This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  By “your data”, “your personal data”, and “your information” we mean any information about you, which you or third parties provide to us. We also sometimes refer to “processing”. This means any operation we perform on such data or information, such as collection, organizing, storing, updating, using, disclosing, and erasing.

Why do we collect your information?

• For Identity verification purposes
• To process your transactions
• To detect and protect against fraud and fraudulent activity
• To comply with laws and regulatory requirements
• To troubleshoot problems that may arise with the service

What information do we collect?

We collect details of your transactions that you carry out through the site and/or application and the fulfillment of such transactions. The types of personal and non-personal information we collect depends on the product or service you have with us. This information can include:

• Date of Birth
• Address
• Email Address
• Phone Number
• Other contact information
• Evidence of Your identity, (for example passport information, social security number; and driver’s license)
• Financial details, such as data relating to you and your beneficiary’s payment data and bank account information obtained for the purposes of money transfers
• Personal details that would help us identify you and/or the beneficiary in transacting funds transfers.
• Lawfully obtained personal data from third party identification services

How do we collect your information?

We may collect your data from your employment/contractor, business partners, suppliers or sub-contractors for the performance of any contract we have entered or enter into with them and/or for the performance of our obligations to you

Information you give to us when you use our services. If you use our services, you will need to provide certain information including the name and other details of the recipients of the remittance transfers. This information must be complete and accurate.

We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyze our records and provide services that may be of interest to You.

How we share your information?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons “ReadyRemit” chooses to share; and whether you can limit this sharing. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries.

We may share your information with selected third parties including:

• Your employer/contractee, business partners, suppliers and sub-contractors for the performance of any contract we have entered or enter into with them and/or for the performance of our obligations to you, we will share your information with: (i) your employer/contractee to enable use of the Brightwell ReadyRemit Service by you; (ii) the Issuer in connection with your remittance transactions; and (as applicable) (iii) the Remitter to facilitate the provision of the Remitter Service to you.
• We may share your information with service providers that are contracted with us or acting on our behalf.
• Third parties that are utilized for fraud and/or transaction monitoring.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Brightwell Payments, Inc. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers/users of the Brightwell Navigator Service will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data inorder to comply with any legal obligation, or in order to enforce or apply the Brightwell Navigator Terms of Use and other agreements; or to protect the rights, property, or safety of Brightwell Payments, Inc., our customers/service users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.

How do we use your data?

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations to your employer/contractee who has contracted with us for the provision of the Ready Remit Service for use by you.
• to carry out our obligations to you (as set out in the Ready Remit Terms of Use) and to provide you with the information, products and services that you request from or via us;
• to fulfill Your remittance transaction;
• to send disclosures and notifications;
• to notify you about changes to our service;
• to prevent fraud, money laundering, and any other illegal activity;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Who will we not share your information?

ReadyRemit will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with ReadyRemit for the purpose of advertising, promoting or selling other services to you. For further information see the Who we might share your personal information with section of this privacy policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

International Transfers

Your personal information may be transferred out of the EU for further processing in the context of any operation we may have outside the EU or by the recipients described above.

Except where the transfer is necessary to perform a contract with you or to implement pre-contract measures at your request or to perform or conclude a contract with a third party (including your associated business) in your interest, we will ensure at least one of the following safeguards is implemented:

• we will only transfer the data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• where we transfer the data to third parties, we will use specific contracts between us and the recipient in a form approved by the European Commission to protect it; or
• where the recipient is a member of our group, where we have in place binding corporate rules approved, where applicable, by relevant data protection authorities.

Security of your personal information

The data that we collect from you will be transferred to and stored in the United States of America. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers and will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we protect your personal data using physical, technical and administrative security measures, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent loss, misuse and unauthorized access

Your Rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you or otherwise processing.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• California Residents: Effective January 1, 2020, the California Consumer Privacy Act (CCPA) permits consumers who are California residents to (a) ask a covered business which categories and pieces of personal information it collects and how the information is used; (b) request deletion of the information; and (c) opt out of the sale of such information, if applicable. These provisions of the CCPA do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law.

To execute Your Rights noted above or request information, you can contact us by the following methods.

• Reaching out to your employer/contractee via support ticket or toll-free support number
• Email us at: Compliance@readyremit.com

We may require proof of your identity before we can give effect to these rights. You should also be aware that some of these rights are qualified and not absolute; therefore, exemptions or limitations may apply. For example, we can refuse to provide information, if fulfilling your request would reveal the personal information about another person, or if you request that we delete information which we are required to retain by law, have compelling legitimate interests to keep, or need access to fulfil our legal obligations.

Any request for access to Your personal information must be in writing and we will endeavor to respond within a reasonable period and in any event within one month, in compliance with Data Protection Legislation.

Retention of Your Personal Information

ReadyRemit will only retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Children’s Privacy

Protecting the privacy of children is important to “ReadyRemit”. For that reason, our site is not structured to attract children under the age of 13 and we do not knowingly solicit nor collect personally identifiable information from anyone under the age of 13.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, you will be notified through your online account or by e-mail. Please check back regularly to see any updates or changes to our privacy policy

Contact Us

If you would like additional information or if you have any questions regarding this Policy, please telephone us at (404) 855-2462 or compliance@readyremit.com. You may also write us at P.O. Box 724026, Atlanta, GA 31139

‍