Privacy Policy

SendFund is the registered trading name of WIRELY, a financial services business registered in the Swiss Commercial Register under UID No. CHE-497.268.005, with its registered office at Wartstr 22, 8400 Winterthur, Switzerland, and a member of ARIF, a Self-Regulatory Organisation recognised by FINMA. In this Privacy Policy, “SendFund”, “we”, “us” and “our” refer to this business, which is the controller of your personal data.

SendFund is committed to respecting and protecting your privacy. This Privacy Policy explains how we collect, use, protect, disclose and otherwise process information about you in accordance with the Swiss Federal Act on Data Protection (FADP/nDSG) and, where applicable, the EU General Data Protection Regulation (GDPR). It applies to personal data we collect when you use our website (www.sendfund.app) or mobile application, visit our office, or contact us by phone, email or online.

The personal data we collect depends on the products or services you request. It can include:

• Identity data: government identifiers (ID card, passport or driving licence number), date of birth, nationality, and — as part of identity verification — a photograph or biometric facial scan with liveness check;
• Transaction data: information about you and the other party to your transaction, transaction reference, amount, dates, purpose of transfer and source of funds, and your transaction history;
• Account data: account number, username and password;
• Financial data: bank account or card information;
• Contact data: name, address, telephone number, email address;
• Technical data collected automatically when you use our website or App (browser type, device information, IP address, pages requested, country of access);
• Other personal data collected with your consent or as permitted or required by law.

We collect personal data directly from you, from the other party to your transaction (for example when a sender names you as receiver), and from third-party sources such as identity-verification providers, sanctions- and PEP-screening services, reference agencies and payout partners, as part of our legally required verification processes.

We process personal data on the following legal bases and for the following purposes:

• Performance of a contract: to execute your transactions, maintain your account and provide customer support;
• Legal obligation: to fulfil our duties under the Swiss Anti-Money Laundering Act (AMLA) and ARIF regulations, including identity verification, sanctions and PEP screening, transaction monitoring, record keeping and reporting to competent authorities such as MROS;
• Legitimate interests: to prevent fraud and abuse, secure our systems, manage our business and records, and improve our services;
• Consent: to send you marketing communications about our own products and services, and for any other purpose we describe when asking for your consent. You may withdraw consent at any time.

Automated identity verification: parts of our onboarding use automated document and biometric verification. Where a check cannot be completed automatically, it is reviewed by a member of our team. You may request human review of any automated decision that affects you.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

We disclose personal data only as needed for the purposes above, including to:

• Service providers acting on our behalf — identity verification, screening, IT hosting, communications and payment processing providers — under contracts containing confidentiality and data protection obligations;
• Payout partners and financial institutions involved in executing your transaction (the receiver's institution will receive the data needed to credit the funds; if you are a receiver, we may disclose your personal data to the sender);
• Regulators, supervisory bodies and law enforcement — including ARIF, FINMA, MROS and other competent Swiss or foreign authorities — where we are legally obliged or permitted to do so, including for the prevention and detection of fraud, money laundering and terrorist financing;
• Parties to a corporate transaction: if SendFund becomes involved in a merger, acquisition or sale of assets, personal data may be disclosed in connection with the evaluation and completion of that transaction, and would remain subject to this Privacy Policy.

International Transfers

Your data may be processed in Switzerland and in the European Union. Where a transaction or service requires a transfer to a country without an adequate level of data protection, we rely on appropriate safeguards such as standard contractual clauses, or on statutory exceptions applicable to the execution of your payment. Personal data is subject to the laws of the country in which it is located, including lawful access requests by authorities there.

We retain personal data only as long as necessary for the purposes described in this policy and as required by law. Transaction and identification records must be retained for at least 10 years under Swiss anti-money-laundering law. When retention periods expire, data is securely deleted or anonymised.

Subject to applicable law, you have the right to:

• access the personal data we hold about you and receive a copy;
• have inaccurate data rectified and, where applicable, incomplete data completed;
• request deletion of your data, where no legal retention obligation applies;
• receive certain data in a portable format;
• object to processing based on legitimate interests, and object at any time to direct marketing;
• withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.

To exercise your rights, email info@sendfund.app or log in to your account to review and update your information. We will take reasonable steps to verify your identity before granting access or making corrections. Note that withdrawing consent for certain processing may mean we can no longer provide some services, and that we may not be able to delete data we are legally required to retain (for example, transaction records).

You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch) or, where the GDPR applies, with your local supervisory authority.

We use physical, technical and administrative security measures to protect personal data against loss, misuse and alteration, applying robust industry-standard practices including encryption of data at rest and in transit. Access to personal data is restricted to employees and service providers who need it for the purposes described in this policy, and our service providers are contractually required to observe equivalent standards of security and confidentiality and to comply with applicable law.

Preventing Identity Theft

Please do not send confidential personal information such as passport numbers, government identification numbers or account numbers by unsecured email. Use posted mail, phone, or the “Contact Us” form on our website. Do not be misled by emails that appear to come from us and ask for personal information — we will never ask for your password by email. If you receive a suspicious email, forward it immediately to support@sendfund.app.

When you use our website we automatically collect certain standard technical information (browser type, requested files, domain and country of access). We use this information to operate and improve the website, ensure it functions correctly, understand how visitors use it, and — as part of our fraud-prevention efforts — to authenticate users where necessary. For details of the cookies we use and your choices, please see our Cookie Policy on the website.

External Websites

Our website may link to or from third-party websites. We are not responsible for the content or privacy practices of those websites.

Children

Our website, App and services are not intended for use by persons under 18. We do not knowingly process transactions for, or collect personal data from, minors.

We regularly review our privacy practices and may update this Privacy Policy from time to time. The current version is always published on our website, with its version date. Where changes are material, we will inform you through the website, the App or by email. Your continued use of our services after publication indicates your acceptance of the updated policy.

If you have questions about this Privacy Policy, about how your personal data is used, or about exercising your rights of access, rectification or objection, please contact us:

• Email (privacy and general enquiries): info@sendfund.app
• Email (customer service): support@sendfund.app
• Tel / SMS / WhatsApp: +41 77 987 32 31
• Post: SendFund, Wartstr 22, 8400 Winterthur, Switzerland
• Social media: @SENDFUND (X/Twitter, Facebook, Instagram)