Privacy Policy

This Policy applies to personal data we collect through:

• your registration for and use of an Account;
• your use of the Wallet, Card, and related funding and conversion functions;
• your interactions with our website, support channels, and the Telegram Mini App once available;
• any communications between you and the Company.

This Policy does not apply to third-party websites, applications, or services that we do not control, including the Card Issuing Partner's own platforms, blockchain networks, or Telegram itself, each of which maintains its own privacy practices.

We collect information:

• directly from you, when you register, complete verification, fund your Wallet, or contact support;
• automatically, through cookies, log files, and similar tracking technologies on the Platform;
• from third parties, including identity verification providers, blockchain analytics providers, the Card Issuing Partner, payment networks, and sanctions/watchlist screening providers, for the purpose of compliance and fraud prevention.

We use personal data for the following purposes:

• to create, verify, and administer your Account;
• to comply with KYC, Anti-Money Laundering ("AML"), counter-terrorist financing, and sanctions screening obligations under applicable law;
• to facilitate Wallet funding, Digital Asset conversion, and Card issuance and transaction processing;
• to detect, investigate, and prevent fraud, unauthorized access, and other illicit activity;
• to provide customer support and respond to inquiries;
• to communicate Service updates, security notices, and, where you have consented, marketing communications;
• to improve, secure, and develop the Platform and the Services;
• to comply with legal, regulatory, and law enforcement requests;
• to enforce our Terms of Service and protect the rights, property, and safety of the Company, our users, and third parties.

Where applicable data protection law requires a legal basis for processing, we rely on one or more of the following:

We may share personal data with:

We do not sell personal data to third parties for their independent marketing purposes.

As the Company operates internationally and engages service providers and partners located in various jurisdictions, your personal data may be transferred to, stored in, and processed in countries outside your country of residence, including the British Virgin Islands and other jurisdictions in which our service providers operate. Where required by applicable law, we implement appropriate safeguards, such as standard contractual clauses or equivalent mechanisms, to protect personal data transferred internationally.

Depending on your jurisdiction of residence, you may have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data, subject to our legal and regulatory retention obligations;
• object to or restrict certain processing activities;
• request a copy of your data in a portable format;
• withdraw consent where processing is based on consent, without affecting the lawfulness of processing prior to withdrawal;
• lodge a complaint with a competent data protection authority.

To exercise any of these rights, contact us at support@spender.cc. We will respond within the timeframe required by applicable law. Please note that certain requests, including deletion requests, may be limited by our obligation to retain KYC/AML records.

We may use automated systems, including risk-scoring and fraud-detection tools, to support decisions such as transaction approval, Account verification outcomes, or fraud flagging. Where such automated processing produces a legal or similarly significant effect on you, you have the right to request human review of the decision by contacting support@spender.cc.

The Services are not directed to, and may not be used by, individuals under the age of 18 or the age of legal majority in their jurisdiction. We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a minor, we will take steps to delete such information.

The Platform may contain links to third-party websites or services, and the forthcoming Telegram Mini App operates within the Telegram platform, which maintains its own independent privacy practices. We are not responsible for the privacy practices of third parties, and we encourage you to review their respective privacy policies.

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable law. Material changes will be communicated via the Platform or by email where applicable. The "Last Updated" date at the top of this Policy indicates when it was last revised. Continued use of the Services following any update constitutes acceptance of the revised Policy.