PRIVACYBELEID VAN DE VS.
Effective Date:March 2018
Personal Data is data which can identify you, directly or indirectly, either from that data or from that data combined with other information that is in, or likely to come into, our possession, it includes data such as your name, your location or online identifiers, and as further identified in this Policy (“Personal Data”). By submitting your Personal Data to us you are accepting and consenting to the practices described in this Policy.
DATA WE COLLECTWe collect Personal Data which you disclose to us via online and offline: We collect your Personal Data and Personal Data of your beneficiaries when you create a money transfer account with us by completing online forms. Personal Data we collect about you may include: name, surname, home address, email address, date of birth, mobile number, email address, credit and payment history, financial information, such as bank account numbers and credit/debit card numbers, and other Personal Data, including government identification numbers such as a driver’s license, state identification, passport, visa, Social Security and tax identification number, which may be required to complete the transaction. We do not knowingly collect and process sensitive Personal Data such as Personal Data revealing racial or ethnic origin, political opinion, religious philosophical beliefs, trade union membership and data concerning health and sexual preference.
Technical dataWe may collect technical information about your visit such as Internet Protocol Address (IP); clickstreams to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); your login information, browser type and version; time zone setting; browser plug-in types and versions; operating system and platform and etc.
Third-party sourcesWe may lawfully obtain information about you from other sources, including but not limited to: computer systems and mobile devices; and third-party sources, such as government agencies, identity verification services, electronic database services and consumer credit reporting agencies.
PURPOSES WE USE YOUR DATAPersonal Data held about you will be used for our core business and our marketing purposes, including joint marketing with other financial companies, such as follows: · to facilitate your monetary transaction; · to respond to any queries or provide you with information, products or services that you request; · to prevent or detect fraud, including fraudulent transactions, or abuses of our website as part of our efforts to keep our website safe and secure; · to ensure that content from our website is presented in the most effective manner for you and for your device; · to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; · to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; · to manage our account and records; · to conduct research and analysis; and · to comply with court orders and applicable laws and regulations such as those relating to “know-your-customer,” and anti-money laundering requirements. We will retain your information for as long as required to provide the services and as necessary to comply with our legal obligations and to enforce our agreements.
YOUR RIGHTSData protection law gives rights to individuals in respect of the Personal Data that organizations collect and hold about them: for example you have the right to ask us not to share your Personal Data (a) with our affiliates and non-affiliates to market to you, and (b) with our affiliates for their everyday business purposes concerning your creditworthiness. If your Personal Data changes, you may exercise your rights to access, correct, or modify your account, by making the change on your account information page or by e-mail to the following address: email@example.com. You may also call us on our customer service number at 1-866-210-8002. If you no longer desire our service or would like to delete your account, please contact our Online Customer Service team (email and phone number listed above). Receiving emails from us is part of our service. You will receive a service related email from us in order for us to manage and administer your account. You may opt-out from promotional emails to you by accessing your email preferences or selecting the “Unsubscribe” function present in each email we send you. Because we have chosen to refrain from certain types of data sharing, such as providing your Personal Data (a) for our affiliates and non-affiliates to market to you, and (b) for our affiliates for everyday business concerning your creditworthiness, the only type of sharing of your Personal Data that you may restrict is as follows: State laws may give you additional rights to limit sharing of Personal Data. See the STATE PRIVACY LAW section below for more regarding your rights under state laws.
TRANSFER OF YOUR PERSONAL DATAWe are a global company; your Personal Data may be transferred outside of the country in which you live. All international transfers of Personal Data are done in accordance with applicable data protection laws for the purposes set out in this Policy.
SECURITYWe will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. We implement technical and organization measures to protect your Personal Data and follow data retention practices in line with applicable law. These measures can include physical, electronic and procedural safeguards. We also limit access to your Personal Data to only employees, agents and representatives who need to know. We have put in place SSL (Secure Socket Layer) encryption technology to protect your sensitive information such as bank account number, credit card number, date of birth and Social Security Number, transmitted through our website. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
TESTIMONIALSWe display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
COLLECTION AND USE OF THIRD PARTY PERSONAL DATAYou may also provide Personal Data about other people, such as their name, email address, beneficiary account number and mobile number. This information is only used for the sole purpose of adding a new beneficiary to send money to.
STATE PRIVACY LAWSWe will comply with state privacy laws to the extent they apply to our services. United States, California residents: In accordance with California law, we will not share information we collect about you with companies outside of Choice Money Transfer, Inc. / Small World except as required or permitted by law. For example, we may share information to service your accounts, complete requested transactions, or to provide rewards or benefits to which you are entitled. You have the right to control whether we share some of your personal information at any time by completing the Privacy form. However, if we do not hear from you and do not receive your completed Privacy form, we may share some of your information with affiliated companies. Click here for the privacy form.
CHANGES TO THIS POLICYAny changes we may make to this Policy in the future will be posted on this page, and where appropriate notified to you by email. We encourage you to periodically review this page for the latest information on our privacy practices.
CONTACT USIf you have questions or concerns about this Policy, please contact us by one of the following methods: · Phone: 1-866-210-8002 · Email: email@example.com · Online contact form: Click here · Or please send us a letter: Choice Money Transfer, Inc. Member of Small World Financial Services Group 560 Sylvan Avenue, Englewood Cliffs, NJ 07632
Last update: May 31st, 2021
CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
(Addendum to SWFS - US Customers Privacy Notice)
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.
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:
|Contact data and
|Such as your name, Internet Protocol
address, email address, telephone or
mobile number and online identifiers.
|Categories listed in
|Such as your name, address, telephone
number, passport number, driver’s
license or state identification card
number, employment and employment
California or federal
|Age (40 years or older), national origin,
|Records of personal property, products or
services purchased, obtained, or
considered, or other purchasing or
consuming histories or tendencies.
|Such as health or exercise data||NO||NO|
|Internet or other
|Browsing history, search history,
information on a consumer’s interaction
with a website, application, or
|Geolocation data|| Device location or Internet Protocol
|Sensory data|| Audio, electronic, visual or similar
|Current or past job history or
|Education records such as student
grades or transcripts
|Profile reflecting a person’s preferences,
characteristics, predispositions, behavior
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
● 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 firstname.lastname@example.org or email@example.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: firstname.lastname@example.org
● Postal Address:
○ Choice Money Transfer Inc., 560 Sylvan Av., Englewood Cliffs, NJ 07632.
○ Attn: Principal Privacy Officer.