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Privacy Policy - UK and EU

v. 2020.02 (July 1st, 2020)

This Privacy Policy describes the way Wave Transfer Limited and Sendwave SA (collectively “Sendwave” or “we”), doing business through our mobile phone application, Sendwave, obtains, uses, stores, manages and disposes of certain information that you, as a user of our services, provide to us. For details regarding what information we collect from our users, please see the “Collection of personal data” section below. To learn more about how the information is used for our business purposes and shared with third party partners, please review the “Use of personal data” and “Storage and sharing of personal data outside of the EEA” sections. You have certain rights, described in the “Your rights, including right to access and correct your personal data” section. Sendwave will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with Sendwave for the purpose of advertising, promoting or selling other services to you.

Sendwave first collects information about you and about the person to whom you are sending money (your "Beneficiary") from the data you supply on the Sendwave application (the "App"). When you provide information to Sendwave, through the App or otherwise, you are warranting to Sendwave that all of the information you provide to us about yourself and about your Beneficiary is accurate and complete. In providing the personal data of any individual other than yourself to us during your use of our services, you promise that you have obtained consent from such individuals to disclose their personal data to us, as well as their consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy. Sendwave is relying on your warranty when Sendwave provides the services to you. The information you provide includes personal data, which is defined as information that can be used, on its own or with other information, to identify you or your Beneficiary.

In addition to the information you provide, Sendwave may have, or may obtain from third parties, information about you or your Beneficiary, some of which may be personal data. More information about these third parties appears below. Sendwave uses this information to provide its services to you, and to help protect you, the Sendwave service, your Beneficiary and the general public from mistakes, fraud, money-laundering and other problems.

Data controller

For the purposes of the relevant data protection regulations, the “data controller” of your personal data depends on where you live as a user of our services:

Wave Transfer Limited and Sendwave SA are wholly-owned subsidiaries of Chime Inc., a Delaware (USA) corporation licensed to provide payment and money transfer services in the United States (“Chime”).

Collection of personal data

The initial information we collect from you is the information that you provide to us on the Sendwave App. This includes information about yourself, such as your full legal name, address, date of birth, telephone number, email address, as well as other information and/or documentation that will allow us to verify your identify. You must also provide us with information about an approved payment source, such as your debit card, and information about your Beneficiary, which may include sensitive personal information such as your Beneficiary's name, address, mobile phone number and/or bank account information. Sendwave may also collect information from your mobile phone or other device from which you access the Sendwave App, including your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the App. Sendwave may also collect information about the websites you have visited prior to accessing the Sendwave service. Sendwave may keep and store such information and associate it with your use, in order to help Sendwave identify you and facilitate your use of our service in the future. We may also need additional information from you if you send high-value or high-volume transactions or as needed to comply with our anti- money laundering obligations under applicable law.

Sendwave may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the Sendwave App) with third parties, including the financial institution that issued the payment card you propose to use, and the telecommunications company or financial institution through which your money is sent to your Beneficiary. Sendwave may also verify such information with identity verification services, electronic databases, social media companies and credit reporting agencies. Sendwave may share your information with the banks, telecommunications providers and other financial services firms who facilitate payment to your Beneficiary. From time to time, Sendwave may require you and/or your Beneficiary to provide us with additional information and/or documentation to confirm your identity and your eligibility to use the Sendwave service.

When you access the Sendwave app, Sendwave may collect and store information regarding your use of the App and the service. This includes information about the frequency with which you access the App, the time you spend there, the way you move through the site, your transfer history, and details regarding the amount of money you transfer and your Beneficiaries.

If you contact us for any reason, whether by telephone, email, text or otherwise, Sendwave will record and store communications that you have with us for evidence and quality assurance purposes. By contacting us by telephone you agree to our recording of the phone conversation.

Use of personal data

Sendwave may maintain and use all of the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties, in order to provide the Sendwave service to you, and to enable Sendwave to comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system. Sendwave may use your information to contact you as necessary to confirm or complete a transaction, and to allow our agents, partners and service providers to fulfill their obligations in providing the Sendwave service to you. Sendwave may also use your information to improve our service, to troubleshoot problems, to develop new products and services, and to create advertising, marketing and promotional campaigns. (More information about Sendwave's use of your data for marketing and promotion is below.) Finally, Sendwave may disclose your information to third parties, including government agencies, when Sendwave reasonably determines that such disclosure is required by law, such as responses to subpoenas and information requests by law enforcement, financial services regulators or national security authorities.

Sendwave will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with Sendwave for the purpose of advertising, promoting or selling other services to you. However, where and to the extent allowed by law, Sendwave may work with third parties to analyze the information that we gather from you when you visit us on- line, including our website, our Facebook page, and our Facebook advertisements, whether or not you use the Sendwave service. Sendwave may use the information we gather there, along with the information we obtain from your use of our service, which may include personal data, to advertise and promote Sendwave services to you and to others. For example, Sendwave provides data to Facebook's Ad Manager account and SDK programs, which provide us with information about the ways customers and other visitors access, view and use the Sendwave website and application. We use that information to create advertisements and promotions; such advertisements and promotions may appear in your Facebook feed or on other sites owned or operated by Facebook, such as Instagram. We may customize our marketing and promotional messages to you based on your use of our service, the information that you provide to us or which we otherwise obtain about you, and algorithms designed to help us anticipate your potential needs, based on your information and the information of others who use Sendwave services. Sendwave believes that such programs provide valuable information and benefits to our current and potential users. However, Sendwave will only use your personal data for marketing and promotional purposes if you "opt in" to such uses, and you can withdraw this permission at any time. You have the right to ask us not to contact you for marketing purposes by contacting us at compliance@sendwave.com.

Protection of personal data collected by Sendwave

Sendwave's leading security experts and practices help ensure that your personal data are secure. All such information is stored on servers with state-of-the-art data protection technology, and is accessible only to Sendwave employees who, for business purposes, need to access it. We use 128-bit encryption and encode your debit card information as soon as it is entered in the Sendwave app, a process that overwrites your details so that they are unreadable by unauthorized parties.

No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Although Sendwave uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, Sendwave cannot absolutely guarantee its security. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

Storage and sharing of personal data outside of the EEA

Sendwave transfers and stores your personal data at a destination outside the European Economic Area (“EEA”). Your personal data will also be processed by staff operating outside the EEA who work for us or for our parent company, Chime. Such staff is engaged in the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with this Privacy Policy. In order to provide our services to you, we also need to transfer you personal data to Chime and to financial/telecom counter-parties in the country of your Beneficiary (for the processing of your payment details and the execution of transactions) and to other, selected third parties (analytics providers that assist us in the optimisation of our App and our communication to you, for details see the “Use of personal data” section above) based outside the EEA. We ensure that both ourselves and our partners take adequate and appropriate technical, physical and organisational security measures to protect your personal data. We also ensure we have appropriate contractual protections in place with these third parties.

Use of cookies and other tracking devices

Sendwave uses "cookies" and other tracking devices to help us recognize you, remember your preferences and facilitate your future transactions and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our App, in order to help us improve it and make it easier for future use. You may be able to disable your device's use of cookies, but that may slow or prevent your ability to use the Sendwave service. For further information please visit https://www.allaboutcookies.org/

Your rights, including right to access and correct your personal data

You have the right to access your personal information stored by Sendwave, subject to applicable laws and in accordance with relevant data protection regulations and Sendwave's policies intended to prevent fraud and other abuses of financial services. In order to do so, you can contact us at compliance@sendwave.com. If the information Sendwave has maintained about you is wrong, incomplete or otherwise inaccurate, you have the right to require Sendwave to correct it or correct the information yourself directly in the App. Under certain conditions you also have the right to request that we transfer the personal data we have collected to another organisation. And you have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Sendwave is subject to. As described in the “Use of personal data” section above, you also have the right to ask us not to contact you for marketing purposes by contacting us at compliance@sendwave.com.

Destruction of personal data

In general, Sendwave maintains information about each transaction for minimum five years and maximum ten years. After that period, Sendwave will destroy such information, and it will no longer be available to you or anyone else. However, there may be circumstances in which Sendwave is required to maintain information for longer periods, if required by law or regulation.

Privacy Policy changes

Sendwave's privacy policy may change in the future. If that happens, the revised version will be posted on our website, www.sendwave.com, and will be sent to current users via the email addresses associated with their Sendwave App registrations.