Privacy Policy of SendMN NBFI LLC

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SendMN NBFI LLC (“SendMN,” “we,” “our,” or “us”) is a licensed non-bank financial institution regulated by the Financial Regulatory Commission of Mongolia. We are authorized to provide remittance, loan, foreign exchange, and trust services, and we are the developer and operator of the SendMN mobile application (“App”).

This Privacy Policy explains how we collect, process, share, store, and protect customers’ personal data when they use the SendMN App, our website, loan services, or any related services (collectively, the “Services”).

By accessing or using our Services, customers acknowledge and consent to the collection, processing, use, and disclosure of their personal data in accordance with this Privacy Policy. If a customer does not agree with this Privacy Policy, they should not access or use our Services.

1. Data Controller

SendMN NBFI LLC is responsible for the collection and processing of your personal data.

• Controller: SendMN NBFI LLC

• Registration Number & Address: 6052363, 7^th floor, Central Park tower, Amusement Park street, Chinggis Avenue-17, 1^st khoroo, Sukhbaatar district, Ulaanbaatar, 14240, Mongolia.

• Data Protection Contact: info@send.mn | +976 7000-0909

If you believe that the collection or processing of your personal data violates your rights, you have the right to file a complaint with the National Human Rights Commission of Mongolia.

2. The Data We Collect

Before providing products and services through the SendMN application, we will present you with the terms and conditions of service and the agreement electronically. After you have reviewed these terms and conditions and voluntarily accepted them, we will collect the following information necessary to deliver our products and services:

• Personal Information: Full name, national ID number, date of birth, gender, nationality, residential address, ID card or passport details

• Contact Information: Mobile phone number, email address, residential address

• Government Information Exchange System Data: Identity verification records, social insurance records and other information retrieved through legally authorized government systems.

• Account & Payment Information: Bank account details, card information, transaction history

• Transaction Data: Transaction amount, date, purpose, recipient relationship, frequency, supporting documents

• Recipient Data: Recipient’s full name, contact details, recipient bank, account or wallet number

• Employment & Income Data: Job title, employment verification, social insurance statement

• Financial Data: Credit history, outstanding debts, bank statements, loan repayment records

• Emergency Contact: Name, and phone number of your designated emergency contact person, relationship to the user

• Credit Information Database Records: Data obtained from the Bank of Mongolia or other authorized institutions

• Biometric Data (if applicable): Facial images, video KYC

• Device & Technical Data: IP address, device identifiers (IMEI, MAC), operating system, browser type, geolocation

• Customer Service Data: Complaints, inquiries, chat messages, call recordings

• Marketing & Preferences Data: Survey responses, promotional participation

3. How We Collect Data

We collect your personal data through:

• Direct interactions (registration, KYC verification, transactions, customer support)

• Automatic means (cookies, device information)

• Partner institutions (financial partners providing remittance or loan services)

• Official and third-party sources (government databases, sanctions lists, media sources, public registers)

4. Purpose and Legal Basis of Processing

We may collect, record, process, and share your personal information in accordance with “the Law of Mongolia Civil Code”, “the Law on Deposits, Loans, and Banking Transactions of Banks and Authorized Legal Entities”, “the Law on Combating Money Laundering and Terrorism Financing”, “the Law of Mongolia on Cyber Security”, “the Law on Personal Data Protection”, and other applicable laws and regulations issued thereunder, as well as the rules and requirements of competent regulatory authorities and SendMN’s internal policies and procedures. We process your personal data for the following purposes:

Processing Purposes include:

a. To perform a contract:

• Provide remittance, loan, and payment services

• Process and confirm transactions

• Register and verify new customers

b. To comply with legal obligations:

• AML/CTF compliance, screening, reporting, and record-keeping

c. To protect legitimate interests:

• Detect and prevent fraud and financial crimes

• Ensure information security, risk management, and service improvement

• Verify accuracy of personal data and customer identity

d. To serve customer needs:

• Deliver tailored products and services

• Analyze and resolve customer feedback and complaints

e. For security purposes:

• Protect customer data and company systems against cyber threats

f. With customer consent:

• Biometric verification

• Marketing and survey participation

5. Automated Decision-Making

We use automated systems to monitor and assess risks related to fraud and electronic crime. This may result in delays, restrictions, or cancellations of transactions. If you believe an automated decision has adversely affected your rights, you may submit a complaint to us for review.

6. Age Restrictions

The SendMN App is intended for users aged 18 and above. If data relating to a minor is collected, the account will be closed and the data deleted.

7. Data Retention

We retain your personal data only for as long as necessary under applicable laws and regulations:

• KYC and transaction records: A Minimum of 5 years following the termination of the business relationship (in accordance with AML/CFT legislation)

• Customer service and complaints: Up to 1 year, or longer if required by law

• Fraud investigation records: As long as necessary for prevention and investigation

• Marketing and optional data: Until consent is withdrawn

• Call recordings: Retained for the legally prescribed period

After the retention period, data will be securely deleted or anonymized.

8. Customer Rights

You have the following rights under the Personal Data Protection Law of Mongolia:

• Right to Access: Obtain a copy of your personal and account information via the SendMN App.

• Right to Rectification: Customers have the right to request correction of inaccurate or incomplete information in the SendMN app, and we will take appropriate measures to update or correct such information upon the customer’s request.

• Right to Erasure: Except where otherwise required by law, customers have the right to withdraw their consent for the collection, processing, and use of their personal data, and to request the deletion of their stored personal data in exercising their right to privacy and personal data protection.

• Right to Restrict Processing: Limit how your data is processed in certain circumstances

• Right to Data Portability: Receive your data in a readable format

• Right to Withdraw Consent: Revoke consent at any time (without affecting prior lawful processing).

To exercise your rights, contact us at info@send.mn.

9. Data Sharing and Transfers

We share customer information with partner institutions, regulators, and law enforcement authorities strictly within the scope required by applicable laws and regulations, in order to comply with reporting obligations under Mongolian and international laws, rules, regulations, orders, and resolutions; to support the prevention, detection, and investigation of crimes; and to successfully provide remittance, loan, and other products and services to customers.

• Service providers: payment processors, KYC/AML service providers.

• International payout partners and banks: for processing transactions.

• Regulatory authorities: FRC, FIU, Bank of Mongolia, law enforcement.

• Business transactions: in mergers, acquisitions, or restructuring.

We require all third parties to protect your data in compliance with applicable laws.

10. International Transfers

Because remittance services require foreign processing, your data may be transferred outside Mongolia. We ensure that such transfers comply with Mongolian law and are protected by legal safeguards (contractual clauses, treaties, or your explicit consent).

11. Loan Services Data Usage

When applying for or using loan services, we may collect additional information (employment, income, credit history). This data is used for creditworthiness assessment, regulatory compliance, reporting to the Credit Information Bureau, and loan servicing and collections. Loan-related data is retained for at least 5 years after the loan relationship ends.

12. Data Security

We implement technical and organizational measures to protect your data, including:

• Encryption of data at rest and in transit

• Multi-factor authentication for account access

• Logging and monitoring of access

• Incident response measures for data breaches

“SendMN NBFI” LLC shall not be liable for any loss or damage arising from the customer’s own fault or negligence resulting in the disclosure or unauthorized use of their access credentials. “SendMN NBFI” LLC cannot access information using the customer’s access credentials.

13. Breach Notification

If your personal data is compromised due to a cyberattack, human error by authorized personnel, or damage to software or a database, we will promptly notify you through your registered email address or mobile phone number and provide guidance on the steps to protect your information.

14. Marketing and Communication

We may send you mandatory service communications (e.g., transaction notifications, security alerts). Marketing messages will only be sent with your consent, and you may opt out at any time through the App settings, email links, or by contacting us directly.

15. Third-Party Links

Our Services may contain links to partner websites or applications. Their privacy policies apply independently, and we are not responsible for their practices.

16. Changes to this Policy

We may update this Policy from time to time. Significant changes will be communicated via the App, website, or email. Updates take effect upon publication.

17. Translation

This Policy is published in Mongolian, English, Chinese, Vietnamese, and Hindi. In the event of any inconsistency between translations, the Mongolian version shall prevail.

18. Contact Information

If you have any questions or concerns about this Privacy Policy, please contact:

SendMN NBFI LLC

Email: info@send.mn

Phone: +976 7000-0909

Address: 7th Floor, Central Park Tower, Chinggis Avenue-17, Sukhbaatar District, Ulaanbaatar, Mongolia