Privacy Policy

1. Information We Collect

At GlobiSend, we collect information you provide directly to us, including:

• Personal Information: Name, email address, phone number, date of birth, and address
• Financial Information: Bank account details, payment method information, transaction history
• Identification Documents: Government-issued IDs, passport, or other verification documents
• Recipient Information: Details of individuals or businesses you send money to
• Device Information: IP address, browser type, device type, and operating system

Location Data: Our app collects the following types of location data: precise GPS location (fine location via Android permission ACCESS_FINE_LOCATION), approximate location (coarse location via Android permission ACCESS_COARSE_LOCATION), and IP-based geolocation (approximate location derived from your IP address). We collect this data to power map features, delivery tracking, transaction verification, service area detection, and location-based services within the app. The app requests location access at runtime on your device only when you use features that need it and also enables WebView geolocation, which allows web content within the app to access your device's location. You may disable location access at any time through your device settings, though certain features may not function properly without it.

2. How We Use Your Information

We use the information we collect to:

• Process and complete your money transfers
• Verify your identity and prevent fraud
• Provide customer support and respond to your inquiries
• Improve our services and develop new features
• Send you transaction confirmations and account notifications
• Comply with legal and regulatory requirements
• Protect against unauthorized transactions and fraudulent activity

3. Location Data

GlobiSend collects and uses your location data. Below is a detailed description of the types of location data we collect, how we collect it, and why we use it.

Types of location data we collect:

• Fine location (GPS): Your precise device location accessed via the Android permission ACCESS_FINE_LOCATION. This is used for map display and delivery tracking.
• Coarse location: Approximate location derived from Wi-Fi networks, cell towers, IP address, and the Android permission ACCESS_COARSE_LOCATION.
• Background location: Location data collected while the app is running in the background, accessed via the Android permission ACCESS_BACKGROUND_LOCATION. This is used for ongoing delivery tracking and service continuity.
• IP-based geolocation: Approximate location derived from your IP address, used for detecting your country and regional service availability.

How we collect location data:

• The Android app requests location permissions (ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION, ACCESS_BACKGROUND_LOCATION) at runtime when you first use the app.
• The app's WebView is configured to allow web content to access your device's location via the browser's Geolocation API.
• Our server-side Google Maps integration uses your IP address to detect your approximate country for service area purposes.
• We use the geolocator and permission_handler Flutter plugins to manage location permissions on your device.

Why we collect location data:

• Map and Delivery Features: To display your current location on maps and track delivery status in real time
• Service Area Detection: To determine which countries and regions are available for sending and receiving money
• Transaction Verification: To help verify transactions and detect fraudulent activity based on location patterns
• Background Location: To maintain service continuity and enable ongoing delivery tracking when the app is running in the background
• IP-based Geolocation: To detect your country and provide relevant service area information

Your control: You can revoke location access at any time by adjusting your device's location permissions in Settings. If you disable location access, certain features of the app may not function properly. You can also disable background location access separately in your device settings. To revoke WebView geolocation access, you can clear app data or revoke permissions through your device's Settings app.

4. Information Sharing

We may share your information with:

• Financial Institutions: Banks and payment processors to complete transactions
• Regulatory Authorities: When required by law or regulation
• Service Providers: Third-party companies that help us operate our business
• Law Enforcement: When required to prevent fraud or comply with legal requests
• Business Partners: With your consent for specific services

We never sell your personal information to third parties for marketing purposes.

5. Data Security

We implement industry-standard security measures to protect your information:

• 256-bit SSL encryption for all data transmissions
• Multi-factor authentication for account access
• Regular security audits and vulnerability assessments
• Secure data storage with access controls
• Continuous monitoring for suspicious activity

6. Your Rights

You have the right to:

• Access your personal information
• Correct inaccurate information
• Delete your account and personal data
• Opt-out of marketing communications
• Request a copy of your data
• Object to processing of your personal data

7. Cookies and Tracking

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve our services and user experience
• Provide personalized content and recommendations

You can manage cookie preferences through your browser settings.

8. Children's Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete such information.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and sending you an email notification.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at:

• Email: privacy@globisend.com
• Phone: +1 (555) 123-4567
• Address: 123 Business Avenue, New York, NY 10001

1. Acceptance of Terms

By accessing and using GlobiSend's services, you agree to be bound by these Terms of Service. If you do not agree to these terms, please do not use our services.

2. Eligibility

To use our services, you must:

• Be at least 18 years of age
• Have the legal capacity to enter into a binding agreement
• Not be prohibited from using our services under applicable laws
• Provide accurate and complete information during registration

3. Account Registration

You are responsible for:

• Maintaining the confidentiality of your account credentials
• All activities that occur under your account
• Notifying us immediately of any unauthorized access
• Providing accurate and up-to-date information

4. Money Transfer Services

Our money transfer services include:

• Bank Transfers: Direct transfers to bank accounts worldwide
• Mobile Money: Transfers to mobile money wallets
• Exchange Services: Currency conversion at competitive rates
• Transaction Tracking: Real-time status updates

Transfer times and availability vary by destination country and payment method.

5. Fees and Exchange Rates

Transaction Fees: We charge transparent fees for each transfer. Fee structures vary by:

• Transfer amount
• Destination country
• Payment method
• Transfer speed

Exchange Rates: We apply a markup to the mid-market exchange rate. The applied rate will be displayed before you confirm your transfer.

6. Prohibited Activities

You agree not to use our services to:

• Transfer funds for illegal activities
• Violate any applicable laws or regulations
• Engage in money laundering or terrorist financing
• Defraud or deceive GlobiSend or any third party
• Use false or misleading information
• Interfere with the operation of our services
• Attempt to gain unauthorized access to our systems

7. Transaction Limits

We may impose limits on:

• Daily, weekly, and monthly transfer amounts
• Number of transactions per period
• Destination countries
• Payment methods

These limits are in place for security and regulatory compliance. Higher limits may be available upon verification.

8. Refund Policy

Refund Eligibility: Refunds may be available if:

• The transfer was not completed successfully
• The recipient information was incorrect
• The transfer was made fraudulently
• There was a system error on our end

Refund Process: Refund requests must be submitted within 30 days of the transaction. Processing time varies by payment method.

Non-Refundable: Fees and exchange rate differences are not refundable.

9. Compliance and Verification

We may require additional documentation to:

• Verify your identity
• Confirm the source of funds
• Comply with anti-money laundering regulations
• Meet international sanctions requirements

Failure to provide requested information may result in transaction delays or cancellation.

10. Disclaimer of Warranties

Our services are provided "as is" without warranties of any kind, either express or implied. We do not guarantee:

• Uninterrupted or error-free service
• Specific transfer times
• Exchange rates or fees
• Compatibility with all devices or browsers

11. Limitation of Liability

To the maximum extent permitted by law, GlobiSend shall not be liable for:

• Indirect, incidental, or consequential damages
• Loss of profits or data
• Delays caused by third parties
• Actions beyond our reasonable control

Our total liability shall not exceed the amount of the specific transaction in question.

12. Indemnification

You agree to indemnify and hold harmless GlobiSend from any claims arising from:

• Your use of our services
• Your violation of these Terms
• Your violation of any third-party rights
• Any fraudulent activity involving your account

13. Account Termination

We reserve the right to suspend or terminate your account if:

• You violate these Terms of Service
• We suspect fraudulent activity
• Required by law or regulation
• Your account remains inactive for an extended period

14. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the State of New York, United States. Any disputes shall be resolved in the courts of New York.

15. Changes to Terms

We may modify these Terms at any time. Continued use of our services after changes constitutes acceptance of the new Terms. We will notify you of material changes via email and website notification.

16. Contact Information

For questions about these Terms of Service, please contact:

• Email: legal@globisend.com
• Phone: +1 (555) 123-4567
• Address: 123 Business Avenue, New York, NY 10001

1. Community Guidelines

GlobiSend is a financial platform built on trust. All users must follow these rules. Violations may result in account restrictions or termination.

• Respectful Behavior: Treat other users, support staff, and partners with respect. Harassment, threats, or abuse of any kind is prohibited.
• Content Standards: Do not upload misleading profile information, fake documents, or fraudulent transaction records.
• Integrity: Do not create fake accounts, manipulate transfer records, or engage in any activity that undermines platform trust.

2. Copyright & DMCA Policy

GlobiSend respects intellectual property rights. Uploading or using content you do not own without permission is prohibited and may result in account termination.

• When a valid DMCA takedown notice is received, infringing content is removed and a copyright strike is issued.
• Accounts receiving multiple copyright strikes may be terminated.
• If you believe your work has been used without authorization, submit a DMCA notice with details to our legal team.
• If content was removed by mistake, you may submit a counter-notification for review.

3. Fraud & Financial Integrity Policy

GlobiSend has zero tolerance for fraud. Any attempt to deceive the platform, other users, or financial institutions is strictly prohibited and will result in immediate account termination, forfeiture of funds, and legal action.

• Identity Fraud: Using fake identities, stolen IDs, or impersonating others to create accounts is prohibited.
• Transaction Fraud: Initiating transfers with stolen payment methods, chargeback abuse, or reversing legitimate transactions is prohibited.
• Money Laundering: Structuring transactions to evade reporting requirements, mixing funds from illegal sources, or layering transactions is strictly prohibited and will be reported to financial authorities.
• Referral & Promo Fraud: Creating multiple accounts to exploit referral bonuses, promo codes, or new-user incentives is prohibited.
• Document Fraud: Submitting forged, altered, or fraudulent identification or financial documents is prohibited.
• Reporting Fraud: If you suspect fraudulent activity, report it immediately through our support channels.

4. Harassment & Cyberbullying Policy

GlobiSend does not tolerate harassment, bullying, or targeted abuse directed at any user, employee, or partner.

• Targeted personal attacks, insults, or threats directed at any individual or group.
• Doxxing — publishing private identifying information without consent.
• Encouraging others to harass or attack a specific person.
• Repeated unwanted contact, stalking, or coordinated harassment campaigns.
• Serious or repeated harassment leads to permanent account suspension and may be reported to law enforcement.

5. Hate Speech Policy

GlobiSend prohibits content that promotes or incites hatred, discrimination, or violence based on protected characteristics.

• Race, ethnicity, nationality, or immigration status.
• Religion or religious belief.
• Gender, gender identity, or gender expression.
• Sexual orientation or romantic orientation.
• Age, disability, or serious medical condition.
• Using slurs, stereotypes, or dehumanizing language targeting protected groups is prohibited.
• Promoting hate groups, supremacist ideologies, or hateful conspiracy theories is prohibited.

6. Child Safety Policy

GlobiSend has zero tolerance for content that endangers minors. Any content depicting child sexual abuse material (CSAM) or exploitation is strictly prohibited and will be reported to the National Center for Missing & Exploited Children (NCMEC) and law enforcement.

• Any sexually suggestive, exploitative, or abusive content featuring minors is prohibited.
• Users must be at least 18 years old to create an account and use services.
• If you encounter content involving child exploitation, report it immediately. Do not share or engage with the content.

7. Spam & Deceptive Practices Policy

GlobiSend prohibits spam, scams, and deceptive practices that mislead users or manipulate platform systems.

• Posting repetitive, irrelevant, or unsolicited messages or communications.
• Using deceptive subject lines or sender information in communications.
• Promoting fake services, pyramid schemes, investment scams, or fraudulent offers.
• Distributing malware, phishing links, or harmful software through any platform channel.
• Creating multiple accounts to evade restrictions or manipulate platform features.

8. Impersonation Policy

Impersonating another person, financial institution, or organization on GlobiSend is prohibited. Accounts that mislead users by pretending to be someone else will be suspended or permanently removed.

• Using another person's name, image, or credentials to create a misleading account.
• Pretending to be a GlobiSend employee, agent, or representative.
• Creating accounts that impersonate banks, money transfer operators, or regulatory bodies.
• Impersonation for fraud, harassment, or deception results in immediate termination and legal action.

9. Enforcement & Termination Policy

GlobiSend enforces these policies through a graduated system of actions, from content removal to permanent account termination and referral to law enforcement.

• Content removal: Violating content or communications are removed.
• Warnings: Policy violations may result in account warnings.
• Feature restrictions: Accounts may lose access to transfers, withdrawals, or other features.
• Temporary suspension: Accounts may be temporarily suspended during investigation of serious violations.
• Permanent termination: Accounts are permanently terminated for fraud, illegal activity, money laundering, or repeated policy violations.
• Funds forfeiture: Funds associated with fraudulent or illegal activity may be frozen or forfeited as required by law.
• Reporting to authorities: GlobiSend cooperates with financial regulators and law enforcement. Violations of anti-money laundering (AML) and know-your-customer (KYC) regulations may result in criminal referral.
• Appeals: If you believe an action was taken in error, submit an appeal through our support channels.

10. Data Retention & Deletion

GlobiSend retains your personal information for as long as your account is active or as needed to provide services and comply with legal obligations. Financial transaction records are retained for a minimum of 5 years (or longer where required by local law) to meet anti-money laundering and tax reporting requirements. You may request account deletion through your profile settings or by contacting support. Some data may be retained after deletion if required by law or for legitimate fraud prevention purposes.

11. Cookie Policy

GlobiSend uses cookies and similar tracking technologies to operate, improve, and personalise the Service.

• Essential Cookies: Required for basic platform functionality such as authentication, session management, and payment processing.
• Preference Cookies: Remember your settings such as language, region, and display preferences.
• Analytics Cookies: Help us understand how users interact with the Service so we can improve the experience.
• Marketing Cookies: Track browsing behaviour to deliver relevant advertisements and measure campaign effectiveness.

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies.

12. Advertising Policy

GlobiSend may display advertisements and promotional content within the Service. All advertisements must comply with applicable laws and these policies.

• Advertisements must be truthful, accurate, and not misleading.
• Ads must not contain offensive, discriminatory, or harmful content.
• Ads must not infringe on the intellectual property rights of others.
• Advertisers are responsible for ensuring their content complies with all applicable laws.

13. Accessibility

GlobiSend is committed to making the Service accessible to all users, including those with disabilities.

• We strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards.
• We regularly audit the Service for accessibility barriers and work to remediate issues promptly.
• We provide alternative text for images, keyboard navigation support, and screen reader compatibility.

If you encounter any accessibility barriers, please contact us at accessibility@globisend.com.

14. Children's Privacy

GlobiSend is committed to protecting the privacy of children and complying with applicable laws such as the Children's Online Privacy Protection Act (COPPA).

• The Service is not intended for users under the age of 18.
• We do not knowingly collect personal information from children under 18.
• If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly.

15. International Data Transfers

GlobiSend is a global platform and your data may be transferred and processed across borders.

• Your data may be transferred to and processed in countries other than your country of residence.
• We ensure that appropriate safeguards are in place for international data transfers, including standard contractual clauses.
• We comply with applicable data protection laws in each jurisdiction where we operate.

16. Account Security

Protecting your account is a shared responsibility between GlobiSend and you.

• Your Responsibilities: Maintain the confidentiality of your account credentials. Do not share your account with any third party. Notify us immediately of any unauthorised access or security breach.
• Our Responsibilities: We implement industry-standard encryption (TLS) for all data in transit. We use secure hashing for password storage. We monitor for suspicious account activity and may require additional verification.

17. Service Availability

GlobiSend strives to provide reliable and uninterrupted access to the Service, but we cannot guarantee 100% uptime.

• We aim for high availability but acknowledge that occasional interruptions may occur due to maintenance, technical issues, or force majeure events.
• We may schedule maintenance windows during off-peak hours and will endeavour to minimise disruption.
• We reserve the right to modify, suspend, or discontinue any feature or service on the Service at any time.

18. Refund Policy

GlobiSend handles refund requests on a case-by-case basis.

• Refund requests must be submitted within 30 days of the transaction date.
• Refunds are processed on a case-by-case basis and may require documentation.
• Refunds are returned to the original payment method.
• Fees and exchange rate differences are not refundable unless otherwise required by law.

19. Subscription & Billing

GlobiSend may offer subscription plans for premium services.

• All subscription fees are billed in advance on a recurring basis.
• Payment is processed securely through our payment processors.
• You will receive a payment receipt by email for each successful transaction.
• You may cancel your subscription at any time through your account settings.
• Cancellation takes effect at the end of the current billing period.

20. Intellectual Property

GlobiSend's intellectual property and the intellectual property of third parties are protected by law.

• All GlobiSend branding, software, and original content are owned by or licensed to GlobiSend.
• You may not reproduce, modify, or distribute any part of the Service without prior written consent.
• Users are responsible for ensuring they have the necessary rights to any content they upload, post, or share.

1. Money Transfer Services

GlobiSend provides international money transfer services that allow you to send funds to recipients in supported countries. Our services include:

• Bank Transfers: Direct deposits to recipient bank accounts worldwide.
• Mobile Money: Transfers to mobile money wallets in supported markets.
• Cash Pickup: Transfers that recipients can collect in cash at participating agent locations.
• Wallet-to-Wallet Transfers: Transfers between GlobiSend user accounts.
• Currency Exchange: Conversion of funds at our displayed exchange rate.

Transfer times vary by destination country, payment method, and the recipient's receiving option. Estimated delivery times are displayed before you confirm your transfer but are not guaranteed.

2. Transfer Execution & Delivery

When you confirm a transfer, you authorize GlobiSend to debit your chosen payment method and pay out the transfer amount to the recipient through the selected delivery method.

• Transfers are processed in the order received, subject to verification checks and system availability.
• Delivery times begin once funds are successfully collected from your payment method and the transfer passes our verification checks.
• Bank transfers may take 1–5 business days depending on the destination bank and country.
• Mobile money and cash pickup transfers are generally faster but still depend on the receiving network.
• Weekends, public holidays, and banking holidays may affect delivery times.

3. Transfer Limits

GlobiSend may impose limits on transfers to comply with regulatory requirements and to manage risk. Limits apply at different levels:

• Per-Transaction Limits: Maximum amount for a single transfer.
• Daily Limits: Maximum aggregate amount you can send in a single day.
• Monthly Limits: Maximum aggregate amount you can send in a calendar month.
• Annual Limits: Maximum aggregate amount you can send in a calendar year.
• Rolling Limits: Limits calculated over a rolling 12-month period for regulatory reporting.

Higher limits may become available after you complete enhanced identity verification and provide additional documentation. We reserve the right to adjust limits at any time and to refuse or hold transactions that exceed applicable limits.

4. Fees & Exchange Rates

Transfer Fees: GlobiSend charges a transfer fee for each transaction. The fee is shown clearly before you confirm your transfer and depends on:

• The transfer amount.
• The destination country and delivery method.
• Your chosen payment method.
• The transfer speed (standard vs. express).

Exchange Rates: For transfers involving a currency conversion, we apply a rate that includes a margin above the mid-market rate. The exact rate is locked and displayed before you confirm your transfer. Once you confirm, the rate is guaranteed for that transaction and will not change.

5. Payment Methods

We accept the following payment methods for sending money, subject to availability in your country:

• Debit and credit cards (Visa, Mastercard, American Express).
• Bank account debits (ACH) in supported regions.
• Bank transfers / wire transfers.
• Mobile money and digital wallets.
• Cash payments at participating agent locations (where available).

When you use a payment method, you must be authorized to use it. Charges may be declined or returned by your card issuer or bank for reasons beyond our control.

6. Recipient Requirements

You are responsible for providing accurate recipient information, including:

• Bank transfers: full name, bank name, account number, routing / SWIFT / IBAN details, and any required reference.
• Mobile money: recipient's mobile number registered with the mobile money provider and correct operator.
• Cash pickup: recipient's full name as shown on a valid government-issued ID, and the pickup location.

Incorrect recipient details may cause delays, failed delivery, or the recipient being unable to collect the funds. GlobiSend is not responsible for delays caused by inaccurate information you provide. If a transfer is returned because of incorrect details, refunds will be subject to our Refund Policy and any fees incurred.

7. Cancellation of Transfers

You may cancel a transfer only under the following conditions:

• Before Funds Are Collected: You may cancel at no cost if funds have not yet been debited from your payment method.
• Before Delivery: You may request a cancellation if the transfer has not yet been paid out to the recipient. Depending on the delivery method and destination, cancellation may be possible up to the point the recipient receives the funds. Cancellation fees may apply.
• After Delivery: Once the recipient receives the funds (e.g., deposit confirmed, mobile money credited, or cash collected), the transfer cannot be cancelled. You must contact support to discuss recovery.

Once you request a cancellation, any refund will be issued to your original payment method and may take up to 10 business days to appear, depending on your bank or card issuer.

8. Refund Policy

When you may receive a refund:

• The transfer was not completed and funds were never paid out.
• The transfer was cancelled under the conditions described above.
• The transfer could not be delivered to the recipient (e.g., invalid account, closed account, or recipient unable to collect) and was returned to us.
• The transfer was unauthorized or the result of a fraudulent transaction.
• There was an error on our part.

Refund process:

• Refund requests must be submitted within 90 days of the transfer date.
• Refunds are issued to the original payment method where possible.
• Processing times vary by payment method (typically 3–10 business days).

Non-refundable amounts: Transfer fees and exchange-rate margins are generally not refundable unless the transfer was never executed or the error was ours. If a transfer is returned after payout, any fees charged by intermediary banks or providers will be deducted from the refund.

9. Failed & Returned Transfers

Transfers may fail or be returned for reasons including:

• Incorrect, incomplete, or invalid recipient details.
• Recipient bank or mobile money account closed, blocked, or restricted.
• Recipient unable or unwilling to provide required identification for cash pickup.
• Restrictions in the destination country or payment network.
• Fraud or compliance flags on the transaction.

If a transfer fails, we will notify you, return the funds (less any non-refundable costs), and record the status in your transaction history. You may correct the recipient details and initiate a new transfer.

10. Error Resolution Policy

If you believe there is an error in a transfer, such as an incorrect amount, an unauthorized transfer, or a transfer to the wrong recipient, contact us immediately:

• Notify us as soon as possible, but no later than 60 days after the suspected error.
• Provide your name, account details, the transfer reference, and a description of the error.
• We will investigate and respond within 10 business days, or notify you in writing if we need additional time (up to 45 days).
• If we find an error, we will correct it promptly and refund any amounts wrongly taken, plus interest where required by law.
• If we find no error, we will provide a written explanation.

11. Unclaimed Funds

If a transfer is successfully delivered but the recipient does not collect the funds (for example, a cash pickup or mobile money transfer that expires unclaimed), the funds will be held for a period and then:

• Returned to the sender, minus any applicable fees, where permitted by law; or
• Transferred to the appropriate government unclaimed-property or escheatment authority if the sender cannot be located and the period required by law elapses.

Unclaimed funds are handled in accordance with applicable escheatment laws in the jurisdictions where we operate.

12. Transfer Status & Notifications

GlobiSend provides the following status stages for every transfer:

• Pending: Transfer created and awaiting payment confirmation or verification.
• Processing: Funds collected and transfer being processed for payout.
• In Transit: Funds sent to the destination network or bank.
• Completed: Recipient has received the funds.
• Failed / Returned: Transfer could not be delivered and is being refunded.

You will receive email or SMS notifications at key stages, and you can view full status in your transaction history.

13. Fraud & Scam Protection

GlobiSend takes fraud prevention seriously. To protect yourself:

• Only send money to people you know and trust. Never send money to someone who claims you won a prize, a sweepstakes, or a lottery.
• Never send money to pay taxes, fees, bail, or security deposits for someone you met online.
• Be cautious of emergency requests that require immediate payment, especially by text or email.
• Never share your account password, OTP, or verification codes with anyone, including people claiming to be GlobiSend staff.
• GlobiSend will never ask you to send money to "test" or "verify" your account.

If you believe you are the victim of fraud, contact us immediately. While we cannot always recover funds sent fraudulently, reporting promptly improves the chance of recovery and helps us prevent further harm.

14. Disputes & Complaints

If you have a complaint about a transfer, please contact our customer support team:

• Submit your complaint through the in-app help center or by email at support@globisend.com.
• Provide your transfer reference, the date and amount, and a description of the issue.
• We will acknowledge your complaint within 3 business days and aim to resolve it within 15 business days.
• If we need more time, we will keep you informed and provide a final response within 35 business days.
• If you remain unsatisfied, you may escalate to the applicable financial ombudsman or regulatory authority in your jurisdiction.

15. Prohibited Uses of Transfer Services

You may not use GlobiSend to send money that involves, relates to, or funds any of the following:

• Illegal activity, including fraud, scams, or the purchase of illegal goods or services.
• Money laundering, terrorist financing, or evasion of sanctions or reporting requirements.
• Gambling or betting where not legally permitted.
• Weapons, ammunition, firearms, or explosives.
• Drugs, drug paraphernalia, or controlled substances.
• Transactions on behalf of third parties not disclosed to us.
• Structuring transfers to avoid transaction reporting thresholds.

Transfers suspected of a prohibited use will be blocked, and the account may be suspended and reported to the authorities as required by law.

16. Force Majeure

GlobiSend is not liable for delays or failures caused by events beyond our reasonable control, including natural disasters, power or network failures, banking system outages, acts of government, war, civil unrest, terrorism, or public health emergencies. Where an event prevents us from completing a transfer, we will make reasonable efforts to complete it once the event ends, or refund the transfer where delivery is no longer possible.

1. Anti-Money Laundering (AML) Policy

GlobiSend maintains a robust Anti-Money Laundering program designed to detect, prevent, and report money laundering and terrorist financing activity, in line with the Financial Action Task Force (FATF) recommendations and the laws of the jurisdictions where we operate.

• Risk-Based Approach: We assess the money-laundering and terrorist-financing risk of every customer and transaction and apply controls proportional to that risk.
• Customer Due Diligence (CDD): We verify the identity of our customers before allowing them to send money, and we apply enhanced due diligence where risk is higher.
• Transaction Monitoring: We monitor transactions for suspicious patterns, including structuring, rapid transfers, and unusual activity.
• Suspicious Activity Reporting: We file suspicious activity reports (SARs) with the relevant financial intelligence units where required by law.
• Record Keeping: We retain transaction and identity records for the periods required by law, typically at least 5 years.
• AML Compliance Officer: A designated AML Compliance Officer oversees our program, trains staff, and acts as the point of contact for regulators.

2. Know Your Customer (KYC) & Identity Verification

To use GlobiSend, you must complete identity verification. This is required by law and helps prevent fraud, money laundering, and identity theft.

• What we collect: Name, date of birth, address, government-issued ID (passport, national ID, or driver's license), and in some cases proof of address and proof of source of funds.
• How we verify: We may verify your identity against public and private databases, check ID documents for authenticity, and perform live liveness checks (e.g., a selfie match).
• Enhanced Due Diligence: For higher-risk customers or higher-value transactions, we may request additional information about the purpose of the transfer and the source of funds.
• Consequences of failure: If you do not complete verification or refuse to provide requested information, transfers may be delayed, blocked, or your account may be restricted or closed.

3. Sanctions Compliance

GlobiSend complies with economic sanctions programs administered by the United Nations, the U.S. Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom, and other applicable authorities.

• Screening: All customers, recipients, and transactions are screened against applicable sanctions lists and watchlists.
• Prohibited parties: We do not provide services to individuals or entities on sanctions lists, or to transactions that would benefit sanctioned persons.
• Restricted jurisdictions: We do not process transfers to or from countries subject to comprehensive sanctions embargoes.
• Matched hits: Where a match is identified, the transaction is blocked and may be reported to the relevant authority.

4. Politically Exposed Persons (PEPs)

Politically Exposed Persons — individuals who hold prominent public positions, their family members, and close associates — are subject to enhanced scrutiny because of the higher risk of corruption and money laundering they may present.

• We screen customers and beneficial owners against PEP databases.
• Where a PEP relationship is identified, we apply enhanced due diligence, including source-of-funds review.
• Transactions involving PEPs may require additional approval and documentation.

5. Counter-Terrorist Financing (CTF)

GlobiSend prohibits the use of its services to finance terrorism in any form. We implement controls to identify and block transactions that may be linked to terrorism, including:

• Screening all parties against terrorist designations and sanctions lists.
• Monitoring for indicators of terrorist financing, such as small, repetitive transfers to high-risk regions.
• Reporting suspected terrorist financing to the appropriate financial intelligence units.

6. Record Keeping & Reporting

In accordance with regulatory requirements, we keep detailed records of:

• Customer identity and verification data.
• Transaction details, including amount, currency, date, destination, and payment method.
• Correspondence relating to compliance reviews and due diligence.

These records are retained for at least 5 years after the last transaction (or longer where required) and are made available to regulators on request. We file legally required reports, including currency transaction reports and suspicious activity reports, without informing the customer where prohibited by law.

7. Data Protection & GDPR

GlobiSend complies with applicable data protection laws, including the General Data Protection Regulation (GDPR) for users in the European Economic Area and the UK GDPR. Key points:

• Lawful basis: We process personal data to perform our contract with you, to comply with legal obligations (including AML/KYC), and based on our legitimate interests (such as fraud prevention), and with your consent where required.
• Your rights: You may access, rectify, erase, restrict, or port your personal data, and object to certain processing. To exercise these rights, contact privacy@globisend.com.
• Data Protection Officer: For data protection matters, contact our DPO at dpo@globisend.com.
• Retention: Compliance data (e.g., KYC and transaction records) is retained for legal and regulatory reasons even after you close your account.
• Transfers: Where personal data is transferred internationally, we rely on appropriate safeguards such as Standard Contractual Clauses.

8. Consumer Protection

We are committed to treating customers fairly and complying with consumer protection laws, including the U.S. Consumer Financial Protection Bureau (CFPB) rules that apply to remittance transfers (Regulation E / the Remittance Rule).

• Disclosures: You receive a written disclosure before payment showing the transfer amount, fees, exchange rate, and the exact amount the recipient will receive.
• Cancellation rights: In certain circumstances, you may cancel a transfer within the timeframes required by law (e.g., 30 minutes of payment for U.S. remittance transfers) without penalty.
• Error resolution: You have the right to dispute errors as described in the Error Resolution Policy, with required investigation and response timeframes.
• No unfair practices: We do not engage in unfair, deceptive, or abusive acts or practices.

9. Licensing & Regulatory Disclosure

GlobiSend operates as a licensed money transmitter / money service business in the jurisdictions where required. Copies of our licenses are available on request.

• Customers may direct questions or complaints to our primary regulator(s) using the contact details provided in our disclosures.
• Licensing information is displayed in our app and website footer where applicable.
• We are not a bank, and funds transferred through GlobiSend are not FDIC-insured deposits.
• Held funds awaiting payout are safeguarded in accordance with applicable money transmitter laws.

10. Safeguarding of Customer Funds

Money collected for transfers is held separately from our operating funds and safeguarded in accordance with applicable regulations:

• Customer funds are held in safeguarded accounts and are not used for our own operating purposes.
• In the event of insolvency, safeguarded customer funds remain available to customers, subject to applicable law.
• Funds are paid out to recipients or refunded to senders in accordance with the applicable Money Transfer Policies.

11. Regulatory Cooperation

We cooperate fully with regulators and law enforcement agencies, including by:

• Responding to lawful requests for information.
• Placing holds on transactions or freezing funds where required.
• Providing access to records and personnel during examinations.
• Promptly reporting suspicious activity and other legally required events.

12. Report a Concern

If you have a compliance concern or suspect that GlobiSend or its services are being misused, please report it confidentially:

• Email:compliance@globisend.com
• Phone: +1 (555) 123-4567
• In-app: Use the "Report" option in your transaction history.

Reports are reviewed by our Compliance team, and whistleblowers are protected from retaliation where required by law. You may also report directly to the relevant regulator in your jurisdiction.

1. Account Security

Protecting your account is a shared responsibility between GlobiSend and you. Both parties play an important role in keeping your funds and data safe.

• Your responsibilities: Keep your login credentials confidential. Never share your password, one-time passcodes (OTPs), or verification codes with anyone. Use a strong, unique password for your GlobiSend account and enable two-factor authentication (2FA).
• Our responsibilities: We implement industry-standard encryption (TLS 1.2+) for all data in transit, secure hashing for password storage, automated suspicious-activity monitoring, and session management to protect your account.
• Two-factor authentication: We strongly recommend enabling 2FA. When enabled, logging in or completing sensitive actions requires a second verification step in addition to your password.
• Unauthorized access: If you suspect that your account has been accessed without authorization, notify us immediately. We will help you secure your account and may place a hold on your account during our investigation to protect your funds.

2. Password Policy

• Passwords must meet minimum length and complexity requirements.
• We never store passwords in plain text. They are stored using a strong one-way hashing algorithm.
• You should not reuse passwords used on other websites or services.
• If you forget your password, you can reset it using the secure reset flow, which verifies your identity before allowing a change.
• For your protection, we may require a password reset or additional verification if we detect suspicious activity.

3. Two-Factor Authentication (2FA)

GlobiSend supports two-factor authentication to add an extra layer of security to your account. You may set up 2FA using:

• An authenticator app (e.g., Google Authenticator) that generates time-based one-time passcodes.
• One-time passcodes sent by SMS or email.

When 2FA is enabled, you will be asked to enter your verification code when logging in from a new device or when performing sensitive actions such as changing your password, updating your payout details, or sending money to a new recipient.

4. Phishing & Social Engineering Protection

Scammers may attempt to trick you into revealing your credentials, OTPs, or personal information. Be aware that:

• GlobiSend will never ask you for your password, OTP, or full card details by email, phone, or SMS.
• GlobiSend will never ask you to send money to "test", "verify", or "unlock" your account.
• Always verify that you are on the official GlobiSend website or app before entering your credentials.
• Check the sender address of any email claiming to be from GlobiSend. Official emails come only from our verified domains.
• If you receive a suspicious message, do not click links or download attachments. Report it to security@globisend.com.

5. Device Management

You can view and manage the devices that are logged into your account in your security settings. This includes:

• Viewing the list of devices and their last activity.
• Removing devices you no longer recognize or use.
• Logging out of all devices remotely if you believe your account has been compromised.

6. Session & Access Controls

• Sessions automatically expire after a period of inactivity.
• We monitor login activity for unusual patterns, such as logins from new locations or devices.
• We may require additional identity verification before completing high-risk actions, such as large transfers or changing payout details.
• After certain sensitive changes, we may temporarily restrict transfers to allow you time to review the change.

7. Fraud Monitoring & Transaction Review

We use a combination of automated systems and trained staff to detect and prevent fraud. This includes:

• Real-time screening: Transactions are screened against fraud rules, sanctions lists, and risk indicators before processing.
• Behavioral analytics: We analyze patterns of behavior that may indicate fraud, such as rapid transfers, unusual beneficiary changes, or account takeovers.
• Verification checks: We may request additional confirmation for transfers to new recipients or to high-risk destinations.
• Account holds: We may place a temporary hold on an account or transaction while we investigate suspected fraud. We will notify you and work to resolve holds as quickly as possible.

8. Data Breach Notification

In the unlikely event of a data breach that may affect your personal information:

• We will notify you without undue delay where required by law.
• We will promptly investigate the breach, contain it, and take steps to prevent recurrence.
• We will notify the relevant data protection authorities in accordance with applicable regulations.
• We will provide guidance on steps you can take to protect yourself.

9. Reporting Security Issues

If you discover a security vulnerability or have a security concern, please report it to our security team:

• Email:security@globisend.com
• Responsible disclosure: We welcome responsible disclosure of vulnerabilities and will acknowledge valid reports. Please do not exploit vulnerabilities or access data beyond what is necessary to demonstrate the issue.
• Immediate threats: If you believe a transaction is unauthorized or your account is actively compromised, contact customer support immediately so we can act quickly.

1. Business Accounts

GlobiSend offers business accounts that allow companies, freelancers, and organizations to send international payments, run payroll, and manage payments to suppliers and partners. Business accounts are subject to the same core Terms of Service and Money Transfer Policies, plus the additional terms in this section.

• Business accounts must be registered with accurate legal entity details.
• Business accounts undergo enhanced verification, including company registration documents and beneficial ownership information.
• Authorized users of a business account are considered representatives of the business and must be authorized to act on its behalf.

2. Business Verification

To open and use a business account, we may require:

• Legal business name, registration number, and jurisdiction of incorporation.
• Registered business address and proof of address.
• Identification of the business owners, directors, and beneficial owners.
• Documentation describing the business's activities and expected use of the service.
• Information about the business's anti-money-laundering program, where applicable.

Failure to provide requested information may result in delays, restrictions, or closure of the business account.

3. Bulk & Batch Payments

Business customers may send multiple payments in a single batch. When using batch payments:

• You are responsible for the accuracy of all recipient details in the batch.
• Batches are processed after review and may be subject to additional compliance checks.
• Batch files must be in a supported format (CSV, XLSX, or API payload) and must meet our field requirements.
• Failed payments within a batch are reported individually in your payment history.
• Batch payments are subject to the same fees, limits, and prohibited-use rules as individual transfers.

4. Payroll Services

Where available, GlobiSend may offer payroll services that allow businesses to pay employees and contractors internationally.

• Payroll runs are scheduled based on the business's pay cycle and are processed subject to fund availability.
• Employers are responsible for tax withholding and reporting obligations in applicable jurisdictions.
• Payroll payments are treated as transfers under these policies and are subject to all compliance requirements.
• We are not responsible for the accuracy of employee details provided by the employer.

5. API Access for Business

Qualified business customers may be granted access to the GlobiSend API to integrate money transfers into their own systems.

• API access is granted subject to a separate agreement and to compliance with our Developer / API policies.
• API keys are confidential and must be stored securely. Never embed API keys in client-side code.
• API usage is subject to rate limits and usage quotas.
• Developers must not use the API to store or process data in ways that violate our Privacy Policy.
• We may revoke API access for abuse, non-payment, or violation of our policies.

6. Business Fees & Pricing

Business accounts may be offered volume-based pricing, custom rates, or dedicated support under a separate agreement. Standard pricing applies unless a written agreement states otherwise.

• Volume discounts are applied at the account level based on qualifying transfer volume.
• Custom rates are subject to minimum volume commitments as agreed in writing.
• Fees for business services are described in the applicable agreement and displayed before processing where possible.

7. Business Restrictions & Prohibited Businesses

We may restrict or decline business accounts in certain high-risk categories, including but not limited to:

• Gambling and betting operators (unless licensed and approved).
• Dealers in weapons, firearms, or ammunition.
• Businesses operating in jurisdictions subject to sanctions.
• Businesses engaged in illegal or unlicensed financial activities.
• Adult content services where prohibited by law.
• Any business that cannot adequately demonstrate a legitimate purpose for cross-border transfers.

8. Business Account Termination

We may suspend or terminate a business account for violations of these policies, fraud, compliance concerns, or inactivity. Upon termination:

• Pending transfers may be cancelled or refunded to the funding source.
• Any balances will be returned in accordance with applicable law.
• We may retain records as required by law and continue to apply compliance obligations.
• Businesses may appeal a termination through the complaints process.

1. Promotional Offers

From time to time, GlobiSend may offer promotions, discounts, promo codes, or special rates (collectively, "Promotions"). Promotions are subject to the specific terms stated in each offer, plus these general terms:

• Promotions are limited to eligible users and may be limited to new customers, specific regions, or specific services.
• Promotions cannot be combined with other offers unless stated otherwise.
• Promotional benefits have no cash value and cannot be transferred, sold, or exchanged.
• We reserve the right to withdraw, modify, or cancel any Promotion at any time without notice.
• Promotional discounts apply to eligible fees and may not apply to taxes, exchange-rate margins, or third-party charges.

2. Referral Program

If we offer a referral program, you may refer friends to GlobiSend and earn a reward when they complete their first qualifying transfer. Terms include:

• Referrals must be new customers who have not previously held a GlobiSend account.
• Your friend must use your unique referral link or code when signing up and must complete a qualifying first transfer.
• Rewards are credited to your account or applied as a discount, as stated in the offer.
• Rewards are not available for self-referrals, duplicate accounts, or accounts created solely to earn rewards.
• Fraudulent referrals (including fake accounts, multi-accounting, or abuse of the program) result in forfeiture of rewards and may lead to account closure.

3. First-Transfer Discounts

We may offer discounted or fee-free first transfers to new customers. These offers:

• Apply only to the customer's first completed transfer unless stated otherwise.
• May be subject to a minimum or maximum transfer amount.
• Apply to the GlobiSend transfer fee and may not cover exchange-rate margins or bank/intermediary fees.
• Cannot be applied retroactively to transfers completed before the offer was claimed.

4. Loyalty & Rewards Programs

Where offered, loyalty or rewards programs allow customers to earn points or status based on transfer volume or frequency.

• Points or status are non-transferable and have no cash value unless stated otherwise.
• Rewards accrue only on qualifying completed transfers.
• Points may expire after a period of inactivity or at the end of the program year, as stated in program terms.
• We may modify or terminate rewards programs at any time. Accrued points may be forfeited upon termination unless required otherwise.

5. Affiliate & Partnership Programs

GlobiSend may offer affiliate programs for partners who promote our services.

• Affiliate agreements are separate from these policies and govern commission rates and payment terms.
• Affiliates must comply with all applicable advertising laws and disclose their relationship with GlobiSend.
• Affiliates may not use deceptive marketing, spam, or paid click schemes to drive sign-ups.
• Commissions may be withheld where traffic or conversions are fraudulent or non-compliant.

6. Promotion Abuse

The following activities constitute promotion abuse and may result in forfeiture of rewards, account restriction, or termination:

• Creating multiple accounts to claim the same offer more than once.
• Using stolen, prepaid, or virtual payment methods solely to claim offers.
• Circumventing geographic or eligibility restrictions.
• Colluding with others to artificially generate referrals or transactions.
• Using bots, scripts, or automated methods to exploit promotions.

1. Mobile App Permissions

The GlobiSend mobile app requests the following device permissions only when needed to deliver its core features. You can review or revoke any permission through your device settings at any time.

• Location: Used for map features, delivery tracking, transaction verification, service area detection, and location-based services. Requested at runtime when you first use location features.
• Camera: Used to capture identity documents and to scan or upload verification documents (KYC). The camera is only accessed when you initiate a document scan.
• Storage / Photos: Used to attach documents or images to support requests and to upload verification documents. We only access media you choose to upload.
• Notifications: Used to send you transfer status updates, security alerts, and account notifications. You can disable notifications in device settings, though you may miss important updates.
• Biometrics (fingerprint / face): Used only if you choose to enable biometric login for faster, secure access to the app.

2. Notifications

GlobiSend sends the following types of notifications:

• Transactional: Transfer confirmations, status updates, receipts, and delivery notifications.
• Security: Login alerts, verification codes, and account security warnings.
• Marketing: Promotions and offers (opt-in only; you may opt out at any time).

You can manage notification preferences in your account settings. Even if you disable non-essential notifications, we will still send security-critical and legally required notifications.

3. Device & Browser Support

The GlobiSend app and website are designed to work on commonly used devices and browsers. We recommend keeping your operating system and browser updated to the latest supported versions to ensure security and performance. Some features may not be available on older or unsupported devices.

4. Offline & Intermittent Connectivity

Some app features require an internet connection. If your connection is interrupted while sending money, the transfer will not be submitted until you are back online. You should not assume a transfer was placed until you receive a confirmation. Check your transaction history before resubmitting to avoid duplicate transfers.

5. Accessibility

GlobiSend is committed to making our app and website accessible to all users, including people with disabilities.

• We strive to conform to the Web Content Accessibility Guidelines (WCAG) 2.1 at Level AA where practical.
• We support screen readers and provide alternative text for meaningful images.
• We support keyboard navigation and ensure sufficient color contrast for readability.
• We aim to keep text resizable without loss of functionality.
• If you encounter an accessibility barrier, contact us at accessibility@globisend.com. We take accessibility feedback seriously and use it to improve the product.

6. Language & Localization

GlobiSend may be offered in multiple languages and currencies depending on your region. Where translations are provided, the English version of these policies governs in case of any conflict or inconsistency. Prices, fees, and rates are always displayed in the relevant currency before you confirm a transaction.