Date of Last Revision: 26th September 2023
This Privacy Policy describes the privacy practices of Sendto Ltd, doing business as “Roam” (“we”, “us”, or “our”) and how we handle personal information that we collect through the website located at sendto.xyz, our mobile web browser, non-custodial digital wallet software, and our front-end interface that facilitates user-controlled transactions on public blockchains (collectively, the “Service” or “Services”).
Information you provide us may include:
We and our service providers may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, online resources, and our communications, such as:
We use the following tools for automatic data collection:
We use personal information for the following purposes or as otherwise described at the time of collection:
We may disclose personal information to:
If you use your account to engage in a transaction with another user, that user will have access to your transaction information. Users with whom you interact with may store or re-share your information with others, on or off of our Services.
You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You can also manage your preferences within your Roam account. You may continue to receive Services-related and other non-marketing emails.
There are a number of ways to limit online tracking, which we have summarized below:
We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:
To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity.
Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.
Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.
We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.
The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to provide the customer the ability to opt out of certain disclosures of their personal information. In addition, the GLBA prescribes certain safeguards for sensitive data held by financial institutions. You can review our GLBA Privacy Notice at www.sendto.xyz/GLBA.
Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.
You will provide personal information directly to our Services in the United States. We may also transfer personal information to our service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.
Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
This Section only applies to Users and Customers of the Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection. At the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect Roam’s or your, property, rights, or safety, or where we have obtained your consent to do so. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in. Where we rely only on your IP address, we cannot apply the terms of this Section to any User or Customer that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this Section conflict with other terms contained in this Policy, the terms in this Section shall apply to Users and Customers in the Designated Countries.
Roam is a data controller with regard to any personal information collected from Customers or Users of its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.
We describe our lawful bases for processing in Section 6 (“How Is Collected Information Used”) and Section 7 (“Information We Share”) under headings entitled “Designated Countries.” The lawful bases on which we rely to process your personal information include: your consent to the processing; satisfaction of our legal obligations; to protect your vital interests; to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; in the public interest; or for our legitimate interests as described in those sections.
Direct marketing includes any communications we send to you that are only based on advertising or promoting products and services. Transactional communications about your account or our Services are not considered “direct marketing” communications. We will only contact Users or Customers by electronic means based on our legitimate interest or their consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way, please click an unsubscribe link in your emails, or contact us at support@sendto.xyz. You can object to direct marketing at any time and free of charge.
We provide you with the rights described below when you use our Services. Please contact us at support@sendto.xyz if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways: (i) where denial of access is required or authorized by law; (ii) when granting access would have a negative impact on other's privacy; (iii) to protect our rights and properties; and (iv) where the request is frivolous or burdensome.
If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.
You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
You have the right to restrict our processing your personal information where one of the following applies:
We will only process your restricted personal information with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.
You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.
If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.
You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.
If you believe we have infringed or violated your privacy rights, please contact us at support@sendto.xyz so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website, or as otherwise required by law.
Sendto Ltd is the entity responsible for the processing of personal information under this Privacy Policy.
Please direct any questions or comments about this Policy or our privacy practices to Sendto Ltd, support@sendto.xyz, 390 NE 191st St #8024 Miami, FL 33179.