Informativa sulla privacy di Zepz
Canada Privacy Policy
Effective 2 January 2024
Introduction
Your privacy and keeping your personal information secure are extremely important to us. At WorldRemit Inc, we are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.
This Privacy Policy ("Policy") explains among other things: what we do with your personal information; what we do to keep it secure; with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information.
We will regularly amend or update this Policy to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
If you don't want to read all the details. Here are the highlights that you may really wish to know:
WorldRemit Inc is an international payment service that provides international money transfer and remittances services in more than 130 countries and over 70 currencies.
WorldRemit Inc is part of the WorldRemit Group, which includes Sendwave Inc, and its affiliate Sendwave Canada Inc. For a list of companies in the WorldRemit Group click here.
You will know us by our brands: “WorldRemit” and “Sendwave”.
We are bound by the Personal Information Protection and Electronic Documents Act 2000 (the 'Act'), which requires that we protect your information and inform you about how we handle your personal information.
Where appropriate we share Your personal information within the WorldRemit Group, our affiliates, partners and other companies. Upon request or where we are legally obliged, we may share your information with public agencies.
We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers). In providing this information you confirm to us that you have their permission to do so.
We use some third parties to process your personal information on our behalf to perform our services for you, and due to the international nature of our business some of them are based outside of Canada.
You have several rights over your personal information and the manner in which you can exercise those rights are contained in this Policy.
We will send you direct marketing if we are allowed to. We do this to encourage you to use our services and send you offers or promotions that may interest you. You can ask us to stop sending you marketing information at any time. Details of how to unsubscribe will be included on each marketing email that we send you. Alternatively, send us an email to dataprivacy@zepz.io with “URGENT - UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.
We will not collect sensitive information about you without your consent unless an exception in the Act applies. For example, if the collection is required or authorised by law.
Who are we?
WorldRemit Inc ("WorldRemit", "we", "us", "our'') is an affiliate of WorldRemit Group (UK) Limited (registered in the United Kingdom and regulated by the Financial Conduct Authority). Our registered office is 2, Bloor Street, W Suite 700, Toronto, ON, M4W 3E2, Canada.
We are an Organization for the purposes of the Privacy Laws (as defined below). In this Policy, references to "You" and "Your" are references to a user of our website and/or of our Mobile App.
WorldRemit Inc is part of the WorldRemit Group, which includes Sendwave Inc, Chime Inc and Sendwave Canada Inc (“Sendwave”).You will know us by our brands: “WorldRemit '' and “Sendwave”. For a full list of companies in the WorldRemit Group click here.
Definitions
To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:
“Customer” means any individual who has registered with us or used any of our Services or inquired about any of our Services.
“Privacy Laws'' means the Personal Information Protection and Electronic Documents Act 2000 (the 'Act'), and other applicable legislation relating to privacy or data protection.
“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.
“Services” means WorldRemit Money Transfer Service; WorldRemit Digital Money Account; Airtime Top Up; and such other services or products that we may introduce from time to time.
The personal information we collect about you
We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Privacy Laws and as set out in this Policy.
The personal information we collect and use may include, amongst other things:
Your name;
Your contact information such as Your email address, postal address and telephone number (or any telephone number used to call our customer services);
Your demographic information such as age, education, gender, and interests;
Evidence of Your identity (for example passport information);
Any correspondence or complaint made to us;
Unique identifiers such as Your username, account number and password;
Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
Information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
Sensitive personal information
Some information is classed as sensitive personal information. This includes information or an opinion about a person's political opinions, philosophical or religious beliefs or affiliations, membership of a political, trade or professional association or trade union, sexual preferences or practices, criminal record, health or genetic information, biometric information that is used for the purpose of biometric verification or identification, or biometric templates.
We will only collect, hold or disclose Sensitive Information if:
You have consented; or
the collection is required or authorised by or under Privacy Laws or a court / tribunal order.
How we collect your personal information
Information You give to us when You use our services.
If You use our services You will need to provide certain information including Your name, address and card number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out. This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
Your communication with us.
We also keep a record of any email correspondence you send us. This helps us provide you with better customer service, and to improve the experience of our customers overall. Telephone calls made to and from the Contact Centre will be recorded for quality, training and monitoring purposes.
Other information You give to us.
This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or you take part in competitions, surveys, or questionnaires about our products or services, or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
From other members of the WorldRemit Group.
We may collect information about You from Sendwave and other companies in the WorldRemit Group.
Social Media.
Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, Linkedin and Instagram, You might give us permission to access information from those accounts or services.
Other Sources.
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 analyse our records and provide services that may be of interest to You.
Information we collect about You.
Like most websites, we use "cookies" to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields.
Log Files.
In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.
Social Media Widgets.
Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
Personal information from third parties.
If we receive personal information about you that we do not request directly from you or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. If we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will destroy or anonymise the information if it is reasonable and lawful to do so.
Mobile App.
When You download our Mobile App, in addition to the information mentioned above we: - collect information on the type of device You use, operating system version, and system and performance information. We may send You push notifications from time-to-time in order to update You about 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; and - may use mobile analytics software to allow us to better understand the functionality of our Mobile Software on Your device. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App.
Cookies and similar technologies
When you visit our site or use a Mobile App we may place cookies or similar trackers (“Cookies) onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our WorldRemit Products Cookie Policy and Sendwave Products Cookie Policy.
How we use your personal information
Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.
We use Your information for the following specific purposes:
to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the Services in accordance with our
and with this Policy;
to register You with a WorldRemit account;
to fulfil Your Transaction / (Airtime Top Up) Request;
to send You confirmations;
to notify You about temporary or permanent changes to our services or other service-related messages;
to assist you where online applications are not completed;
to prevent fraud, money laundering, and any other illegal activity that may cause you, us or others harm including in relation to the Services;
comply with our legislative and regulatory requirements in any jurisdiction;
to ensure that content from our site is presented in the most effective manner for You and for Your computer;
to promote our business;
to send You Marketing communications except you tell us not to do so.
to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our site, Mobile App and our services 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 services that may interest You or them;
to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
to consider and investigate any concerns or complaints you may have; and
to display personal testimonials of satisfied customers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial.
Our legal grounds for processing your personal information
We only use your personal information for a specific purpose, and before we do so we must have a legal reason. Subject to applicable law, we will use your personal information where:
We have obtained your prior consent to the processing.
Processing is necessary: - for the performance of a contract, or to take steps prior to entering a contract with us; - for compliance with any legal obligation which we are subject to other than the obligation imposed by a contract; - to protect your vitally important interest; - for the administration of justice; - to respond to a national emergency, comply with the requirements of public order and safety, or to fulfill functions of a public authority; - for the exercise of any functions conferred on any person by or under any law; or - for our legitimate interests or that of a third party (to the extent that such legitimate interests are not overridden by your interests).
Direct Marketing
We may use the contact details You provided to send you marketing communications by email, telephone, direct mail or other communication formats about similar products or services where permitted by applicable law (unless you have opted out).
In other cases, we may ask for your consent to send you marketing communications about products or services offered by Sendwave and other companies within the WorldRemit Group, for a full list of these companies click here.
Notice to Sendwave Customers before 2 January 2024
If you were a Sendwave customer before 2 January 2024, we will only use your personal information for marketing and promotional purposes if you had “opted in'' to such uses before [...] January 2024. You can withdraw this permission by opting out at any time.
Opting Out of Direct Marketing
If you have a WorldRemit or Sendwave account, you can opt out of receiving WorldRemit marketing communications by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out message included in the message.
Alternatively, simply send an email to dataprivacy@zepz.io with “URGENT - UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.
Please note that if you request we stop sending you Marketing messages, we may continue to send you service and administrative communications (such as transfer updates and other important or transactional information).
Who we might share your personal information with
Your personal information is very important to us. However there are circumstances where it is necessary for us to share your information in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:
Our affiliates
- we share your information with Sendwave and other companies within the WorldRemit Group. - for our internal business, operational, management and service needs; - for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations; - to understand and support our Customers who use our services, apps and sites, as well as visitors to those apps and sites; and - to send Marketing communications.
Third party processors
which include
- people with whom we do business or who provides services to us. If we engage a third party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements. We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property. Processors may include: - Credit reference agencies or other service providers to verify Your identity or the identity of recipients of the money transferred through our services or for any other purpose related to providing our services; - Debt collectors; - Professional advisers, such as our auditors and lawyers; - Companies that capture or analyse information to help us understand how our services, sites and Mobile Apps are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide; - Companies that provide us with marketing assistance, including: the management of email marketing operations, SMS and other services that deploy marketing on the internet or social media platforms (such as Facebook and Google); the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or customer engagement we do; - Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services; - Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps; - Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted; - Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganisation; and - Any successor in business to us.
Fraud Prevention Agencies
- Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
Public Agencies
- We release accounts or other personal information when we consider it appropriate to comply with the law or an order of a court or tribunal, to enforce our Terms and Conditions and any other agreement to protect the rights, property, health or safety of WorldRemit, our employees or Customers, our business partners or others or the public. In these circumstances, we will only provide them with the information they require to perform their function.
Facebook -
We may share with Facebook actions that you take on our website such as your visits to our website, your interactions on our website, use of Facebook Connect and information collected from cookies or similar technologies including the Facebook Pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and helps us deliver more relevant advertising to you and people like you (including on social media such as Facebook). This arrangement means that WorldRemit has to provide you this notice, but you should contact Facebook if you wish to exercise your data protection rights. Further information, including how Facebook enables you to exercise your data protection rights, and subsequently processes your information can be found in Facebook Data Policy
If you would like to know more please contact us using the details below.
Google
We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.
Research companies -
We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.
International transfer of your personal information
Due to the international nature of our business, we may need to transfer your personal information to other WorldRemit entities, to other third parties as stated in the “Who we might share your information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Where recipients are located outside Canada we ensure that the information will be protected by: safeguards comparable to Canada’s Privacy Laws; or by methods including using contractual clauses; or by ensuring the recipient is subject to laws of another jurisdiction that provides comparable protection to the Privacy Laws.
We also ensure that our data protection and information security controls applying to your personal information in Canada continue to apply in the hands of our affiliates or contracted service providers located overseas.
How we keep your personal information secure
We have implemented appropriate technical and organisational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee the security of Your data transmitted to our site; and any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your Rights
Subject to applicable law, you may have a number of rights regarding our processing of your relevant personal information, including:
the right not to provide your personal information to us (however, please note that we may be unable to provide you with the full benefit of our site, our Mobile App, or our services, if you do not provide us with your personal information);
the right to request access to your personal information, together with information regarding the nature, processing and disclosure of those personal information;
the right to request for the correction of any inaccuracies in your personal information;
the right to prevent processing for direct marketing purposes as stated in the “Direct Marketing” section of this policy;
where we use your personal information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal) this right is subject to contractual or legal restrictions as may be applicable; and
the right to lodge complaints with the
Office of the Privacy Commissioner of Canada
regarding the use of your personal information by us or on our behalf.
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.
You can contact us at dataprivacy@zepz.io if you want to enforce any of these rights. We will comply with our legal obligations as regards Your rights as a data subject.
Any request for access to Your personal information must be in writing and we will endeavour to respond within a reasonable period. Generally, this will be within 30 days from the date of your request. We may extend this period if the circumstances justify an extension. We reserve the right to charge a reasonable fee (reflecting the costs of providing the information) or to refuse to respond where requests are manifestly unfounded or excessive: in this case, we will explain the situation to You and we will inform You about Your rights.
How long will we keep your personal information for
We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, unless applicable law requires a longer retention period, we will keep our records for as long as you are our Customer and for 6 years after the end of your relationship with us.
For more details of the retention periods we apply to your personal information please contact dataprivacy@zepz.io.
How to make a privacy complaint?
WorldRemit takes all complaints seriously and will investigate your complaint accordingly.
If you believe that there has been a breach of the Act or elements of this Policy, or if you have any concerns about WorldRemit's handling of your personal information, please contact us using the contact us tab on our website or by emailing us at dataprivacy@zepz.io. Your privacy complaint should be directed and addressed to the Privacy Officer.
Please note that we aim to respond to complaints within thirty (30) days of receipt. If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Privacy Commissioner of Canada by:
Writing to: 30 Victoria Street, Gatineau, Quebec K1A 1H3 Canada
Telephone: 1-800-282-1376 (Toll free)
Contact us
Questions, comments and requests regarding your personal information and our Policy are welcome and should be sent to: dataprivacy@zepz.io or you can send it by post addressed to: Privacy Officer, WorldRemit Inc 2, Bloor Street, W Suite 700, Toronto, ON, M4W 3E2, Canada
Email: dataprivacy@zepz.io. Telephone: +1 833 596 0890.
You may also use these contact details if You wish to make a complaint to us relating to Your privacy.