, and other documents.
• Consumer credit report information.
• Transaction information: information about when and where your transactions occur, the names of the transacting parties, a description of the transactions, the payment or transfer amounts, billing and shipping information, and the devices and payment methods used to complete the transactions.
• Device and usage data: information about the geographic location and specifics of your device, including your hardware model, operating system and version, unique device identifier, mobile network information, information about the device’s interaction with our Services, and information about other software running on the device, IP address, domain name, browser type, access time, and language.
• Marketing communications and interaction information: the content and metadata (meaning records) associated with these communications, and other information you provide when you participate in contests or promotions offered by us or our partners or respond to our surveys; your email address as well as other information. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email.
• Cookies: Our website uses a technology called "cookies". For more information on our use of cookies, including to manage your cookies settings, please see our Cookies Policy.
• Analytics data: We may use a third party such as Google Analytics to help us gather and analyse information about the areas visited on the website (such as the pages most read, time spent, search terms, and other engagement data) in order to evaluate and improve the user experience and the website. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics data privacy and security at the following links: https://policies.google.com/technologies/partner-sites, https://support.google.com/analytics/topic/2919631

2. How do we collect your personal information?

We may collect Personal Information about you from various sources, depending on our relationship and interaction with you. These sources may include;

• directly from you (online through our Services and forms, including when you register for a Paysend account or communicate with us), or
• indirectly from third parties, who give us your personal information to provide our services, or
• from our business clients with whom you have a relationship, and who may pass on your personal information so that we can help them deliver their services to you, or
• from financial institutions, or
• third-party identity verification services when we’re performing identity verification, which includes the processing of biometric data while capturing your face and processing of the biometric identifies, taking facial scan image(s) of you (which is part of our onboarding process), during your account verification process (when you call us or make a transaction request for instance), or
• your computer or devices when you interact with our platforms, websites, and applications or through other automatic technologies.

3. Why We Collect Personal Information and How We Use It?

We collect personal data to:

4. Information Security and Data Retention

We use physical, technical, organisational, and administrative safeguards to help protect your Personal Information from unauthorized access or loss. For example, we use encryption and other tools to protect sensitive information. We retain your Personal Information as needed for the purposes listed above and as permitted by law.

We retain personal data for 10 years after your Paysend account is closed, or the maximum period required by law, whichever is longer, unless otherwise required by applicable law or legal process. This period is based on regulatory and contractual obligations, including financial compliance, fraud prevention, and dispute resolution.

5. Categories of Third Parties and Our Disclosure of Personal Information

We may disclose your Personal Information to:

• Paysend Affiliates within our corporate group to ensure seamless service integration and compliance with international security measures.
• Third-party verification providers who process personal data strictly under contract. Their categories;
  1. identification and verification services, who verify your identity
  2. data management and storage services, where we store your information and backups to the same
  3. systems applications that we use to manage and store data internally in a structured way
  4. marketing partners, who assist us in providing you with our marketing content
  5. financial institutions, who help us process your payments and deliver the same to your recipients
  6. debt collection agencies, who we may need to instruct in the event of payment deficits
  7. analytics and search engine providers that assist us in the improvement and optimisation of our site
• Fraud/Crime Prevention Agencies, including regulatory authorities.
• Other Users of the Services: facilitating your usage of our services we share with other users that have you saved in their phone’s contact list, information that you’re also using our services (if you opt-in to share this information with such users).
• Law enforcement agencies, regulators, or courts, where legally required or as permitted by other laws.

6. International Transfers

Paysend and its global affiliates and service providers may process and transfer your Personal Information across international borders, including to countries that may not offer the same level of data protection as your home jurisdiction. Regardless of where your data is stored or accessed, we ensure that it is handled securely and in accordance with this Privacy Policy and applicable international data protection standards. Where required by law, we implement appropriate safeguards—such as contractual clauses —to ensure your data remains protected during cross-border transfers.

7. Your Rights and Choices

Depending on your country’s laws, you may have rights such as:

• Right to information.
• Right to access your personal data.
• Right to rectification, to correct inaccuracies in your data.
• Right to erasure: you may ask us to delete your personal information, or to restrict or object.
• Right to data portability.
• Right to avoid automated decision-making including profiling.
• Withdraw consent at any time and request deletion of your data, subject to legal and regulatory retention requirements.
• Withdraw consent at any time and request to “unsubscribe” to receive our marketing communications.
• Opt-out of Cookies; to manage your cookies settings, please see our Cookies Policy.
• File a complaint with the appropriate regulatory body if your data is mishandled.

To exercise your rights, contact dataprotection@paysend.com. Alternatively, you may use the technical tools and features of your Paysend Account which will connect you with our customer services team through our chat function.

8. Children's Privacy

Paysend does not knowingly collect personal information from individuals who are under the minimum age required to use our services in their country of residence. If we become aware that we have inadvertently collected personal information from a minor without proper parental or guardian consent, we will take immediate steps to delete the data under applicable laws and regulations.

9. Data Controllers

Your data controller depends on your country of residence and the services you use. You can find a list of our local entities at the table below.

10. Contact Information

For questions about this Global Privacy Policy or to exercise your rights, contact by e-mail:

Paysend Group Data Protection Officer
Email: dataprotection@paysend.com

This notice was last updated on [March 2025]. We may update it periodically, and we encourage you to review it regularly.