Datenschutzbestimmungen

Effective Date: 10 September 2026

This Privacy Policy explains how SMARTFLOW PAYMENTS LIMITED collects and uses personal data. It is written to comply with the UK General Data Protection Regulation as it forms part of the law of England and Wales, the Data Protection Act 2018, and the guidance issued by the Information Commissioner's Office. We believe that the correct business relationship is built only on the basis of honesty and trust. Therefore, the confidentiality of Your information is extremely important for us. We take all measures to ensure the safety of your data.

1.1. This Policy contains provisions applicable to this website www.sends.co, as well as Sends App and Sends Platform. The controller and the processor of the personal data of the users on the website www.sends.co, as well as Sends App and Sends Platform. is the company SMARTFLOW PAYMENTS LIMITED registered in England and Wales (Company number 11070048) and is having its registered address at 11 Garden Court Tewin Road, Welwyn Garden City, Herts, England, AL7 1BH (hereinafter referred to as the "Company" or "We"). Personal data subjects are visitors of this website and/ or persons who use the functionality of this website (hereinafter referred to as "Users" or "You"). «The Company» and «the User» are together referred to as «Parties», and «the Party» when being mentioned separately. This Policy explains how we use and protect any personal data we collect about this website`s users.

1.2. Your acceptance of our Privacy Notice is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Notice, you must stop using our Website immediately.

1.3. We comply with the principles established by the General Data Protection Regulation (Regulation (EU) 2016/679), namely, ensuring that the personal data:1.3.1. is processed legally, honestly and "transparently" by us;1.3.2. is collected for certain, explicit and legitimate purposes and are not processed further in a way that is incompatible with these purposes ("purposes limitation");1.3.3. is adequate, appropriate and limited to what is necessary for the purposes for which they are processed ("data minimization");1.3.4. is accurate and, if necessary, updated; every reasonable step should be taken to ensure that personal data which were inaccurate, taking into account the purposes for which they were processed, were erased or corrected without delay ("accuracy");1.3.5. is stored in a form that allows identification of users no longer than it is necessary for the purposes for which personal data are processed; ("limitation of storage");1.3.6. is processed in a way that provides proper protection of personal data, including protection from unauthorized or illegal processing, as well as from accidental loss, destruction or damage using appropriate technical or organizational measures ("integrity and confidentiality").

2.1. Under data protection law you have a number of rights over your personal data.● You have the right to be informed about how we use it, which is the purpose of this Policy.● You have the right to ask for a copy of the personal data we hold about you.● You have the right to ask us to correct data that is inaccurate or incomplete.● You have the right to ask us to erase your personal data where there is no good reason for us to keep it.● You have the right to ask us to restrict how we use it in certain circumstances.● You have the right to object to our use of your personal data where we rely on legitimate interests, and to object at any time to its use for direct marketing.● You have the right to ask us to transfer certain personal data to you or to another provider in a structured, commonly used and machine readable format.

2.2. Where we rely on your consent, you have the right to withdraw it at any time. To exercise any of these rights, contact us at [email protected]. Some rights do not apply in every situation, and we will explain our reasons if we cannot meet a request in full.

3.1. Personal data refers to data about an individual who can be identified from either that particular data or from that data and other information that the Company has or is likely to have access to. Such personal data shall also refer to the data which is already in the Company’s possession or the data to be collected by the Company. This Privacy Policy supplements but does not supersede nor replace any other consent that the Client may have previously provided to the Company, nor does it affect any right that the Company may have at law in connection with the collection, use, disclosure and/or retention of the Client’s personal data.

3.2. The Company only collects personal data which is knowingly and specifically supplied to it by the Client for the purpose as specified prior to the supply by the Client, that is necessary to provide the Services or that is necessary for compliance with a legal obligation. Without limitation, this can occur during or before the Client:• sets up an Account;• uses our Services;• provides any feedback or complaints with regard to the Services through the Website;• uploads or submits any material through the Website; and/or participates in any marketing activity held by the Company.

Commonly collected personal data may include the following:• the Client’s name, email and postal addresses, telephone number, country of residence, nationality, age, gender, date of birth, copy of passport, business information, account information and other payment information;• details of any transaction the Client makes using the Services;• and/or details of any correspondence, queries, or any other forms of communication (i.e. telephone, email etc.) the Client makes with the Company regarding the Services.

In addition to personal data provided to the Company, certain information related to the Client that is not considered personal data may also be collected. The Company collects this information to improve its Website and Services. Such non-personal data may include information such as details of the Client’s operating system, domain name, IP address, the internet browser used, details of the Client’s interaction with the Website and the details of any website the Client has linked from to the Website.

3.3. We may receive information about you if you use any of the other websites we operate or through the Services we provide. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

3.4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

4.1. The Company collects personal data from existing and prospective clients and employees for various reasons. Any personal data will not be further processed in a manner that is incompatible with the purpose as stated before processing, for the performance of the Services, or to comply with a legal obligation. Without limitation, these purposes can include:• confirming the Client’s identity during the creation of his/its Account and to ensure the Client’s eligibility to use the Services provided;• communicating with you and responding to your queries;• improving the Services and the Client’s experience on the Website;• providing you with information and updates on selected products and services that the Company thinks may be of interest to you;• administering and processing credit transactions in connection with the Client’s use of the Services;• analyzing the effectiveness of our advertisements and promotions;• customising the Client’s Website experience, as well as evaluating statistics on Website activity, such as what time you visited it, whether you have visited it before and what website referred you to it;• conducting required anti-money laundering checks;• notifying you of any changes to the Services that may be relevant to you;• conducting surveys, research and statistical analysis with the aim of helping the Company monitor and improve the Services;• supplying the Client with information that is relevant to the Client’s existing relationship with the Company; and/or• any other purposes as permitted by applicable laws.

4.2. Where the Company collects personal data for a specific purpose, the Company will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. Where we hold personal data in connection with your Account, we generally keep it for six years after your Account is closed, so that we can meet our legal, regulatory and anti-money laundering record keeping obligations, deal with any complaint or dispute, and bring or defend legal claims. We may keep some personal data for longer where the law requires it only for legitimate business or legal reasons. When we no longer need your personal data, we delete it or make it anonymous.

4.3. We are allowed to process your personal data on the following lawful grounds:• as necessary to perform our contract with you for our Services;• in order to comply with our legal obligations;• as necessary for our legitimate interests. This means we have good, sensible, practical reasons for processing your data in the interests of the Company. To do so, we have considered the impact on your interests and rights, and have in place appropriate safeguards to protect them.

4.4. We will only send you marketing about products and services offered by our group companies or partners where you have agreed to receive it. You can withdraw that agreement at any time using the unsubscribe link in any marketing message or by contacting us.

5.1. The Company takes securing your personal data and preserving your privacy very seriously. The Company will not offer, publish or share your personal data with third parties, without seeking the Client’s explicit permission, unless the Company expressly states otherwise elsewhere in this Privacy Policy, the Agreement, or the Company is obliged by law. The Company will never sell your data.

5.2. If agreed upon, or based on law, the Company may process, use and disclose your personal information with third parties. Such third parties may be based abroad and may include but are not limited to the following:• third parties providing regulated financial services where we provide related administration services and customer services, which may change from time to time.;• regulatory authorities and enforcement agencies;• any court of law or any relevant party in connection with any claim or legal proceeding;• contractors, service providers, consultants, auditors and advisors on a need to know basis;• advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions;• our subsidiaries, parent company or related companies and third parties required to process the Services for you or otherwise provide any Services to you (Partners);• professional service providers;• web analytics tool providers, such as Google.

5.3. We may share your personal data for the following reasons:• reasons provided under ‘using your personal data’;• to enforce any provision of the Terms and/or Agreement;• to protect the rights or property of any member of the Company (including but not limited to any intellectual property rights);• to conduct investigations in respect of any possible breach of applicable laws (only if legally obliged); and/or• to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate (only if legally obliged).

5.4. In situations where a third party under contract with the Company collects and/or receives personal data about you, the Company will require the third party to act according to laws regarding personal data and to exercise reasonable care in protecting your information.

5.5. You are responsible for providing accurate and complete information about yourself and any other person whose personal information you provide us, and to notify us (either by the Website, SENDS APP, SENDS Platform or by email) if there are any changes to your personal information.

6.1. We store your personal data on servers located within the European Economic Area (EEA).

6.2. Some of the Partners, service providers and other third parties we work with are located outside the United Kingdom and the EEA. Where this is the case, your personal data may be transferred to, stored in or processed in a country outside the UK and the EEA, for example to set up and provide a service you have requested, to process a payment, or to provide our Services.

6.3. Whenever we transfer your personal data out of the UK or the EEA, we make sure it receives a level of protection essentially equivalent to that required under UK data protection law and the EU General Data Protection Regulation. We do this by relying on one or more of the following safeguards: (a) a transfer to a country that the UK Government or the European Commission, as applicable, has decided provides an adequate level of protection. (b) a contract that incorporates the UK International Data Transfer Agreement, the UK Addendum to the European Commission Standard Contractual Clauses, or the European Commission Standard Contractual Clauses, as applicable to the transfer. (c) for transfers to the United States, a recipient that is certified under the EU-US Data Privacy Framework and, for personal data transferred from the UK, the UK Extension to that Framework (the UK-US data bridge).

6.4. In the limited cases where none of these safeguards is available, we will transfer your personal data outside the UK or the EEA only where an exception under data protection law applies, for example where the transfer is necessary to perform our contract with you.

6.5. You can ask us for more information about the safeguard we use for a particular transfer, or for a copy of it, by contacting us at [email protected].

7.1. Should you have a complaint about the protection of your personal data, please send an e-mail to [email protected]. Please clearly state that you are submitting a complaint, to assure the soonest resolution and best support possible.

7.2. If you are not satisfied with how we have handled your personal data, you have the right to complain to the Information Commissioner's Office, which is the UK's supervisory authority for data protection. You can contact the Information Commissioner's Office through its website at www.ico.org.uk, by telephone on 0303 123 1113, or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

8.1. Where you choose to use a product or service that is provided by a Partner and made available through our website or app (a Partner Service), we will share the personal data needed to set up and provide that Partner Service with the relevant provider. This may include your name, contact details, account identifiers, device information and details of the product you have selected. The provider will usually process your personal data as a separate and independent controller under its own privacy notice, which we will make available to you when you request the Partner Service.

8.2. We will only share personal data where we have a lawful basis to do so. The lawful basis may include performance of our contract with you, compliance with legal obligations, our legitimate interests, the legitimate interests of a Partner, or your consent where consent is required by law.

9.1. The Company endeavors to take all reasonable steps to protect your personal data and to store it securely. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While security cannot be guaranteed, the Company strives to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks. In using the Services, you accept the inherent security implications of engaging in transactions online over the internet and you agree that you will not hold the Company responsible for any breach of security unless we have been grossly negligent or in willful default.

9.2. To protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

9.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10.1. If you wish to access, correct (including update) and remove the personal data held by the Company or you do not want your personal data to be shared according to this Privacy Policy, you may contact the Data Protection Officer as follows:

by e-mail to: [email protected]

10.2. You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.

11.1. The Company reserves the right to update this Privacy Policy at any time to take into account any changes in law or for any other reason. If we update this Privacy Policy, we will post a new version on the Website. Any amendments will be effective immediately upon us posting the updated Privacy Notice on the Website. We will also post a notice of the changes on our Website or notify you by email (sent to the email address specified in your Account). We encourage you to periodically review this page for the latest information on our privacy practices.

11.2. Your continued use of the Website and Services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided. If there is a conflict between two versions of the Privacy Policy to which you have agreed or been deemed to agree, the more recent version shall take precedence unless it is expressly stated otherwise. If there is a conflict between the Privacy Policy and the Agreement, the Agreement takes precedence.

11.3. Policy concerning Children

SENDS does not provide services to anyone under the age of 18.

11.4. Governing law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of England and Wales.

12.1. If you wish to communicate with us about anything related to this Privacy Policy, you may contact the Data Protection Officer by email at [email protected].