Effective and last updated as of March 23, 2023
If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.
- Information We Collect Online
- How We Use Your Information
- How We Share Your Information
- Cookies and Other Tracking Technologies
- “Do Not Track” Signals
- Choices About Your Information
- Third Party Links
- Children’s Privacy
- Notice to California Residents
- How to Contact Us
We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:
Information You Provide
We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Site and Services. If you interact with a Platform that uses our Services, we will receive your Personal Data and process that Personal Data on behalf of the Platform.
- Register for an Account. To register for an account, you will provide us with your name, physical address, phone number, and you will create a password for future logins.
- Transfer Money. To transfer money, you will add recipient information to your account. You will provide us with the recipient’s name, physical address, phone number, email address, date of birth, driver’s license number or a government-issued identification card, and depending upon the type of transfer, the recipient’s bank account information or debit card information. To transfer money to the recipient you will provide us with your debit card information, including the number, CVV, and expiration date or banking details for ACH payments. We use third parties (including Vantiv and Wells Fargo) to process payments. Please review those third parties’ privacy policies for more information on their privacy practices.
- Identity Verification. To verify your identity when you use our Services, you will provide your name, email address, Social Security number (if applicable), and driver’s license or government-issued identification card (if applicable).
- External Bank Account Information. Depending on the Services you use, we may collect information regarding a bank account including the account name, account type, account number, and routing number.
- Contact Us. To contact us, you will provide us with your name, email address, and any other information you choose to provide.
Information as You Navigate Our Site
We automatically collect certain Personally Identifiable Information through your use of the Site, such as the following:
- Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from Site visitors on a city-regional basis.
Third Party Information
We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:
- Provide the Services, perform obligations under our agreements, and carry out related business functions;
- Process your transactions and send money transfers to your recipients;
- Verify your identity;
- Process your debit card application and provide you with a debit card;
- Collect payment for your use of the Services;
- Allow our partners to fulfill their promotional obligations to you;
- Contact you regarding our products and services that we feel may be of interest to you;
- Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
- Provide customer support to you or the Platforms, including to help respond to your inquiries related to our Services;
- Maintain and improve our Site and Services;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with legal obligations, audit requirements, and applicable law, including relating to customer identification, “know-your-customer” procedures, and anti-money laundering and counter terrorism financing.
We may share the information that we collect about you in the following ways:
- With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, and financial service providers who enable you to use certain features;
- With the bank we partner with to provide you with debit card services;
- With the recipients you transfer money to;
- With vendors to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- To protect you against actual or potential fraud, identity theft, unauthorized transactions, claims, or other liability;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding or in preparation for any of these events;
- With any other person or entity where you consent to the disclosure; and
- For any other purpose disclosed by us when you provide the Personally Identifiable Information or for any other purpose we deem necessary, including to protect the health or safety of others.
- Estimate audience size and usage patterns;
- Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
- Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
- Recognize when you return to the Site.
How You Can Opt Out of Cookies
You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.
You can opt out of Cookies set by specific entities by following the instructions found at these links:
- Google: https://adssettings.google.com
- Facebook: https://www.facebook.com/about/ads
- Microsoft: https://account.microsoft.com/privacy/ad-settings/
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
Other Types of Collecting Activities
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
Review and Request Changes to Your Information
You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at email@example.com.
To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at firstname.lastname@example.org.
We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.
The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
The CCPA’s privacy rights described below do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
Finally, as described in the “Collecting and Using Information” section above, we collect certain Personal Information in our role as a service provider for other entities. If you would like to make any requests or queries regarding Personal Information that we process on behalf of Platforms, please contact those entities directly. Your rights under the CCPA will depend on our relationship with you.
Notice at Collection of Personal Information
- Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Personal information described in California’s Customer Records statute (California Civil Code 1798.80(e) (telephone number, bank account number, debit card number, account information, as well as the categories listed in the “Identifiers” category above)
- Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
- Commercial information (records of products or services purchased, obtained or considered)
- Characteristics of protected classifications under California or federal law (age (40 and older)
- Sensitive Personal Information including Personal Information that reveals: your Social Security number, driver’s license, state identification card, or passport number
We collect Personal Information directly from California residents and from Platforms, consumer reporting agencies, identity verification providers, and publicly available sources. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with us, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with us
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing similar services
- Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service that is owned, or controlled by us, and to improve, upgrade, or enhance the service that is owned, or controlled by us
- Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction
Disclosure of Personal Information
|Category of Personal Information||Categories of Recipients|
|Name||Identity verification providers; payment processors; fraud prevention providers; financial service providers; marketing service providers; partner banks|
|Email address||Identity verification providers; financial service providers; marketing service providers|
|Postal address||Identity verification providers; payment processors; financial service providers; partner banks|
|Social Security number||Identity verification providers; fraud prevention providers; partner banks; financial service providers|
|Driver’s license number or passport number||Identity verification providers; fraud prevention providers; partner banks; financial service providers|
|Telephone number||Identity verification providers; financial service providers; marketing service providers|
|Debit card number||Payment processors; partner banks; financial service providers|
|Bank account number and information||Partner banks; financial service providers|
|Characteristics of protected classifications under California or federal law (age (40 and older)||Identity verification providers; partner banks; financial service providers|
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct by emailing us at email@example.com or by calling us toll free at 1-866-858-9928.
As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.
To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, you must submit:
- Your first and last name;
- Your mailing address;
- Your email; and
- Your date of birth.
To contact us for questions or concerns about our privacy policies or practices please email us at firstname.lastname@example.org or write to us at:
Pangea USA, LLC
1 N State Street STE#1350
Chicago, IL 60602