Effective Date: May 01, 2020
Last Reviewed: May 01, 2020
Trans-Fast Remittance LLC and its affiliates including, but not limited to, Wyndpay Ltd, Trans-Fast Remittance Inc. of California, Trans-Fast Remittance Inc-Nevada, TF Mexico Soluciones S de R L de CV (Mexico), Trans-Fast Financial Services Private Limited (India), New York Bay Philippines, Inc. (Philippines), Trans-Fast Canada, Inc., and Trans-Fast Remittance Holdings LLC (collectively, "Trans-Fast") are wholly owned subsidiaries of Mastercard International Inc and are committed to the respect for your privacy.
Trans-Fast processes payment transactions on behalf of your bank, financial institution, payment or e-payment service provider, or mobile network operator (collectively Trans-Fast's "Customers") to provide a B2B, P2B and B2P digital money transfer solution (the "Service"). The Service is offered to you by Trans-Fast's customers and it enables you to send or receive money to and from mobile money accounts, payment cards, bank accounts or cash outlets, regardless of your location or that of the recipient or sender.
This Privacy Notice applies to the processing of Personal Data collected by Trans-Fast for its own purposes in the context of operating any of the Trans-Fast websites, including www.transfast.com, global.transfast.com, www.wyndpay.global, www.transpay.com, as well as any other site or application that may be used to access the service (the "Website"). This Privacy Notice does not cover the collection and use of your Personal Data by Trans-Fast on behalf of Trans-Fast's customers (e.g., when Trans-Fast processes your transactions in the context of the Service) or by third parties on other Trans-Fast branded websites. To learn more about the privacy practices of Trans-Fast's customers, please visit their respective websites.
This Privacy Notice describes the types of Personal Data we collect, the purposes for which we collect that Personal Data, the other parties with whom we may share it and the measures we take to protect the security of the data. It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us to update your contact information or get answers to questions you may have about our privacy practices.
We may collect the following Personal Data:
- Personal Data collected via cookies and similar technologies.
- Personal Data we obtain when you apply for a job with us.
- Personal Data we obtain in the context of the use of the Service.
- Personal Data we collect in the context of our business relationship with customers.
For the purpose of this Privacy Notice, "Personal Data" means any information relating to an identified or identifiable individual. We obtain Personal Data relating to you from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to use the relevant service or submit your job application with Trans-Fast if that information is necessary or if we are legally required to collect it.
Personal Data Obtained from Your Interaction with the Trans-Fast website
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to "remember" your actions or preferences over time. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.
When you use the Website, we may collect certain information by automated means (e.g., via cookies and similar technologies), including IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our Website, and other mobile trackers. We may use third-party web analytics services on our Website. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyze how visitors use our Website.
We use this information to improve our Website by assessing how many users access or use our Website, which content, products, and features most interest our visitors, what types of offers our customers like to see, and how our service performs from a technical point of view.
Personal Data We Obtain when You Apply for a Job with Us
If you are applying for a job at Trans-Fast, we may collect certain Personal Data from your job applications, such as your contact information (including name, postal address, email address and phone number), job history, resume or CV, contact details of your references and any other Personal Data you choose to submit along with your application.
Personal Data We Obtain in the context of the Service
We obtain Personal Data about you when we process transactions on behalf of our financial institutions and corporate customers. For more information on the processing of your Personal Data on behalf of our customers, please refer to the relevant customer's website.
This information may include the following elements:
- Amount of transactions
- Purpose of transactions
- Sending and receiving country
- Uniform resource identifier (URI) for both the source and the destination of the transaction (i.e., mobile number, e-wallet identifier, bank account or other unique identifier)
- Contact information (such as name, date and place of birth, occupation, nationality, country, postal or e-mail address, and (mobile) phone numbers)
- Proof of identify (type of identity document, number, date and place of birth, expiry date and authority responsible for issuing the document)
Personal Data We Collect in the Context of our Business Relationship with Customers
We may collect Personal Data from individuals working for one of our customers, partners or suppliers, including name, job title, department and name of organization, business email address, business postal address, business telephone number, answers to security questions, security passwords and other credentials. We may use this information to provide products and services directly to our customers and partners, to manage our business relationships and financial reporting, for franchise development and integrity, for marketing and to comply with applicable law, as well as for accounting, auditing and billing purposes.
We may use your Personal Data to:
- Operate, improve, and develop our services.
- Perform data analysis.
- Perform accounting, bookkeeping auditing, billing, reconciliation activities, as well as claims management.
- Manage the Customer relationship.
- Anonymize Personal Data.
- Evaluate your interest in employment and contact you regarding possible employment.
- Protect against fraud and ensure safety and security.
- Enforce our Terms and Conditions and comply with our legal obligations.
- Comply with our own legal and regulatory obligations.
We may use Personal Data we obtain about you for the purposes set below. Depending on the country in which you are located, we will only process your Personal Data, when we have a legal basis for processing as listed below:
|Processing activity||Legal Basis for Processing (where required under applicable law)|
|Operate, evaluate, develop and improve our business (including developing new products and services; manage our communications; determine the effectiveness of and optimizing our advertising; analysing our products, services and websites).||
|Perform accounting, bookkeeping auditing, billing, reconciliation activities, as well as claims management.||
|Evaluate Customers for inclusion as inbound/outbound payment providers, managing the Customer relationship.||
|Anonymize Personal Data, prepare and furnish aggregated data reports showing anonymized information (including, but not limited to the following: compilations, analyses, analytical and predictive models and rules, and other aggregated reports) for the purpose of advising our customers and partners regarding past and potential future patterns of money transfer, fraud and other insights that may be extracted from this data.||We, or a third party, have a legitimate interest in using your Personal Data for the purposes of anonymising Personal Data and preparing and furnishing aggregated data reports.|
|Evaluate your interest in employment and contact you regarding possible employment.||
|Enforce our Terms and Conditions or other legal rights, where necessary.||
|As may be required by applicable laws and regulations, including anti-money laundering, terrorist financing and sanction list screening obligations and government disclosure obligations, or requested by any judicial process or governmental agency having or claiming jurisdiction over Trans-Fast or Trans-Fast's affiliates.||
|Comply with applicable legal requirements and industry standards and our policies.||
We may share Personal Data with:
- Our affiliates.
- Our service providers acting on our behalf.
- Other participants involved in the end to end processing of the payment instruction, including financial institutions.
- Third parties for fraud monitoring and prevention purposes, or other lawful purposes.
- Third parties in the event of a sale or transfer of our business or assets.
Subject to applicable law(s), you have the right to:
- Access your Personal Data, rectify it, restrict its processing, or request its deletion.
- Receive the Personal Data you provided to us to transmit it to another company.
- Withdraw any consent provided.
- Where applicable, lodge a complaint with your Supervisory Authority.
You may also submit a request as described in the "How to Contact Us" section.
Subject to applicable law(s), you have certain rights regarding the Personal Data we maintain about you and certain choices about what Personal Data we collect from you, how we use it, and how we communicate with you.
- Request access to and receive information about the Personal Data we maintain about you, to update and correct inaccuracies in your Personal Data, to restrict the processing of your Personal Data, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
Withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal
Additionally, if you are located in California, we will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights, except where the different price or level of quality of good or service is reasonably related to the value of the data that we receive from you. In some instances, we may not be able to provide you with the good or service that you request if you choose to exercise certain rights.
If you are located in California you may also choose to exercise the following right(s):
- Not to provide Personal Data to Trans-Fast by refraining from conducting payment transactions or from submitting Personal Data directly to us. When we collect Personal Data from you, we indicate whether and why it is necessary to provide it to us, as well as the consequences of failing to do so. If you do not provide Personal Data, you may not be able to benefit from the full range of Mastercard products and services, and we may not be able to provide you with the Mastercard products or services if that information is necessary to provide you with them, or if we are legally required to collect it in relation to the provision of such product or service.
- To opt out of certain uses of information, which we collect about you by automated means when you visit third-party websites and interact with our ads. We may use service providers to serve ads on those third-party websites. These ads may be customized and served based on the use of data we and our partners have collected on our websites and apps. In addition, some of our service providers and partners may collect information about your online activities over time and across third-party websites to customize and serve these ads. Mastercard ads are sometimes delivered with icons that help consumers (i) learn more about how their data is being used and (ii) exercise choices they may have regarding the use of their data.
- To tell us not to send you marketing emails by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below.
The above rights may be limited in some circumstances by local law requirements.
If we fall short of your expectations in processing your Personal Data or you wish to make a complaint about our privacy practices, please tell us because it gives us an opportunity to fix the problem. To assist us in responding to your request, please give full details of the issue. We attempt to review and respond to all complaints within a reasonable time and, in any event, within the legal time limit for responding, where applicable.
We maintain appropriate security safeguards to protect your Personal Data and only retain it for a limited period.
We maintain appropriate administrative, technical, and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. We use SSL encryption on our Website and restrict access to your Personal Data to only those employees who need access to that data, in accordance with this notice.
We also take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we processed it or when you request their deletion, unless we are required by law to keep the information for a longer period. We complete periodic reviews of our databases, and have established specific time limits for data deletion, taking into account the type of data collected, the type of services provided, and the length of the customer relationship, possible re-enrolment with the Service, mandatory retention periods, regulatory requirements and the statute of limitations.
Trans-Fast is a global business. We may transfer your Personal Data to the United States and other countries which may not have the same data protection laws as the country in which you initially provided the information, but we will protect your Personal Data in accordance with this Privacy Notice, or as otherwise disclosed to you.
If you are located in the EEA, we will process your Personal Data in accordance with our Binding Corporate Rules and other data transfer mechanisms.
Trans-Fast is a global business. We may transfer or disclose Personal Data we collect about you to recipients in countries other than your country, including to the United States. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Data to other countries, we will protect that information in compliance with applicable laws as described in this Privacy Notice.
We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Data to countries other than the country where you are located. In particular, we have established and implemented a set of Binding Corporate Rules ("BCRs") that have been recognized by EEA data protection authorities as providing an adequate level of protection to the Personal Data we process globally. A copy of our BCRs are available here. We may also transfer Personal Data to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Data to third parties, such as the European Commission's Standard Contractual Clauses (SCCs), or rely on third parties' certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us as specified in the "How to Contact Us" section below to obtain a copy of the safeguards we use to transfer Personal Data outside of the EEA.
You may choose to use certain features for which we partner with other entities that operate independently from Trans-Fast.
On our Website, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with Trans-Fast. These features, which may include, social networking, geo-location, security, and spam filtering tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share Personal Data in accordance with their own privacy policies. We strongly suggest you review these third parties' privacy policies if you use these features.
Trans-Fast's products and services are not directed to or intended for children.
Trans-Fast does not offer services to minors and does not knowingly collect Personal Data from children under the age of 13. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us using our contact details below.
This Privacy Notice may be updated periodically to reflect changes in our privacy practices.
This Privacy Notice may be updated periodically to reflect changes in our Personal Data practices. We will notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. If we update this Privacy Notice, in certain circumstances, we may seek your consent. This Privacy Notice will be reviewed at least once every twelve months and accordingly we will indicate at the top of this notice the last time that this review occurred, even if that review did not result in a change to the Privacy Notice.
You can e-mail us at firstname.lastname@example.org with any questions, comments, or concerns around our privacy practices and policies.
You may submit a request to exercise your rights or share any questions, comments, or complaints about this Privacy Notice or our privacy practices by e-mailing us at email@example.com, or at the contact below:
If you are located in the EEA or Switzerland, Mastercard Europe SA is the entity responsible for the processing of your Personal Data.