COLLECTION, USE, DISCLOSURE, AND SECURITY OF PERSONAL INFORMATION
This policy applies to personally identifiable information (“personal information”), which is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; social security number; call records; wireless device location). Personal information does not include “anonymous” or “aggregate” information – neither of which are associated with a specific person or entity.
Collection of Personal Information
We collect personal information when you e-mail, call, or otherwise communicate with us. We may also collect personal information when you call or e-mail our customer service representatives, enter information on our Web sites, submit survey responses, pay for service, or submit a job application or résumé. If you provide personal information to us in connection with a co-sponsored Web site, this policy will apply to our use of the information and the co-sponsor’s policy will apply to their use of the information.
Use of Personal Information
We use personal information for a variety of business purposes, including for example, to complete transactions and bill for products and services; verify your identity; respond to your requests for service or assistance; anticipate and resolve actual and potential problems with our products and services; create and improve products and services; suggest additional or different products or services; make internal business decisions about current and future offers; provide personalized service and user experiences; and protect our rights and property. If you submit a job application or résumé, we use personal information to communicate with you and, subject to applicable law, evaluate your qualifications for employment. We may also use personal information to contact you about Transfer Global or third-party products, services, and offers that we believe you will find of interest. We may contact you by telephone, postal mail, e-mail, or other methods. You may opt-out of receiving marketing communications from us at any time as outlined below in Choices Regarding Use of Your Information.
Disclosure of Personal Information
We do not sell, rent, or otherwise provide your personal information to unaffiliated third-parties to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows:
* With your consent. We may disclose personal information about you to third-parties with your consent. We may obtain your consent in several ways, such as in writing; online, through “click-through” agreements; orally, including through interactive voice response; or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.
* Transaction processing. We may disclose personal information to third-parties who complete transactions or perform services on our behalf (for example, billing, shipping, customer service, and marketing), transactions on your behalf (for example, verification of your account information at your request to some third-party business), or transfers related to your service (for example, number portability). We typically restrict by contract the manner in which these third-parties may use and disclose personal information about you without your consent.
* Business transfers. We may disclose personal information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which personal information could be transferred to third-parties as a business asset in the transaction.
* Legal process & protection of Transfer Global and others. We may disclose personal information or communications where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (for example, lawful subpoena, court order, E-9-1-1 information); to enforce or apply agreements; to initiate, render, bill, and collect for services and products; to protect our rights or property; in connection with claims, disputes, or litigation; to protect users of our services and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or if we determine disclosure is necessary in an emergency situation.
Security and Retention of Personal Information
We use a variety of physical, electronic, and procedural safeguards to protect personal information from unauthorized access, use, or disclosure while it is under our control. Although we cannot guarantee that loss, misuse, or alteration of your personal information will not occur, we strive to prevent such occurrences.
Our practices and procedures are designed to limit personal information access to those Transfer Global employees and agents with a legitimate need to access such information. Transfer Global employees are bound by confidentiality obligations and our Code of Conduct, which obligate them to protect the confidentiality of our customers’ personal information. Violations subject employees to disciplinary action, up to and including termination.
We retain personal information for as long as we have a business need or as applicable laws, regulations, or government orders require. When we dispose of personal information, we use reasonable procedures to erase or render it unreadable (for example, shredding documents and wiping electronic media). We will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred and creates a risk of identity theft or service disruption, or as otherwise required by law.
Access and Choice
Access to Your Information
You may access and modify your contact information by contacting Customer Service. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical.
Choices Regarding Use of Your Information
We want to provide you with meaningful choices regarding our marketing communications and you may choose to limit or opt-out of certain communications from Transfer Global at any time. While you may elect not to receive marketing information from us, if you enter into a contract with us, you will continue to receive relevant invoices, customer-service and transactional notices, and similar communications.
OTHER PRIVACY INFORMATION
Cookies, Web Beacons, and Similar Technologies
Customer Service Monitoring
We may monitor and record phone calls, e-mails, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests.
Other Governing Terms
This policy does not modify or alter any applicable agreement you have with Transfer Global. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency.