Gift Network

Privacy Policy

Effective 11 August 2026 · Last updated 11 August 2026

Gift Network is a social gifting app. You can send money, gift cards, greeting cards and other gifts to people you know, and see your gifting history as a network. Moving money and showing social activity both mean handling personal information, so this policy sets out exactly what we collect, why, who we send it to, and what you can do about it.

The short version. We collect what we need to run your account, move your money, keep the platform lawful and safe, and show you the parts of the app that are social by design. We never see your card number, we never store photos of your ID, we cannot read your direct messages, and we never give other users your exact location. We do not sell your personal information, and we do not use it for advertising.

1. Who we are

Gift Network is operated by Seasons Inc. (“Seasons Inc.”, “we”, “us”), based in Ontario, Canada. We are the organisation responsible for the personal information described in this policy — the “data controller”, in the language of privacy law.

This policy covers the Gift Network iOS app and the pages on network.gift. Questions, requests and complaints all go to support@network.gift.

2. What we collect

Information you give us

Information created by using Gift Network

What we deliberately do not collect

3. How we use it

PurposeInformation usedWhy we are allowed to
Create and run your account Account details, profile content To provide the service you asked for
Send, deliver, redeem and refund gifts Gift content, wallet and transaction records, recipient details To perform our contract with you
Show your profile, gift network and social activity Gift records, social graph, profile content To provide the service, subject to your privacy settings
Verify your identity and screen against sanctions lists Identity verification records Legal obligation (Canadian anti-money-laundering law)
Detect fraud, abuse, and prohibited activity Transaction records, device data, reports and blocks Legal obligation and our legitimate interest in a safe platform
Moderate images and video you upload Uploaded media Our legitimate interest in keeping the app safe and lawful
Show you on the Nearby map Approximate location Your consent — you can withdraw it at any time
Send push notifications and service emails Push token, email address Your consent for push; contract for essential service emails
Fix crashes and keep the app working Diagnostic data Our legitimate interest in a reliable product
Answer your support requests Support request, account details, device data To perform our contract with you

We do not sell personal information, we do not share it with data brokers, and we do not use it to target advertising — in the app or anywhere else.

4. What other people can see

Gift Network is social, so some information is visible to others by design. Specifically: your username, display name, profile photo, biography, follower and following counts, and the gifts shown in your Gift Network.

Your email address, date of birth, wallet balance, transaction history and identity verification records are never shown to other users.

5. Location and Nearby

Nearby lets you discover other Gift Network members within roughly 150–250 metres. It is off until you turn it on, and it is built so that turning it off leaves nothing behind.

6. Messages and end-to-end encryption

Direct messages in Gift Network are end-to-end encrypted. Text, photos, videos and files are encrypted on your device using keys held on your device, and are decrypted only on the devices of the people in the conversation. Your identity key is stored in your iCloud Keychain so your messages survive getting a new phone.

Message transport runs on Stream. Stream and Gift Network both hold only ciphertext: we cannot read your messages, and we cannot produce their contents to anyone else, including in response to a legal demand. What we do hold is the fact that a conversation exists, who is in it, and when messages were sent.

7. Identity verification and screening

Canadian law requires us to identify customers before they move money. Until you are verified, your account can receive gifts but not send money or withdraw it.

Verification runs through Stripe Identity. You photograph your ID and your face inside Stripe’s flow; Stripe authenticates the document and checks that the face matches. Those images go to Stripe, not to us. What we receive and store is the record we are required to keep: your legal name, date of birth, document type, issuing jurisdiction, document number and expiry date, and the verification result.

We also screen your name and date of birth against international sanctions and politically-exposed-person lists using OpenSanctions, both when you verify and periodically afterwards, because those lists change. A possible match is reviewed by a person before any decision is made. Being flagged as politically exposed does not by itself restrict your account.

We monitor transactions for patterns that suggest money laundering or fraud, and we may freeze an account, refuse a transaction, or file a report with Canadian authorities where the law requires it. We may be prohibited from telling you when such a report has been made.

8. Who we share information with

We share personal information with the service providers below, only to the extent each one needs it to do its job. Each is bound to protect it and to use it only on our instructions.

ProviderWhat it does for usWhat it receives
Google (Firebase & Google Cloud) Authentication, database, file storage, backend functions, hosting, push notifications, crash reporting Substantially all account, profile, gift and transaction data
Stripe Card payments, bank payouts (Stripe Connect), identity verification (Stripe Identity) Card details, payment amounts, your identity documents and personal details
Stream Direct message transport Your user ID, display name, avatar, and encrypted message content only
Reloadly Gift card and mobile top-up fulfilment Order details, and the recipient email or phone number for delivery
OpenSanctions Sanctions and politically-exposed-person screening Your name and date of birth
Google Cloud Vision & Video Intelligence Automated safety scanning of uploaded images and video The image or video you uploaded

We may also disclose information when we are legally required to — in response to valid legal process, to comply with anti-money-laundering and sanctions obligations, to enforce our Terms of Service, or to protect the rights, safety and property of our users or ourselves. If Gift Network is ever involved in a merger, acquisition or sale of assets, personal information may transfer as part of that transaction, and we will tell you before it becomes subject to a different privacy policy.

9. Where your information is stored

Our primary database is hosted in the European Union (Google Cloud’s eur3 multi-region) and our backend servers run in the United States. Uploaded files are stored on Google Cloud Storage. Our service providers operate globally, including in the United States and the European Union.

This means your personal information is stored and processed outside Canada, and is subject to the laws of those countries — including lawful access by their courts, law enforcement and national security authorities. We rely on contractual protections with each provider, including standard contractual clauses where they apply.

10. How long we keep it

InformationKept for
Account, profile and social data Until you delete your account
Transaction and ledger records At least 5 years after the transaction, as required of Canadian money services businesses — this survives account deletion
Identity verification and screening records At least 5 years after your account closes, as required by law
Nearby presence Deleted when you turn Nearby off; stale records purged daily
Direct messages Until deleted by a participant — and unreadable to us throughout
Support requests Up to 2 years after the request is resolved
Crash and diagnostic logs Up to 90 days

11. Your rights and choices

Under Canadian privacy law — and comparable laws elsewhere — you can:

Email support@network.gift to exercise any of these. We will verify who you are before acting, and respond within 30 days.

There is no automated decision-making that produces legal effects about you, with one exception: sanctions screening can restrict your account. Every such case is reviewed by a person, and you can contest the outcome by contacting us.

12. Deleting your account

You can delete your account from Settings → Delete Account in the app. Deletion is scheduled 30 days out, during which you can cancel it by signing back in. After that, we delete your login, profile, photos, stories, username and social data.

Withdraw any remaining balance first — deleting your account does not return it to you. Transaction, ledger, identity verification and screening records are retained for the periods in section 10, because Canadian law requires it. Gifts you sent to other people remain in their history, since they are part of their records too.

13. Security

We encrypt data in transit and at rest, end-to-end encrypt direct messages, hold card details and identity documents with Stripe rather than ourselves, enforce server-side access rules on every read and write, and keep an append-only ledger so financial records cannot be silently altered.

No system is perfectly secure. Keep your password private and your device locked, and contact us immediately at support@network.gift if you think someone else has access to your account. If a breach creates a real risk of significant harm to you, we will notify you and the Privacy Commissioner as the law requires.

14. Children

Gift Network is not intended for children under 13, and we do not knowingly collect their personal information. Sending money or withdrawing funds additionally requires identity verification, which requires you to be at least 18. If you believe a child under 13 has created an account, tell us at support@network.gift and we will delete it.

15. Changes to this policy

We will update this policy as Gift Network changes. The effective date at the top always reflects the current version. If a change materially affects your rights or how we use your information, we will tell you in the app or by email before it takes effect, and where the law requires it we will ask for your consent again.

16. Contact us

Privacy questions, access requests and complaints: support@network.gift.

Seasons Inc.
101 Heartview Road
Brampton, Ontario, Canada L6Z 0C9