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Privacy Policy
How MbokaSend collects, uses, and protects your personal information
Effective : February 9, 2026
Last Updated : April 2026
Contact : privacy@mbokasend.org
π Our Commitment: MbokaSend is committed to protecting your personal information. We collect only what is necessary to provide our services and comply with legal obligations. We do not sell your personal data to third parties.
1. Who We Are
MbokaSend Inc. ("MbokaSend," "we," "us," or "our") is an Illinois C-Corporation (File #75461593) registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN MSB #MRX26-00003122), headquartered at 3502 Mustang Rd, Joliet, IL 60435.
MbokaSend operates a digital remittance platform (mbokasend.org) enabling individuals in the United States to transfer money to recipients in the Democratic Republic of Congo via mobile money networks.
This Privacy Policy applies to all personal information collected through our website (mbokasend.org), mobile application, and related services.
2. Information We Collect
A. Information You Provide Directly:
| Category | Examples | Purpose |
| Identity Information | Full name, date of birth, government ID | KYC verification, AML compliance |
| Contact Information | Email address, phone number, mailing address | Account management, transaction notifications |
| Financial Information | Bank account, card number (tokenized), SSN (last 4) | Payment processing, identity verification |
| Transaction Data | Transfer amounts, recipient info, transaction history | Service delivery, regulatory reporting |
| Recipient Information | Recipient name, phone number, mobile money network | Fund delivery to DRC |
B. Information Collected Automatically:
- IP address and device information
- Browser type and version
- Pages visited and time spent on site
- Transaction timestamps and geographic data
- Login and activity logs
C. Information from Third Parties:
- Identity verification services (for KYC)
- OFAC screening databases
- Payment processors (Stripe, Helcim)
- Mobile money operators (M-Pesa, Airtel, Orange) for delivery confirmation
3. How We Use Your Information
We use your personal information for the following purposes:
- Service Delivery: Processing and completing your money transfers to the DRC
- Account Management: Creating and maintaining your MbokaSend account
- Identity Verification: Verifying your identity to comply with KYC/AML regulations
- Regulatory Compliance: Filing required reports with FinCEN (CTRs, SARs) and complying with BSA, OFAC, and other laws
- Fraud Prevention: Detecting and preventing fraudulent activity and money laundering
- Customer Support: Responding to your inquiries and resolving issues
- Communication: Sending transaction confirmations, account alerts, and service updates
- Security: Protecting the security and integrity of our platform
- Legal Obligations: Complying with applicable laws and court orders
Legal Basis: We process your data based on: (1) contract performance (delivering your transfers), (2) legal obligations (AML/BSA compliance), (3) legitimate interests (fraud prevention, security), and (4) your consent where required.
4. Information Sharing & Disclosure
MbokaSend does not sell your personal information. We may share your information in the following circumstances:
Required by Law:
- FinCEN (Currency Transaction Reports, Suspicious Activity Reports)
- Law enforcement agencies with valid legal process
- OFAC and other regulatory authorities
- Illinois IDFPR (state money transmitter regulator)
Service Partners:
- Payment Processors: Stripe, Helcim (payment processing only)
- Payout Partners: MOKO Afrika, Onafriq (fund delivery to DRC)
- Identity Verification: KYC verification services
- Cloud Infrastructure: Google Firebase (data storage, authentication)
Business Transfers:
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to the same privacy protections.
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We Never: Sell your data to advertisers, data brokers, or marketing companies. Your financial and personal information is used solely for service delivery and legal compliance.
5. Data Security
MbokaSend implements industry-standard security measures to protect your personal information:
- Encryption: All data transmitted using 256-bit SSL/TLS encryption
- Authentication: Multi-factor authentication (MFA) for account access
- Database Security: Google Firebase Firestore with role-based access controls
- Payment Security: Card numbers are never stored β tokenized by payment processor
- Access Controls: Employee access limited to job-required data only
- Monitoring: 24/7 security monitoring and anomaly detection
Despite our security measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account password.
6. Data Retention
We retain your personal information for as long as necessary to provide our services and comply with legal obligations:
| Data Type | Retention Period |
| Account information | 5 years after account closure |
| Transaction records | 5 years (BSA requirement) |
| KYC/Identity documents | 5 years after account closure |
| SAR-related records | 5 years (BSA requirement) |
| CTR filings | 5 years (BSA requirement) |
| Log files and activity data | 2 years |
| Marketing communications | Until opt-out + 1 year |
7. Your Rights & Choices
Depending on your location, you may have the following rights regarding your personal information:
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Right to Access
Request a copy of the personal information we hold about you
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Right to Correction
Request correction of inaccurate or incomplete information
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Right to Deletion
Request deletion of your data (subject to legal retention requirements)
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Right to Object
Object to certain processing activities, including marketing
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Data Portability
Receive your data in a structured, machine-readable format
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Opt-Out
Unsubscribe from marketing emails at any time
Note: Some rights may be limited by our legal obligations (e.g., AML/BSA recordkeeping requirements prevent deletion of transaction records within the 5-year retention period).
To exercise your rights, contact us at privacy@mbokasend.org. We will respond within 30 days.
8. Cookies & Tracking
MbokaSend uses cookies and similar tracking technologies to:
- Maintain your login session (essential cookies)
- Remember your preferences
- Analyze site usage to improve our services (analytics)
- Detect and prevent fraud
You can control cookies through your browser settings. Disabling essential cookies may affect the functionality of our service.
9. Children's Privacy
MbokaSend services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we discover that we have collected information from a minor, we will delete it immediately.
If you believe we have inadvertently collected information from a minor, please contact us at privacy@mbokasend.org.
10. International Data Transfers
As a money transfer service operating between the United States and the Democratic Republic of Congo, some of your information may be transferred internationally. Specifically:
- Recipient information is shared with DRC mobile money operators (M-Pesa, Airtel, Orange) for fund delivery
- Data is stored on Google Firebase servers (primarily US-based)
We ensure that any international transfers comply with applicable data protection laws and that appropriate safeguards are in place.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:
- Posting the updated policy on mbokasend.org
- Sending an email notification to registered users
- Displaying a notice on our platform
Continued use of MbokaSend services after notification of changes constitutes acceptance of the updated policy.
12. Contact Us
Privacy Officer: Clodi Matuakanunu Mutantu
Email: privacy@mbokasend.org
Phone: (815) 2421815
Address: MbokaSend Inc., 3502 Mustang Rd, Joliet, IL 60435
For privacy complaints, you may also contact the Illinois Attorney General's office or file a complaint with the FTC at ftc.gov.