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EFFECTIVE JUNE 1, 2026

Privacy Policy.

Governs information collected and processed through the SendGlobe Commercial Certainty Infrastructure platform.

OVERVIEW

1. Introduction

This Privacy Policy describes how Automation Partners AI LLC ("SendGlobe," "we," "us") collects, uses, and handles information in connection with your use of the SendGlobe Commercial Certainty Infrastructure platform.

SendGlobe is a Commercial Certainty Infrastructure platform. We support Commercial Readiness, facilitate Commercial Agreements, record Verification Outcomes, and determine Settlement Eligibility according to predefined workflow rules.

SendGlobe does not hold funds, receive funds, move funds, or custody assets. Information we collect supports these workflow functions and the compliance obligations associated with Commercial Readiness.

DATA COLLECTION

2. Information We Collect

We may collect the following categories of information in connection with the platform:

Identity & Verification Information

Information collected as part of Commercial Readiness, which may include identity verification data, sanctions screening results, compliance review records, and eligibility review records. This information supports responsible participation in commerce.

Commercial Agreement Data

Information defining conditions, deliverables, and acceptance requirements established by counterparties in connection with Commercial Agreements, including Verification Outcomes and workflow status records.

Platform Usage Information

Technical information associated with your use of the platform, including access logs, workflow events, and audit records maintained in connection with Commercial Agreements.

Communications

Information you provide when contacting us, submitting support requests, or communicating with our compliance team.

USE OF DATA

3. How We Use Information

We use information to:

  • support Commercial Readiness workflows, including identity verification, sanctions screening, and eligibility review;
  • facilitate and record Commercial Agreements;
  • record Verification Outcomes and maintain audit records;
  • determine Settlement Eligibility according to predefined workflow rules;
  • comply with applicable legal, regulatory, and sanctions obligations;
  • maintain platform integrity, security, and operational resilience;
  • respond to inquiries and provide support.
THIRD PARTIES

4. Information We Share

We do not sell your information. We may share information in the following circumstances:

Service Providers

Third-party providers that support hosting, communications, identity verification, sanctions screening, and compliance services may process information on our behalf. Providers are evaluated according to operational, security, and business requirements.

Independent Settlement Infrastructure

Settlement Eligibility status and related workflow information may be communicated to Independent Settlement Infrastructure as required to support their functions. Information shared with Independent Settlement Infrastructure is governed by their separate privacy practices.

Legal & Regulatory Obligations

We may disclose information when required by law, regulation, legal process, or government request, including obligations under sanctions laws, anti-money laundering requirements, and applicable watchlist screening requirements.

RETENTION

5. Retention

We retain information for as long as necessary to fulfill the purposes for which it was collected, including to support Commercial Readiness workflows, maintain audit records for Commercial Agreements, and comply with applicable legal and regulatory obligations.

Audit records and Verification Outcomes recorded in connection with Commercial Agreements are maintained according to applicable record-retention requirements. Records written to underlying blockchain infrastructure are retained according to the properties of that infrastructure and may not be deletable by SendGlobe.

SAFEGUARDS

6. Security

SendGlobe maintains administrative, technical, and organizational safeguards designed to protect information processed through the platform. Security controls are designed to support confidentiality, integrity, availability, accountability, auditability, and operational resilience.

No security program can guarantee absolute security. We maintain processes for identifying, investigating, and responding to security incidents, and will notify affected parties as required by applicable law. For details on our security program, see our Enterprise Security Overview.

YOUR RIGHTS

7. Your Rights

Depending on your jurisdiction, you may have rights with respect to your personal information, including rights to access, correct, or request deletion of information we hold about you, subject to applicable legal requirements and our retention obligations.

Some information, including audit records and Verification Outcomes recorded in connection with Commercial Agreements, may not be deletable as a result of applicable record-retention requirements or the properties of the underlying infrastructure on which such records are maintained.

To submit a rights request, contact compliance@sendglobe.app. We will respond within the timeframe required by applicable law.

CROSS-BORDER

8. International Data Transfers

SendGlobe operates infrastructure on the Internet Computer Protocol, a globally distributed blockchain network. Information recorded on the Internet Computer Protocol may be processed across multiple jurisdictions as part of the normal operation of that network.

When we transfer personal information across borders, we do so in accordance with applicable data protection requirements. If you have questions about international transfers of your information, contact compliance@sendglobe.app.

UPDATES

9. Policy Changes

We may update this Privacy Policy from time to time. Updated policies will be posted at sendglobe.app/privacy with a revised effective date.

Material changes will be communicated to platform users through appropriate means. Continued use of the platform following notice of updated policy constitutes acceptance of the updated policy.

CONTACT

10. Contact

For privacy inquiries, rights requests, or questions about this policy:

Automation Partners AI LLC

Email: compliance@sendglobe.app