Last update: May 31st, 2021


CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS


1.- PURPOSE

This Privacy Notice for California Residents (“Notice”) supplements the information contained in SWFS US Privacy Notice and applies to all visitors, users, and others who
reside in the State of California, even if the person is temporarily outside of the State of California (hereinafter, the “consumers” or “you”).
We have drafted and adopted this CCPA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms used but not defined herein shall
have the meaning ascribed to them in the CCPA.


2.- SCOPE

The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that
individual. This means that even though the CCPA generally applies to Personal Information that identifies, relates to, or could reasonably be linked with a particular
California resident, it may not apply to certain Personal Information that is subject to certain sector-specific privacy laws.

This means, for example, Personal Information that is subject to more restrictive privacy laws, such as the Gramm-Leach-Bliley Act (“GLBA”), or Small World Financial Services
(SWFS) collects and uses as a provider of money transfer services and products that is subject to GLBA, will not be subject to CCPA.

 For more information about how we collect, disclose and secure information relating to these consumers, please refer to our SWFS - US Customers Privacy Notice.

As established by the CCPA, personal information is information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include
your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other personal
information that could create a profile about your preferences and characteristics. Personal information does not include publicly available information that is from federal, state, or
local government records, such as professional licenses and public real estate/property records.


3.- WHAT INFORMATION SWFS COLLECTS AND DISCLOSE TO THIRD PARTIES

In the past twelve (12) months, we have collected, and disclosed to third parties,among which are member entities of the Small World Financial Services (SWFS) group, for our
business purposes, the following categories of Personal Information relating to California Residents covered by this Notice:

 

Category Examples Collected  Disclosed
Contact data and
Identifiers
Such as your name, Internet Protocol
address, email address, telephone or
mobile number and online identifiers.
YES YES
Categories listed in
the California
Customer Records
statue
Such as your name, address, telephone
number, passport number, driver’s
license or state identification card
number, employment and employment
history.
YES YES
Protected
classification under
California or federal
law
Age (40 years or older), national origin,
citizenship.
YES YES
Commercial
information
Records of personal property, products or
services purchased, obtained, or
considered, or other purchasing or
consuming histories or tendencies.
YES YES
Biometric
information
Such as health or exercise data NO NO
Internet or other
similar network
activity
Browsing history, search history,
information on a consumer’s interaction
with a website, application, or
advertisement.
YES YES
Geolocation data  Device location or Internet Protocol
locations.
YES YES
Sensory data  Audio, electronic, visual or similar
information.
NO NO
Professional or
employment-related
information.
Current or past job history or
performance evaluations.
YES YES
Non-public
education
information
Education records such as student
grades or transcripts
NO NO
Inferences drawn
from personal
information.
Profile reflecting a person’s preferences,
characteristics, predispositions, behavior
and attitudes.
NO NO


4.- HOW WE COLLECT YOUR PERSONAL INFORMATION (SOURCES)


We collect personal information in a variety of ways, including:
● Directly from you: when you interact with us and use our services. For example, when (a) you ask us or one of our affiliated companies, Small World agents to send
or receive money sign up to or use any of our other products or services; (b) you submit personal information on applications or other forms to us or our Agents
(transactions); or (c) you otherwise submit personal information to us, our Agents or other.

If you provide information about someone else, you represent that you have permission to do so.
● Indirectly from other third party sources: such as our business customers, government agencies, consumer and credit reporting agencies, public databases,
joint marketing partners, social media platforms, and from other third parties.

5.- HOW WE USE YOUR PERSONAL INFORMATION

We may use or disclose the Personal Information we collect for one or more purposes. Therefore, we have segmented the different purposes and legitimation for the main
Personal Information processing operations, in order to facilitate its reading, clarity and comprehension:
● With the aim to perform and administer our contractual relationship with you, we may use your Personal Information to:

○ Provide, deliver and assist in providing, managing and delivering any products and services to you (including money transfers, administer and enforce
transactions, manage your customer relationship, payment services and other Small World products or services);

○ Confirm your eligibility for any service you apply for, and to verify any of the information you provide and maintain accuracy of our records, and to help us
improve and develop these services.

● We may use your Personal Information to comply with applicable laws and regulation around the world, including to:

○ Comply with legal, auditing, insurance, security and regulatory obligations including those aimed at monitoring and preventing money laundering and
related criminal or suspected criminal activity;
○ Establish, exercise, or defend legal rights or claims and assist in dispute resolution; or 

○ As required or permitted by law (such as performing due diligence on customers before approving their registration/applications).
● For our legitimate interests or for the legitimate interests of others, we may use your Personal Information to deliver services, advertise, conduct research and analysis,
and manage our fraud and security risks, in the following ways:
○ Improve your experience and the operation of our business, store your preferences, passwords and other information and track activity on our
Website or Mobile App;
○ Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activities, and prosecute those responsible for that activity.
○ To better understand the effectiveness of our promotional campaigns;
○ Determine whether you came to our site from a banner ad or an affiliate website;
○ Deliver information specific to your interests on additional websites, to determine whether you've acted on our promotional messages;
○ Manage fraud and security risks, including to review and approve individual transactions you make through digital channels, detect and prevent fraud or
criminal activity and/or safeguard the security of your information);
○ Report to credit bureaus, court orders and legal investigations;
○ For testing, research, analysis, and product development, including to develop and improve our Website or Mobile App, products, and services;
○ Help verify or maintain the quality, safety, security, and integrity of our Website or Mobile App, products and services, databases and other technology
assets, and business as well as to improve, upgrade, or enhance the same.
○ As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

We will not use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.


6.- CATEGORIES OF THIRD PARTIES WE SHARE YOUR PERSONAL INFORMATION

In the prior 12 months, we may have shared your Personal Information to the following
categories of third parties for our legitimate business purposes:
● Our Small World Financial Services affiliates and subsidiaries;
● Service providers and/or vendors;
● Our agents and business partners;
● Governmental entities such as law enforcement agencies;
● Advertising and social networks;
● Internet service providers; and
● Data analytics providers.

When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information
confidential and not use it for any purpose except for performing the contract.

7.- SALE OF PERSONAL INFORMATION

In the preceding 12 months, we have not sold Personal Information subject to CCPA, including Personal Information of minors under the age of sixteen (16). For the purposes of
this Privacy Notice, “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration.

8.- RIGHTS AND CHOICES UNDER CCPA

The CCPA provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to
exercise those rights.

1. Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of
your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, to the extent allowed by law, we will disclose to
you:
● The categories of Personal Information we collected about you.
● The categories of sources for the Personal Information we collected about you.
● Our business or commercial purpose for collecting your Personal Information.
● The categories of third parties with whom we share your Personal Information.
● The specific pieces of Personal Information we collected about you.

 

2. Deletion Request Rights. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain
exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our
records, unless an exception applies. For example, we will not honor your request where we need the Personal Information to comply with a legal obligation; there are
internal and lawful uses of that information that are compatible with the context in which you provided it; the disclosure of Personal Information would adversely affect
the rights and freedoms of another consumer; or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.


9.- WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM YOUR RIGHTS

If you are a California resident, to exercise the access, data portability, and deletion rights described above, you may submit a verifiable consumer request to us by either:
● Calling us at 877-26-6458;
● Emailing us at cs@smallworldfs.com or dpo@smallworldfs.com;
● Visiting our website at www.smallworldfs.com


Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable
consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information
relates to you. Therefore, we may need to ask you for additional information for verification purposes.

We endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will inform you of the reason and extension
period in writing. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we
cannot comply with a request, if applicable.

We reserve the right to amend this Notice at our discretion at any time. When we make changes to this Notice, we will post the updated Notice on our Website and update the
Notice's effective date. Your continued use of our Website following the posting of changes
constitutes your acceptance of such changes.


10.- CHANGES & CONTACT DETAILS

Small World reserves the right to modify this Privacy Notice. To the extent required byapplicable law, we will notify you and give you the opportunity to opt out of any material
change in the way we use or disclose personal information you previously have provided.

If you have any questions or comments about this Privacy Notice, the ways in which we collect and process your information described here and other information or exercise your
rights under the CCPA, you may contact us at:

● Phone: 877-26-6458
● Website: www.smallworldfs.com and click on the “Contact Us” link.
● Email: dpo@smallworldfs.com
● Postal Address:
○ Choice Money Transfer Inc., 560 Sylvan Av., Englewood Cliffs, NJ 07632.
○ Attn: Principal Privacy Officer.

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