Effective Date - September 30, 2021
What We Do
On behalf of any End User or any merchant (as designated in the relevant agreement) integrated with Sendcash Pay, we can carry out the following actions:
Sendcash Pay Checkout- We use our proprietary technology to initiate bank transfers on behalf of End Users using publicly available internet banking platforms. We are able to pull your financial information, including all security information and KYC needed to detect any anomaly or money laundering activity.
Sendcash Pay Wire- We receive instructions on the details of the transfer to be initiated by any merchant and transfer the requested funds in the requested foreign currency.
By agreeing to pay with Sendcash Pay, End Users and merchants are giving the developer & Sendcash Pay the authority to act on their behalf to access & transmit the End User’s Information from the relevant bank.
Please note that we do not have any official affiliations whatsoever with any of the banks or merchants we support.
How We Do What We Do
For Sendcash Pay Checkout
Checkout is able to do what it does when you connect your financial accounts with a developer application, without storing user's passwords by doing something called Double Key Encryption:
With Double Key Encryption, users' passwords are encrypted with a randomly generated encryption key stored on the user's device. We never have access to this encryption key.
On our servers, we further encrypt the already encrypted password with our own encryption key, before saving that to our database.
As such, the actual password can only be accessed if decrypted on the user's device, as a result of them giving such authorisation. This means we cannot ever sign in to a user's internet banking account without their permission.
It is important to note that Checkout does not store End Users' internet banking passwords. We don't have any access to the passwords and as such, cannot access their internet banking account without their explicit authorisation.
We can only initiate and authorise a transaction on behalf of an End User when they authorise this action by linking their bank account & entering their transaction pin or any such credentials. We do not control where the money is being transferred to, this is the responsibility or function of the developer/application that implements transfers.
For Sendcash Pay Wire
This is as straightforward as Sendcash Pay can demonstrate, we receive your foreign currency wire instructions, and use the details provided to initiate the relevant transfer on behalf of the merchant.
We can also read the End User’s account numbers and account balances. We also store account numbers and transaction information - like the amount of money sent and received by the End User.
The information that we collect from your financial institutions and service providers also include but is not limited to:
Information We Collect and Store
At Sendcash Pay, we collect financial information used as an internet banking account identifier and information from all your sub-accounts accessible through a single set of account credentials. This might be the End User’s email address, username, user ID, phone number or anything that their internet banking account requires for them to sign in or initiate a transaction.
We can also read the End User’s account numbers and account balances. We also store account numbers and balances.
As stated above, we do not store credentials used to authorise transactions like "transaction pins" or the End User’s 2-factor authentication/token OTPs.
The legal grounds for processing sensitive personal information outlined above are contained in the EU’s General Data Protection Regulation and the Nigeria Data Protection Regulation 2019.
How Long Do We Keep Your Personal Information
We will hold your personal information on Sendcash Pay’s systems for as long as is necessary to fulfill the purpose for which it was collected or to comply with applicable legal, regulatory or internal policy requirements.
Disclosing Your Personal Information
We may disclose your personal information with third parties including our affiliates, employees, officers, service providers, agents and subcontractors as may be reasonably necessary for the purposes set out in this Policy. Sendcash Pay will only share or disclose your personal information on one of the following conditions:
- The consent of the End User has been obtained. Sendcash Pay shall bear no liability for any breach which may occur from such authorisation by the End User;
- The disclosure is necessary to conclude a contract between Sendcash Pay and a third party in the interest of the End User;
- The disclosure is necessary for reason of public interest, and to detect, prevent or otherwise address fraud, security or technical issues;
- The disclosure is to satisfy any applicable law, regulation, legal process or enforceable governmental request;
- The disclosure is for the establishment, exercise or defense of legal claims;
- The disclosure is necessary in order to protect the vital interests of the End User or other persons, where the End User is physically or legally incapable of giving consent.
Sendcash Pay will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner.
International Data Transfers
As a global product, Sendcash Pay will operate internationally, and may transfer information collected from the End User across international borders for processing and storage purposes. However, the End User’s information will only be processed as required by law or in accordance with this Policy.
Data Protection Rights
Subject to applicable laws, and subject to any limitations and exceptions provided by law, End Users who have personal information held by Sendcash Pay are entitled to the following rights:
- Right to request for and access any personal information collected and stored.
- Right to information on their personal information collected and stored;
- Right to objection or request for restriction with respect to the personal information;
- Right to request rectification and modification of the personal information which Sendcash Pay keeps;
- Right to request for deletion of their data; and
- Right to object to, and to request that Sendcash Pay restricts the processing of their information.
Changes To This Policy
We reserve the right to update, amend or change this Policy at any time as required by law or technology. Any update, modification or amendment to this Policy will be posted on the Sendcash Pay’s website with the effective date updated.
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Contacting Sendcash Pay
If you have any questions or complaints about this Policy, you can contact us at email@example.com