HomeSend Privacy Notice
Effective Date: 25 May 2018
HomeSend SCRL and its affiliates (“HomeSend”, “we”, “us”, or “our”) respect your privacy.
HomeSend processes payment transactions on behalf of HomeSend’s customers (e.g., your bank, financial institution, payment or e-payment service provider, mobile network operator) to provide a mobile-enabled person-to-person, B2B, P2B and B2P digital money transfer solution in emerging markets (the “Service”). The Service is offered to you by HomeSend’s customers and it enables you to send or receive money to and from mobile money accounts, payment cards, bank accounts or cash outlets, regardless of your location or that of the recipient or sender.
This Privacy Notice applies to the processing of Personal Information collected by HomeSend for its own purposes in the context of operating the homesend.com website (the “Website”) and the customer portal on the Website. This Privacy Notice does not cover the collection and use of your Personal Information by HomeSend on behalf of HomeSend’s customers (e.g., when HomeSend processes your transactions in the context of the Service) or by third parties on other HomeSend branded websites. To learn more about the privacy practices of HomeSend’s customers, please visit their respective websites.
This Privacy Notice describes the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Information, and how you can reach us to update your contact information or get answers to questions you may have about our privacy practices.
1. Personal Information We May Collect
For the purpose of this Privacy Notice, “Personal Information” means any information relating to an identified or identifiable individual. We obtain Personal Information relating to you from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to use the relevant service or submit your job application with HomeSend if that information is necessary or if we are legally required to collect it.
a. Personal Information Obtained from Your Interaction with the HomeSend website
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.
When you use the Website or our Customer Portal, we may collect certain information by automated means (e.g., via cookies and similar technologies), including IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our Website, and other mobile trackers. We may use third-party web analytics services on our Website, such as those of Adobe Omniture. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyze how visitors use our Website.
We use this information to improve our Website by assessing how many users access or use our Website, which content, products, and features most interest our visitors, what types of offers our customers like to see, and how our service performs from a technical point of view.
b. Personal Information We Obtain when You Apply for a Job with Us
If you are applying for a job at HomeSend, we may collect certain Personal Information from your job applications, such as your contact information (including name, postal address, email address and phone number), job history, curriculum vitae, contact details of your referees and any other Personal Information you choose to submit along with your application.
c. Personal Information We Obtain in the context of the Service
We obtain Personal Information about you when we process transactions on behalf of our customers. For more information on the processing of your Personal Information on behalf of our customers, please refer to the relevant customer’s website.
We may use some Personal Information we collect in the context of the Service for our own purposes, including for product development and analytics purposes. This information may include the following elements:
• Amount of transactions
• Purpose of transactions
• Sending and receiving country
• Uniform resource identifier (URI) for both the source and the destination of the transaction (i.e., mobile number, e-wallet identifier, bank account or other unique identifier)
• Contact information (such as name, date and place of birth, occupation, nationality, country, postal or e-mail address, and (mobile) phone numbers)
• Proof of identify (type of identity document, number, date and place of birth, expiry date and authority responsible for issuing the document)
d. Personal Information We Collect in the Context of our Business Relationship with Customers
We may collect Personal Information from individuals working for one of our customers, partners or suppliers, including name, job title, department and name of organization, business email address, business postal address, business telephone number, answers to security questions, security passwords and other credentials. We may use this information to provide products and services directly to our customers and partners, to manage our business relationships and financial reporting, for franchise development and integrity, for marketing and to comply with applicable law, as well as for accounting, auditing and billing purposes.
2. How We May Use Your Personal Information
We may use the Personal Information we obtain about you to:
• Operate, evaluate, develop and improve our business (including developing new products and services; manage our communications; determine the effectiveness of and optimizing our advertising; analyzing our products, services and websites).
• Perform accounting, bookkeeping auditing, billing, reconciliation activities, as well as claims management.
• Anonymize Personal Information, prepare and furnish aggregated data reports showing anonymized information (including, but not limited to the following: compilations, analyses, analytical and predictive models and rules, and other aggregated reports) for the purpose of advising our customers and partners regarding past and potential future patterns of money transfer, fraud and other insights that may be extracted from this data.
• Process your job applications.
• Enforce our Terms and Conditions or other legal rights, where necessary.
• As may be required by applicable laws and regulations, including anti-money laundering, terrorist financing and sanction list screening obligations and government disclosure obligations, or requested by any judicial process or governmental agency having or claiming jurisdiction over HomeSend or HomeSend’s affiliates.
• Comply with applicable legal requirements and industry standards and our policies.
• Use the information in other ways for which we provide specific notice at the time of collection.
We will only process your Personal Information for the above purposes when we have a valid legal ground for the processing, including if:
• You consented to the use of your Personal Information. For example, we may seek to obtain your consent for our uses of cookies or similar technologies, to process Personal Information deemed sensitive pursuant to applicable law and as otherwise required by law.
• We need your Personal Information to provide you with products and services, or to respond to your inquiries.
• The processing is necessary for compliance with a legal obligation such as to prevent and monitor fraud in payment transactions.
• We, or a third party, have a legitimate interest in using your Personal Information, such as to ensure and improve the safety, security, and performance of our products and services, to protect against and prevent fraud, to anonymize Personal Information and carry out data analyses.
3. How We Share Your Personal Information
We do not share or otherwise disclose Personal Information we collect about you, except as described in this Privacy Notice or otherwise disclosed to you at the time the data is collected.
We share Personal Information with our affiliates, subject to the terms of this Privacy Notice or as otherwise disclosed to you at the time the data is collected.
We may share Personal Information we collect with financial institutions and other entities that process financial transactions. We share personal information and perform activities that you request. We also may share Personal Information with entities that assist with fraud prevention, to protect financial transactions against fraud, and to ensure the security of the transaction processing system. In addition, we may share Personal Information with other third parties with your consent.
We also may share Personal Information with our service providers who perform services on our behalf and in relation to the purposes described in this Privacy Notice. We require these service providers by contract to only process Personal Information in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements. We also require them to safeguard the security and confidentiality of the Personal Information they process on our behalf by implementing appropriate technical and organizational security measures and confidentiality obligations binding employees accessing Personal Information.
We also may disclose data about you: (i) if we are required to do so by law or legal process, (ii) in response to a request from a court, law enforcement authorities, or government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
We also reserve the right to transfer Personal Information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with this Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that information.
4. Your Rights and Choices
Subject to applicable law, you have the right to:
• Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
Those rights may be limited in some circumstances by local law requirements.
If we fall short of your expectations in processing your Personal Information or you wish to make a complaint about our privacy practices, please tell us because it gives us an opportunity to fix the problem. To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time and, in any event, within the legal time limit for responding, where applicable.
If you provide us with any information or material relating to another individual, you should make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so for example you should duly inform that individual about the processing of her/his Personal Information and obtain her/his consent, as may be necessary under applicable laws.
5. How We Protect Your Personal Information
We maintain appropriate administrative, technical, and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We use SSL encryption on our Website and restrict access to Personal Information about you to those employees who need to know that information to provide products or services to you.
We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request their deletion, unless we are required by law to keep the information for a longer period. We complete periodic reviews of our databases, and have established specific time limits for data deletion, taking into account the type of data collected, the type of services provided, and the length of the customer relationship, possible re-enrolment with the Service, mandatory retention periods, and the statute of limitations.
6. Data Transfers
HomeSend is a global business. We may transfer or disclose Personal Information we collect about you to recipients in countries other than your country, including to the United States where our majority shareholder is headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Notice.
We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. In particular, we have established and implemented a set of Binding Corporate Rules (“BCRs”) that have been recognized by EEA data protection authorities as providing an adequate level of protection to the Personal Information we process globally. A copy of our BCRs is available here. We may also transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us as specified in the “How to Contact Us” section below to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.
7. Features and Links to Other Websites
On our Website, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with HomeSend. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share Personal Information in accordance with their own privacy policies. We strongly suggest you review these third parties’ privacy policies if they use the relevant features.
8. Updates to This Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in our Personal Information practices. We will notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. If we update this Privacy Notice, in certain circumstances, we may seek your consent.
9. How to Contact Us
HomeSend SCRL is the entity responsible for the processing of your Personal Information, except where HomeSend processes your Personal Information on behalf of its customers.
You may also submit a request to exercise your rights or share any questions, comments, or complaints about this Privacy Notice or our privacy practices by e-mailing us at firstname.lastname@example.org, or writing to us at:
Rue des colonies, 56
Data Protection Officer – Mastercard Group
Mastercard Europe SA
Chaussée de Tervuren 198A