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SendVia Data Privacy Policy (“Policy”)

Last Update: May 10, 2024 

The SendVia Marketplace comprises: (a) the services of SendVia, LLC (“SendVia” or “we”); (b) the services of third-party website hosting, payment processing and money exchange sub-service providers (“Subservice Provider(s)”); and (c) overseas products and/or services provided by one or more of our independent global partners (“Global Partner(s)”).   Together, SendVia, Subservice Provider(s) and Global Partner(s) (“SendVia Providers”) make available websites and other products and related services (“SendVia Services”) for the use of you and your entity, including members of your household or others using your account (“User” or “Users”). 

 

INFORMATION NOTICE 

By using any SendVia Services to enter your personal information, you acknowledge that “SendVia” may use your personal information for the purposes explained in this Policy and that SendVia Providers, may have their own separate data privacy policy(s) which you acknowledge may use your personal information for the purposes explained in the data privacy policy of respective SendVia Providers (“Purpose”). 

SendVia has created an online marketplace of risk management gift packages that connects individuals and risk management package providers through the purchase and gifting of risk management packages (“Purpose”). This Policy applies to natural persons who reside in the United States (“consumers” or “you”) who communicate, disclose, or provide personal information in connection with the Purpose. 

SendVia has adopted this Policy to comply with its obligations under applicable US data privacy regulations, including, without limitation, the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199), as amended by the California Privacy Rights Act of 2020 (together, “CCPA”). More complete information about the SendVia California Consumer Privacy Policy are provided in Exhibit A. Please note that the content of this Notice is subject to change based on changes to applicable laws and regulations. 

 

PERSONAL INFORMATION COLLECTED

SendVia is committed to safeguarding the privacy of any personal information that may come into its possession. In connection with the Purpose, by entering your personal using SendVia Services platforms, SendVia will receive the following categories of personal information from you: 

  • Identifiers. This category includes real name, telephone number, mobile number, email address, and other similar identifiers.  
  • Commercial Information. This category includes confirmation that your account was created, order ID, payment confirmation that your order is received, and date of purchase on SendVia Services platform(s).  

SendVia collects this information in order: 

  • To ensure the secure transfer of information. 
  • To facilitate the purchase and delivery of risk management packages. 
  • To act as a point of contact for consumers and the product recipients. 

 

SendVia will disclose this information to its affiliates, contractors, or service providers who are subject to a duty of confidentiality solely in connection with the Purpose.  

SendVia will not sell or share the above categories of personal information. The CCPA defines “sell” as the disclosure of personal information for monetary or other valuable consideration, and “share” as the disclosure of personal information by a business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration. The CCPA further defines “cross-context behavioral advertising” as targeting advertising to a consumer based on the consumer’s personal information obtained from their activity across businesses, distinctly branded websites, applications, or services, other than those with which the consumer intentionally interacts. 

 

RETENTION OF PERSONAL INFORMATION 

SendVia retain consumer personal information for as long as necessary to fulfill the Purpose outlined in this Policy, unless a longer retention period is required by law. If personal information must be kept for administrative, legal, or regulatory purposes, or to comply with any SendVia document retention policies. SendVia will keep the minimum amount of personal information necessary to comply with such obligations. 

 

RELATED POLICIES

WEBSITE TERMS AND CONDITIONS 

Please see our Website Terms and Conditions for more complete information about SendVia’s California Consumer Privacy Policy. The use of SendVia Services for any illegal purposes is strictly prohibited.  

 

DO NOT TRACK SIGNALS

SendVia sites currently do not respond to Do Not Track signals in browsers.

 

EXHIBIT A

California Consumer Privacy Policy

Last update: January 2023

 

Important Information for California Residents

SendVia take data privacy very seriously. This California Consumer Privacy Policy sets out the principles governing SendVia’s use and protection of personal information of California residents that individuals and clients share with us (“personal information”) as well as describing the rights of California residents regarding their personal information. These disclosures are intended to supplement the disclosures contained in the SendVia Global Data Privacy Policy for SendVia Global Gifting Marketplace. This California Consumer Privacy Policy applies to SendVia’s data collection and use through this website and through its business operations in the United States.

The California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act of 2020 (together, “CCPA”) provides California consumers (California residents) with specific rights regarding their personal information. We have provided a detailed description of your rights under the CCPA and how to exercise them in this Privacy Policy.

 

Rights of California Residents

The California Consumer Privacy Act of 2018 (CCPA) provides California consumers (California residents) with specific rights regarding their personal information. This section describes those rights and explains how to exercise them.

As a California resident, you have the right under the CCPA to exercise free of charge:

  1. Disclosure of Personal Information We Collect About You

You have the right to know:

    1. The categories of personal information we have collected about you;
    2. The categories of sources from which the personal information is collected;
    3. Our business or commercial purpose for collecting, selling, or sharing personal information;
    4. The categories of third parties to whom we disclose personal information, if any;
    5. The specific pieces of personal information we have collected about you; and

You have the right to correct inaccurate personal information that we maintain about you;

Please note that we are not required to:

    1. Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
    2. Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
    3. Provide the personal information to you more than twice in a 12-month period.
  1. Disclosure of Personal Information Sold or Shared

In connection with any personal information, we may sell or share to a third party for a business purpose, you have the right to know:

    1. The categories of personal information about you that we sold and shared and the categories of third parties to whom the personal information was sold and shared; and
    2. The categories of personal information that we disclosed about you for a business purpose. 
  1. Right to Opt-Out of the Sale or Sharing of Personal Information

Under the CCPA, you have the right to opt-out of the sale or sharing of your personal information. Please be aware that SendVia is not in the business of selling or sharing personal information and that SendVia has not sold nor shared personal information in the precedent twelve (12) months. SendVia does therefore not offer a mechanism to exercise the right to opt-out. SendVia uses and/or discloses sensitive personal information for the permitted purposes specified in the CCPA and therefore does not offer a mechanism to exercise the right to limit the use of sensitive personal information.

  1. Right to Deletion

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Subservice Provider(s) and Global Partner(s) to delete) your personal information from our records, unless an exception applies.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Subservice Provider(s) and Global Partner(s) to delete) your personal information from our records, unless an exception applies.

Please note that we may not delete your personal information if it is necessary to:

    1. Complete the transaction for which the personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform services under a contract;
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
    3. Debug to identify and repair errors that impair existing intended functionality;
    4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
    7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
    8. Comply with an existing legal or contractual obligation; or
    9. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  1. Right to Correction

You have the right to correct inaccurate personal information that we maintain about you.

  1. Protection Against Discrimination

You have the right to not be discriminated against by us because you exercise any of your rights under the CCPA. This means we cannot, among other things:

    1. Deny goods or services to you;
    2. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    3. Provide a different level or quality of goods or services to you; or
    4. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you if that difference is reasonably related to the value provided to you by your personal information.

Submitting Requests

Requests to Know, Correct and Delete* may be submitted to:

  • Calling us at 1-888-462-3048; or
  • SendVia, LLC PO Box 7101 Appleton, WI   54912 USA 

* Because SendVia is not in the business of selling personal information, the opt out option is not offered.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative thereof; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

The above applies regardless of whether a request is submitted by you on your own behalf, by an authorized representative on your behalf, or by you on behalf of your minor child.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Collection of Personal Information

Categories of personal information that we collect and disclose. We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

 

Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. The sections below set out generally the categories of personal information about California residents that we collect from and disclose to others for a business purpose. We collect these categories of personal information from the sources described in the Sources of Information Collected section below, and for the purposes described in the Categories of Personal Information Collected and Purpose of Collection section below. We do not sell or share the personal information of individuals under 16 years of age.

 

Categories of Personal Information Collected and Purposes of Collection

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Categories of Personal Information Collected

Purposes Personal Information, Including Sensitive Information, is Used

Identifiers and Contact Information. This category includes names, telephone number, mobile number, email address and other similar contact information and identifiers.

SendVia collects this information in order:

  • To ensure the secure transfer of information.
  • To facilitate the purchase and delivery of risk management packages.
  • To act as a point of contact for consumers and the product recipients.

Commercial information. This category includes confirmation that your account was created and order identifiers.

SendVia collects this information in order:

  • To ensure the secure transfer of information.
  • To facilitate the purchase and delivery of risk management packages.
  • To act as a point of contact for consumers and the product recipients.

 

This Section on the rights of California residents does not address or apply to SendVia’s handling of:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information;
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994;
  • Personal information we collect about job applicants, independent contractors, or current or former full-time, part-time, and temporary employees and staff, officers, directors, or owners of SendVia; and
  • Personal information about individuals acting for or on behalf of another company, to the extent the information relates to our transactions with such company, products, or services that we receive from or provide to such company, or associated communications or transactions (except that such individuals have the right to opt-out of any sale of their personal information and to not be subject to any discrimination for exercising such right).

 

Sources of Information Collected

We collect personal information directly from you, as well as automatically related to your use of our websites and other services, and from third parties. For example, we collect personal information:

  • From any form you may complete and submit through our websites, for example information collected from the “Contact Us“ page of our websites;
  • From the content of surveys that you may complete;
  • When you provide information as a client in connection with us providing professional services to you;
  • From other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties; and
  • From or on behalf of clients when we provide professional services, which could include personal information about their employees, benefits recipients, insureds, etc.

 

Data Minimization

In order to achieve the purposes identified above, the collection, use, and retention of personal information shall be reasonably necessary and proportionate. We collect the minimum personal information that is necessary to fulfill such purposes. When we act as a Service Provider, we only request the minimum personal information that is necessary to provide the services to our clients acting as Businesses. The terms Service Provider and Business are given the meanings set forth in the CCPA.

 

Disclosing Personal Information to a Third Party

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

  • In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
    • Categories A & B in the above table.
  • We disclosed your personal information for a business purpose to the following categories of third parties:
    • SendVia affiliates;
    • Service providers and independent contractors we use to help deliver our products and/or services;
    • Other third parties we use to help us run our business, such as marketing agencies, website hosts, technical security solutions;
    • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
    • Our insurers and brokers; and,
    • Our banks.

 

We may disclose your personal information in response to subpoenas, court orders, or other lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information in order to enforce or apply our rights and agreements, or when we believe in good faith that disclosing this information is necessary or advisable, including, for example, to protect the rights, property, or safety of our businesses, our websites, our customers, our users, or others, as permitted under the applicable laws, or as otherwise required by law or by government and regulatory entities. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

 

Changes to Our California Privacy Disclosures

We reserve the right to amend these California specific privacy disclosures at our discretion and at any time. SendVia therefore asks all concerned California residents to check it occasionally to ensure that you are aware of the most recent version.

 

How to Contact Us

If you reside in California and have questions or comments about this Privacy Policy, you may contact us at: data.protection@sendvia.com. If you have questions about the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, see the Rights of California Residents above.