Privacy Policy

Last Updated: January 24, 2026

1. Information We Collect

1.1 Personal Information

When you create an account or use our Services, we collect:

Data Type	Examples
Identity Information	Full name, date of birth, government-issued ID, Social Security Number
Contact Information	Email address, phone number, physical address
Financial Information	Bank account details, card information, transaction history
Device Information	IP address, browser type, operating system, device ID
Usage Data	Pages visited, features used, time spent on site

1.2 Information from Third Parties

We may receive information about you from:

• Identity verification providers (Jumio, Onfido) - to verify your identity
• Payment processors (Stripe, PayPal) - to process transactions
• Credit bureaus - for fraud prevention
• Social media platforms - if you sign up using social login

1.3 Automatically Collected Information

We automatically collect technical information when you visit our website or use our app:

• IP address and geolocation
• Browser type and version
• Device type and operating system
• Cookies and tracking technologies (see our Cookie Policy)
• Pages viewed and links clicked

2. How We Use Your Information

We use your personal information for the following purposes:

2.1 To Provide Our Services

• Process money transfer transactions
• Verify your identity (KYC compliance)
• Send transaction confirmations and receipts
• Provide customer support
• Manage your account

2.2 Legal & Compliance Obligations

• Comply with anti-money laundering (AML) regulations
• Prevent fraud and financial crimes
• Report suspicious activities to FinCEN
• Respond to legal requests and court orders
• Maintain records as required by law (minimum 5 years)

2.3 To Improve Our Services

• Analyze usage patterns and trends
• Develop new features and products
• Conduct market research
• Improve security and fraud detection

2.4 Marketing & Communications

• Send promotional offers and updates (with your consent)
• Notify you about new features or services
• Conduct surveys and request feedback
• Referral program communications

Opt-Out: You can unsubscribe from marketing emails by clicking the "unsubscribe" link in any email or by contacting us at [email protected].

3. How We Share Your Information

We may share your personal information with the following parties:

3.1 Service Providers

• Payment Processors: Stripe, PayPal, bank partners
• Identity Verification: Jumio, Onfido, Trulioo
• Mobile Money Operators: M-Pesa, Orange Money, Airtel Money
• Cloud Services: AWS, Google Cloud (for data storage)
• Analytics: Google Analytics, Mixpanel
• Customer Support: Zendesk, Intercom

3.2 Legal & Regulatory Authorities

We may disclose your information to:

• Law enforcement agencies (with valid legal request)
• Financial Crimes Enforcement Network (FinCEN)
• State and federal regulators
• Courts and legal proceedings

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you before your information is transferred and becomes subject to a different privacy policy.

3.4 With Your Consent

We may share your information with third parties when you provide explicit consent, such as when using social sharing features.

4. Data Security

We implement industry-standard security measures to protect your information:

4.1 Technical Safeguards

• Encryption: All data transmitted over the internet is encrypted using TLS 1.3
• Secure Storage: Personal data is encrypted at rest using AES-256
• Firewall Protection: Network firewalls prevent unauthorized access
• Regular Security Audits: Third-party penetration testing annually

4.2 Access Controls

• Multi-factor authentication (MFA) required for employee access
• Role-based access control (RBAC) - employees only access data necessary for their role
• Regular access reviews and revocation procedures

4.3 Data Breach Response

In the unlikely event of a data breach, we will:

• Notify affected users within 72 hours
• Report the breach to relevant authorities
• Provide guidance on protective measures
• Conduct a thorough investigation and implement corrective actions

5. Your Privacy Rights

Depending on your location, you may have the following rights:

5.1 Access & Portability

• Right to Access: Request a copy of your personal data
• Data Portability: Receive your data in a machine-readable format

5.2 Correction & Deletion

• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal retention requirements)

5.3 Control & Objection

• Right to Object: Object to certain processing activities (e.g., direct marketing)
• Right to Restrict Processing: Limit how we use your data
• Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

5.4 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: [email protected]
• Phone: +1 (800) 962-5265
• Mail: Privacy Officer, MbokaSend LLC, 3502 Mustang Rd, Joliet, IL 60435

We will respond to your request within 30 days.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal and regulatory obligations (minimum 5 years for financial records)
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

Data Type	Retention Period
Transaction Records	5 years (required by law)
KYC/Identity Documents	5 years after account closure
Account Information	Duration of account + 5 years
Marketing Data	Until opt-out or 3 years of inactivity
Support Communications	3 years

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have different data protection laws than your country.

When we transfer your data internationally, we ensure adequate protection through:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions
• Privacy Shield frameworks (where applicable)

8. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at [email protected], and we will delete it.

9. Third-Party Links

Our website and app may contain links to third-party websites and services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any information.

10. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request information about data we collect, use, and share
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: Opt-out of the "sale" of your personal information (Note: We do not sell personal information)
• Right to Non-Discrimination: Exercise your rights without discriminatory treatment

11. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), you have rights under the General Data Protection Regulation (GDPR):

• Right of access, rectification, and erasure
• Right to restrict or object to processing
• Right to data portability
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

Legal Basis for Processing: We process your data based on:

• Contractual necessity (to provide our Services)
• Legal obligations (AML/KYC compliance)
• Legitimate interests (fraud prevention, service improvement)
• Your consent (marketing communications)

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Send you an email notification
• Display a prominent notice on our website/app

Your continued use of our Services after changes are posted constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:

• Privacy Officer: [email protected]
• Support Team: [email protected]
• Phone: +1 (800) 962-5265
• Mail: Privacy Officer, MbokaSend LLC, 3502 Mustang Rd, Joliet, IL 60435, United States