Privacy Policy

SCOPE

This Privacy Policy explains the practices of Path2USA.com Inc. (“CompareRemit”, “we”, “us” or “our”) regarding the collection, use and disclosure of information that we receive when you access and use our website located at compareremit.com (the “Site”), or our remittance comparison mobile device application (the “App” and together with the Site, the “Services”) or through contacting us by telephone or other form of communication. This Privacy Policy applies only to CompareRemit’s remittance comparison and exchange rate tracking offerings and doesn’t apply to any of our other offerings or any third-party websites, services or applications, even if they are accessible through our Services.

By using or accessing our Services, you give us your consent to collect store and process your personal data in accordance with this Privacy Policy (except in certain cases described below, where you may specifically opt out of certain uses of your personal data). If you do not wish to allow us to do so, please do not use our Services. If you wish us to stop collecting and processing your personal data, please contact us as indicated in this Privacy Policy.


INFORMATION WE MAY COLLECT

Personal data means any information about an individual person from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, and country and/or state of residency.

Contact Data includes your email address.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device version, and other technology on the devices you use to access our Site or on which you run our App.

Profile Data includes your interests, preferences, feedback, survey responses, and the reviews or other commentary you contribute to the Services

Usage Data includes information about how you use our Services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. This also includes us making a note of conversations we have had with you in person and/or communications you sent to us. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


HOW WE COLLECT YOUR DATA

We collect different information about you in a number of ways:

Information you give us

When you sign up for our marketing communications, post a review or other commentary on our website, or contact us to ask a question or give us feedback, we will store the personal data you give to us such as your name, email address, and other details. We will also keep a record of our communications with you (including information like your survey responses and the reviews or other commentary).

Automated technologies or interactions

As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Information from third parties

We may receive information about you from third parties as set out below:

  • Analytics providers such as (by way of example only) Google
  • Advertising networks such as (by way of example only) Facebook or Quora
  • Publishers who run our advertisements on their websites or mobile apps
  • Search information advertising providers such as Google AdWords


HOW WE MAY USE YOUR INFORMATION

We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have your explicit consent before using your personal data in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal data and you have the right to withdraw consent to marketing at any time by contacting us (or by using any other mechanism we provide, such as an “unsubscribe” link in an email). You will find the relevant contact details at the end of this policy.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Finally, while the table below describes our practices, we do not use any personal data (in any of the categories we have identified) relating to individuals in the European Economic Area for any marketing communications or advertising unless such individuals have opted in to receive marketing communications or advertising from us.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) Responding to your inquiries
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and the products/services of our business partners)
To enable you to complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services and the products/services of our business partners)
To administer and protect our business and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Services content, product offerings, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services and the products/services of our business partners, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Services, product offerings, marketing and communications with you, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products /services and the products/services of our business partners, to keep our Services updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)


ADDITIONAL DETAIL

Marketing Communications

We may use personal data in order to display custom, personalized content to our visitors and to send information by email and mobile device notifications, such as newsletters feature articles, advertisements and promotional material, surveys and other updates. We may send advertisements or extend offers to users on behalf of our partners about a particular product or service that may be of interest to you, but we will never give out personal data in a form identifiable to you for those purposes without your permission. You may, at any time, opt out of receiving such email communications by using the mechanism provided at https://www.compareremit.com/set-alerts/, by contacting us, or by using any other mechanism we provide, such as an “unsubscribe” link in an email.

Our App uses the built-in notification services provided in Apple iOS and Android to send notifications to users on their mobile devices. We comply with the user’s notification settings applicable to our App on each user’s mobile device, so if you don’t want us to provide certain mobile device notifications (or any), just use your mobile device’s notification settings and the settings for our App on the mobile device.

Other Disclosures or Uses

We may disclose personal data to trusted third party vendors working for us in connection with the operation of our Site and Service and our business, so long as those parties agree to use this information only to provide services to us, and to keep this information confidential.

We reserve the right to use or disclose any information as needed to satisfy any law, regulation or legal request (e.g., subpoenas or search warrants), to conduct investigations of consumer complaints or possible breaches of law, to protect the integrity of our Services and our property, or to protect the safety or fundamental rights of our visitors or others.

Personal data may be transferred to a third party if there is a transfer of the assets or ownership of CompareRemit or if CompareRemit files for bankruptcy.


USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies

Your browser offers so-called "cookies" which, if you allow their use, store small amounts of data on your computer when you visit a Web site. We use cookies to customize our content according to your preferences.

Web Beacons

Some of our Site’s pages may contain electronic images known as Web beacons, which are also called single-pixel gifs. These images allow us to count users who have visited those pages and to deliver co-branded services. We also may include Web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal data but they are a technique we use to compile aggregated statistics.

Opting Out

If you prefer, you can change your browser settings to have your browser provide a warning each time a cookie is being sent, you can choose to turn off only third party cookies (that is, cookies that are placed by a domain other than compareremit.com or whatever domain you’re currently viewing), or you can choose to turn off all cookies. If you turn cookies off, many elements of the Service, like most websites, may not function properly.

You may also disable Web beacons by disabling HTML images in your email program, which may also affect other images in emails you receive.

Analytics Partners

We may contract with third-party service providers to assist us in better understanding the users of our Services. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. Presently, the only third-party analytics service provider we use is Google Analytics. While Google Analytics may collect personal data to derive the information that it shows to us, we cannot view Google Analytics information identifiable to you.

For Google’s privacy practices see https://www.google.com/analytics/learn/privacy.html.


EXTERNAL LINKS AND THIRD PARTIES

This privacy policy does not apply to information users give to third parties not affiliated with CompareRemit. Any information users give to another party is governed by the rules of that party's privacy policy, which may differ from this privacy policy. CompareRemit. is not responsible for information given to other parties.


CHILDREN

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act). We do not knowingly collect or process any information from anyone under 13 years of age (16 in the EU). Our Site and Service is directed to people who are at least 13 years old or older (16 in the EU).


DO NOT TRACK

We do not respond to the Do Not Track setting in your browser. We use only content customization cookies as described above. We do not otherwise use cookies to collect personally identifiable information or track users’ online activities over time. We do not use cookies to track personally identifiable information or users’ online activities across different web sites. However, certain of the third party advertising providers we use (e.g., Google, Facebook, Quora) may be able to do so, though we do not have access to that information. For information regarding Do Not Track mechanisms, see http://allaboutdnt.com.


INTERNATIONAL TRANSFER

Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your personally identifiable information to us, we may transfer your personal data to the United States and process it there.


SECURITY

We implement a variety of security measures to maintain the safety of personal data when a user enters, submits, or accesses their personal data, when we retain that information, and when we transmit that information to third parties as permitted under this privacy policy.

We offer the use of a secure server for compareremit.com. All personally identifiable information supplied by you to us via compareremit.com is transmitted via Secure Socket Layer (SSL) or similarly secure technology. We allow personally identifiable information to be accessed only by persons with specified rights to do so.

You should be aware that if you voluntarily disclose information in visible forum online (whether through CompareRemit's services or any other services available online), personal or otherwise, that information could be collected and used by others. For example, if you post a review on CompareRemit or use chat forums, bulletin boards, and you post your e-mail or other identifying information, you may receive unsolicited messages form others. CompareRemit has no control over this use of your personal data.

Due to the open nature of communication through the Internet, we cannot guarantee that communications between you and CompareRemit, or between CompareRemit and the insurance carriers to which you ask us to submit your information, will be free from unauthorized access by third parties, nor that third parties will not be able to circumvent the safeguards we have put in place. We cannot absolutely guarantee the security of any information that is disclosed or transmitted online.


DATA RETENTION

We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized 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 requirements.


YOUR RIGHTS AND CONTROLLING YOUR PERSONAL DATA

Your Rights

Under the applicable laws of various countries, you may have certain rights concerning your personal data, such as under EU law: the right to access to, rectification or erasure of, and/or suspension or restriction of, or objection to, processing of your personal data, and the right to data portability. If you have any questions or want to exercise any of your rights with respect to your personal data, please contact us by the methods indicated at the end of this section.

Exercising Your Rights

Before we process any request, we may request personal data to verify your identity where allowed by law, and to verify any new or corrected information you may provide.

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

To exercise your rights with respect to your personal data or otherwise ask us about our collection and processing of your personal data, use our contact us form.


CHANGES

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll provide notice of such changes by posting them here, and we’ll indicate when such changes will become effective. Information will continue to be governed by the Privacy Policy in effect at the time such information was collected.

Last updated August 14, 2018

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