Dahabshil Inc. Privacy Policy

The purpose of Dahabshil’s Privacy Policy is to formulate the company’s policy to comply with the specific requirements set forth in the Gramm-Leach-Bliley Act (GLB Act). The guidelines entailed here shall enable Dahabshil to protect its entrusted customer information as required by the GLB Act.

Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information. This Private Policy gets updated periodically and was last updated June 4, 2020.

The objective of our Private Policy is to:

• Insure the protection, security, and confidentiality of non-public customer information.
• Protect against loss or destruction of our customer information.
• Protect against unauthorized access to or use of customer information.

Dahabshil Inc., a money service business with its head office in Dublin, Ohio is serious about protecting your privacy. This Privacy Policy (“Policy”) covers how Dahabshil collects and uses the personal information you provide on our website and or mobile application and in conjunction with any of the services hosted at www.dahabshiil.com (“Service” and “Website”), including money transfer services accessed by internet enabled devices. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

• This Policy explains what personal information we collect about you, with whom we share it, and how you can elect in certain situations to not share information with third parties. “Personal Information” refers to information such as name and email that can be used to identify you individually.

• We may amend this Policy at any time, and whenever we do so we will notify you by posting a revised version on the Website. If, however, we plan to make a material change in the way we collect, use, or store your personal information, we will provide prior notice on our website, and by email. You will then have the chance to decide whether or not we will use or disclose your information in that new manner, whether through an “opt-out” procedure or by ending your relationship with us. Such changes will become effective, at the earliest, 30 days after the date of the email notifications.

• Minors (those under the age of 18 years) are not eligible to use our Service. We ask that minors refrain from using our Service or submitting any personal information to us.

• If you have questions or concerns regarding this Policy, you should contact us.

INFORMATION WE COLLECT

We will collect the following information about you when you register on our site or mobile app, make a transaction, enter information or interact with customer service which may include non-public personal information:

1. Personal and financial Information you give us as a result of using the Service, such as your address, e-mail address, date of birth, telephone number, all or part of your Social Security number, bank account online login information, bank account number, and credit/debit card number. Under certain circumstances we will also collect and save information obtained from scanned copies of official identification documents, including your Passport, Drivers’ License or state issued ID.
2. Third party personal information you provide in order for us to facilitate funds transfers, such as your recipient’s full name, physical address, email address, and phone number. However, we will not contact your recipients except as instructed by you or as required to complete a transaction. This information is only used for the sole purpose of completing your request or for whatever reason it may have been provided.
3. Information about your usage of the Service, including your transaction history, and how and to whom you use the Service to send or receive money;
4. Information that we lawfully obtain from third parties, such as identity verification services, electronic database services, and credit reporting agencies;
5. Information that we indirectly obtain from you, such as information about the hardware and software you use when accessing the Service, your IP address, and the pages you access on this website;
6. Recordings of your communications with our Customer Service department, including telephone calls and electronic communications.
7. Any additional personal information you provide to Dahabshil online, by e-mail, chat or telephone.

COOKIES AND OTHER TRACKING DEVICES

Dahabshil uses “cookies” and other tracking devices to help us recognize you, remember your preferences and facilitate your future transactions and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our website and App, in order to help us improve it and make it easier for future use. You may be able to disable your device’s use of cookies, but that may slow or prevent your ability to use the Dahabshil service.

WHY WE COLLEC INFORMATION

We collect your Personal and Non-Personal information and will retain it for as long as your account is active or as needed to provide you Service. We will retain and use your information as necessary to comply with our State and Federal legal obligations, resolve disputes, and enforce our agreements. The information collected is for the following purposes:

1. To process your transactions.
2. To verify your identity.
3. To collect payment for your use of the Service.
4. To track, improve and personalize our Services, content and advertising
5. To troubleshoot problems with the Service.
6. To comply with applicable laws and regulations, such as those relating to “Know Your Customer,” and Anti-Money Laundering requirements.
7. To detect and prevent fraud and other illegal uses of the Service.
8. To create an account connection between your Dahabshil account and a third-party account or platform (such as your online bank account);
9. To send you marketing notices, service updates, and promotional offers
10. To collect survey information that will be used to monitor or improve the use of our Service and overall customer satisfaction.

SHARING INFORMATION WITH OTHERS

We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell or rent the information we collect to third parties for their promotional purposes. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us.

Nevertheless, we may share information about you (including nonpublic, personal information) with:

1. Third-party service providers under contract with Dahabshil Inc. that help us with our business operations, such as transaction processing, fraud prevention, marketing, market research, and validation of information provided. These third parties are prohibited from using your information for their own separate business purposes.
2. In the event of the sale, acquisition or merger of some or all of our assets, your personal information might be a part of the transferred assets. We shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our website.
3. Law enforcement, government officials or other third parties, but only
   • in connection with a formal request, subpoena, court order, or similar legal procedure; and,
   • 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 Agreement.

1. Other third parties that you consent or direct, which may include you authorizing an account linking for a third-party service, account and/or platform.
   • For the purposes of this privacy policy, an “account linking” with such a third party is a connection you authorize or enable between your Dahabshil account and a non-Dahabshil account, payment instrument, or platform that you lawfully control or own. When you authorize such a connection, Dahabshil and the third-party will exchange your personal information and other information directly. Examples of account connections include: connecting your Dahabshil account to a third-party data aggregation or financial services company, if you provide such company with your account log-in credentials;
   • If you connect your Dahabshil account to other banking or similar accounts, directly or through a third-party service provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account linkage, we may receive information from the third-party about you and your use of the third-party’s service. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this privacy policy.
   • 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 information as part of the account connection.

ACCESSING YOUR INFORMATION

You can access, modify, delete or update your personal information submitted on our Website by logging into your account and changing your preferences, by emailing our Customer Support at [email protected], or by contacting us by telephone 1 866 428-7799. We will respond to your request to access within a reasonable timeframe.

RESEARCH PARTICIPANTS

We collect personal information from you if you participate in any research projects for us (by phone, in-person, electronic survey or otherwise). we will hold your name, contact details and any other personal information you choose to give us when taking part in our research projects.

We will use this information for our legitimate interests namely to conduct our research projects which may also help us to improve and/or develop our products and services.

We will share this information with:

• our staff (but their use shall be limited to the performance of their duties and in line with the reason for processing);
• other companies within our group if any;
• our platform, database, and website hosting suppliers to enable them to maintain, protect, support and host those solutions which are used to store our research;
• various third parties who provide software and tools which are used to operate our business (including email, instant messaging, document/contract management and file-sharing);
• Other third parties in the event of the sale, acquisition or merger of some or all of our assets if your personal information is part of the transferred assets (we shall notify you in the event of such an occurrence, as well as any choices you may have regarding your personal information, by placing a notice on our Site).

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider (amongst other things):

• obligations and/or retention periods imposed on us by applicable laws and/or our regulators
• the amount, nature, and sensitivity of the personal information
• the potential risk of harm from unauthorized use or disclosure of your personal information, and
• the purposes for which we process your personal information and whether we can achieve those purposes through other means.

MOBILE APPLICATION

When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and system and performance information.

We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

We collect your location-based information for the purpose of locating a place that you may be searching for in your area. We will only share this information with our mapping provider for the sole purpose of providing you this service.

We may share your geo-location data with third parties for the purpose of them serving you ads for places (such as restaurants) in your area. If you do not wish to allow us to share your information in this manner please opt-out by contacting us at [email protected].

You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at [email protected].

We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

SYSTEM SECURITY

We employ industry accepted standards in protecting the information you submit to us through our branch or agent locations, Website and Mobile App.

We have put in place SSL (Secure Socket Layer) encryption technology to protect your sensitive information such as bank account number, credit card number, date of birth and Social Security Number, transmitted through our Website/mobile App. We also require a username and password from each user who wants to access their information on our Website/Mobile App. Although we try our utmost, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

We also dedicate trained resources to the development, implementation, and maintenance of the security program to identity and respond to any security threats or data breaches

If you have any questions about security on our Web site, you can contact us at [email protected].

CHOICES YOU CAN MAKE ABOUT OUR 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 all types of sharing. Because we have chosen to refrain from certain types of data sharing, the only type of sharing of your personal information that you may restrict is as follows:

You may opt-out from promotional emails to you by selecting the “Unsubscribe” function present in each email we send you.

LINKS TO 3RD PARTY SITES

Our Site includes links to other web sites whose privacy practices may differ from those of Dahabshil, Inc. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

CHAT

We use a chat feature to answer questions about our service and assist you with our website’s functionality. If our chat feature is offline we will collect your name and email address so that we may reply to your request.

SOCIAL MEDIA WIDGETS

Our web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

CHANGES TO THIS POLICY

We may amend this policy at any time, and shall notify you by posting a revised version on our website. Should we make a material change to the manner in which we collect, use or store your personal information, we shall provide prior notice on our website, or by email.

COMPLAINTS

If you have a complaint, contact Dahabshil Customer Service, online; by phone 1 866 428-7799 or by email at [email protected].

CONTACT

If there are any questions or concerns regarding this privacy policy you may contact us at:

Dahabshil, Inc.,

240 Bradenton Avenue

Dublin, OH 43017

www.dahabshiil.com

[email protected]

614 527-9300/01

614 428-5613

1 866 428-7799

1 888 205-4042 FAX

TalkRemit Privacy Policy

Who are we?

In this privacy policy, terms such as “TalkRemit”, “us” and “we” refer to TalkRemit Ltd, a limited liability company registered in England and Wales (registration number 10283207), with its registered office at Cannon Place, 78 Cannon Street, London, England, EC4N 6AF. TalkRemit is registered with UK Information Commissioner’s Officer (reference number ZA196312). TalkRemit Ltd is authorised as an electronic money institution by the Financial Conduct Authority (reference number 900825). In accordance with Data Protection Regulations, TalkRemit is a data controller and you – our customer – will be a data subject. As a data controller, we determine the purposes for and means of the processing of your personal data while at the same time ensuring your rights as a data subject are respected. Unless otherwise defined in this privacy policy, terms defined in the Terms and Conditions, which are available here, have the same meanings in this privacy policy.

What data we might collect?

We collect personal information about you when you access the Site (such as behavioural information, including links you click and pages you enter, your IP address and device information), when you contact us (such as your name and email address) and if you opt out of marketing communications. We will collect your email address for marketing purposes. We may also collect an email address which has not been registered with us for ticket tracking purposes, but we will ask for your consent in such cases. We will collect personal information from you either directly, such as when you contact us, or indirectly, such as your browsing activity while on the Site. As a company providing money remittance, electronic wallet and chat services, we may also have to collect various types of personal data in the course of providing our Services to you:

1. Personal data such as your name, address, phone number, email address, date of birth and/or nationality. We might also need to collect copies of your identity document, utility bills, bank statements or any other documentary evidence. We might need this data in order to satisfy our know your customer (“KYC”) obligations.
2. Financial data such as your card or bank account information.
3. Personal dataabout your recipient such as their name, address and/or phone number. When you provide details about your recipient, you guarantee that you have obtained the necessary consent for the processing activities outlined in this privacy policy.3. about your recipient such as their name, address and/or phone number. When you provide details about your recipient, you guarantee that you have obtained the necessary consent for the processing activities outlined in this privacy policy.
4. Technical datasuch as (1) the internet protocol you use to login to your Account or submit a Transaction, (2) information about your device such as the device manufacturer, device model, device operating system, device operating system version, application version, carrier, connection type and/or time zone; and (3) event-based attributes such as button clicks and other in-app events.

When you install the TalkRemit application, we will also ask you to allow us to access your mobile device’s address book. A copy of the phone numbers and names of all your contacts (whether they are TalkRemit users or not) will be collected and stored on our servers so that we can enable you and your contacts to connect. The TalkRemit application might also ask you to allow us to access your media files (to enable you to share images with your TalkRemit contacts), location (to share your location with your TalkRemit contacts), microphone and speaker (to enable you to talk with your TalkRemit contacts). You can choose not to allow us to have such access, however this would mean that some of the Services might not work. You can change your access preferences through your device settings. We shall use automated processing to track your behaviour when using the Site, for example how you leave the Site, and to track if, and when, the Site crashes. This shall allow us to develop, maintain and improve the Site and our Services and tailor our communications with you accordingly.

Do you have to provide information and, if so, why?

We require you to provide us with, as a minimum, your email address and phone number in order to provide you with the Talk Services. We require you to provide us with, as a minimum, your full legal name, date of birth, address and nationality in order to provide you with the Remittance Services. We may also require you to provide us with further information about yourself and/or your Receiver in relation to providing you with the Services such as an address, phone number, nationality, identity documentation, proof of address (such as utility bills), source of funds, bank statements or any other documentation as required by applicable laws and regulations. We will inform you at the point of collecting information from you whether you are required to provide the information to us.

Why might we process your data?

We strive to provide you with a safe, personalised and delightful experience when you use our Services. To this end, we might process your data for the following reasons, which are necessary for the purposes of our legitimate interests in accordance with the lawful processing requirements indicated in the Data Protection Regulations:

1. To provide you the Services.We need to collect your financial details and details about your recipient to complete money transfers or enable Top-Up of your Electronic Wallet. We also need your contact information for us to allow you to chat and talk with your friends and family.
2. To comply with the law.As a financially regulated institution, we are obliged to know who our customers are and to perform our anti-money laundering and combating terrorism financing checks.
3. To provide relevant marketing.We might process your contact details such as email address and telephone number to provide you, as our customer, with a relevant and personalised marketing communication. Our goal is to market you only information which might benefit you and to do so in such a way which does not undermine your rights as a data subject. You will always have an absolute right to object at any time to any marketing communication sent to you.
4. To improve our Services.We might process technical data about your usage of our application to improve our Services. We will use anonymous identifiers and aggregated data, not your personal data. We will not sell your data to third party companies.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

How do we protect your data?

Protecting your personal data is very important to us. TalkRemit maintains physical, electronic and procedural safeguards that comply with the applicable laws to protect your personal information from unauthorised access:

1. Using network and application firewallsWhen you transmit your personal data from your device to our servers, your information is protected by both a “firewall” and industry standard SSL (secure socket layer) encryption.
2. Secure storage.Once your data reaches our servers, data is securely stored.
3. Access control.TalkRemit maintains a strict policy to control who can have access to your personal data. Any personal data will be accessible by TalkRemit employees on the need-to-know basis only. TalkRemit regularly trains staff on data protection practices to ensure all employees are aware of the Data Protection Regulations, data protection principles and customers’ rights as data subjects.
4. Payment Card Industry Data Security Standard (“PCI-DSS”).Any financial information you transmit when you enter your card details is processed in accordance to PCI-DSS standards.
5. System testing.TalkRemit regularly tests and reviews its systems and security practices.
6. Controlled data sharing.Before we decide to share your data with any third party, we make a careful assessment of that third party’s level of data protection. Any agreement to share data is made only with third parties which have an adequate level of data protection which complies with the Data Protection Regulations.

Even though TalkRemit will make every effort to protect your data, you accept that we cannot guarantee security when you transmit it over the internet, and any transmission is at your own risk. To minimise your risk, we highly recommend that you do not share your login credentials, passwords, pin numbers or any other Account details with anyone else. We also highly recommend that you use appropriate anti-virus software to protect yourself from your data being compromised. We have procedures in place to deal with any suspected data security breach. If at any point you suspect or become aware of a security incident, please contact us at [email protected].

How long do we retain your data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including holding your personal data until we are lawfully required to do so. To comply with relevant KYC, anti-money laundering and counter-terrorism financing regulations, we are obliged to retain your data for at least five years after your last transaction with us in respect of the Remittance Services. We will store your data in respect of the Talk Services for one year after you close your account with us. We might retain your data for a longer period if instructed so by the relevant authorities or if required to protect rights of TalkRemit. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Who might we share your data with?

We might share your data with third party service providers which enable us to provide you with the Services:

1. Payment service providers (“PSPs”) – we will use PSPs to enable card processing, bank payment services and accounting.
2. Money service businesses (“MSBs”) – we will partner with MSBs in different countries to provide you and your receiver with different payout services ranging from cash to mobile wallets.
3. KYC service providers – we might rely on trusted KYC providers to verify your identity. This might involve verifying your information against credit institutions.
4. Regulatory authorities and law enforcement agencies – in order to comply with relevant laws and regulations, we might be obliged to share your personal data as well as your account/transaction data with relevant authorities.
5. Analytics and marketing companies – to provide you with a high-quality service, we might share anonymised data with analytics companies. In order to provide you with relevant and personalised marketing communications we might also share anonymous aggregated data with our partners.

We select our partners carefully. Before starting any relationship, we make sure they are fully compliant with the Data Protection Regulations and employ adequate data protection practices.

Transfers out of the EEA

The Site is controlled, operated and administered by us from our office within the European Economic Area (“EEA”). The Talk Services are intended for use worldwide and the Remittance Services are intended only for use within the EEA. Personal data may be transferred to and stored and accessed by Service Providers located in countries both inside the EEA and outside the EEA in countries that do not have the same data protection laws as the United Kingdom and EEA. Where personal information is transferred outside of the EEA, we shall apply mechanisms to ensure similar levels of protection are afforded to it such as (i) transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or (ii) providing appropriate safeguards such as using specific contracts approved by the European Commission which give personal data the same protection it has in Europe. If you use the Remittance Services to pay a Receiver in another country or the Talk Services to communicate with a person (or persons) in another country, personal data will be transferred as necessary to complete the Transaction or communication.

What are your rights?

When you share your personal data with us, you have all the below rights:

1. Right to Withdraw Consent – at any point in time you can easily withdraw your consent to allow us to process your personal data. This can be done easily in your Account settings or by sending us an email to [email protected]. Please note that (i) this will not affect the lawfulness of any processing based on consent given before its withdrawal, and (ii) withdrawing consent might mean that we will not be able to provide all or part of the Services to you.
2. Right to Be Informed – you have a right to be informed about what data we collect, how we use it and who we share it with.
3. Right to Access – you can ask us to provide you with all the data we have collected about you, how it is used and who it has been shared with. If you wish to do so, please send us an email to [email protected]. We will have one month from the day of receipt of the request to send you back the results (this may be extended by two further months where necessary, in which case we will inform of you of the extension and the reasons for it within one month of receipt of the request).
4. Right to Rectify – you have a right to rectify incomplete or inaccurate personal information concerning you.
5. Right to Erasure – you have the right to require the erasure of personal data concerning you in certain circumstances.
6. Right to Data Portability – you have the right to receive the personal information concerning you which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations.
7. Right to Restriction of Processing – you have a right to request that we stop processing any personal data.
8. Right to Object to Direct Marketing Processing – you have the right to object to the processing of your personal information for the purposes of direct marketing at any time by sending us an email to [email protected].
9. Right to Object – you have the right to object to the processing of personal information concerning you in certain other circumstances.
10. Notification Obligation – you have a right to be informed without undue delay about a personal data breach where this is likely to result in a high risk of adversely affecting your rights and freedoms.
11. Right to Complain – you have a right to complain to a supervisory authority, in particular in the European Union (or EEA) state where you work, normally live or where any alleged infringement of data protection laws occurred (in the UK, this is the Information Commissioner’s Office who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113) if you believe we didn’t process your data correctly.

You can exercise your data protection rights by sending us an email to [email protected].

Cookies policy

A cookie is a small piece of data sent from a website and stored on your device while you are browsing that website. Cookies were designed to be a reliable mechanism for websites to remember important information about the usage of the website. We use cookies on the Site to gather important information about you as our user. It allows us to provide you with a smooth experience when using our Services as well as to better understand and improve our Services. The types of cookies we use are as follows:

1. Essential cookies – these are the cookies required for good functioning of the Site. For example, to store your session ID.
2. Analytical cookies – these are the cookies that allow us to see and count how many users visit our Site, which pages they go through and how they behave on our Site.