I. EFFECTIVE DATE
July 1st, 2019
II. PRIVACY REGULATION
The privacy provisions of the Gramm-Leach-Bliley Act 15. U.S.C §§6801-6809 (“GLBA”) require financial institutions to adhere to specific requirements concerning the protection and disclosure of non-public personal information (“NPI”) about consumers and customers of the financial institution. Since Monty Global Payments USA, LLC (“MGP”) is an authorized Agent of Community Federal Savings Bank (“CFSB”); a money transmitter that is registered as a Money Services Business (“MSB”), it falls within the GLBA definition of financial institution as it obtains nonpublic personal information from the consumers who use its services.
The GLBA requires financial institutions to explain their information-sharing practices to their consumers and to safeguard sensitive data. The GLBA regulates the sharing of personal information about individuals who obtain financial products or services from financial institutions. Under the GLBA, a “consumer” is defined as an individual, or that individual’s legal representative, who obtains or has obtained a financial product or service from a financial institution that is to be used primarily for personal, family, or household purposes. Consumers do not need to be provided a privacy notice as long as a company does not share consumers’ information with nonaffiliated third parties.
MGP shares information for its own marketing purposes and for joint marketing with other financial companies. In addition, MGP may also share U.S. consumers’ personal information with its affiliates or nonaffiliates for marketing purposes. MGP shares information with affiliates about consumers’ transactions and experiences for everyday business purposes. MGP does not share or obtain customers’ creditworthiness information as part of providing financial services with its affiliates. MGP’s Privacy Notice is therefore based on providing an opt out for the consumer for information sharing related to its own marketing purposes and joint marketing with affiliates, nonaffiliates and financial companies.
III. OUR COMMITMENT TO PRIVACY
IV. ROLES & RESPONSIBILITIES
V. APPLICABILITY OF POLICY
VI. THE INFORMATION WE COLLECT
The types of personal information we collect and share depends on the products or services you have with us. We may collect the following information about the Sender and Beneficiary, which may include non-public Personal Information (“NPI”):
- Government issued identification information, such as driver’s license, state identification, passport, visa, Social Security or tax identification number;
- Contact information, such as name, address, email address, mobile and home telephone number, age, date of birth, gender, citizenship, country of birth, nationality, occupation and marital status;
- Account balances and transaction history;
- Credit, debit, bank account and payment history information;
- Computer and mobile device information, such as the domain and host you use to access the Internet, your computer’s IP address, mobile device geolocation, number and other information from and about your device (such as device properties, settings, applications, stored information and usage) and carrier, the browser and operating system software you use, websites you have visited or later visit, social profile and network information, the date and time you access our website, the internet address used to link to our website when you visit us, and cookie information; and
- Any and all additional information that you choose to provide us to obtain additional Services.
You consent to our collection, storage and transfer of information by computers or storage devices in the United States and elsewhere.
VII. HOW DO WE PROCESS YOUR INFORMATION?
We may Process your 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 employees and our partners to fulfill their obligations to you;
- to troubleshoot problems with the Service;
- to comply with applicable laws, regulations, and rules, such as those relating to "know-your-customer" and anti-money laundering requirements;
- to detect and prevent fraud and other illegal uses of the Service;
- to send you marketing notices, service updates, and promotional offers, both on our website and on third-party websites;
- to provide you with advertising, search results, and other content based on your location, when you provide us access to location services; and
- to respond to your requests.
VIII. WHEN DO WE COLLECT YOUR INFORMATION?
We collect your personal information, for example, when you:
- send or receive money, complete a payment, or use or request other products or services from us or other financial companies;
- submit information to us or other third parties on applications, forms, and by other means, including when you contact our customer service team;
- use or visit our or other online sites (for example, to complete a transaction, manage your accounts, provide your choices, and provide us feedback);
- enter a promotion, register for email alerts or marketing communications, or join a loyalty program; and
- use our mobile app or internet sites, such as www.clicktransfer.us.
We also collect and aggregate data to corroborate information about you from a variety of sources, including without limitation, computer systems and mobile devices; third party sources such as our business clients, government agencies, advertising agencies and networks, social media operators and networks, and other suppliers of information; and consumer reporting agencies. We may collect, track and combine information across devices, platforms and transaction channels. We may retain Personal Information for a time period longer than that required by law as part of our business needs and if doing so is not prohibited by law.
IX. DO WE SHARE INFORMATION?
MGP does not sell or rent the information we collect to third parties for their promotional purpose unless we receive your permission to do so. Nevertheless, we may share information about the Sender and the Beneficiary (including NPI) in the following manners and under the following conditions:
Disclosures not subject to an opt-out include:
- disclosures necessary to effect, manage or execute a transaction you requested;
- disclosures to our authorized vendors, or service providers; and
- disclosures permitted or required by law or disclosures to prevent fraud or other illegal activities.
Without obtaining your consent, MGP has the right to share your personal information for the following reasons:
- for our everyday business purposes, such as to process your transactions; manage our consumer relationships; provide requested products and services; maintain your account(s); respond to court orders and legal investigations; report to credit bureaus; gather information about website access, usage and performance; enhance your consumer experience; validate your creditworthiness or your identity; in connection with a merger, acquisition or sale of the company or any of its assets; make risk decisions; detect and prevent fraud and other illegal activity; or as otherwise permitted or required by law;
- for our marketing purposes such as to offer our products and services to you or notify you about future events and promotions;
- for our affiliates’ everyday business purposes such as information about your transactions and experiences;
- in the event of the sale, acquisition or merger of some or all of our assets, Personal Information about you, your Recipient, or your Beneficiary might be a part of the transferred assets. We shall notify you in the event of such an occurrence and inform you of any choices you may have regarding your Personal Information, by placing a notice on our websites;
- law enforcement, government officials or other third parties, but only in connection with a formal request, subpoena, court order, or similar legal procedure; or
- 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.
By establishing a relationship with or conducting a transaction with MGP, you are consenting to MGP sharing your personal information for the following reasons:
- for our affiliates to market to you; or
- for non-affiliates to market to you.
If you prefer that we limit sharing with affiliates or nonaffiliated third parties your personal information, you may elect to opt-out by notifying us via electronic mail your desire to “opt out” to the following email address: firstname.lastname@example.org.
Please note: If you are a new consumer, we are entitled to begin sharing your information 30 days from the date we provided this notice. When you are no longer our consumer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing where applicable.
X. OUR ACCESS AND USE OF YOUR INFORMATION
Federal and state laws allow you to restrict the sharing of your Personal Information in certain instances. However, these laws also state that you cannot restrict other types of sharing.
You may decline to provide Personal Information when you so request it, however, certain Services or all of the Services may be unavailable to you.
If your Personal Information changes, or if you no longer wish to use our Service, you can access, modify, delete or update your Personal Information submitted on our websites by logging in to your account and changing your preferences. You may also contact MGP Customer Service by email at email@example.com, or by mail at 2999 NE 191 St. Suite 702. Aventura, FL, 33180, and we will respond to your request within a reasonable timeframe.
By signing up for our service you are giving us your permission to share your Personal Information with third parties with whom we market our jointly offered products. If you later decide that you no longer want us to share such information, you may notify us by email at firstname.lastname@example.org, or by mail at 2999 NE 191 St. Suite 702. Aventura, FL, 33180.
You may also opt-out from promotional email messages to you or your blog subscription by accessing your Email Preferences under "My Account" or selecting the "Unsubscribe" function present in each promotional or blog email message we send out and providing the required information.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include your internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data with other information we collect about you for analysis, security, content generation, or marketing purposes.
We may use the analytics tool in order to develop and analyze use of the Service. Analytics companies may access anonymous data (such as your identifier for advertising or device identifier) to help us understand how the Service is used. They use this data on our behalf and do not use this data for their own purposes, except in aggregate form. Moreover, they do not share data as to any individual user, except in limited circumstances. If you wish to opt-out from analytics, please follow this link.
We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the mobile applications, the events that occur within the mobile applications, aggregated usage and performance data, and location from where the mobile application was downloaded. We may link the information we store within the analytics software to any Personal Information you submit within the mobile applications.
We engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our websites. MGP partners with third parties, to provide certain features on our websites or to display advertising based upon your Web browsing activity and to collect and store information.
XII. HOW DO WE PROTECT YOUR PERSONAL DATA?
Despite our efforts, third parties may unlawfully intercept or access your personal information, transmissions to us, or may wrongly instruct you to disclose information to them. Always use caution and good judgment when sending money and when using internet and mobile technologies. Moreover, we are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.
XIII. INFORMATION FROM CHILDREN
The Sites and Services are not directed to children under the age 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
XIV. THIRD PARTY SITES
Our website may be linked to or from third party websites. MGP is not responsible for the content or privacy practices of websites that are linked to or that link from our website.
- linking your Account to a social media account or social messaging service;
- connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or
- using your Account to make payments to a merchant or allowing a merchant to charge your Account.
Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third-party that will gain access to your Personal Data as part of the account connection. For example, Personal Data that MGP shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices.
XV. CHANGES TO THIS POLICY
XVI. HOW TO CONTACT US
XVII. CONSUMER PRIVACY NOTICE
Effective Date: July 1st, 2019
This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses our Sites or Services for your own personal, family or household purposes.
|Facts||What does MGP do with your personal information?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
The types of personal information we collect, and share depend on the product or service you have with us. This information can include, but is not limited to, the following:
You consent to our collection, transfer and storage of information by computers or other transfer or storage devices in the United States and elsewhere.
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share consumers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers’ personal information; the reasons MGP chooses to share; and whether you can limit this sharing.|
|When?||This privacy statement was last revised on May 31, 2019.|
|Reasons we share your personal information||Does MGP share?||Can you limit this sharing?|
|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||Yes||No|
|For our marketing purposes – to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||Yes||Yes|
|For our affiliates’ everyday business purposes – information about your transactions and experiences||Yes||No|
|For our affiliates’ everyday business purposes – information about your creditworthiness||No||We don’t share|
|For our affiliates to market to you||Yes||Yes|
|For nonaffiliates to market to you||Yes||Yes|
|To limit our sharing?|
If you are a new consumer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.
|Questions?||Call 1(850)792-7024 or go to www.clicktransfer.us|
Mark any/all you want to limit:
□ Do not share information about my creditworthiness with your affiliates for their everyday business purposes.
□ Do not allow your affiliates to use my personal information to market to me.
□ Do not share my personal information with nonaffiliates to market their products and services to me.
Monty Global Payments USA LLC
2999 NE 191 St. Suite 702.
Aventura, FL, 33180
City, State, Zip
|Cell Phone user|
|Who we are|
|What we do|
|How does MGP protect my personal information?|
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law.
These measures can include physical, electronic, procedural, and computer safeguards and secured files and buildings. MGP also limits the sharing of personal information to only those employees that need access to it.
|How does MGP collect my personal information?|
We collect your personal information, for example, when you:
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies, all in compliance with and subject to the limitations of applicable law.
|Why can’t I limit all sharing?|
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
Companies related by common ownership or control. They can be financial and nonfinancial companies.
Companies that are not related by common ownership or control. These can be financial and nonfinancial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
Files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identity and track users as they navigate different pages on a website, and to identify users returning to a website.
Information that can be used to identify an individual.
A document that explains how an organization handles any customer, client or employee information gathered in its operations.
Any method or way that we handle Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.