Privacy Policy

This Privacy Policy describes how Primera Business Group("Primera," "we," "us") processes personal data when you use Ulasend at our website, APIs, dashboard, checkout, and related services (the "Services").

It explains what data we use, why we need it, and what rights you have. Personal information means data that identifies or relates to you directly or indirectly. This Policy covers information you submit or that we obtain from partners; it does not apply to anonymized data that cannot identify you.

By using the Services or accepting this Policy, you agree to its terms. If you disagree, stop using the Services. The Services are not intended for children under 18; we do not knowingly collect their data. Contact us if you believe a child has provided information.

Primera Business Group, an S corporation organized under the laws of the State of New York.

Principal address: 800 Third Avenue, Suite A, New York, NY 10022, USA

Contact: privacy@ulasend.com or support@ulasend.com

Personal data may be processed when you use the website, APIs, third-party integrations listed in the Services, payment processing, support channels, or (if you opt in) marketing emails.

• We take reasonable measures to protect personal data from unauthorized access, loss, misuse, alteration, or destruction.
• We do not intentionally process special-category data such as racial or ethnic origin, political opinions, or religious beliefs, except biometric data where needed for identity verification (liveness / face match) under our compliance program.
• Automated checks may be used to speed verification or fraud review; you may contact us to contest decisions that affect you.
• We do not sell personal data for monetary reward.

• Sign-up / account: first and last name, email, legal business name, website URL, industry, and similar profile fields.
• Transactions: wallet addresses, amounts, assets, networks, transaction hashes, invoice/payment-link metadata, and related ledger data; bank or payout details if you provide them.
• Identification / KYC:Employer Identification Number (EIN), the last four digits of an authorized representative's Social Security number, government ID, phone number, photo, proof of address, biometric data (liveness and face match), AML screening results, and other documents we request. See our AML / KYC / KYB Policy.
• Communications: name, email, phone, and message content when you contact us or opt into updates.
• Technical data: IP address, language, country, browser type/version, plug-ins, approximate location, OS and version.
• Usage data: URL clickstreams, page timing, errors, time on page, and actions on pages.
• Cookies and similar technologies (see below).

• Statistics, analytics, support, and improvement of the Services;
• Account authorization and profile access;
• Performing transactions and providing the Services;
• KYC/KYB, AML/CFT, sanctions screening, fraud prevention, and legal compliance;
• Communicating about the Services and, with consent where required, offers or updates;
• Enforcing our Terms of Service.

Depending on context, we rely on:

• Consent — for example certain cookies, marketing, or optional fields;
• Contract — to register you and provide the Services;
• Legal obligation — AML/KYC and similar duties;
• Legitimate interests — security, fraud prevention, service improvement, and protecting our rights, balanced against your interests.

Cookies are small data fragments stored on your device so the Service can function (for example keeping you logged in). We may use:

• Necessary cookies — navigation, secure areas, authentication; the site may not work without them.
• Statistics cookies — anonymous or aggregated understanding of how visitors use the site.
• Marketing cookies — where enabled, to measure or deliver more relevant communications.

Some cookies are session-based; others may persist. Third-party analytics may measure usage to help us improve the product. You can control cookies in your browser; disabling necessary cookies may break sign-in or checkout.

If you are a Merchant, you must determine the privacy laws that apply to each Customer and comply with them. Where required, you must obtain consent or another lawful basis to collect, store, and process Customer personal data (including sharing with Primera) for using the Services. You are responsible to your Customers for protecting their data and for providing required notices about transfers to us. If your violation causes us loss, you will indemnify us.

Blockchain networks are public. Wallet addresses, amounts, and transaction hashes published on-chain are visible to anyone and outside our control once broadcast.

We may share data with contractors under confidentiality obligations, including:

• Group entities or service affiliates, if any;
• Government, law enforcement, courts, or regulators when required;
• Business partners, suppliers, hosting providers, analytics, identity / AML vendors, and similar processors.

We share personal information to:

• Provide and administer the Services;
• Comply with law, detect fraud or unlawful activity, and respond to legal process;
• Prevent activity that is illegal, unethical, or poses safety risk;
• Complete a merger, acquisition, or reorganization, with consent where required by law.

Anonymous or aggregated data that does not identify you may be used for analysis. For a current list of processors relevant to your use, email privacy@ulasend.com.

Subject to applicable law, you may have rights to:

• Access — ask what personal data we hold and how we use it;
• Correct — update incomplete or inaccurate data;
• Delete — request deletion and account deactivation (some data may be retained where law requires);
• Object — object to certain processing;
• Transfer — request an export in certain circumstances;
• Complain — lodge a complaint with a supervisory authority.

To exercise rights, email privacy@ulasend.com or write to Primera Business Group, 800 Third Avenue, Suite A, New York, NY 10022, USA. We will respond within a reasonable period and as required by law. We may verify your identity before acting.

We limit retention to what is reasonably necessary for the purposes above, to resolve disputes, enforce agreements, protect rights, and meet legal and security requirements.

Consistent with our compliance program, KYC/KYB, customer, and transactional records are generally retained for at least five (5) years after the end of the business relationship (or longer if required by law). Some records may be kept longer for accounting, audit, or ongoing investigations. When no longer needed, we delete or de-identify data where feasible.

We primarily operate from the United States. Providers may process data in other countries. Where required, we use appropriate safeguards for cross-border transfers.

We may update this Policy from time to time. Continued use means you accept the changes. Material changes may require affirmative acceptance; if you decline, you may not be able to continue using the Services.

Primera Business Group
800 Third Avenue, Suite A
New York, NY 10022, USA
Privacy: privacy@ulasend.com
Support: support@ulasend.com