WorldRemit Privacy Policy

United States of America

Effective 30 June 2020

Introduction

WorldRemit Corp (“WorldRemit”, “We”, “Us”, “Our”), a Delaware corporation with business address, 600 17th Street, Suite 200 South, Denver CO, 80202  is committed to protecting and respecting your privacy, handling your information in an open and transparent manner, and keeping your information secure.

This Privacy Policy ("Policy") explains among other things: what we do with your personal information; what we do to keep it secure;  with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information. In this Policy, references to "You" and "Your" are references to users of our website and/or of our Mobile Apps, and a consumer.

We will amend or update this Policy regularly to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.

If you don't want to read all the details, here are the highlights that you may really wish to know:

• WorldRemit is an online payments business that helps its consumers transfer money globally.
• Where appropriate we share your personal information with our affiliates, partners and other companies. Upon request or where we are legally obliged, we may share your information with public agencies.
• We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers). In providing this information you confirm to us that you have their permission to do so.
• We use third parties to process your personal information on our behalf to perform our services for you, and due to the international nature of our business some of them are based outside the United States of America.
• You have several rights over your personal information, and the manner in which you can exercise those rights are contained in this Policy.
• We will send you direct Marketing if we are allowed to do so. We do this to encourage you to use our services and send you offers or promotions that may interest you. You can ask us to stop sending you marketing information at any time. Details of how to unsubscribe will be included on each email that we send you. Alternatively, send us an email to privacyusa@worldremit.com with “URGENT - UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.
• We also use your personal information to display online advertisements and Marketing relating to our services on our website, online media channels or by sending you push notifications if you use our mobile app.
• We do not intentionally use children’s information (our website and mobile application are not intended for children).

Definitions

To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:

“Data Protection Legislation” means the Gramm-Leach-Bliley Act of 1999, the CAN-SPAM Act of 2003, and such applicable legislation as may exist in your State or Territory of residence.

“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.

“Services” means WorldRemit Money Transfer Service; WorldRemit Digital Money Account; Airtime Top Up; and such other services or products that we may introduce from time to time.

The personal information we collect about you

We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Data Protection Legislation and as set out in this Policy.

The personal information we collect and use may include, amongst other things:

• Your name;
• Your contact information such as Your email address, postal address and telephone number or any telephone number used to call us;
• Your demographic information such as age, education, gender, and interests;
• evidence of Your identity (for example passport information);
• unique identifiers such as Your username, account number and password;
• Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
• Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
• Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We also collect from you information in relation to other people (for example, details of the recipients of your money transfers), where you provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.

How we collect your personal information

• Information you give to us when you use our services. If you use our services you will need to provide certain information including Your name, address and card number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out. This information must be complete and accurate and if not, we may have to take additional steps to complete the transaction.
• Other information You give to us. This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, when You sign up to receive notifications, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
• Social Media. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
• Other Sources. We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.
• Information we collect about You.
  • Like most websites, we use "cookies" to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. Please see our Cookies Policy for further information.
  • Log Files. In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.
  • Social Media Widgets. Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
• Mobile App. When You download our Mobile App, in addition to the information mentioned above we:
  • automatically collect information on the type of device You use, operating system version, and system and performance information. We may send You push notifications from time-to-time in order to update You about events or promotions that we may be running. If You no longer wish to receive these types of communications, You may turn them off at the device level. To ensure You receive proper notifications, we will need to collect certain information about Your device such as operating system and user identification information;
  • may collect Your location-based information for the purpose of locating a place that You may be searching for in Your area. We will only share this information with our mapping provider for the sole purpose of providing You with this service. Your geo-location data may be shared with third parties. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at privacyusa@worldremit.com; and
  • may use mobile analytics software to allow us to better understand the functionality of our Mobile Software on Your device. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App

How we use your personal information

Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.

We use Your information for the following specific purposes:

• to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the Services in accordance with our terms and conditions and with this Policy;
• to register You with a WorldRemit account;
• to fulfil Your Transaction / (Airtime Top Up) Request;
• to send You confirmations or other notifications;
• to notify You about temporary or permanent changes to our services or other service-related messages;
• to assist you where online applications are not completed;
• to prevent fraud, money laundering, and any other illegal activity;
• to ensure that content from our site is presented in the most effective manner for You and for Your computer;
• to promote our business;
• to send You Marketing communications, provided that You have given us Your contact details in the course of a sale (or of negotiations for a sale) of our products or services and that you do not decide to opt out from this type of communications, in accordance with Data Protection Legislation (including the CAN-SPAM Act).
• to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our site, Mobile App and our services safe and secure;
• to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
• to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
• to train, monitor and assess the effectiveness of the manner we provide the Services to You;
• to consider and investigate any concerns or complaints you may have; and
• to display personal testimonials of satisfied consumers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, contact us at privacyusa@worldremit.com.

Our Legal basis for processing your personal information

We only use your personal information for a specific purpose; and before we do so we must have a legal reason. For example, when it is necessary for us to perform a contract with you for our services, for our legitimate interest, or where you have given us your consent, or to fulfil our legal obligations. These are all known as the “legal basis for processing”.

Direct Marketing

With your consent, we may use your personal information to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

When you provide us with your personal information, we will request for your consent to receiving direct Marketing information from us. We give you a choice to ‘opt in’ or ‘opt out’ of receiving Marketing communications. If you ‘opt in’, we will send you Marketing communications by email, SMS or by push notification to keep you informed of new products, promotions and other information that we believe may interest you.

You can ask us to stop sending you Marketing information by contacting us at any time. You also have the option of ‘unsubscribing from our mailing list for Marketing communications, alerts and updates at any time thereby disabling any further Marketing email communication from being sent to you.

Details of how to unsubscribe will be included on each electronic mailing we send you. Alternatively, simply send an email to privacyusa@worldremit.com with “URGENT - UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.

Please note that if you request that we stop sending you Marketing messages, we may continue to send you service and administrative communications (such as transfer updates and other important or transactional information). 

Who we might share your personal information with

Your personal information is very important to us. However there are circumstances where it is necessary for us to share your information for legitimate business purposes (including operating our site and our Mobile App, and providing services to you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:

• Our affiliates - we share your information with our affiliates and other companies within the WorldRemit group of companies:
  • for our internal business, operational, management and service needs;
  • for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations;
  • to understand and support our consumers and other individuals who use our services, apps and visit our sites; and
  • to send Marketing communications.
• Third party processors which include people with whom we do business or who provides services to us. If we engage a third party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property. Processors may include:
  • Credit reference agencies or other service providers to verify Your identity or the identity of recipients of the money transferred through our services or for any other purpose related to providing our services;
  • Professional advisers, such as our auditors and lawyers;
  • Companies that capture or analyse information to help us understand how our services, sites and Mobile Apps are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide;
  • Companies that provide us with marketing assistance, including: the management of email marketing operations, SMS and other services that deploy marketing on the internet or social media platforms (such as Facebook and Google); the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or consumer engagement we do;
  • Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
  • Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps;
  • Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
  • Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganisation; and
  • Any successor in business to us.
• Fraud Prevention Agencies - Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
• Public Agencies - We release accounts or other personal information when we consider it appropriate to comply with the law, to enforce our Terms and Conditions and any other agreement to protect the rights, property, or safety of WorldRemit, our employees, consumers, our business partners and the public. In these circumstances, we will only provide them with the information they require to perform their function.
• Research companies - We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.

Links to Other Sites

Our sites may contain links to other websites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once You link to another website from our site You are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before You submit any data to these websites.

International transfer of your personal information

Due to the international nature of our business, we may need to transfer your personal information to other WorldRemit entities, to other third parties as noted in the “Who we might share your information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. 

How we keep your personal information secure

We have implemented appropriate technical and organisational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee the security of Your data transmitted to our site; and any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.

Protecting your own information

It is important to keep your password secure to prevent fraudulent use of your account. Do not disclose your password to anyone else and especially anyone who requests it from you by telephone or email. WorldRemit will never ask you to provide your password or personal information via email. Please be aware of the following:

• Change your password regularly and avoid using the same password on other websites to prevent hackers from access to your account;
• Avoid simple passwords that can easily be guessed;
• Be aware that public WiFi networks are risky and hackers may capture your online transactions and personal information. Only connect to a network you can trust;
• If you use a shared computer, make sure you log out immediately after you have finished using the website; and
• Beware of ‘phishing’ where criminals may attempt to steal your information by sending you bogus emails.

How long will we keep your personal information for

We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. Generally, unless applicable law or our legal and regulatory obligations requires a longer retention period, we will keep our records for at least seven years after you have terminated your relationship with us.

Your Rights

Subject to applicable law, you have certain rights regarding our processing of your relevant personal information, including:

• the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services, if you do not provide us with your personal information);
• the right to request access to your personal information, together with information regarding the nature, Processing and disclosure of those personal information;
• the right to request for the correction of any inaccuracies in your personal information;
• the right to request for the erasure of your personal information. This is also known as the right to be forgotten. We will keep a note of your name if you ask for your personal information to be erased;
• the right that we restrict our use of your personal information;
• the right to have certain personal information transferred to another company, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal information in reliance upon any other available legal basis); and
• the right to lodge complaints with a Data Protection Authority regarding the use of your personal information by us or on our behalf.

We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute. Therefore, exemptions or limitations may apply. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person, or if you request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

You can contact us at privacyusa@worldremit.com if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.

Any request for access to Your personal information must be in writing and we will endeavour to respond within a reasonable period and in any event within one month (three months for complex or numerous requests), in compliance with Data Protection Legislation. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.

 Automated decision making and profiling

In certain circumstances we may use automated decision making, including profiling, for example when it is in our legitimate interests to do so, or where we have a right to do so because it is necessary for us to enter into, and perform, a contract with you. We also use profiling to enable us to give you the best service across the WorldRemit Group including specific marketing which we believe you will be interested in.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects for you or affects you in any other significant way. If you are seeking to exercise this right, please contact us at privacyusa@worldremit.com.

Cookies and similar technologies

When you visit our site or use a Mobile App, we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our Cookie Policy.

Contact us

Questions, comments and requests regarding your personal information and our Policy are welcome and should be sent to privacyusa@worldremit.com or you can call us at 1-888-772-7771.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of Your information, You can make a complaint to the Attorney General of your State or Territory of residence, or to our regulator in your State or Territory of residence. You can find a list of regulators and their contact information and instructions here: https://www.worldremit.com/en/faq/file-a-complaint-usa

California Laws and Regulations

California Online Privacy Protection Act (“CalOPPA”)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. According to CalOPPA we agree to the following:

• Users can visit our site anonymously.
• Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
• Our Privacy Policy link includes the word 'Privacy' and can be easily found on the page specified above.

California Consumer Privacy Act (“CCPA”)

Your information

WorldRemit does not sell any of your personal information.

We may disclose your personal information to third parties for business purposes only. We do not collect or sell the personal information of persons under 16 years of age. The categories of personal information we collect about you (as detailed below) come from the following categories of sources:

• You, including through your use of our Services.
• Automatically collected from You.
• Our affiliate companies.
• Third parties.

Categories of Business/Commercial purposes for using your personal information

All the categories of personal information we collect about you (as detailed above) are used for the following purposes:

• Providing our services (money transfers, account servicing and maintenance, customer services, advertising and marketing, analytics and communication about our services).
• For our operational purposes, and the operational purposes of our service providers and integration partners.
• Improving our existing services and developing new services.
• Prevention, detection, protection and prosecution of security incidents, illicit or fraud related activity.
• Bug prevention, error reporting, and activities to maintain the quality or safety of our services.
• Auditing consumer interactions on our site.
• Short term use such as customizing the content of our website.
• Our legitimate interests in promoting our business.
• Any other use that we will inform you about.

Your Rights

Subject to exceptions, you may have certain rights regarding our processing of your personal information, including:

• The right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services, if you do not provide us with your personal information);
• The right to request access to your personal information. You have the right to request that we disclose the categories of personal information that we collect or use. You may also request the specific information that we have collected about you. However, we may withhold some information where the risk to you, your personal information, a third party, or our business is too great to disclose the information;
• The right to request for the correction of any inaccuracies in your personal information;
• The right that we restrict our use of your personal information;
• The right to request for the deletion of your personal information. We will delete your personal information on receipt of a Verifiable Consumer Request. You should also be aware that this right is qualified and not absolute. Therefore, we may refuse to delete your personal information if we need it for one or more of the following purposes:
• Contract:
  • To complete the transaction for which we collected your personal information;
  • To provide a product or service which you have either requested, or you would reasonably expect in the context of our relationship with you; and
  • To carry out a contract with the consumer.
• Security:
  • To detect security incidents;
  • To protect against malicious, deceptive, fraudulent, or illegal activity; and
  • To prosecute people responsible for such activities.
• Debugging, to detect and repair errors that affect intended functionality.
• To comply with California's Electronic Communications Privacy Act.
• Research: To engage in public or peer-reviewed scientific, historical, or statistical research, that:
  • Is in the public interest;
  • Would be seriously impaired or impossible to carry out without retaining the personal information; and
  • Has been consented to by the consumer.
• Internal purposes: To use it for a purpose that is:
  • Internal to WorldRemit; and
  • In-line with the reasonable expectations of the consumer, in the context of their relationship with your business.
• To comply with a legal obligation.
• For the establishment, exercise or defence of legal claims.
• Other purposes: To use it for any other purpose that is:
  • Lawful; and
  • Internal to WorldRemit.

How to exercise your rights of access and deletion

To exercise your rights, please submit a verifiable consumer request to us by sending an email to privacyusa@worldremit.com or you can call us at 1-888-772-777.  Only you, or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your personal information.

You may make a verifiable consumer request for access, deletion and portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

If you have an account with us, logging into your account and sending us a request through the account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised.

For security reasons(and notwithstanding any of the above), 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. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We will deal with your request within 45 days. If reasonably necessary, we can extend this period by an additional 45 days. We shall notify you if we extend this period.

Right of non-discrimination

You have the right not to receive discriminatory treatment from WorldRemit Corp. for exercising your CCPA privacy rights. Please note: this right is a “passive right” and so you cannot exercise it.

Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. However, we do not currently provide any financial incentives.

If you feel that you have received discriminatory treatment as the result of exercising your CCPA rights, you may contact us at privacyusa@worldremit.com. You can contact us about our privacy policy and practices at privacyusa@worldremit.com or at 1-888-772-7771.