Last modified: July 30, 2020
1. A few definitions:
When we say “we,” “us” and/or “Pangea” we are referring to Pangea Universal Holdings, Inc. (“PUH”), Pangea USA, LLC (“PUSA”) and any of our subsidiaries or affiliates. When we say “you,” “customer” or “user” we are referring to the individual that has registered to use Pangea’s Services.
2. Information we collect from you and why we collect it
We collect information from you through various mechanisms, including: (1) your transactions with us and the Network; (2) your use of our Website, Mobile Applications, Network and Services; and (3) other third parties, including but not limited to consumer reporting agencies, identity verification services, and publicly available sources.
3. Personally Identifiable Information
Personally identifiable information (“PII”) is information that we can link to you personally and includes data like your name, address, date of birth, email address, phone number, or mobile device’s unique identifier. You do not have to provide PII to access certain information on the Website or download the Mobile Application, but we collect certain PII concerning you and the beneficiary of the money transfer when you create a Pangea account and create a transfer.
The following are examples of PII that we may collect from you in the course of providing our Service:
- Your full name, address, email address, date of birth and telephone number(s). We may also collect certain sensitive information from you, including your bank account number, debit card number, an ID and social security number.
- PII that you provide to us in the course of your participation in promotional or rewards programs.
- Third-party PII that you may provide to enable the transfer of funds, such as your recipient’s full name, address, phone number, email address, ID and date of birth. We may also collect from you sensitive financial information about your recipient depending on the type of transfer you select, including but not limited to, bank account or debit number information. If you provide us with PII and sensitive financial information about your beneficiary, you represent that you have obtained permission from your beneficiary to provide this information.
- Information about your usage of the Service, including your transaction history, how you use the Service to send or receive money, and to whom you send money.
- Information that we lawfully obtain from third parties, including credit reporting agencies and identity verification and database service providers.
- Information provided during recorded communications with our Customer Service department, including telephone calls and electronic communications.
We collect this information for the following purposes:
- To process your transactions;
- To verify your identity;
- To collect payment for your use of the Service;
- To allow our partners to fulfill their promotional obligations to you;
- To troubleshoot problems with the Service;
- To comply with applicable laws and regulations relating to customer identification, “know-your-customer” procedures, and anti-money laundering and counter terrorism financing;
- To detect and prevent fraud and other illegal uses of the Service;
- To send you marketing notices, service updates, and promotional offers;
- To survey information that will be used to monitor or improve the use of
our Service and overall customer satisfaction.
4. Other Information
When you use the Service, Pangea and our third party partners may collect non-personally identifiable information that does not reveal your specific identity (“Other Information”). We may collect this information through (i) server log files, (ii) environmental variables, (iii) cookies, (iv) web beacons, and (v) information that you voluntarily provide.
Examples of Other Information that we may collect from you:
- IP Address: Your internet protocol (“IP”) address is a number that is automatically assigned to the computer that you are using by your Internet service provider. This number is identified and logged automatically in our server log files whenever you visit the Website. We and our third-party service providers use IP addresses for administering the Website. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
- Environmental variables, such as your MAC address, computer type, screen resolution, OS version, internet browser and version are collected by most websites, and can be used to optimize your experience on the Website.
- Cookies: Cookies are very small files that we send to your computer to uniquely identify your browser. Cookies allow us to collect data and other information about your use of our Services and your transactions with us. They also allow us to customize the Service so you can use it more efficiently. Most browsers automatically accept cookies as the default setting. However, you can modify the settings to reject cookies or to prompt you before accepting a cookie from the websites you visit by editing browser options. If you decide not to accept cookies, you may have a less satisfactory experience using our Service.
- Web Beacons:Web beacons (internet or pixel tags, single-pixel, clear, invisible and 1X1 GIFs and web bugs) are tiny graphic files placed on a web page that send a signal when a user has visited that page, allowing the website to collect standard access information, such as time and date of a page view, and a description of the page on which the web beacon resides. Our web beacons do not contain any PII, and we do not link web beacons to information about you.
Other Miscellaneous Information (e.g. your interests, your geographic location, etc.) is collected when you voluntarily provide such information to us. Additionally, we may aggregate PII in a manner that does not personally identify you. Such aggregated information is considered Other Information. Because this Other Information does not personally identify you, we may use such information for any lawful purpose. In addition, we reserve the right to share such Other Information with anyone to the extent permitted by law.
- Interest-based Ads: Pangea displays interest-based advertising on Pangea-owned and operated sites, and unaffiliated sites, using information you make available to us when you interact with our Website, content, or Services. You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website.
5. How and when we share your information
We do not disclose information about current or former consumers except as permitted by law.
Examples of disclosures of information permitted by law include the following:
- disclosures made to effect, administer, or enforce a transaction requested or authorized by the consumer, or in connection with the servicing or processing of a financial product or service requested or authorized by the consumer;
- disclosures made to protect the confidentiality or security of records pertaining to our consumers, our Services and products, or the transactions we process or handle;
- disclosures made to protect you against actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
- disclosures made to resolve consumer disputes or inquiries; and
- disclosures made to comply with federal, state and local laws or regulations and other legal requirements, such as subpoenas or other legal processes.
Please, note that this list of examples of the types of sharing of information that is permitted by law is not meant to be comprehensive. We reserve the right to transfer any and all information that we collect to any third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
If you use our Website, Mobile Application or Network, or otherwise provide us with data from outside the United States, you acknowledge and agree that your information may be transmitted outside your resident jurisdiction.
6. Policy against the sale of information
We do not sell or rent information that we collect from you to third parties for their promotional purposes unless we receive your permission to do so. Nevertheless, we may share information, including PII, about you with:
- Third-party partners and service providers under contract with Pangea that help us with our business operations, such as transaction processing, identity verification, compliance checks, fraud prevention, and marketing. These third parties are prohibited from using your information for their own separate business purposes. These companies are authorized to use your information only as necessary to provide these services to us.
- Third parties that we partner with to offer additional products and services, but only when you elect to participate and/or to receive information about those additional products and services.
- Law enforcement, government officials or other third parties, but only: (i) in connection with a formal request, subpoena, court order, or similar legal procedure; or (ii) when we believe in good faith that disclosure is necessary to comply with the law, prevent physical harm or financial loss, report suspected illegal activity, or to investigate violations of our Terms and Conditions.
7. Safeguards to protect your privacy
We take reasonable measures, including the implementation of administrative, technical, and physical safeguards, to help protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.
We also require a username and password from each user who wants to access their information on our Website, Mobile Application and Network. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
Finally, access to your information is restricted to employees who require your information to perform any duties in connection with the Service. Although Pangea’s measures conform to industry standards, Pangea makes no claim or warranty as to the security or impenetrability of Pangea’s system under unusual circumstances or its resilience to future potential sophisticated attacks.
8. Privacy practices of third parties
9. Retention of user information
We will retain your information while your account is active and beyond as needed to:
- provide you with the Service;
- comply with record keeping requirements and legal obligations;
- resolve disputes; and
- enforce agreements.
In the event that you deactivate your account, all PII and account information (e.g., transfer history) will be retained for at least ten years.
During this time you can request access to your account by calling our customer service team at +1 (844) 611-2040.
10. Choices you can make about our use of your information
Federal and state laws allow you to restrict the sharing of your information in certain instances. However, these laws also state that you cannot restrict all types of sharing. Because we have chosen to refrain from certain types of data sharing, the only forms of sharing of your information that you may restrict are as follows:
- If, after giving us your permission to share your information with third parties, you decide that you no longer want us to share such information, you may contact us by email at email@example.com.
- California Residents. Please see below
12. Your California privacy rights
California Shine the Light Law
California Civil Code Section 1798.83, also known as California’s “Shine the Light” law permits residents of California to request certain details about information we may disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us by email at firstname.lastname@example.org
California Consumer Privacy Act
The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide additional privacy-related information to residents of California. If you are a California resident, please note the following about how we collect, use and disclose your personal information, including additional rights you may have to your personal information:
– CA Personal Information. Consistent with the “Personally Identifiable Information” and “Other Information” sections above, we may collect certain categories of information about California residents, such as:
– Identifiers: name, address, email address, date of birth, telephone number(s), identification number, social security number, IP address, and MAC address;
– Commercial information: bank account number, debit card number, transaction history, how you use the Service to send or receive money, and to whom you send money;
– Internet or Other Electronic Network Activity: information collected through cookies and web beacons; and Other information: information provided in the course of participation in promotional or rewards programs, third-party personal information provided to enable the transfer of funds to the recipient, information lawfully obtained from third parties, including credit reporting agencies and identity verification and database service providers, and information you provide during recorded communications with Customer Service.
– Sources of CA Personal information. Consistent with the “Information we collect from you and why we collect it” section above, personal information is provided directly by you (or by the devices you use) via your transactions with us and the Network and when you use our Service. Personal information is also provided by other third parties, including but not limited to consumer reporting agencies, identity verification services, and publicly available sources.
– Use of CA Personal information. Consistent with the “Personally Identifiable Information” and “Other Information” sections above, we may use your personal information as follows:
|Categories of Personal Information||Business or Commercial Purposes||Sources of Personal Information||Categories of Third Parties Personal Information is Shared With|
|Identifiers||To process your transactions; to verify your identity; to collect payment for your use of the Service; to allow our partners to fulfill their promotional obligations to you; to troubleshoot problems with the Service; to comply with applicable laws and regulations; to detect and prevent fraud and other illegal uses of the Service; to send marketing notices, service updates, and promotional offers||Consumers and third parties||—|
|Commercial Information||To process your transactions; to verify your identity; to collect payment for your use of the Service; to troubleshoot problems with the Service; to comply with applicable laws and regulations; to detect and prevent fraud and other illegal uses of the Service; to survey information that will be used to monitor or improve the use of our Service and overall customer satisfaction.||Consumers and third parties||—|
|Internet or Other Electronic Network Activity||To process your transactions; to verify your identity; to collect payment for your use of the Service; to allow our partners to fulfill their promotional obligations to you; to troubleshoot problems with the Service; to comply with applicable laws and regulations; to detect and prevent fraud and other illegal uses of the Service; to send you or your recipient/beneficiary marketing notices, service updates, and promotional offers; to survey information that will be used to monitor or improve the use of our Service and overall customer satisfaction; to administer the Website; and/or for interest-based advertising and other marketing purposes||Consumers; Consumers’ devices; and third parties||Third-party advertising networks|
– CA Personal information Sold or Disclosed For Business Purposes.
– Sharing Personal information for Business Purposes: In the preceding twelve months, we may have shared the following categories of personal information for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, and Other Information.
– Sale of Personal information: We share information collected from cookies and web beacons, such as how you interact with our site, with advertising technology partners in order to create user profiles and present advertising messages based on your preferences, which is considered a sale under California law.
– California Privacy Rights. As a California resident and subject to certain exceptions, you may have the right to access, correct (rectification), and/or delete your personal information. You also have the right to request information about the personal information we have “sold” or disclosed for business purposes, by contacting us at email@example.com.
– To protect your privacy and security, we will verify your identity before responding to such request, and may request you provide us your name, email, and transaction history, or additional proof where necessary. You will not be penalized for exercising your rights to your personal information.
– “Do Not Sell My Personal Information.” You also have the right to opt-out of Pangea “selling” your personal information as defined under CCPA. To exercise this right, please click here. If you are making this request on behalf of someone else, we may request the authorized agent provide us a signed power of attorney. If we have actual knowledge that you are under the age of 16, we will not sell your personal information without proper consent.
13. Your Vermont privacy rights
Pangea will not disclose any PII to nonaffiliated third parties except as necessary to effect, administer, or enforce a transaction that you have requested or authorized. Notice and opt-in consent will be required for any other form of disclosure outside established exceptions pursuant to Article 4 of The Vermont Privacy of Consumer Financial and Health Information Regulation.
Chicago, IL 60654
© Pangea Universal Holdings, Inc. 2019
© Pangea USA, LLC 2019
© Pangea Latin America, S.A. de C.V. 2019