TRANSFERSTOME PRIVACY POLICY
Effective Date: 10/02/2025
This Privacy Policy (hereinafter, the “Policy”) describes how TransfersToMe LLC (registration number 3847 LLC 2024), registered in Saint Vincent and the Grenadines (hereinafter, the “Company,” “we,” or “our”), processes the personal data of users (hereinafter, the “Users,” “you”) when using the “TransfersToMe” mobile application (hereinafter, the “Application”) and related services.
1. INTRODUCTION
1.1. Privacy Principles
We recognize the importance of privacy and are committed to ensuring the lawful and secure processing of your data. This Policy is aimed at transparently disclosing how we collect, use, store, and protect personal data.
1.2. Scope
This Policy applies to information obtained from you while you use the Application, as well as during any other interactions with us in the course of providing services.
1.3. Consent
By using the Application, you confirm that you have read this Policy and agree to its terms. If you do not accept these terms, please discontinue using our services.
2. DATA WE COLLECT
2.1. Information You Provide
Registration: name, surname, email address, phone number.
Verification (KYC): for financial transactions, we may request a photo or scan of your identity document and a facial photograph (selfie). The actual uploading and storage of such images are carried out by a third-party KYC provider. We do not receive or store these files on our servers; we only receive information about the status of your verification (e.g., “verified” or “rejected”).
Content in the Application: any messages, images (receipts, etc.) that you send via the in-app chat.
2.2. Information Collected Automatically
Device Data: device type, OS version, unique identifiers.
Connection Data: IP address, timestamps, network information.
Location Data: approximate location based on IP address.
2.3. Information from Third-Party Sources
We may receive the verification result (e.g., successful identity confirmation or rejection) from an external verification service if required for identity confirmation (KYC) or to comply with legal requirements. Photos or other copies of documents are stored directly with the third-party KYC provider, not with us.
We may also receive information from payment system providers and Partners (e.g., the status of completed transactions) if necessary to provide our services.
3. HOW WE USE YOUR PERSONAL DATA
3.1. Service Provision and Improvement
Ensuring the functioning of the Application and access to its features (transfers, chat, etc.).
Adapting interfaces and content to your preferences.
3.2. Compliance with Legal and Regulatory Obligations
Meeting anti-money laundering (AML) and counter-terrorism financing (CTF) requirements.
Responding to government requests and complying with local and international regulations.
3.3. Communications and Notifications
Sending service messages (updates, policy changes, transaction notices).
Responding to your requests in the Application’s chat and through other communication channels.
3.4. Marketing and Analytics
Performing statistical analyses to improve the user experience and optimize the service.
Retargeting and advertising campaigns (you may opt out of receiving marketing messages at any time by following the opt-out instructions provided in those messages).
3.5. Security and Fraud Prevention
Detecting suspicious activity and preventing unauthorized access.
Monitoring operations to identify potential violations and protect users’ rights.
4. DISCLOSURE OF INFORMATION TO THIRD PARTIES
4.1. External Verification Service
During KYC procedures, we transfer your data (photos of documents, selfies) to a third-party provider who verifies their authenticity.
4.2. Partners and Service Providers
We may share certain information with third-party services that assist us in hosting, analytics, payment processing, and other operations. These services may only use your information to the extent necessary to provide their services.
4.3. Legal Requirements
If we receive a lawful request or court order from competent authorities, we may disclose your personal data to the extent required to comply with the law.
4.4. Corporate Transactions
In the event of a merger, sale of the business, or corporate reorganization, we may transfer your data to successors, provided confidentiality is ensured and your rights are protected.
5. STORAGE AND SECURITY
5.1. Retention Period
We store your data for as long as it is necessary to achieve the purposes described in this Policy, or as required by law. If you request the deletion of your data, we will honor this request unless there are other legal grounds for further retention.
5.2. Security Measures
We use encryption and other technical measures to protect data from unauthorized access.
We limit internal access to your data, granting it only to employees who require such access for their job duties.
Despite these measures, no method of data transmission over the internet or electronic storage is 100% secure.
6. YOUR RIGHTS
6.1. Access and Correction
You have the right to request a copy of your personal data and to request the correction or updating of inaccurate information.
6.2. Deletion and Restriction of Processing
You may ask us to delete your personal data or restrict its processing if there are no legal grounds for continued use.
6.3. Withdrawal of Consent
If data processing is carried out based on consent, you may withdraw your consent at any time. However, this may affect your ability to use certain features of the Application.
6.4. Right to Object
In certain cases, you may object to the processing of your data (e.g., for direct marketing).
6.5. Contact for Exercising Rights
To exercise your rights, please contact us using the details provided in the “Contacts” section.
7. COOKIES AND SIMILAR TECHNOLOGIES
7.1. Use of Cookies
When using our website or the web version of our service, we may employ cookies and other tracking technologies to personalize your experience, analyze traffic, and save preferences.
7.2. Managing Cookies
You can manage cookie settings in your browser, disable them, or delete them. However, this may affect the functionality of the service.
8. AGE RESTRICTIONS
Our service is not intended for individuals under 18 years of age. If we become aware that a user is under this age, we reserve the right to block or delete their account and any associated data.
9. CHANGES TO THE POLICY
We may amend this Policy to reflect changes in legislation or in our service. If there are significant changes, we will inform you by publishing a new version of the Policy on our website or in the Application. By continuing to use our services after the changes take effect, you accept the updated Policy terms.
10. CONTACTS
If you have any questions or complaints regarding this Policy, or if you wish to exercise your rights regarding personal data, please contact us by email at:
manager@transfersto.me