Golden Money Transfer, Inc. Privacy Policy-Version 3-August 19th, 2020

Golden Money Transfer, Inc. (GMT), conducting business under the trade name Inyo, takes your privacy very seriously. This Privacy Policy applies to GMT websites, and the services associated with GMT. This Privacy Policy applies only to the Service and does not apply to the practices of other GMT services. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services. Please read the following Privacy Policy to gain a better understanding of how GMT may collect, store, and use the personal identifiable information of its visitors to our website and users of our service (as defined in the User Agreement). Federal law gives you the right to limit some, but not all sharing of your personal identifiable information.

What Personal Information Do We Collect?

  • Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. We collect: your name, address, telephone number, email address, and other identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services to protect and verify your identity, detect and prevent fraud, process your transaction, and collect payment.
  • Transaction and experience information – When you use our Services or access our Sites to send money to friends and family, we collect information about the transaction and other information associated with the transaction such as amount sent or requested, amount paid for service, merchant information, including information about any funding instruments used to complete the transaction, device Information and IP geolocation Information.
  • Participant information – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction.
    • Send money: When you send money through the Services, we collect Personal Data such as name, address, telephone number, and financial account information about the participant who is receiving money from you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
  • Information about you from third-party sources – We obtain information from third-party sources such as merchants and data providers as permitted by law.
  • Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us or contact our customer support teams.

By using the service and visiting the website, you, the customer, (i) consent to our collection, transfer, and storage of your personal information, and (ii) authorize us, directly or through third parties, to make any inquiries we consider necessary to validate the information that you provide to us.

How We Process Your Personal Information?

We may process your information for the following reasons:

  • To operate the Sites and provide the Services, such as:
    • Send money and initiate a payment;
    • Authenticate your access to an account; communicate with you about your Account, the Sites, the Services, or GMT;
    • Create an account connection between your Account and a third-party account or platform;
    • Compare information with third party vendors for accuracy and verification purposes; and keep your Account and financial information up to date.
  • To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality.
  • To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. GMT’s risk and fraud tools use Personal Data, Device Information, and IP Geolocation Information from our Sites to help detect and prevent fraud and abuse of the Services.
  • To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.
  • To respond to your requests, for example to contact you about a question you submitted to our customer service team.

How We Collect Information and Cookies

We may utilize “cookies” to improve the customer’s experience in using the service by helping us remember your information. If your browser permits, you may decline the use of cookies. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings, or visiting the website of its manufacturer. Because cookies allow some of GMT's essential features to operate properly, we recommend that you leave them turned on, otherwise, the website may not function properly.

Our social media services (Facebook) may use both session ID and cookies. The use of cookies by our social media services are not covered in this Privacy Policy. You are free to decline these cookies if your browser permits. We do not have access or control over these cookies. We may use an analytics tool to develop and analyze use of the service. Analytics companies may access anonymous data (such as your identifier for advertising or device ID) to help us better understand how the service is utilized. They use this data solely on our behalf. This information is not shared except in aggregate form; no data is shared as to any individual user. If you wish to opt-out from analytics, please contact GMT us at info@gmtnorthamerica.com.

Sharing Your Information

GMT does not sell your personally identifiable information to third parties. If we change this policy, we will let you know beforehand and give you the option to "Opt Out." As exceptions to this policy, we may from time to time provide personally identifiable information about you to third parties in the following ways:

  • To assist with business operations, such as payment processing and fraud prevention. Your personal information is shared with these third parties only as necessary to ensure the accuracy and security of the information provided.
  • As part of legal or regulatory requirements imposed upon us such as, a subpoena, court order, or other request issued to GMT from law enforcement or government officials.
  • Information to our third-party service providers, such as pay-out partners in foreign countries and databases that we use to verify your information.
  • To credit bureaus or collection agencies, if you delay or fail to make payment for the Services.
  • Information required to comply with State and federal applicable laws, to report suspected suspicious activity, violation of our User Agreement, or to prevent financial harm or loss.
  • To processes your transactions. This includes other Users you are sending funds to, and merchants and their service providers.
  • With other third parties for our business purposes or as permitted or required by law: We may share information about you with other third parties for GMT’s business purposes or as permitted or required by law, including:
    • If we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
    • To protect the vital interests of a person;
    • To investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
    • To protect our property, Services and legal rights;
    • To facilitate a purchase or sale of all or part of GMT’s business;
    • To help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that involves our business partners, strategic ventures, or other individuals and merchants, etc.;
    • To banking partners as required by card association rules for inclusion on their list of terminated merchants;
    • To credit reporting and collection agencies;
    • To companies that we plan to merge with or be acquired by; and
    • To support our audit, compliance, and corporate governance functions.

We do not share your Personal Data with third parties for their marketing purposes.

Options Regarding Use of Your Information

Federal and State laws allow you to restrict the sharing of your personal information in certain instances. However, these laws also state that you cannot restrict other types of sharing. Because we have chosen to refrain from certain types of data sharing, the only type of sharing of your personal information that you may restrict is as follows:

  • You may also opt-out from promotional email messages sent to you by GMT by accessing your Email Preferences under “My Account” or selecting the “Unsubscribe” function present in each promotional email message we send out and providing the required information.

What Privacy Choices are Available to you?

You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

  • Choices Relating to the Personal Data We Collect
    • Personal Data. You may decline to provide Personal Data when it is requested by GMT, but certain Services or all of the Services may be unavailable to you.
    • Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that GMT may collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
  • Choices Relating to Sharing Your Personal Data
    • If you reside in the United States and have opened an Account for your own personal and family or household purposes, please see our Consumer Privacy Notice for additional information on opt out rights you may have and how to exercise these rights.
  • Choices Relating to Account Connections If you authorize an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have.
  • Choices Relating to Cookies
    • You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using the core features and functions available on a Service or Site.
    • You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
  • Choices Relating to Your Registration and Account Information
    • If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us if you have questions about your Account information or other Personal Data.
    • Please log in to your account to modify or update your personal information as necessary. If any changes occur to your contact information, please update it in your account settings as soon as possible so that we may continue to process your transactions and contact you with important updates.

How do we protect your data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection of your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

Can Children use our Service?

The Sites and Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

Consumer Privacy Notice

This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses our Sites or Services for your own personal, family or household purposes.

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number
  • Payment history or transaction history

When you are no longer our customer, we may continue to share your information as described in this notice.

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 GMT chooses to share, and whether you can limit this sharing. Reasons for sharing your personal information include for our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus; sharing this information cannot be limited.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

We collect your personal information when you:

  • Open an account or provide account information
  • Use your credit or debit card or give us your contact information
  • Use your GMT account to send funds

We also collect your personal information from others third party vendors.

Federal law gives you the right to limit sharing of only

  • Sharing for affiliates’ everyday business purposes — information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

California Customers

The California Financial Information Privacy Act Division 1.4 of the Financial Code (“Division 1.4”) became effective on July 1, 2004. Division 1.4 broadly regulates the sharing of nonpublic personal information of customers. In accordance with the California Financial Information Privacy Act ("Division 1.4"), GMT does not share its customer’s nonpublic personal information outside of its corporate family prior to written consent from the customer, except as permitted by law.

GMT will disclose information about its customers with a valid California mailing address only with customer’s written authorization, unless otherwise permitted by law. Written authorizations from California customers may be delivered to us at the address above or by email at info@gmtnorthamerica.com and must contain your name, address, signature and your consent. You may revoke your consent at any time by calling us at 1-888-702-5656 or by writing or emailing us at the addresses provided above.

Users of the service, regardless of their state of residence, cannot opt-out of certain disclosures including:

  • Disclosures necessary to process, send, administer or enforce your transaction;
  • Disclosures to our authorized service providers, including our pay-out partners;
  • Disclosures permitted or required by law;
  • Disclosures to prevent fraud, or other illegal activities.

Notice to All Texas Customers:

Golden Money Transfer, Inc. is licensed under the laws of the State of Texas pursuant under MSB license number 3057, and by state law is subject to regulatory oversight by the Texas Department of Banking.

If you have a complaint, first contact GMT Customer Service at 1-888-702-5656. If you still have an unresolved compliant regarding the company’s money transmission activity, please direct your complaint to the Texas Department of Banking.

Consumers/customers may file complaints with the Texas Department of Banking by contacting the Department through one of the means indicated below:

In Person or U.S. Mail: Texas Department of Banking
2601 N. Lamar Boulevard
Austin, TX 78705-4294
Telephone Number: 512-475-1300 OR 512-475-1300 (toll free)

E-mail: consumer.complaints@dob.texas.gov

Website: www.dob.texas.gov

Future Changes to this Policy

We may amend this policy at any time, and shall notify you by posting a revised version on our website. Should we make a material change to the manner in which we collect, use or store your personal information, we shall provide prior notice on our website.

Complaints

If you have a complaint, please contact GMT Customer Service at 1-888-702-5656 or via email at info@gmtnorthamerica.com.