General Privacy notice

Last updated January 14, 2025

Your Trust, Our Commitment.

Introduction

In fulfillment of our legal obligations to our “Users”, or “You” (i.e all our website visitors, mobile application users, and anyone who uses any of our current and future products and services), under the Nigerian Data Protection Act, Personal Information Protection and Electronic Documents Act (PIPEDA) and all applicable data protection laws, we have curated this privacy notice to define our collection, disclosure, and use of the data collected from you either physically or digitally, whether collected or stored electronically or in hardcopy.

The execution of this privacy notice seals our relationship with you and we shall keep updating it to meet legal and regulatory standards while you use our services. In cases where you provide data about someone else, you warrant that you have that person’s informed consent to provide such data to us.

If you have any questions about your personal data with us, please contact our Data Protection Officer - Theophilus Oladipo via legal@yousend.co.

Who we are

YouSend is a money service business engaged in the provision of remittance services in select countries across the globe through a host of licences and a network of partners. Our focus is to provide ease and facility for emigrants in major destination countries like Canada and the UK to send money back to Africa.

Yousend Inc (“Yousend”, “us”, “we” or “our”) operates this website/application (the “Platform”). You may contact us via legal@yousend.co.

We value your privacy

At Yousend, we recognize that your privacy is important, hence, we treat your personal information as confidential and private. We are committed to protecting your privacy at all times and providing you with the most efficient level of security as you use our services and interact with us.

This document outlines the types of personal information we receive and collects when you use the service, what we do with it, the basis of processing, and some of the steps we take to safeguard your information. We hope this will help you make an informed decision about sharing your personal information with us.

To enjoy full access to our website, mobile application, and other service points, you need to accept and consent to the collection, storage, usage, disclosure, and processing of your data in accordance with the terms stated in this privacy notice.

Hence, we employ you to read this privacy notice carefully to understand the terms and what constitutes our best practices in relation to your data. If you do not consent to this privacy notice, you may not be able to use our services.

Unless otherwise defined in this Privacy Notice, terms used in this Privacy Notice have the same meanings as our Terms of Use. We are committed to protecting your Data while You use this Application.

Information collection and use

We collect different types of information from you voluntarily when you visit our website or download our mobile application. The collected information is duly stored on our servers and used internally to provide and improve our service to you, communicate with you, cross-check your identity with third parties, and NOT sell to third parties. If we make material changes in collecting personally identifiable information, we will inform you by placing a notice on our site.

The information we collect includes but is not limited to:

Personal identification information: full name, title, date of birth, nationality, cellphone or mobile number, email address, place of residence (and/or proof of residence), employment status, the industry of employment, and/or national identification number.
Why we collect
  1. Updating our records, creating your profile, and processing your transactions.
  2. Managing and maintaining your account with us.
  3. Communicating with you concerning your account transactions and managing our relationship with you, including for purposes of quality control and staff training to make sure we continue to provide you with accurate information, products, and services.
  4. Contacting you during routine compliance reviews or to share news/updates in the financial sector and other personalized advertising and marketing.
Lawful Basis for Processing

Legal Obligation

Information for purposes of biometric identification, such as the selfie you provide to us when creating your Yousend account.

Why we collect

Verifying your identity and completing Know Your Customer (KYC), Anti-Money Laundering, Combating the Financing of Terrorism (AML/CFT/CPF) requirements.

Lawful Basis for Processing

Legal Obligation

Identity Information: such as a copy of your national identity card, driver’s license or passport, tax identification number, source of funds, employment information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
Why we collect

Verifying your identity and completing Know Your Customer (KYC), Anti-Money Laundering, Combating the Financing of Terrorism (AML/CFT/CPF) requirements.

Lawful Basis for Processing

Legal Obligation

Transaction information: such as your transaction data on your Yousend account and information on the recipient of any transaction(s). Details of when you contact us and when we contact you.
Why we collect

Managing our risks, identifying and investigating illegal activities, and complying with AML/CFT/CPF policies.

Lawful Basis for Processing

Legal Obligation

Banking Information: such as your bank verification number, card details, and account details.
Why we collect

Verifying your identity and completing Know Your Customer (KYC), Anti-Money Laundering, Combating the Financing of Terrorism (AML/CFT/CPF) requirements.

Lawful Basis for Processing

Legal Obligation

Correspondence such as information provided to us when engaging with our customer support and/or responses to surveys.

Why we collect

Addressing any disputes concerning your account, our services, and investigations by law enforcement or regulatory bodies.

Lawful Basis for Processing

Consent

Device/Technical Information: Usage, device, and location information such as cookies, geolocation information, browser name and version information, IP address information, device fingerprint data, authentication data, and/or clickstream data.
Why we collect

Detecting and preventing fraudulent or unauthorized use of our products and services.

Lawful Basis for Processing

Legal Obligation

Any other related information that is necessary for the fulfillment of your requests to us and our regulatory obligations.

Why we collect

Any other purpose that we disclose to you while providing services to you.

Lawful Basis for Processing

Case by case assessment

How we collect your data

We collect public and non-public data from you through;

  1. Your direct disclosures to us when you onboard on our platform, use our Services, or access our platform.
  2. Through your communication with us via email, chat, telephone, or any other customer support channels.
  3. When you read our emails or notices, online research on social media and websites that may not be publicly available;
  4. Investigations on publicly available databases in furtherance of our compliance obligations.
  5. When you participate in surveys, competitions, and promotions that we make available to you.
  6. When you view the site via its browser’s cookies or submit reviews, messages or comments.
  7. When you use the Yousend platform, we collect information on your transactions and usage of your account.
  8. When we obtain information from third parties such as identity verification services, credit reference agencies, regulatory and enforcement agencies, and public sources.
  9. Through other ways permitted by law.

How we use/process your data

Any personal information provided by you will be used and processed with your consent, for compliance with legal and regulatory obligations, to respond to your queries, and to meet the legitimate business obligations of Yousend. In using/processing your personal data, we rely on one or more of the following lawful grounds:

  1. Legal obligation: In most cases, we process your personal data to comply with an obligation imposed by applicable laws.
  2. Contractual necessity:We may process your personal data where it is necessary for us to provide our products and services to you, perform a contract to which you are a party, take steps at your request before entering a contract, or otherwise comply with our obligations under our Terms of use.
  3. Legitimate and Public interest: In some cases, we may need to process your personal data where it is in our legitimate legal interests to do so, for the performance of a task carried out in the interest of public policy, or the exercise of official public mandate vested in Yousend.
  4. Consent: In some cases, we will only process your personal data where you provide us with your express consent for such processing.

Types of data collected

  1. Personal Identification Data: While using our Service, we may ask you to provide us with certain personally identifiable information that we can use to contact or identify you (“Personal Data”).
  2. Usage Data: We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
  3. Location: The access to your device location will be used to verify your address, make a better credit risk decision, expedite your KYC process, customer risk assessment, and scoring purposes.
  4. Mobile Device: This permission enables us to track specific information about your device, such as device name, model number, location, language settings, device identifier, network operator, roaming state, MNC and MCC codes, MAC address and mobile network information, hardware and software information, status, usage habits, unique device identifiers such as IMEI and serial number to uniquely identify the device and to ensure that unauthorized devices do not act on your behalf to prevent fraud, misrepresentation, and identity theft.
  5. Non-Personal Information Collected By Us: In providing you with quality service, we sometimes collect certain information during your visits to perform certain tasks such as access to our website or conduct research on your behavior on our site to improve our services. We will not disclose your information to any person outside our organization except as described in this Privacy Policy.
    When you input your card details on our website, app, or other platforms, we do not directly collect your card information. Our partner institution may collect the information and process the card payments. If you have any issues relating to the card payments or its security, you may refer to us and we will escalate to our card payment partners.
    We also collect email address, mobile phone number, and address. Our physical and virtual access control measures ensure your card information is kept safe and secure on our servers. We also have cyber security policies and procedures, including the use of encryption and firewall technologies in compliance with international standards.
  6. Tracking & Cookies Data: We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
    Cookies are files with a small amount of data, including a unique anonymous identifier that is usually stored on your computer whenever you visit a website. They help us identify you as a user and memorize your preferences to tailor your experiences while on our site to help us analyze our website traffic. We use cookies to improve your experience while on our site, help us understand your user experience, and discover what content is most applicable to you. Cookies also allow our servers to remember IP addresses, dates, and times of visits, monitor web traffic, and prevent fraudulent activities. The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons.
    Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and improve and analyze our Service. You can instruct your browser to accept or refuse all cookies or indicate when a cookie is being sent. However, if you do not accept cookies, you may not experience and use some portions of our Service. Examples of Cookies we use:

    1. Session Cookies. We use Session Cookies to operate our Service.
    2. Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
    3. Security Cookies.We use Security Cookies for security purposes.

Transfer of data

Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer. We shall take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. Any personal information you provide to us, including and similar to your name, address, telephone number and e-mail address, will not be released, sold, or rented to any entities or individuals except in accordance with this notice, our privacy policy and applicable law.

Your rights over your data

You have certain rights/control over the information you submit to us or those information we collect from you. This includes the right;

  1. To access and confirm your personal information held by Yousend. This right of access can be exercised by sending an email to legal@yousend.co
  2. To withdraw consent from or object to the processing of your Information (this does not affect already processed information).
  3. To delete, rectify or update any inaccurate or outdated information.
  4. To know the purpose for processing your Information.
  5. To restrict the processing of your Information. We might continue to process your data if there are valid legal or operational reasons.
  6. To remove yourself from our mailing list. For this to happen, you can send an email to legal@yousend.co or simply unsubscribe from our mailing list.
  7. To request for the erasure of any information Yousend holds about you if any, subject to the provisions of applicable law. We might continue to retain such data if there are valid legal, regulatory, or operational reasons.
  8. To request a copy of the information Yousend keeps about you in a structured, commonly used, and machine-readable format, or request that such data be sent to a third party. To carry out this request, please refer to our Data Subject Access Request page or by sending an email to legal@yousend.co. We will not hinder you from transmitting your data in our database to another company where the processing is based on consent, on a contract, and the processing is carried out by automated means in compliance with applicable laws and where technically feasible.
  9. To object/refuse access to your information for direct marketing.
  10. To contest the accuracy of your personal data. Where this is done, Yousend shall have the right to a specified period to verify the accuracy of the personal data.

You may decline to provide your personal Information when we request for it, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us via legal@yousend.co

If you believe your privacy rights have been violated or you disapprove of our data privacy practices, you have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada.

How to exercise your rights

When you request to exercise any of the above rights, we will provide you with your personal information and other necessary information you request. However, we reserve the right to charge you or refuse your request where we notice that the request is repetitive or excessive.

Where any of your rights as provided for under this Privacy Notice is breached, the resolution shall be in accordance with the provision of our Terms of Service, provided that you can only apply for a remedy within a period of 2 years within which the breach occurred.

Storage of personal data

All Personal Information you provide to us is stored on our secure servers and cloud infrastructure (where applicable). The data that we collect from you may be transferred to and stored at a destination outside Nigeria . However, whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with applicable law.

We take the security of the Personal Data we collect very seriously, hence, we have set up reasonable and appropriate technical and organizational measures to prevent and reduce the risk of accidental destruction, loss, misuse, or unauthorized access, modification, and disclosure of such information under our control.

Some of the measures we have put in place include:

  1. Frequent updates of our security controls and processes to meet industry standards.
  2. Continuous training of employees to respect the confidentiality of any personal information held by us.
  3. The use of role-based access control (RBAC) as an internal security measure in granting permission to access customers’ data.

Please note that no system involving the transmission of information via electronic storage systems or the Internet is entirely secure. We therefore employ you to take reasonable caution as follows:

  1. Where we have provided you (or where you have chosen) a password or security pin that grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not share your password/security PIN or other authentication details with anyone and ensure you sign off when using a shared computer.
  2. Two-Factor Authentication: We have added Two Factor Authentication as an additional layer of security to your account. You will be required to enter a One-Time Password (OTP) (a code sent to you to verify directives. Please note that you may opt to disable this feature. In the event you opt out of this feature, despite our strong recommendation, Yousend shall not be liable for any loss or damages incurred because of your decision.

Record retention

In line with regulatory obligations under different applicable laws, we may retain your data for 5 years or longer where necessary for the purpose(s) for which it was collected. Storage of your data is also determined by legal, regulatory, administrative, or operational requirements.

Account deletion

You may request for the deletion of your account via the Yousend Platform. This request will be reviewed within 72 hours after which you shall receive a notification on whether or not your request was approved. Please note that this timeline may be exceeded in extenuating circumstances.

The grant of your deletion request is subject to your use of your account in accordance with this Privacy Notice, our Terms of Use, and all applicable laws. Where your request is granted, your account shall be deleted within 7 days. Where your request is denied, a reason for the denial shall be provided to enable you to comply and reapply for the deletion.

We may continue to retain your personal data for analytical or business purposes where there are valid legal or regulatory reasons for such retention.

Disclosure of personal data

  1. Any person who works for or partners with Yousend, our affiliated businesses, and sponsored platforms.
  2. Financial and other institutions we partner with to provide our products and services.
  3. Companies and organizations that provide third-party services to us, including technical infrastructure, marketing and analytics, web, and app development.
  4. Companies and organizations that assist us with identity verification, background screening, and due diligence.
  5. Our professional advisers, external auditors, consultants, and other similar service providers.
  6. Regulators, law enforcement agencies, and other government agencies.

We will otherwise treat your personal data as private and confidential and will not share it with other parties except:

  1. Where you have permitted us to do so.
  2. Where we believe it is reasonably necessary to comply with any law, regulation, legal process, or governmental request, to enforce our Terms of Use or other agreements, or to protect the rights, property, or safety of us, our customers, or others.
  3. Where we may transfer rights and obligations according to our agreement with you.

Service providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf, where necessary, and they are obligated not to disclose or use it for any other purpose. We put some safeguards in place to manage the risks associated with this sharing including signing confidentiality and data processing agreements to put them under the obligation of secrecy and compliant processing.

External sites

Our Service may contain links to other sites not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the privacy notice or policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

In some cases, we use Third-Party API services, and by signing up for this Service, you agree to be bound by the Terms and Policies applicable and/or governing such Third-Party content. Links to Third-Party websites and online services that may be contained in these Terms are not owned or controlled by us.

We make no representation and assume no liability or responsibility for the content, privacy policies, or practices of these third-party Services, or the accuracy, reliability, or correctness of those services.

Children’s privacy

Our products and services are not designed for, addressed to, or intended for anyone under the age of 18 ("Children" or “Minors”). We do not knowingly collect personally identifiable information from anyone under 18.

If you are a parent or guardian and know that your child has provided us with Personal Data, please contact us via legal@yousend.co for removal of such data. If we become aware that we have collected Personal Data from a child without verification of parental/guardian consent as required by law, we will remove that information from our servers.

Changes to privacy policy

This Privacy Notice shall be updated from time to time to meet legal and regulatory requirements, and as our technology evolves. We will notify you of any changes by posting the updated version of this Privacy Notice on this page.

We will notify you via email and/or by a notice on our Mobile App/ Website before the change becomes effective and update the "effective date" at the top of this Privacy Notice. You are advised to review this Privacy Notice periodically for any changes.

Changes to this Privacy Notice are effective and immediately become applicable to you once posted on this page.

Contact us

If you have any questions about this Privacy Notice, please contact us via legal@yousend.co.