PRIVACYBELEID VAN DE VS.

Effective Date:March 2018

This Privacy Policy (the “Policy”), applies to all subsidiaries owned and operated by Choice Money Transfer, Inc. / Small World Financial Services Group Limited (“Choice Money Transfer, Inc. / Small World”, “We”, “Us”, “Our”). This Policy describes how we collect and use the Personal Data you provide on our website www.smallworldfs.com, and on our mobile websites and mobile applications. This Policy also applies for the Personal Data collected offline. The Policy describes the choices available to you regarding our use of your Personal Data and how you can access and update this data. 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.


SCOPE OF PRIVACY POLICY

This Policy applies to Personal Data collected by us in connection with services we offer. This Policy applies to Personal Data we may collect via electronic channels and in hard copies (for example letters you post to us). Our website may contain links to and from the websites of our partner networks, advertisers and affiliates (for example Google, Facebook, Twitter, Linkedin, Instagram). If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites. Our website is not directed at minors (those under the age of 18 years) and minors are not eligible to use our services. We ask that minors refrain from using our service or submitting any Personal Data to us.


DATA WE COLLECT

We 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 data

We 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 sources

We 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 DATA

Personal 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.


INFORMATION SHARING

We may share your Personal Data about your transactions and experiences with our affiliates for their everyday business purposes. We may provide your Personal Data to trusted third parties who help us with our business activities such as processing your monetary transaction or offering customer service. These companies are authorized to use your Personal Data only as necessary to provide these services to us. We may also disclose your Personal Data: · in the event of a merger, acquisition, or sale of all or a portion of its assets, we will share your Personal Data with our successor; · with analytics and search engine providers that assist us in the improvement and optimization of our website; · to any other third party with your prior consent to do so; and · if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use and other agreements; or to protect the rights, property, or protect our safety, our members, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.


YOUR RIGHTS

Data 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: online.usa@smallworldfs.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 DATA

We 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.


SECURITY

We 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.


LINKS TO THIRD PARTY SITES

Our website includes links to other sites whose privacy practices may differ from those of Choice Money Transfer, Inc. / Small World. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any site you visit.


TESTIMONIALS

We 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 online.usa@smallworldfs.com.


COLLECTION AND USE OF THIRD PARTY PERSONAL DATA

You 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.


COOKIES

A cookie is a piece of text information that a web server may transfer to your web browser when you visit this website. Cookies are commonly used by websites to improve your experience and to enable systems to recognize your browsers. Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer and only the site that created the cookie can interpret it. We may use cookies for a variety of purposes: to assist us in providing our services to you, to allow you to change pages during your visit to our website without reentering your password, to track activity on our website, or to determine whether you came to our site from an affiliate website. We may use temporary, session cookies that expire and are automatically erased when you close your browser window to enable you to perform actions when you are logged into your account. We may use long term, persistent cookies that expire in the distant future to better understand usage patterns so that we can improve our Service or to remember your choices for our Services. We may permit third parties to place cookies through our website to provide us with better insights into the use of our Services and user demographics or to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use our Services. By accessing or using our Services, you consent to the placement of cookies on your computer or other device as described in this Privacy Policy. You may adjust your browser settings to refuse or limit cookies, but if you do, certain features of our site may be limited or not work at all. To learn more about cookies visit www.allaboutcookies.org/manage-cookies. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.


GOOGLE ANALYTICS

We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You may opt out of Google Analytics by visiting the Google Analytics opt-out page.


SOCIAL MEDIA WIDGETS

Our website includes Social Media Features, such as the Facebook and Twitter buttons and Widgets, such as the Share this button or interactive mini-programs that run on our website. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy policy of the company providing it. Please refer to the Cookies section within the Privacy Policy and to our Cookies Policy to obtain more information about cookies we use.


STATE PRIVACY LAWS

We 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 POLICY

Any 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 US

If you have questions or concerns about this Policy, please contact us by one of the following methods: · Phone: 1-866-210-8002 · Email: info@smallworldfs.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)


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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