Effective date: May 31, 2016
Why Do We Collect Information?
1. OFX is always willing to explain our purposes for collecting personal information, which include the following:
- to provide, analyze, develop and improve our products and services;
- to communicate with you about issues such as product or service announcements or updates;
- security alerts, technical notices, confirmation of transactions, promotions or offers, and to provide you with advertising and marketing;
- to comply with our legal, audit or business obligations, such as to verify your identity or location (or the identity or location of your representative or agent), risk control, or fraud prevention;
- to protect our company or others against unlawful conduct or harm; and
- for other purposes as described herein.
What Information Do We Collect?
2. When you initiate the online registration process for a transaction with OFX, we ask for certain personal information, for example, name and contact information, email address, driver’s license number, Social Security Number and financial or banking account information. In general, we seek to limit the amount and type of information collected to that which is necessary to run our everyday business and provide our products and services. We collect the following personal information from you about your contacts or friends: email address, mailing address, phone number and use to fulfill the order to you are sending, invite your friends to use our service, send your friends our newsletters, refer your friends to our service.
3. We may combine the information collected through the online registration process with other online or offline information about you that we may obtain from third parties, such as fraud prevention services or credit reporting agencies. OFX will make reasonable efforts to inform you if we have collected personal information about you from someone else.
4. We and our business partners may also collect information through cookies and similar technologies (such as pixel tags, web beacons, clear GIFs, log file data, and flash objects).
Cookies are small data files that are placed on your computing device when it accesses our website or Mobile App. Cookies collect information such as your computing device’s IP address and other technical information. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our website or mobile app, and for ensuring that advertising or marketing delivered to your computing device is more relevant to your interests. Flash cookies and HTML5, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use HTML5 to collect and store Usage Information. Flash cookies are different from standard browser cookies because of the amount of, type of, and how, data is stored. Clear GIFs or web beacons can be used to anonymously track the online usage patterns of web users, or to track the effectiveness of HTML email marketing campaigns. Log file information, which may include data such as IP addresses, browser data, and referral and exit pages, is automatically reported by your browser when you access a web page. We may use the information we collect through tracking technologies to (a) remember your information so that you will not have to re-enter it during your subsequent visits; (b) enhance your experience on our websites, including through the display of customized content and targeted advertising; (c) provide and monitor the effectiveness of our Service and our content; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems; and (f) help you efficiently access your information after you sign in.
You can manage your computing device’s settings to reject cookies or accept them only under specified circumstances. Refer to your browser’s or device’s technical manual for further instructions on how to manage cookies. Please note that if you choose to reject cookies on your device, you may not be able to use certain features and functionalities provided by our website and Mobile App.
Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
We Share Your Information With Others?
5. OFX, like many other companies, shares information with third-party service providers, business partners, and transactional parties so that we can run our business, serve our customers, and fulfil the purposes listed in Paragraphs 2, 3 and 4 (above). For example, if you register with us and initiate a transaction, we may disclose certain information about you to unaffiliated, third-party intermediary banks in order to process the transaction on your behalf.
6. Please refer to our Consumer Privacy Notice for more information about how we share information and your options for limiting our sharing.
7. There may be circumstances in which OFX is obliged to collect, use, or disclose certain personal information without notice to you or your consent. Such circumstances may include, for example:
- a serious and imminent threat to any individual’s life, health or safety;
- a serious threat to public health or public safety;
- unlawful activity has been, is being or may be engaged in;
- where disclosure is required or authorized by law such as to comply with a subpoena or similar legal process;
- where OFX reasonably believes in its sole discretion that the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of, among other things:
- criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
- the enforcement of laws relating to the confiscation of the proceeds of crime;
- the protection of the public revenue;
- the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
- the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
8. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets, shares, or other transaction, or in the event of any insolvency, bankruptcy, receivership, dissolution or similar proceeding, the personal information of our users may be one of the assets merged or sold in connection with such transaction or proceeding. Such information may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
Can You Access and Control Your Information?
9. OFX will upon request, retrieve or verify your personal information. Please use the contact information below to make such a request. In addition, where you point out to OFX that any of your information held by us is inaccurate or incomplete, please advise us promptly so that we can provide you with the best possible service. However, if you wish to have your information deleted, we may not be able to honor your request due to applicable legal statutes, rules or regulations. We will respond to your request within a reasonable timeframe.
10. There may be circumstances which preclude OFX from providing access to some or all of your personal information, for example where:
(i) the information contains references to or personal information about an individual other than you;
(ii) the information is subject to legal, investigative, security, or commercial proprietary protections;
(iii) the information is subject to attorney/solicitor-client or litigation privilege;
(iv) the information has been destroyed pursuant to legal requirements or because we no longer need it for the purposes for which it was collected;
(v) disclosure may in reasonable belief threaten the safety or physical or mental health of you or another individual; or
(vi) disclosure may contravene another law that prohibits the disclosure.
11. If you are registered with OFX, as noted above, we may send you information related to the provision of our services, which may include advertising or marketing. For marketing communications, you can call us or send us an email opt-out (or as applicable, click on an “unsubscribe” link at the bottom of the email communication) to request that you not be included in future marketing efforts. Note, however, that you cannot opt out of receiving technical, account, transactional or related communications.
12. Please refer to our U.S. Consumer Privacy Notice for more information about how we share information and your options for limiting our sharing.
Note that we do not provide an opt-out choice for information uses in support of our everyday business purposes, such as to process transactions, maintain accounts, perform information technology functions, respond to court orders and legal investigations, report to credit bureaus, or offer our products and services, because these disclosures are necessary to run our everyday business.
How Long Do We Retain Your Information?
13. OFX retains your personal information for so long as our relationship remains active and to fulfill the purposes listed in Paragraphs 2, 3, and 4 (above). Where lawful to do so, we may destroy, erase or aggregate/anonymize your personal information when it is no longer required to fulfill the purposes for which it was collected.
14. OFX may also retain your personal information to the extent we determine in our sole discretion that the retention is warranted under circumstances such as those listed in Paragraphs 8 and 10 (above), or required by applicable laws, rules or regulations.
How Do We Protect Your Information?
15. OFX has implemented reasonable safeguards to help protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. These safeguards include physical, organizational, and technological measures such as encryption. The specific safeguards used by us may differ based on our sole judgment as to the sensitivity of the information at issue and the format or location in which it is maintained.
Links To Third Party Websites and Services
16. Our website or Mobile App may contain links to or from third-party websites or services, including social networking sites such as Facebook or Twitter. We do not own or control such third-party sites or services, and any information you provide to them is subject to their privacy practices and policies.
Social Media Widgets
17. Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website (collectively, “Features”). These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
18. Our Services are intended for adults. We do not intentionally collect or solicit personal information from individuals under 13 years of age. If you become aware that we have inadvertently collected information from anyone under the age of 13, please notify us immediately at the contact details below.
How Can You Contact Us?
20. You can contact us with any questions or concerns at: USForex Inc. dba OFX, 49 Stevenson St, 13th Floor, San Francisco, CA 94105 or by email at firstname.lastname@example.org