In order to operate the
FXRemit.com and to reduce the risk of fraud,
AT Pacific, Inc. (“FXRemit.com” or “we”)
must ask you to provide us information about
yourself and your credit card and/or bank
account. This Privacy Policy describes the
information we collect and how we use that
information. FXRemit.com takes the privacy
of your personal information very seriously
and will use your information only in accordance
with the terms of this Privacy Policy. We
will not sell or rent your personally identifiable
information or a list of our customers to
third parties. However, as described in
more detail in Part C below, there are limited
circumstances in which some of your information
will be shared with third parties, under
strict restrictions, so it is important
for you to review this Privacy Policy. This
Privacy Policy applies to all services that
are offered by the FXRemit.com Web site.
Notification of Changes
This policy may be revised
over time as new features are added to the
FXRemit.com service or as we incorporate
suggestions from our customers. If we are
going to use or disclose your personally
identifiable information in a manner materially
different from that stated at the time we
collected the information, you will have
a choice as to whether or not we use or
disclose your information in this new manner.
Any material changes will be effective only
after we provide you by e-mail with at least
30 days’ notice of the amended Privacy Policy
(if you have closed your FXRemit.com account,
you will not be contacted to notify you
of the amended Policy and your personal
information will not be used or disclosed
in this new manner).
We will post the amended
Privacy Policy prominently on our Web site
so that you can always review what information
we gather, how we might use that information,
and whether we will disclose it to anyone.
Please check the FXRemit.com Web site at
www.FXRemit.com at any time for the most
current version of our Privacy Policy.
Other pages on the FXRemit.com
Web site include links to third party Web
sites. These sites are governed by their
own privacy statements, and FXRemit.com
is not responsible for their operations,
including but not limited to their information
practices. Users submitting information
to or through these third party Web sites
should review the privacy statement of these
sites before providing them with personally
identifiable information.
B. Information We Collect
Required Information To
open an FXRemit.com account, you must provide
your name, address, phone number, and e-mail
address. In order to make payments through
FXRemit.com, you must provide credit card,
debit card or bank account information (bank
account information is required to make
payments totaling more than $1,000). We
also ask you to choose two different security
questions to answer (such as your city of
birth or your pet’s name) This required
information is necessary for us to process
transactions, issue a new password if you
forget or lose your password, protect you
against credit card fraud and checking account
fraud, and to contact you should the need
arise in administering your account.
Transaction Information
When you use FXRemit.com to send money to
someone else or request money from someone
else, we ask you to provide information
related to each transaction, including the
amount of the transaction, the type of transaction
(purchase of goods, purchase of services,
or simple money transfer (“quasi-cash”))
and the e-mail address of the third party.
We retain this information for each of your
transactions through FXRemit.com. We also
collect the Internet address (IP address)
of the computer or device you use to access
your FXRemit.com account, in order to help
detect possible instances of unauthorized
transactions.
Information About You
From Third Parties In order to protect all
our customers against potential fraud, we
verify with third parties the information
you provide. In the course of such verification,
we receive personally identifiable information
about you from such services. In particular,
if you register a credit card or debit card
with FXRemit.com, we will use card authorization
and fraud screening services to verify that
your card information and address matches
the information that you supplied to FXRemit.com,
and that the card has not been reported
as lost or stolen. If you register your
online business with FXRemit.com Shops,
in some circumstances we will conduct a
background check on your business by obtaining
information about you and your business
from a credit bureau or a business information
service such as Dun & Bradstreet. If you
incur a debt to FXRemit.com, we will generally
conduct a credit check on you by obtaining
additional information about you from a
credit bureau, to the extent permitted by
law.
Additional Verification
If we cannot verify the
information that you provide, or if you
request a withdrawal by check to an address
other than your verified credit card billing
address, we ask you to send us additional
information by fax (such as your drivers’
license, credit card statement, and/or a
recent utility bill or other information
linking you to the applicable address),
or to answer additional questions online
to help verify your information.
Web Site Traffic Information
Because of the way that
World Wide Web communication standards work,
when you arrive at or leave the FXRemit.com
Web site, we automatically receive the Web
address of the site that you came from or
are going to. We also collect information
on which pages of our Web site you visit
while you are on the FXRemit.com site, the
type of browser you use and the times you
access our Web site. We use this information
only to try to understand our customers’
preferences better and to manage the load
on our servers, so as to improve our service
and your experience with FXRemit.com. We
do not track the Web sites that you visit
before or after you leave the FXRemit.com
site.
Our Use of “Cookies”
”Cookies” are small files
of data that we send to your computer to
allow us to recognize you as a FXRemit.com
customer if you return to the FXRemit.com
site using the same computer and browser.
We send a “session cookie” to your computer
if and when you log in to your FXRemit.com
account by entering your e-mail address
and password. These cookies allow us to
recognize you if you visit multiple pages
in our site during the same session, so
that you don’t need to re-enter your password
multiple times. Once you log out or close
your browser, these session cookies expire
and no longer have any effect.
We also use longer-lasting
cookies to display your e-mail address on
our sign-in form, so that you don't have
to retype the e-mail address each time when
you log in to your FXRemit.com account.
In addition, we use cookies to process our
referral program, described in Section C
below. Our cookie files are encoded so that
your e-mail address and other information
can only be interpreted by FXRemit.com
Customer Service Correspondence
If you send us correspondence,
including e-mails and faxes, we retain such
information in the records of your account.
We will also retain customer service correspondence
and other correspondence from FXRemit.com
to you. We retain these records in order
to measure and improve our customer service,
and to investigate potential fraud and violations
of our Terms of Use. We may, over time,
delete these records if permitted by law.
Questionnaires, Surveys
and Profile Data
From time to time, we
offer optional questionnaires and surveys
to our users for such purposes as collecting
demographic information or assessing users'
interests and needs. The use of the information
collected will be explained in detail in
the survey itself. If we collect personally
identifiable information from our users
in these questionnaires and surveys, the
users will be given notice of how the information
will be used prior to their participation
in the survey or questionnaire.
Non-member Recipients
and Requests
When a member either sends
a payment to, or requests a payment from,
an individual who is not a registered member
of FXRemit.com, we will retain the information
that the member submits to us, including,
for example, the other party's email address
and/or name, for the benefit of the member
who is attempting to contact the non-member,
so that the member can see a complete record
of his or her transactions, including uncompleted
transactions. Although this information
is stored indefinitely, we will not market
to the non-member in any way at any time.
Additionally, these non-members have the
same rights to access and correct information
about themselves (assuming that their email
addresses were correct enough to reach them)
as anyone else who uses FXRemit.com.
C. Our Use and Disclosure
of Information Internal Uses
We use the information
we collect about you in order 1) to provide
our services and process your transactions,
2) to provide customer service, 3) to determine
your eligibility to receive offers for special
features or products. and 4) to improve
our products and services. At your option
(as indicated in your FXRemit.com Profile
settings), we use the information you provide
to access specific third party services
on your behalf and perform the actions that
you request us to perform.
We give access to individually
identifiable information about our users
only to those employees who require it to
fulfill customer service requests. If you
are a registered FXRemit.com user, your
name, e-mail address, date of sign-up, may
be displayed to other FXRemit.com customers
whom you have sent moneys. If you are a
Business account holder, we may also display
to other FXRemit.com customers the Web site
address (URL) and customer service contact
information that you provide us. Currently,
we do not keep your credit card number,
bank account and other financial information
and will NEVER be revealed to anyone should
we decide to keep them.
If you are buying goods
or services and paying through FXRemit.com,
the seller of the goods or services may
request that you provide a mailing address
that FXRemit.com has confirmed as matching
the billing address in the credit card system.
You do not have to provide this information.
If you do not provide the information, however,
the seller may choose not to accept your
FXRemit.com payment and not to complete
the transaction.
Disclosure to Third Parties
Other Than FXRemit.com Customers
FXRemit.com will not share
any of your personally identifiable information
with third parties except in the limited
circumstances described below, or with your
express permission (and to other FXRemit.com
customers as described above). These third
parties are limited by law or by contract
from using the information for secondary
purposes beyond the purposes for which the
information is shared.
We share information with
companies that help us process the transactions
you request and protect our customers’ transactions
from fraud, such as sharing your credit
card number with a service that screens
for lost and stolen card numbers. See “Information
About You From Third Parties” in Section
B above. Additionally, if you owe us money
due, tp rpblems in your account or credit
card, we may share information with processing
companies including collection agencies.
We disclose the information
we collect, as described in Section B above,
to companies that perform marketing services
on our behalf or to other financial institutions
with whom we have joint marketing agreements.
We disclose information
that we in good faith believe is appropriate
to cooperate in investigations of fraud
or other illegal activity, or to conduct
investigations of violations of our Terms
of Use. Specifically, this means that if
we conduct a fraud investigation and conclude
that one side has engaged in deceptive practices,
we can give that person or entity's contact
information (but not bank account or credit
card information) to victims who request
it.
We disclose information
in response to a subpoena, warrant, court
order, levy, attachment, order of a court-appointed
receiver or other comparable legal process,
including subpoenas from private parties
in a civil action. When a user signs up
for a co-branded version of FXRemit.com
through links on our co-branded partner's
website, FXRemit.com will share with the
co-branded partner that user's name, e-mail
address and physical address in order to
provide enhanced integration between FXRemit.com's
services and the services of our co-branded
partner. When a user signs up for a co-branded
version of FXRemit.com. If a user does not
want his or her information shared with
FXRemit.com's co-branded partner, he or
she should not use this aspect of the site.
We disclose information
to your agent or legal representative (such
as the holder of a power of attorney that
you grant, or a guardian appointed for you).
We share aggregated statistical
data with our business partners or for public
relations. For example, we may disclose
that a specific percentage of our users
live in California. However, this aggregated
information is not tied to personally identifiable
information.
As with any other business,
it is possible that FXRemit.com in the future
could merge with or be acquired by another
company. If such an acquisition occurs,
the successor company would have access
to the information maintained by FXRemit.com,
including customer account information,
but would continue to be bound by this Privacy
Policy unless and until it is amended as
described in Section A above.
Our Contacts with FXRemit.com
Customers
We communicate with users
on a regular basis via e-mail to provide
requested services, and we also communicate
by phone to resolve customer complaints
or investigate suspicious transactions.
We use your e-mail address or phone to confirm
your remittance transactions or to send
you notice of payments that you send or
receive through FXRemit.com (including referral
payments described below), to send information
about important changes to our products
and services, and to send notices and other
disclosures required by law. Generally,
users cannot opt out of these communications,
but they will be primarily informational
in nature rather than promotional.
We also use your e-mail
address to send you other types of communications
that you can control, including the FXRemit.com
Periodical newsletter. You can choose whether
to receive some, all or none of these communications
when you complete the registration process,
or at any time thereafter, by logging in
to your account on the FXRemit.com Web site
and changing your preferences in the Profile
page. You can also change your choices at
any time through the same procedure.
In connection with independent
audits of our financial statements and operations,
the auditors may seek to contact a sample
of our customers to confirm that our records
are accurate. However, these auditors cannot
use personally identifiable information
for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access
times to analyze trends, administer the
site, improve site performance and gather
broad demographic information for aggregate
use.
D. Information Security
FXRemit.com is committed
to handling your customer information with
high standards of information security.
Your credit card and bank account information
are stored only in our partner institutions
like PayPal, Bank of Hawaii, etc. We do
not keep any copy of your credit card or
bank account numbers.
The security of your FXRemit.com
account also relies on your protection of
your FXRemit.com and paypal password. We
strongly urge that you never share your
FXRemit.com and paypal password with anyone.
FXRemit.com representatives will never ask
you for your password, so any e-mail or
other communication requesting your password
should be treated as unauthorized and suspicious.
If you do share your FXRemit.com and paypal
password with a third party for any reason,
the third party will have access to your
account and your personal information, and
you may be responsible for actions taken
using your password. If you believe someone
else has obtained access to your password,
please change it immediately by logging
in to your account at www.FXRemit.com and
changing your Profile settings, and also
contact us right away as described in Section
F below.
E. Accessing and Changing
Your Information You can review the personal
information you provided us and make any
desired changes to such information.
You can also close your
account through the FXRemit.com Web site.
If you close your FXRemit.com account, we
will mark your account in our database as
“Closed,” but will keep your account information
in our database. This is necessary in order
to deter fraud, by ensuring that persons
who try to commit fraud will not be able
to avoid detection simply by closing their
account and opening a new account. However,
if you close your account, your personally
identifiable information will not be used
by us for any further purposes, nor sold
or shared with third parties, except as
necessary to prevent fraud and assist law
enforcement, or as required by law.
F. Contacting Us
If you have any questions
about this privacy statement, FXRemit.com’s
information practices, or your dealings
with FXRemit.com, you can contact us using
this form, call (671) 647-1888 Monday through
Friday between the hours of 8am and 5pm
Guam Time, or write us at FXRemit.com, P.O.
Box 11797, Tamuning, GU 96931.