1. Background
The Services are powered and hosted by GMT. During your registration on the Site or opening an Account, you are registering with GMT. An “Account” means a unique login to the Site, the App or other platform provided by GMT though which you may access the Services.Services are provided pursuant GMT user agreement that are separate from this Privacy Policy and are posted at the Site (the “Agreement”). Your rights and obligations and those of GMT with respect to your funds are detailed in the Agreement and not in this Privacy Policy.The Site may be hosted or operated by an Agent. Agent assists us in supplying our Services. Agent may, separately, supply you with other services governed by separate terms and policies (each a “Third Party Servicer Agreement”). We are not party to Third Party Servicer Agreements or their related privacy policies that form part of them and we are not liable for the acts of Third Party Servicers that are not also acting as Agents for the activity in question.
2. Information we collect
We collect personal information about you from a variety of sources in the course of providing the Services. Personal information is any information or data relating to you that may be used to identify you, either directly or indirectly, or to contact you. Personal information we collect about you and the sources of such personal information include the following:
We collect personal information directly from you when you express an interest in obtaining information about us or the Services, when interact with the Site, or when you contact us. The personal information that we collect depends on the context of your interactions with us and the Site, the choices you make, and the products and features you use. The personal information we collect may include but is not limited to the following:
Your name; phone numbers; email addresses; mailing or residential addresses; job titles; usernames; passwords; billing addresses; contact or authentication data; contact preferences; debit/credit card numbers; source of funds (description of document); copy of identification (document); unique governmental identification number; IP address; place of birth; date of birth; and beneficiary’s information (full name, address, and country; bank, bank code, account number and account type).
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
We collect personal information when you submit personal information on applications or other forms to us or our Agents, including in connection with sending and receiving money transfers, through your enrollment and participation in loyalty programs, and when you provide additional information that we may reasonably request for fraud prevention purposes.In case your mode of payment is ACH Pull, we collect information relating to your bank accounts such as account number and routing number which are obtained during the process of your bank account verification. Such bank account verification is completed by GMT using the services of its third party partners or vendors.
We collect information about your transactions with us, including transaction history, frequency of use, amounts transferred, origin currency, original payment method, destination currency, service type, net amount, fees, exchange rate and receiving amount.
In connection with identity verification, fraud prevention and similar security purposes, we collect and/or confirm certain identity-related information, financial background and similar information through third party sources such as our business customers, government agencies and consumer reporting agencies.
We collect information regarding your online activity as described in the section below titled “Internet Technology”.
We may collect personal information otherwise with your consent or as permitted or required by law.
3. How we use personal information
We use personal information to provide the Services, and for the following purposes:
3.1. A lot of the information we collect is collected by our Agent on our behalf, so Agents will often collect, store and provide to us all information you provide. We may also use an Agent to deliver information to you, such as transaction information and receipts.
3.2. Authorizing and processing your transactions, including effecting and administering money transfers and payments and ensuring proper payment to the designated recipient of funds.
3.3. Collecting amounts owing to us, and otherwise enforcing and collecting on your Accounts or agreements with us.
3.4. Meeting legal, regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in the United States or in other countries. For identity verification purposes, senders and recipients of money transfers or payments may be required to produce valid identification (or consent to verification by other means) before releasing funds.
3.5. For marketing and promotional purposes, unless you “opt out” or withdraw consent, as described in the section entitled “Offers, Promotions and Opting Out” below.
3.6. Maintaining business and transaction records for reasonable or required periods of time, and generally managing and administering our business.
3.7. In connection with certain business transactions relating to GMT, its business or assets, as further described in the section entitled “Information We Disclose” below.
3.8. Meeting insurance, audit and processing requirements.
3.9. Otherwise with your consent or as permitted or required by law.
4. Information we disclose
We may disclose your personal information to our Agents, Partners (as defined below) and to unaffiliated third parties as follows:
4.1. To Provide Services. In order to provide the services, we may disclose personal information to the recipient of a money transfer or payment, to our Agents, Partners (each “Partner” being any third party service providers engaged by GMT that assists in the provision of the Services including but not limited to, Agent and any correspondent agents of GMT), and, if applicable, and any intermediary banks or other financial institutions or financial services companies involved in the transaction or our Services.
4.2. To Business Partners. Some of our services or programs that you participate in are provided jointly with other third-party business partners, and certain personal information may be disclosed to these third-party businesses for the purpose of administering the service or program.
4.3. For Marketing Purposes. We may disclose personal information to third parties for marketing and promotional purposes, unless you “opt-out” or withdraw consent to this disclosure, as described in the section entitled “Offers, Promotions and Opting Out” below.
4.4. To Third Party Service Providers. We may transfer personal information to Agents, Partners, vendors or third party service providers, and affiliates of GMT that perform services on our behalf, for example, marketing, information technology, payment processing, data analysis, and/or data hosting, email delivery, and customer service. Some of these third party service providers may be located outside of the United States, and your personal information may be collected, used, disclosed, stored, and processed in or outside of the United States. In the Agreement, these third parties are referred to as Third Party Servicers or Partners. We take reasonable measures to ensure that personal information that may be processed by these third party service providers on our behalf is protected and not used or disclosed for purposes other than as directed by us, subject to legal requirements in the United States and other foreign countries. We may allow selected third parties to use tracking technology on the Site, which will enable them to collect data on our behalf about how you interact with our Site over time. This information may be used to among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
4.5. Affiliates. We may share your information with our Affiliates, in which case we will require those Affiliates to honor this privacy policy. “Affiliates” include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
4.6. Business Transactions. Your personal information may be used by us and disclosed to third parties connected with financing, securitization, insuring, sale, assignment, or other disposals of all or part of our business or assets (including, for example, your Account with us).
4.7. Successors and Assigns. Successors and assigns of GMT and/or its business or assets may use and disclose your personal information for similar purposes as in this Privacy Policy.
4.8. Legal, Regulatory. We may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including applicable United States and foreign laws). This may include lawful requirements to disclose personal information to government authorities in the United States and in foreign countries, for example disclosures in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations in the United States or in foreign countries.
5. Offers, promotions and opting out
We may use your personal information and information about your use of the Services for marketing and solicitation purposes. This may include sending you offers, promotions or information about additional products and services that may be of interest to you. In addition, we may disclose your contact information to third parties so that they may provide information about their products and services that may interest you. These third parties may include, as examples:
5.1. Agents
5.2. Affiliates
5.3. Financial services companies, such as banks, credit card companies, brokerage houses, mortgage lenders and mortgage originators
5.4. Non-financial companies such as retailers, home furnishers, clothing stores, catalogue companies, florists, direct marketers, telephone companies, airlines, publishers and other providers of goods and services.
You may “opt out” or withdraw consent to the use and/or disclosure of your personal information for the purposes described in this section at any time by checking the appropriate box on an online or offline form, if available, or by contacting us as described in “Contact Us” below. If you do not “opt out” or withdraw your consent as described above, we will assume that you consent to our use and disclosure of your personal information for marketing and solicitation purposes as described in this section.
6. Deletion of account
Upon your request for deletion of your Account or the personal information that we hold, we will process the request and delete your Account along with all of your records and personal information. In accordance with Federal and State regulations pertaining to money transfers, we will retain your records in archive for as long as necessary to adhere with our record keeping obligations. We will only utilize the archive for limited purposes such as to fulfil our regulatory obligations or to adhere to any request from a regulatory body having jurisdiction over our activities.
7. Electronic communication
Some of the Services are made available using online forms on the Site. Personal information you provide on online forms or by other electronic means will be collected used and disclosed as described generally in this Privacy Policy.
In addition, when you visit or use the Site, we collect information about the domain and host from which you access the Internet; your computer’s Internet address; the browser and operating system software you use; the date and time you access this Site and the Internet address of the site from which you linked to this Site when you visit us. We use this information to diagnose, administer and optimize this Site and web-related services. When registering or creating an Account with us, we collect your password, login name and other information we may request in order to identify you, maintain security of this Site and verify and control access to your Account or online profile. If you make inquiries through the e-mail links, forms or other contact methods provided on this Site, these inquiries are forwarded to the relevant office or department, and are used to respond to your inquiry and maintain a record of correspondence.
We use Internet technologies like cookies and web beacons to facilitate the services we provide on this Web site and your use of this Web sites, including:
7.1 To assist us in providing services to you;
7.2. To allow you to navigate the Site during your visit without having to re-enter your password;
7.3. To store your preferences and other information and to track activity on our website;
7.4. To better understand the effectiveness of our promotional campaigns;
7.5. To determine whether you came to our site from a banner ad or an affiliate website;
7.6. To deliver Information specific to your interests on additional websites; and
7.7. To determine whether you’ve acted on our promotional messages
A “cookie” is a text file placed on your computer’s hard drive by a web server, which allows for personalization of certain aspects of your visit to that Web site. “Web beacons” are transparent electronic images placed in the web code that collect non-personal information while visiting a web site. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies may limit the performance of the Site. If cookies are disabled, certain features of our Site may not function properly, and you may not be able to register or use your Account.
8. Children’s privacy
The Services are not directed at children under the age of 13. We do not knowingly collect or maintain personal information from persons under the age of 13. Information collected about persons between the ages of 13 and 18 (or the legal age is in their jurisdiction), is only collected with parent or guardian permission. If we learn that we have inadvertently collected personal information of persons under the age of 13 years old, or between the ages of 13 and 18 years old without parent or guardian permission, we shall immediately take steps to delete the information as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at the contact information listed below.
9. External sites
This Site may be linked to or from third party websites. These links are provided as a convenience only, and this website is not responsible for the content or privacy practices of Sites that are linked to or from this Site. You are advised to review the privacy policies of any third party websites you visit as GMT is not responsible for such third-party services.
10. Your consent
Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).
Generally, by providing us with your information including personal and bank account related information, we will assume that you consent to our collection, use and disclosure of such information for the purposes described in this Privacy Policy. In using this service, you also consent to entering your bank account related information (e.g. internet banking credentials and MFA responses) in order to enable GMT and its Agents and Partners to verify the ownership of such bank accounts. Such verification will be completed by GMT using the services of its third party service providers.
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide all or some of our products or Services. Note also that where we have provided or are providing Services to you, your consent will be valid for so long as necessary to fulfil the Services and for the purposes described in this Privacy Policy or as otherwise described at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to The United States and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).
We may also be required or permitted under applicable law to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
11. Confidentiality and security
We endeavor to maintain physical, electronic and procedural safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, Agents, Partners, representatives and mandataries that require access to your personal information in order to fulfill their job requirements will have access to your personal information.
No data transmission over the Internet or the telephone can be guaranteed to be perfectly secure, and any personal information you submit to us or access electronically or over the telephone is done at your own risk, and this website does not guarantee or warrant the security of information transmitted in these manners. You should be aware that third parties may unlawfully intercept your transmissions or may wrongly instruct you to disclose personal information to them while posing as this website and you should exercise caution when providing personal information to any person.
Our record retention policies dictate that we maintain information about you, including your opt-out choices, for a fixed time period. If you do not perform another transaction during the fixed time period, your Information, as well as your opt-out choice will be removed. If you perform another transaction or otherwise provide us with personal information thereafter, you will be afforded another opportunity to opt-out.
12. How long do we keep your information?
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process or store your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
13. Access and correction
We may establish and maintain a file of your personal information for the purposes described in this Privacy Policy, which will be accessible at the location listed in the Contact Us section below. If you wish to request access or correction of your personal information in our custody or control, you may write to the mailing address provided below, with attention to the Chief Privacy Officer. Your right to access or correct your personal information is subject to applicable legal restrictions. To protect your privacy and security, we may require additional information to verify your identity when requesting access or correction.
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. We may share your personal information for our everyday business purposes, such as to process your transactions, maintain your Account(s), respond to court orders and legal investigations, or report to credit bureaus. We may also share personal information as stated above in the section entitled “Information We Disclose.” You may not limit sharing of this information. Certain states may have additional rights.
14. Changes
We reserve the right to modify this Privacy Policy from time to time. You can get updated versions of this Privacy Policy by calling us at the telephone number listed below or by visiting the Site. We urge you to review this Privacy Policy frequently to obtain the current version. Your continued use of the services or provision of personal information following any changes to this Privacy Policy constitutes your acceptance of any such changes.
15. California residents have specific privacy rights
If you are a resident of California, you are granted specific rights regarding access to your personal information.
While the California Consumer Privacy Act of 2018 (“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 the Gramm-Leach-Bliley Act (“GLBA”). GMT is subject to GLBA as a provider of money transfer services, as such certain Personal Information will not be subject to CCPA. For California residents, personal information not subject to GLBA may be subject to CCPA rights as outlined below.
15.1. Right to know and access personal information
You may submit a verifiable request to be informed about the (1) categories of personal information collected, sold, or disclosed by us, (2) purposes for which categories of personal information are collected or sold by us, (3) categories of sources from which we collect personal information, (4) categories of third parties with whom we disclosed or sold personal information, and (5) specific pieces of personal information that we collected about you during the prior twelve months.
115.2. Right to request deletion of personal information
Subject to certain exceptions, you may submit a verifiable request that we delete the personal information about you that we collected from you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers with whom we shared your personal information to also delete your personal information from their records.
There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to: (1) retain your personal information to complete a transaction, provide a good or service, fulfill the terms of a written warranty, or to perform under a contract between us; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity; and (3) comply with the law.
15.3. Verification
Requests for access to or deletion of personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To request access or deletion, you can contact us as per the contact us section in this Privacy Policy. To verify your identity based on information previously provided to us, we may request additional information.
You have the right to opt-out of the sale of your personal information.
15.4. Right to opt-out of the sale of personal information
You have the right to opt-out of the sale of your personal information.
15.5. Right to equal service and price
You have the right not to receive discriminatory treatment by a business for the exercise of your CCPA privacy rights, subject to certain limitations.
15.6. Right to initiate a private cause of action
You have the right, if certain parts of your personal information are part of a data security breach, to initiate a private cause of action.
15.7. Right to correct inaccurate personal information
If you believe that the personal information we have about you is incorrect, you may submit a request for such personal information to be corrected. We shall use commercially reasonable efforts to correct the personal information we hold about you.
15.8. Right to limit use and disclosure of sensitive personal information
You have the right to limit our use of sensitive personal information (“SPI”) to what is necessary or reasonably expected of us in order to perform the Services. If we use SPI beyond what is necessary to provide the Services, we shall provide you notice of the additional purposes for our use of SPI and remind you of your right to request that we limit the use of the SPI.
SPI is a subset of personal information that reveals (i) your social security number, driver’s license number, state identification card or passport number; (ii) your Account log-in, financial account information, debit or credit card number in combination with any password or access code to grant access; (iii) your precise geolocation; (iv) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (v) the content of your mail, email or text messages unless we are the intended recipient of said communications; and (vi) your genetic data.
15.9. Submit requests
If you are a California resident and would like to exercise your rights under the CCPA, please send your request to the contact information listed in the Contact Us section of this Privacy Policy with “Your California Privacy Rights” as the subject. Once you contact us, we may need to confirm your identity to process the request.
15.10. Authorizing an agent
If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please send a message to the email in our Contact Us section of this Privacy Policy and attach a written authorization signed by the resident.
15.11. Do not track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
16. Contact us
If you have any questions or concerns about how we collect, store, process or disclose information concerning you please contact us or our Agent:
Golden Money Transfer, Inc. dba Inyo
45 Prospect Street, Suite 201, Cambridge, MA 02139
Tel: 1-888-702-5656
Email: info@gmtnorthamerica.com
