- Introduction: Xpress Money as Data Controller
- Purpose of this Privacy Statement
- Personal Information Processed by XM
- 3.1 What Personal Information means?
- 3.2 Personal Information collected by XM through XM Agents
- 3.3 Personal Information collected by XM through Social Media
- 3.4 Personal Information collected by XM through its websites and mobile applications
- 3.4.1 Definition and usage of cookies:
- 3.4.2 Third Party Marketing Cookies and Social Advertising
- 3.4.3 How to manage cookies
- Legal grounds to process Personal Information
- Purpose for Personal Information Processing
- Personal Information Sharing
- Individual’s rights
- XM Contact
- Solicited/Un-Solicited Communications
- Security Measures to Protect Personal Information
- Retention of Personal Information
- Changes to this Privacy Statement
Xpress Money is an international money transfer organisation, working with some of the largest banks and non-banking financial companies, Xpress Money have established one of the largest agent-based remittance networks in the industry. Present across 200,000 agent locations in 165 countries, Xpress Money is focused on rapid expansion to the far corners of the globe. These “agents” are independent entities from Xpress Money who offers, along with other services, money remittance trough Xpress Money platform (hereinafter “XM Agents).
Xpress Money Canada Limited (hereinafter “XM”) is accountable for the personal information we collect in the course of operating our business in Canada, including the Personal Information collected through XM Agents.
XM is committed towards protecting the Personal Information of its customers and beneficiaries, including potential and former ones (hereinafter referred to as “Individuals”).
XM has created this privacy statement to provide information on how it collects, uses, discloses, and manages Personal Information.3.1 What Personal Information means?
Personal Information means any information about an identified or identifiable individual such as name, address, telephone number and e-mail address, as well as credit, financial, demographic and biographical information. XM encourages Individuals to review its privacy statement and become familiar with it. It’s important to know that XM collects Personal Information from Individuals mainly through its network of agents and in some other cases, through digital mechanisms, such as XM website.3.2 Personal Information collected by XM through XM Agents
To provide the financial services asked by XM customers, and for other purposes described in this privacy statement, XM collects the following Personal Information through its network of XM Agents:
- Full Name (sender and recipient of the transaction)
- Address (sender and recipient of the transaction)
- Nationality (sender and recipient of the transaction)
- Telephone number, including mobile (sender and recipient of the transaction)
- Relationship between sender and recipient of the transaction
- E-mail address
- Birth Place
- Employment details
- Financial background (e.g. source of funds to be transferred)
- Information from government issued identification documents (e.g. National ID, Driving License, Passport)
- Bank Statements
- Transaction amounts
- Bank account numbers
- Credit / Debit card numbers
- Marketing & other Contact Preferences.
As a financial institution and in connection with identity verification, fraud prevention and similar security purposes, XM collects and/or confirms some of these Personal Information elements through third parties’ sources such as government agencies and consumer reporting agencies.3.3 Personal Information collected by XM through Social Media
If you choose to interact with XM on social media, XM may collect Personal Information from the social media resource. These social media resources include: Facebook, Twitter, YouTube, LinkedIn, Instagram, Google+, Pinterest, Weibo and WeChat. These Personal Information elements may include but not limited to:
- Public Social Media Profile Name
- E-mail (if left public)
- Mobile number (if left public)
- Region (if left public)
- XM related posts (if left public). For example: Mentions & Hashtags
A "cookie" is a small piece of information that is stored on Individual’s device (such as your computer) and which records the way that Individuals use a website so that, when Individuals revisit that website, it allows XM to provide tailored options based on the information that has been collected from Individuals’ last visit. Cookies can also be used to analyse traffic and, in some cases, for providing Individuals with tailored advertising and marketing.
We use the following types of cookies on our website:
- Essential cookies: These cookies make XM website operation work and therefore they cannot be turned off or rejected. These cookies do not gather any information about Individuals and do not have the ability to remember how Individuals have used XM website;
- Performance cookies: XM use these cookies to help in the analysis on how its website is used and to improve its performance. For example, XM use them to understand where visitors to XM site are based, how many people visit the website and which sections of the website are the most used;
- Functionality Cookies: These cookies allow XM website to remember if Individuals have previously visited XM site or the choices Individuals made to provide a more personalised online experience.
- Third-Party cookies: These cookies are used to track your behaviour on the XM website and on third party websites, and may also collect other information, such as demographics. These cookies and information may be used to provide Individuals with personalised advertising on our website and on third party websites. See below for more information.
XM performance, functionality and third-party cookies are not strictly necessary for our website to work but will provide Individuals with a better browsing experience. Individuals can delete or block these cookies through their browser settings, but if Individuals do this, Individuals may have to manually adjust some preferences every time they visit XM website and some features of the site may not work as intended. Most internet browsers are initially set up to automatically accept cookies, however Individuals can decide at any time what type of cookies they want to accept. Individuals can change the settings on their browser to block cookies or to alert them when cookies are being sent to their device.4.1 Consent
XM collects, uses and discloses your Personal Information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose your 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.
Generally, by providing XM with your Personal Information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection. If you provide us with Personal Information of a third party, you represent that you have the consent from that Individual to provide us with his/her Personal Information.
Consent may be given in various ways as explained in the following table,
|Consent Type||Example/ Explanation|
|Express||Express consent is given explicitly, either orally, in writing, or through a specific online action, such as clicking on “I agree”. Express consent is unequivocal and does not require any inference on our part.|
|Implied||Implied consent will arise where your consent will reasonably be inferred from your action or inaction.|
|“Opt out” option||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 by using the “opt out” option provided.|
|Consent by authorised representative||For an individual who is a minor, seriously ill, or mentally incapacitated, consent will be obtained from a legal guardian, or person having power of attorney.|
XM may collect, use and disclose Personal Information without consent of the Individual:
- if the Personal Information is used for the investigation of a breach of agreement or contravention of any law of Canada;
- for settling of an insurance claim;
- for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual; or
- if it is required by law, among other circumstances.
XM generally uses Personal Information for the purposes of providing them a service. This may include the following purposes:
- Authorising and processing Individual’s transactions, including effecting and administering money transfers and ensuring proper payment to the designated recipient of funds.
- Collecting amounts owing to us, and otherwise enforcing and collecting on Individual’s accounts or agreements with us.
- Monitoring and improving our services including websites/mobile apps and its content.
- Sending information about our products and services.
- Customer care initiatives to improve XM services
- Meeting legal, regulatory, self-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.
- Maintaining business and transaction records for reasonable periods, and generally managing and administering our business.
- Meeting insurance, audit and processing requirements.
- Otherwise with the Individual’s consent or as permitted or required by law.
XM may conduct automated processing of Individuals’ Personal Information, such as: address, employment information, date of birth and transactions amounts with the sole purpose to comply with anti-money laundering regulations.
In alignment with the purposes established in this Privacy Statement, XM may disclose Personal Information to:
Data Processors: XM will share Personal Information with third-party service providers, acting on behalf of XM (hereinafter “Data Processors”) including affiliates of XM acting as Data Processors to perform services on XM behalf, for example: information technology, data hosting, marketing, customer care, fraud prevention, etc. XM takes reasonable measures to ensure that Personal Information that is processed by Data Processors is protected and not used or disclosed for purposes other than as directed by XM. Some of our service providers acting as Data Processors are located outside of Canada including, for example: in the United States, United Arab Emirates, India and Philippines.
Third Party Data Controllers and Joint Controllers: XM will share Personal Information with third parties acting independently from XM but only in connection to the services required by the Individuals, for example: any intermediary banks or other financial institutions involved in the transaction of XM services.
Successors: if XM is purchased by/sold to a third party, in which case Personal Information held by XM including you as our customer will be transferred. We will notify you of this through the most appropriate means
Relevant Authorities: XM may disclose Individuals’ Personal Information as necessary to meet legal and regulatory requirements or where otherwise required by law. This may include lawful requirements to disclose Personal Information to government authorities (including outside of Canada), for example, disclosures in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations.
Individuals have certain right over their Personal Information being processed by XM. In summary, any Individual may have the following rights:
- Access: Individuals have the right to request access to their Personal Information in XM’s custody or control and to be informed of how that information was used and with whom it was shared.
- Rectify: Individual’s right to correct their Personal Information when this is not accurate.
- Erasure: Individual’s right to permanently delete their Personal Information after fulfilling certain requirements. The right is not absolute and only applies in certain circumstances.
- Restriction of processing. This means that an Individual can limit the way that XM processes their Personal Information. In such case and if applicable, XM will only store the Personal Information to comply with relevant regulation, but it won’t be processed for anything else.
- Right to object: In some cases, Individuals have the right to object to certain processing, for example, if the Individual does not want to be contacted by XM for marketing purposes.
- Data portability. In certain scenarios Individuals may request XM to provide a copy of their Personal Information in a digital format or send it to a third party appointed by them.
Also, if you believe that XM is processing your Personal Information in a manner that does not comply with the applicable regulation, you have the right to submit a complaint to the relevant Data Protection Authority.
XM will take appropriate steps to verify your identity before acting on any Individual Rights requests. In certain situations, XM may not be able to provide access to all the Personal Information it holds about an Individual. The exceptions to the access requirement will be limited and specific. The reasons for denying access will be provided to the Individual upon request. Exceptions may include:
- Information that is prohibitively costly to provide,
- Information that contains references to other Individuals,
- Information that cannot be disclosed for legal, security, or commercial proprietary reasons, and
- Information that is subject to solicitor-client or litigation privilege.
For Individual Rights request, and if you have any questions or suggestions about our Privacy Statement, you can contact our Data Protection and Privacy Officer at: firstname.lastname@example.org
You may unsubscribe from our marketing emails at any time. Please note that opting not to receive email does not exempt the user from receiving administrative emails.
XM Customer Care department may contact Individuals in response to their inquiries, to provide services at the Customer’s request and to manage their requirements.
Our websites and emails may contain links to various other websites. While we make every effort to ensure that our advertisers post clear and complete privacy statements and observe appropriate data protection practices, we are not responsible for the privacy practices of third parties and their privacy statements may differ from ours. The privacy practices of other websites and companies are not covered by this policy.
XM has implemented reasonable physical, organizational and technological security measures to protect the Personal Information in our custody and control and to ensure that it is treated securely and in accordance with this Privacy Statement. Personal Information is maintained on our servers (or those of our Data Processors) and is accessible to authorized employees and representatives who require access in connection with their role.
XM retains Personal Information for as long as is necessary for XM to use it as described above or to comply with XM legal obligations. However, please be advised that XM will retain some of the Personal Information after Individuals cease to use XM services, for instance if this is necessary to meet XM legal obligations, such as retaining the information for tax and accounting purposes or for Anti Money Laundering obligations. When determining the relevant retention periods, XM will take into account factors including: contractual obligations and rights; legal obligations to retain data for a certain period of time (for example, anti-money laundering laws); statute of limitations under applicable law; potential disputes; guidelines issued by relevant data protection authorities; and XM legitimate interests, where we need to consider retaining information to meet any other obligations.
Otherwise, XM securely erases Personal Information once this is no longer needed.
Please note that we review our Privacy Statement from time to time, and we may make periodic changes to it in connection with that review. Therefore, the user may wish to bookmark this page and/or periodically review this page to make sure the user has the latest version.