Last updated: 18 December 2014
A. Information We Collect
We may obtain information about you in a variety of ways. When you visit the peerTransfer website or use our online services, we collect information sent to us by your computer, mobile phone or other access device. We may obtain information from you in our role as a processor of payment transactions, or we may have a direct relationship with you and in the context of that relationship you may choose to provide personal information to us.
The information sent to us automatically includes your computer IP address, the pages you access, device identifiers, the type of operating system you are using, standard web log data, data associated with cookies and other information. Web log data includes the browser type you’re using and traffic to and from our site.
In addition to this information, in the event that you use our services and engage in making a payment transaction through peerTransfer we may collect the following types of information:
- Contact information (such as name, physical address, phone number or email);
- More detailed personal information, such as your date of birth, name of educational institution attended, year of graduation and Student ID;
- If you are submitting a payment on behalf of a student, we may collect contact information (such as name, physical address, phone number or email) about you from the student;
- Financial information, such as bank account numbers, names and routing codes (we do not directly handle credit card data);
- Employment-related information such as your C.V., if you apply for a job with us;
- Logs of our chat or other communication with you.
We may also collect information from you through other means, such as through your contact with our Support, Operations and Account Management teams.
In the course of processing your payment transaction we work with payment collection and banking partners. In doing so, a partner or bank may share with us information about the originating account such as account name, number, routing code and other identifying information to provide us with notification that a payment has been received.
B. How We Use The Information We Collect
We may use the information we obtain about you to:
- Process your payment transaction and keep you informed about the status of your payment;
- Comply with and enforce applicable legal requirements, industry standards and our policies;
- Respond to your inquiries, resolve disputes and provide support;
- Analyze, operate and improve our business (including enhancing our user experience, managing communication and functionality and developing new products and services);
- Inform you of services we provide through targeted marketing messages, service updates and promotional offers based on your communication preferences;
- Compare information for accuracy and verify it with third parties;
- Further our business relationship with you, if we have collected your personal information in the context of an actual or potential business relationship;
- Evaluate your application for employment and contact you regarding possible employment at peerTransfer, if you have applied for a job;
- Fulfil other purposes to which you have consented, which would be reasonably expected by you or which are otherwise authorised or required by law.
C. Information We Share
- We may share your information with service providers who assist us with our business. For example, to process your payment to an educational institution, we may share some of your personal information with the institution. In some cases, in order to execute the successful processing of your payment, we may share bank/payment receipt documents that you have sent to us with service providers or banking partners under contract whom we work with to assist with the reconciliation of that payment. Our contracts dictate that these service providers only use your information in connection with the services they provide to us and not for their own benefit;
- peerTransfer Corporation is a United States corporation, which also operates several international affiliates and subsidiaries. We may share personal information with these, or future, affiliates;
- If we are required to do so by law or legal process or to comply with the law, or when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity or to investigate violations of our Terms of Us and other agreements.
On our website, you may choose to use certain features which are provided by other entities. These features, which include social networking buttons (which will be prominently displayed on our webpage), are operated by third parties that are not affiliated with peerTransfer, and they may collect information directly from you. These third parties may use any personal information that you provide to them in accordance with their own privacy policies and practices. peerTransfer strongly suggests you review the third parties’ privacy policies before interacting with them.
D. Rights and Choices
You may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.
- When we request information from you on our site, you may always choose not to provide us with that information. However, if you decline to provide us with certain information, we may not be able to provide you with the services offered;
- You may opt-out of e-mail marketing communications by clicking on the unsubscribe link within marketing e-mails you receive from us or by contacting us;
- If you are located in the European Economic Area or Switzerland, you may direct us not to share your personal information with third parties, except (i) with service providers under contract we have retained to perform services on our behalf, (ii) in the event we are acquired or we transfer all or a portion of our business or assets, (iii) if a legal process or law requires disclosure, (iv) at the request of law enforcement authorities, or (v) when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity;
- Where required by law, peerTransfer obtains your prior opt-in consent at the time of collection for the processing of (i) personal information for marketing purposes and (ii) personal information deemed sensitive pursuant to applicable law;
E. Data Transfer
F. How We Protect Your Personal Information
peerTransfer maintains appropriate safeguards combining technical and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.
We limit access to information you provide us to those employees who we believe reasonably need that information in order to do their jobs.
We use Secure Socket Layer (SSL) encryption on our website when transmitting information and use other commercially reasonable efforts to protect your information. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate.
G. Links to Other Websites
I. Questions, Comments and Complaints about Our Handling of Personal Information
When contacting us please provide as much detail as possible in relation to your question, comment or complaint.
peerTransfer will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
J. Contact Information
- peerTransfer Corporation
- Attn: Privacy Officer
- 295 Devonshire Street, 4th Floor
- Boston, MA 02110, USA