Privacy Policy

This policy explains what information Sempo collects when you use the website and the product, what it is used for, who it is shared with, and your rights over it. Sempo does not use analytics or advertising trackers on the website or in the product.

What we collect depends on how far into Sempo you are:

• If you join the waitlist: your name and email address.
• When you create an account: your name, your email address, and the credentials you sign in with — an email code, a password if you set one, or the public key of a wallet you link. Sempo never holds a wallet’s private key.
• When you verify your identity: the documents and the photograph you submit are collected by Align on its verification partner’s pages. Sempo receives the result of the check and the information needed to open your account, not the documents themselves.
• When you use the product: the bank account details opened for you, any bank account you give us to pay out to, the contacts you save, every deposit and withdrawal, and the blockchain addresses created for you.
• Automatically: the device and browser you sign in from, for keeping your session secure, and the emails we send you and whether they were delivered.

To open and run your account; to verify who you are, which the law requires before money can move; to receive and send money on your instruction; to email you when something happens to your money; to keep your account secure; to answer you when you write to us; and to meet legal and regulatory obligations, including record-keeping and responding to lawful requests. We do not sell your personal data, and we do not share it with anyone for marketing.

Sempo shares personal data with three service providers, each of which handles it under its own privacy policy:

• Align, which provides bank accounts, transfers and identity verification. Align is a Canadian money services business registered with FINTRAC. It receives your name, email address, residential address, the identity documents and photograph you submit for verification, the bank accounts opened for you and given by you, and every transfer through them. Align may transfer that data to its own service providers, including its verification partner and banking partners, and to regulators and authorities where required by law.
• Clerk, which provides sign-in and account security. It receives your name, email address, any password you set, and the device and session information needed to keep you signed in and to let you see and sign out other devices.
• Resend, which delivers the emails Sempo sends. It receives your email address and the content of each message — for example that a deposit arrived, or that a withdrawal was submitted.

• Align’s Privacy Policy
• Clerk’s Privacy Policy
• Resend’s Privacy Policy

The providers above operate outside the country you may be in, so using Sempo means your personal data is transferred to them and to their service providers where they are. It may also be disclosed to regulators, law enforcement and other authorities where the law requires it — by Sempo, or by a provider under its own obligations.

For as long as you have an account, and afterwards for as long as the law requires. Records of who you are, what you agreed to and every transaction are kept for at least five years from the transaction or from the closing of your account, whichever is later — the retention that applies to Align as a registered money services business, and that Sempo mirrors. Those records are kept in a form that cannot be altered or deleted before then, even by us. Waitlist details are kept until you are let in or ask to be removed.

You may ask for a copy of the personal data Sempo holds about you, ask us to correct it, ask us to delete it, or withdraw your consent to our using it. We will do so except for the records the law requires us to keep for the period above, and withdrawing consent means we can no longer provide the account. We tell Align within two business days when you withdraw consent, since it holds your data too. Data held by Align is subject to Align’s Privacy Policy and its own retention obligations; we will help you reach them.

We may update this policy from time to time. The date at the top is when it last changed, and a change that materially affects how your data is used will be announced by email before it takes effect.

To exercise any of these rights, or with any question, write to hello@sempo.xyz.