Facts

WHAT DOES PRONTO MONEY TRANSFER INC. DBA USEND DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

We will collect the following information about you, which may include non-public personal information:
1. Personal and financial Information, including: Name, address, date of birth, phone number and email address; Social Security number, Driver’s License number, Passport number or other government identification number; Bank account and routing numbers, bank statements, credit card number, expiration date, CVV and billing address. We may require additional information from you we can use to verify your identity, address or other information to manage risk.
2. Third-party account credentials (such as Facebook or Bank login); These services will authenticate your identity and provide you the option to share certain personal information with us
3. Third party personal information you provide in order to use our service: Recipient’s full name, address phone number, CPF number or any other information required to complete your transaction.
4. Commercial information about your business, such as Legal name, DBA, address, EIN or any other information required to complete your transaction.
5. Information about your usage of our service: transaction information such as transaction history, recipients’ names, amount sent, payment methods, device information, IP and Geolocation.
6. Information about you from third-party sources such as identity verification services, data providers, and credit bureaus, where permitted by law.
7. We may use third-party Service Providers to monitor, analyze, improve and protect the use of our service:
Google Analytics: web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit: https://policies.google.com/technologies/partner-sites
Fullstory: FullStory is provided by FullStory, Inc. You can prevent FullStory from using your information for analytics purposes by opting out at www.fullstory.com/optout/. For more information on what type of information FullStory collects, please visit the FullStory Terms & Conditions page at www.fullstory.com/legal/terms-and-conditions/.

Dwolla: We use Dwolla, Inc. to originate credit transfers to your financial institution account. You authorize us to collect and share with Dwolla your personal information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data. Dwolla’s Privacy Policy is available here (https://www.dwolla.com/legal/privacy/)

Plaid Technologies, Inc. ("Plaid"): We use Plaid to gather your data from financial institutions. By using the Services, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy located at https://plaid.com/legal/.

Synapse
Synapse Terms of Service
Synapse Privacy Policy

Collection from the Usend App:
UXCam: We may use UXCam, which is an analytics solution. UXCam may record: Screens visited, Interaction patterns (such as screen actions, gestures: taps, scrolls) and Device details (Type, Version, Model, Operating System). We are using the information collected by UXCam to improve our app. UXCam does not collect personally identifiable information and does not track your browsing habits across apps. For more information see Privacy Policy for Information Collected by the UXCam Service.
Crashlytics: We use Crashlytics. It may automatically collect certain information that does not personally identify users who access or use the App. This information includes, but is not limited to, device state information, unique device identifiers, device hardware and OS information, information relating to how an application functions, and the physical location of a device at the time of a crash. Crashlytics is owned and operated by Google Inc. The information may be shared with third party service providers, including, but not limited to, Crashlytics. Crashlytics may use aggregate and anonymous information to improve Crashlytics, create analysis of trends or behaviors, and other similar uses. To read Crashlytics’ privacy policy, click this link: https://firebase.google.com/terms/crashlytics
8. We use cookies for site functionality, remembering user’s settings (e.g. source & destination country), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies some features or areas of our site will be limited.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information. The reasons Pronto Money Transfer Inc. dba USEND chooses to share; and whether you can limit this sharing.

Reasons We Share Your Personal Information

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Does Share? - Yes
Can you limit this sharing? - No

For our marketing purposes – to offer our products and services to you
Does Share? - Yes
Can you limit this sharing? - No

For joint marketing with other financial companies
Does Share? - Yes
Can you limit this sharing? - No

For our affiliatesʼ everyday business purposes – information about your transactions, experiences and creditworthiness
Does Share? - Yes
Can you limit this sharing? - No

For non-affiliates to market to you
Does Share? - No
Can you limit this sharing? - We do not share

Questions?

1. Call 1-888-305-7264 – our menu will prompt you through your choice(s) or
2. Visit us online: www.usend.com and click on the Contact Us link

Who we are

Who is providing this notice?
Pronto Money Transfer Inc. dba USEND

What we do

How does USEND protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We also attempt to limit personal information access to only employees, agents and representatives who need to know. Despite our best efforts, third parties may attempt to unlawfully intercept or access your transmissions to us or may persuade you to disclose information to them by posing as USEND or by misinforming you about our services. Always use caution and good judgment when sending money and when using Internet and mobile technologies.

How does USEND collect my personal information?
We collect your personal information, for example, when you

1. send money or complete a payment
2. provide account information or otherwise give us your contact information
3. show your government issued ID
4. use our online sites (for example, to complete a transaction, manage your accounts, or provide your choices) or click on our online ads on other sites

We also collect your personal information from a variety of sources, including without limitation, computer systems; third party sources such as our business clients, government agencies and other suppliers of information; and consumer reporting agencies – all in compliance with and subject to the limitation of applicable law.

Why can’t I limit all sharing?
Federal law gives you the right to limit only

1. sharing for affiliatesʼ everyday business purposes information about your creditworthiness
2. affiliates from using your information to market to you
3. sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

OTHER IMPORTANT INFORMATION

STATE PRIVACY LAWS
We will comply with state privacy laws to the extent they apply to Pronto Money Transfer Inc. dba USEND services.

California residents: In accordance with California law, we will not share information we collect about you with companies outside of Pronto Money Transfer Inc. dba USEND except as required or permitted by law. For example, we may share information to service your accounts, complete requested transEactions, or to provide rewards or benefits to which you are entitled.

USEND CALIFORNIA PRIVACY POLICY

This USEND California Privacy Policy sets forth the Pronto Money Transfer Inc. privacy policy applicable with respect to consumers residing in California.

“You” and “yours” means you the customer, residing in California, who has registered for or is otherwise using our money transfer services, USEND E-Wallet services, or any other services provided by Pronto Money Transfer Inc. (collectively the “Services”).

“We,” “us,” and “our” means Pronto Money Transfer Inc. (d/b/a “USEND” and “Pontual”) and our successors, assignees or affiliates. Pronto Money Transfer Inc. is referred to in this Addendum as “USEND”.

It is the policy of USEND to collect, use, store and protect customer information in accordance with applicable law. You may review our general Privacy Policy here: https://usend.com/privacyPolicy

The following Addendum is applicable our customers who are residents of California. For California residents it is our policy to collect, use, store, provide access to and protect customer information in accordance with the California Consumer Privacy Act of 2018 (“CCPA”).

In providing services, including remittance services and/or E-Wallet Services (collectively “Services”) we will collect personal information (“Personal Information”) including: (a) information such as your name, address, tax identification number, identification number and email address that you provide when you register for service, (b) information about transactions made by you, such as date, amount, and beneficiary and/or payee information, (c) electronic information concerning your use and access to our website, mobile applications and social media, and (d) biometric information that you provide or we collect when you register for service, including digital images of you (“selfie”), or other biometric identifiers such as fingerprint, retina scan, voiceprint or similar biologically based identifying information.

For example, we may collect Personal Information from forms you complete, through customer support interactions when you provide the information to us, when you complete online forms or register for our loyalty and reward programs. We may also collect Personal Information indirectly from you, such as when you visit our website through cookies or similar technologies. We may also collect Personal Information from service providers, vendors and other third parties; public record sources (federal, state or local government sources); information from our website, mobile application activities and social media networks; and information from our partners or agents about individuals associated with them (e.g., an employee or owner).

Over the preceding twelve (12) months, USEND may have collected the following categories of Personal Information from the various sources set forth below. As noted, this Personal Information may have been shared with the types of Third Parties and for the listed Business and/or Commercial Purposes as set forth below.

Categories of Personal Information:

Identifiers: contact information (such as your name, postal address, email address, and telephone number), device identifier, cookies, date of birth, social security number, passport number, driver’s license, or similar identifiers

Categories of Sources:
* You, * Our Website, * Mobile Apps, * Affiliates, Agents, * Vendors

Business and Commercial Purposes:
* Performing Our Services, * Providing Customer Service, * Verifying customers, * Transaction auditing, * Data Security, * Marketing and Advertising

Categories of Third Parties:
* Agents and correspondents, * Government agencies, * Auditors, * Professional services organizations, * Advertising and social media, * Affiliates and subsidiaries

Categories of Personal Information
Biometric identifier: facial digital image (“selfie”) or other biometric identifier such as fingerprint, retina scan, voiceprint that you may provide.

Categories of Sources:
* You, * Our Website, * Mobile Apps, * Affiliates, Agents, * Vendors

Business and Commercial Purposes:
* Performing Our Services, * Providing Customer Service, * Verifying Customers, * Transaction auditing, * Data Security
Categories of Third Parties:
* Agents and Correspondents, * Government Agencies, * Auditors, * Professional Services Organizations, * Advertising and Social Media, * Affiliates and Subsidiaries

Categories of Personal Information:
Geolocation data: may be collected from your devices only if enabled.

Categories of Sources:
* Use of our mobile applications

Business and Commercial Purposes:
* Auditing, * Security, * Service Quality, * Safety

Third Party Categories:
* Advertising and social networks, * Data analytics providers, * Operating systems and platform

Categories of Personal Information:
Internet activity: browsing and search history, use of website or applications

Categories of Sources:
* Use of our website or mobile applications

Business and Commercial Purposes:
* Auditing, * Security, * Service Quality, * Safety

Third Party Categories:
* Advertising and social networks, * Data analysis providers, * Operating systems and platform

OUR SALE AND USE OF PERSONAL INFORMATION

USEND respects your privacy. We do not sell or provide access to your personal information to any third parties in exchange for money or other compensation.

USEND does, however, participate in advertising and marketing programs and other programs to analyze market trends, whereby we and third parties with whom we contract may review Personal Information and derive some form of value, which exchanges of Personal Information may constitute a “sale” under applicable law.

As set forth, our customers have the right to opt-out of having their Personal Information used for such purposes.

CALIFORNIA CONSUMER RIGHTS

In accordance with the CCPA, consumers residing in California have the right to request that their Personal Information not be sold to third parties, and that the provider otherwise disclose how their Personal Information has been used. Additionally California consumers may request that any of their Personal Information held by the provider be deleted. This section describes your rights under the CCPA and explains how you may exercise those rights.

Right to Access Specific Information and Data Portability Rights
As a California consumer you have the right to request that we disclose to you information to you about how we have collected and used your Personal Information over the past twelve (12) months. You may make such a request up to 2 times during any single twelve (12) month period.
Upon our receipt and verification of your written request, we will disclose to you the following information:
- All categories of Personal Information we collected on you.
- All categories of sources for the Personal Information we collected on you.
- Our business or commercial purpose for collecting your Personal Information.
- All categories of third parties with whom we share your Personal Information.
- The specific items of Personal Information we collected about you.

Deletion Request Rights
As a California consumer you also have the right to request that USEND delete all of your Personal Information that we collected from you and retained, subject to certain exceptions and regulatory record keeping requirements.
Upon our receipt and verification of your written request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
For example, we will be unable to adhere your request where we are required to maintain the Personal Information in order comply with a legal or regulatory requirement, such as maintenance of certain information pertaining to cross-border money transfer activity. You may make such a request up to 2 times during any single twelve (12) month period.

Making A Request
If you are a California resident, you may exercise your rights under this section by submitting consumer request to us by either:

Emailing us at: help@usend.com
Or calling us at: 888-305-7264
Or writing to us at:
Pronto Money Transfer Inc.
Attention: Customer Service
111 N. Sepulveda Blvd., Suite 340
Manhattan Beach, CA 90266

Changes to This Notice
We hereby reserve the right to amend this Notice at any time. In the event of any changes to this Notice, USEND will post the amended Notice and effective date thereof on our website. Your continued use of our website and Services following the posting of changes constitutes your acceptance of such changes.

Nevada residents:
This notice is provided to you pursuant to state law. Nevada state privacy laws permit us to make marketing calls to existing customers, but if you prefer not to receive marketing calls, you may be placed on our internal opt-out list by calling us at 1-800-926-9400 FREE or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132; email: BCPINFO@ag.state.nv.us.

Vermont Residents:
In accordance with the state of Vermont we will not disclose non-public personal financial information only with your written authorization, unless otherwise permitted by law. Written authorizations may be delivered to us by email at doc@pontualmt.com or mail to 111 N. Sepulveda Blvd., Suite 340, Manhattan Beach, CA 90266. Your consent or consent revocation must include your name, address and your signature. Any questions please contact us at 1-888-305-7264.
You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose to Pronto Money Transfer Inc., DBA Pontual Money Transfer, DBA Usend and its third-party service providers your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, solely to verify your identity and prevent fraud for the duration of the business relationship. See our Privacy Policy for how we treat your data.

USEND BIOMETRIC DISCLOSURE AND AUTHORIZATION
This Usend Biometric Disclosure and Authorization (“Disclosure”) sets forth the Pronto Money Transfer Inc. policy applicable with respect to our customers.
“You” and “yours” means you the customer who has registered for or is otherwise using our USEND money transfer services, USEND E-Wallet services, or any other services provided by Pronto Money Transfer Inc. (collectively the “Services”).
“We,” “us,” and “our” means Pronto Money Transfer Inc. (d/b/a “USEND” and “Pontual”) and our successors, assignees or affiliates. Pronto Money Transfer Inc. is referred to in this Disclosure as “USEND”.
“Biometric Information” means biometric information that you provide and we collect when you register for or use the Services, including digital images of you (“selfie”), or other biometric identifiers such as fingerprint, retina scan, voiceprint or similar biologically based identifying information.
It is the policy of USEND to collect, use, store and protect customer Biometric Information in accordance with applicable law. You may review our general Privacy Policy here: https://usend.com/privacyPolicy. California residents should refer to our California Privacy Policy here: https://usend.com/privacyPolicy.
Please be advised that your Biometric Information, specifically a digital image of your face (“selfie”) will be collected, captured, received, stored, and used in connection with your registration with USEND for the Services and our verification of your identity. USEND may also collect, capture, receive, store and use other biometric identifiers that you provide and authorize us to collect, use and store. Such collection, capture, receipt, storage, and use of your biometric information may occur at the time of your initial registration for the Services, or any time thereafter that you provide such information, as the case may be, where permitted by law.
Your biometric information is being collected, captured, received, stored, disclosed to USEND, and used in order to verify your identity in connection with the use of the Services in accordance with applicable federal and state law. To accomplish these purposes, USEND may disclose your biometric information to a secure third-party provider that we have contracted with to conduct such identify verification services (e.g., AU10TIX.com) and as otherwise permitted by law.
Your biometric information will be retained, stored and protected by USEND in accordance with our customer privacy policies (see links above) and as required by applicable laws and regulations.
With respect to the destruction of your biometric information, we utilize best practices when purging electronic Biometric Information. We do not retain hard or paper copies of Biometric Information. The proper destruction method depends on the type of media and the intended disposition of the media. The process is to render potential access to target data on the media infeasible in the event of a recovery attempt. Electronic media may be purged of biometric information using steps such as: clearing/wiping, data purging, and physical media destruction. We ensure that destruction of all physical and electronic media is witnessed or carried out by authorized personnel.
If you should have any questions concerning this Disclosure and your rights, please contact us by:
Emailing us at: help@usend.com
Or calling us at: 888-305-7264
Or writing to us at: Pronto Money Transfer Inc.
Attention: Customer Service
111 N. Sepulveda Blvd., Suite 340
Manhattan Beach, CA 90266

Changes to This Disclosure: We hereby reserve the right to amend this Disclosure at any time. In the event of any changes to this Disclosure, USEND will post the amended Disclosure and effective date thereof on our website. Your continued use of our website and Services following the posting of changes constitutes your acceptance of such changes.