US PRIVACY POLICY
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.
