WESTERN UNION’S GLOBAL PRIVACY STATEMENT

SCOPE OF THIS GLOBAL PRIVACY STATEMENT

At Western Union, we are committed to making financial services accessible to people everywhere. This commitment to our customers includes doing the right thing with their personal information.

The purpose of our Global Privacy Statement is to explain how we collect, use, store, protect, disclose, and share your personal information when you use any of our services online through our website, in retail, and through our mobile apps, as well as to inform you of your choices about the way your information is collected and used.

PERSONAL INFORMATION WESTERN UNION COLLECTS

When you use our money transfer, foreign exchange, or other financial services, such as our digital wallet or prepaid card; contact us; access or register an account on our websites or applications; or join our loyalty programs (collectively, the “Services”), we collect personal information about you and may use it along with other information collected or generated during our relationship with you. We collect different types of personal information relating to you, which may include:

  • Your personal information and identifiers: Basic personal information such as your name, contact information (for example, your postal address, email address, telephone number), photo or other image of you (if you choose to provide it), place of birth, date of birth, gender, citizenship, occupation, marital status, and government or national identification numbers and accompanying documentation;
  • Your financial and transactional information: Financial and transactional information such as your money transfers, payments, deposits and the source/destination of funds for each, information about how you use our Services, bank and credit information, and employer information;
  • Recipient personal information: Name and contact information relating to recipients to whom you send or from whom you request or receive money or with whom you otherwise choose to transact when using the Services;
  • Your technical information: Technical information, such as the host from which you access the internet, your IP address or device advertising ID, geolocation if enabled, information about your device (such as device properties, settings, applications, storage and usage information), mobile application, browser and operating system software, social profile and network information, the date and time you access our websites, and the address of the site from which you linked to our website when you visit us. We collect personal information on your online activities as described in the section titled “INTERNET TECHNOLOGIES.”;
  • Your sensitive personal information: Sensitive or special categories of information, such as biometric information used to uniquely identify you (for example, fingerprints or facial recognition) or criminal conviction information.  We will only hold this data when we need to for the purposes of the Services which we provide to you, where we are processing the data for a substantial public interest, where we have a legal obligation, or where we have your consent to do so;
  • Your information from third party sites or services: If you link, connect, or login to Western Union websites or mobile applications using a third party service (e.g., Google and Facebook), you direct the relevant third party service to send us information such as your name, email address, profile picture, and other information as controlled by that service or as authorized by you via your privacy settings with that service.

HOW WESTERN UNION COLLECTS PERSONAL INFORMATION

Western Union collects your personal information in several ways, including:

  • Information that you give to us in person, online or through our mobile app including through transaction forms, registrations for our financial services or loyalty programs, interactions with Western Union agents and business partners;
  • Information that you provide to us while we provide customer support or consultation, including using email, postal mail, call centers, online chatbots, or live chat;
  • Information that others may provide about you through their use of our Services;
  • Information that we learn about you through the use of our Services;
  • Information about you that is acquired through automated means, such as communications protocols, email communications, and cookies or similar INTERNET TECHNOLOGIES;
  • Information about you that is acquired through our vendors, fraud risk management companies, law enforcement bodies, commercial and public data sources, and other lawful third-party data sources which we may use to augment our customer information;
  • Information about you that is acquired through your use of social media; and
  • Information about you that is acquired through your interest in advertisements placed by or about Western Union on our own or third party sites.

HOW WESTERN UNION SECURES YOUR PERSONAL INFORMATION

We are committed to the security of your personal information.  We use organizational, technical, and administrative safeguards that comply with applicable government laws and regulations to secure your personal information. We also endeavor to restrict access to the personal information that we process to only our employees, agents, and representatives that have a business need to know it. Despite our efforts, third parties may unlawfully intercept or access your personal information.

INTERNET TECHNOLOGIES

We and our third-party partners use internet technologies like cookies, tags, and web beacons on our websites, in mobile applications, and when you open email communications from us. These technologies may collect data about your usage of our websites or mobile applications, including through analysis of keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools. We use these technologies for a variety of purposes, which are identified in the section titled “HOW WESTERN UNION USES THE PERSONAL INFORMATION IT COLLECTS”.

For more information on how we use cookies please click the “Cookie Information” link in the footer of the applicable Western Union webpage. In certain regions we have implemented the capability for the user to manage cookies on our websites; where available, we will only read or write cookies based on your preference level.

We may use third parties to deliver personalized ads to you while you browse the Internet. You can generally opt out of receiving personalized ads from these third-party advertisers and ad networks who follow the Digital Advertising Alliance’s (DAA’s) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out page DAA websites.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals, unless required by applicable law.

HOW WESTERN UNION USES THE PERSONAL INFORMATION IT COLLECTS

We use the personal information we collect for the following business and commercial purposes:

  • Performing the Services: To assist us in providing Services and customer support to you, to help you to receive a personalized experience, to assist you in carrying out transactions and accessing account information, and to associate your personal information when you use multiple Services (for example, when you create a digital wallet or bank account, to link to your loyalty program information or to any transactions that you made before you created your digital wallet or bank account). Failure to provide necessary personal information may affect our ability to provide our Services to you;
  • Communication: To contact you with information relevant to the Services that you use or the loyalty programs that you participate in, to answer questions or respond to other requests that you send to our customer service teams or to market and advertise to you based on your preferences;
  • Authentication: To recognize you and to allow you to remain signed-in during your use of the Services without having to re-enter your password;
  • Analytics: To perform analytics on understanding our customers, improving their experience;
  • Web Traffic Analysis: To determine whether you came to a Western Union website from an online ad, partner, or an affiliate; or have clicked an advertisement or link on one of our websites;
  • Advertising: To deliver information specific to your interests on Western Union and non-Western Union websites and applications;
  • Providing advertising and marketing services for advertising partners, including targeted advertising
  • To train artificial intelligence technologies which includes but is not limited to: utilized for customer care, customer onboarding and the prevention of fraud or other unlawful activity;
  • Analysis of Promotions: To better understand the effectiveness of our promotional campaigns and whether you acted on our promotional messages;
  • Prevention of Fraud, Financial Crime (including money laundering), and Other Unlawful Activity: To promote safety, reduce financial risk, and combat fraud across our Services and, as necessary, to ensure the effectiveness of our compliance processes aimed at such prevention of criminal activity.

LAWFUL BASES UPON WHICH WE USE YOUR PERSONAL INFORMATION

We may use your personal information as explained elsewhere in this Statement for each of the following lawful bases:

  • We use your personal information to provide our Services to you: This includes using personal information necessary for providing digital wallet and banking services, conducting money transfers, financial services, prepaid cards, or loyalty programs. We may use this information in the performance of a contract with you or for taking steps to enter into a contract for any of the Services.
  • We use your personal information for legitimate business purposes, where these legitimate business purposes do not outweigh the rights and freedoms of the individuals whose data we process: This includes using personal information to analyze and improve our products, locations, services, operations, the running of this site and your customer experience, and for measuring marketing return on investment and brand satisfaction. This may also include using your information to conduct market research surveys, as well as marketing and advertising based on your use of our Services and your interests. We may also use your personal information to provide customer services and to help protect the security and integrity of our technology, systems, and services. It may also include the prevention of fraud, money laundering, and other unlawful activity, or the establishment or defense of a legal claim.
  • We use your personal information for legal and compliance purposes: This includes using personal information needed to comply with legal and regulatory duties related to anti-money laundering, counter-terrorist financing and other financial regulations; detection, prevention and prosecution of fraud and theft; as well as preventing illegitimate or prohibited use of our Services or other illegal or wrongful activity and operating a global compliance program for doing so. This may also include establishing, exercising, or defending legal rights and claims of Western Union and others, and monitoring and reporting compliance issues. This may further include using your personal information to validate and authenticate your identity and utilizing third parties to help us do so.
  • We may process your personal information based on your consent as outlined in this Statement: This includes consent for receiving marketing communications, for processing biometric data, for enabling your bank or digital wallet account profile to be visible to others, or where otherwise required by applicable law. If we request your consent, we will inform you of the intended purposes for which your information will be processed.
  • We will inform you when your information is required to provide the Services which you request or when required by law. In certain cases, such as performing money transfer and banking or digital wallet account services, we may be unable to provide you with our Services unless you provide certain personal information.

HOW WESTERN UNION MARKETS TO ITS CUSTOMERS

Subject to your preferences, we will notify you of offers, promotions, and updates regarding our products and Services or other products and services that may be of interest to you. These may include offers by email, telephone, postal mail, SMS, social media, and other communication or digital channels.

You can opt out of receiving direct marketing communications at any time. If you no longer want to receive direct marketing-related communications from us, you may opt out of a channel(s) by following the instructions in the relevant electronic communication, by adjusting your settings in your digital bank or wallet account or app, or by contacting us as described in the “CONTACTING US” section.

Please note that if you opt out of receiving marketing-related communications from us, we may still send important service, administrative, or transaction-related communications to you.

INFORMATION FROM CHILDREN

We do not direct our Services or products towards children under the age of 18. We do not knowingly collect information from our website or mobile apps from persons under the age of 18.

EXTERNAL WEBSITES

Our websites may be linked to or from third party websites. We have not reviewed, do not control, and are not responsible for the content or privacy practices employed by websites that are linked to or from our websites. We do not assume responsibility for any of these sites, their content, or their privacy policies. We do not endorse third party websites or make any warranties about any information, software, or other products or materials you may find there, or any results that may be obtained from using them.

WHO WESTERN UNION SHARES YOUR PERSONAL INFORMATION WITH

For any of the purposes listed in this Statement, we may disclose applicable personal information including, but not limited to, your name, contact information, national identification number and/or related documentation, customer ID number, address, transaction details and patterns, and bank account information to the following types of organizations or parties:

  • Western Union group companies and affiliates, including those listed in the section titled “WESTERN UNION LEGAL ENTITIES”;
  • Our agents or business partners who facilitate the money transfer or payment transaction or other specific Services you have requested;
  • Vendors, payments processors, banking partners, and data processors contracted to provide business and customer services;
  • Services providers, based on your consent where applicable, including those that provide marketing services, advertising services, shopping services related to our loyalty programs, and customer satisfaction and market research services on our behalf. Such sharing may include sharing with third parties (such as social media companies) to facilitate more relevant and targeted advertising;
  • Vendors and data processors contracted to help us validate the accuracy of the information provided by you, and to authenticate your identity and manage risks related to security, fraud, and identity; and Third parties that you have authorized to access your account and/or your account information in order to perform Services for you, such as account information service providers and payment initiation service providers.

If you are a customer of a Service that allows for a public profile, you may choose to make your profile publicly visible. This may include sharing limited personal details such as name, photo of you, available currencies of your account, and the fact that you are a customer. Also, if you are a bank or wallet account customer, other bank or wallet account customers may also be able to search for you with your phone number as well as utilize a QR code you may provide in order to transact with you. We may transmit your personal information in connection with a sale or transfer of all or part of our business. We may also disclose your personal information globally, as required or permitted by applicable laws and regulations, to regulatory and financial authorities, credit reporting agencies, law enforcement bodies, courts, governments, or government agencies to meet compliance and legal obligations or to assert or defend the rights and interests of Western Union or others.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

We transfer your personal information to parties in countries outside the country in which it was collected, including but not limited to the USA, as permitted or required by applicable law, regulatory authorities, law enforcement, and government agencies. Additionally, when you send or receive money to or from another country, we will also be required to share some of your personal information with that country as required or permitted by law. We transfer certain personal information about you to our data centers located in the USA or within a region as required by local law and process it to fulfil our legal and compliance obligations which apply to our Services.. By using the Services, you acknowledge that such transfers of information outside of your country of residence may occur.

TRANSFERS FROM THE EEA, THE UK, AND SWITZERLAND

Personal information transferred outside the EEA, the UK, and Switzerland to countries that the European Commission or UK Information Commissioner’s Office (ICO) have not found to provide adequate protection will be protected by appropriate Standard Contractual Clauses or other EU or UK –approved  mechanisms, as required by law.

RETENTION OF PERSONAL INFORMATION

Your personal information will be retained in accordance with statutory periods contained in regulations applicable to financial transactions and accounts including those in anti-money laundering, anti-terrorist financing and other laws applicable to us. Otherwise, we will retain your information only if necessary for the specific purposes for which it was collected, or to resolve any query you may raise. We subscribe to data minimization principles and strive to retain information for no longer than necessary for the purpose(s) for which it was obtained.

ACCESSING, DELETING AND CORRECTING YOUR PERSONAL INFORMATION AND CHANGING YOUR CHOICES

 

RightDescriptionHow to exercise
Right to know and accessYou have the right to know if we are processing your personal information and to ask us for a copy of your information free of charge. You have the right to request a structured and machine-readable copy of certain information you have provided to us.If you use our Services online or via mobile app, you may log into your account at any time to access your statements, transactional information, and certain personal information. To exercise these rights, please visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section titled “CONTACTING US”.
Right to stop marketing communicationsYou have the right to stop us from sending you marketing communications.If you are a registered user of westernunion.com as a digital money transfer consumer, you may also visit westernunion.com and edit your profile settings to change your marketing communications and third-party data sharing preferences. To exercise these rights, please visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section titled “CONTACTING US”.
Right to correctionYou have the right to ask us to correct information about you that is incomplete, inaccurate or out-of-date.To exercise these rights, please visit http://www.westernunion.com/datasubjectrights%20or contact Western Union through the section titled “CONTACTING US”.
Right to deletion, restriction, and objectionYou have the right to ask us to delete certain information about you, to restrict certain uses of information relating to you, and to object to certain uses of it.To exercise these rights, please visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section titled “CONTACTING US”.
Right to withdraw consentTo the extent we are processing personal information based on your consent, you may withdraw your consent as permitted by applicable law.To exercise these rights, please visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section titled “CONTACTING US”.
Right to lodge a complaintYou also have the right to lodge a complaint with a relevant data protection regulator or supervisory authority about our processing of personal information.To exercise these rights, please  contact Western Union through the section titled “CONTACTING US”.

 

Additional rights may also be available in various jurisdictions under local laws. These will be accessible via the means provided above.

 

WESTERN UNION LEGAL ENTITIES

 

EntityContact Information / Address
Global Collection Services S.A.Montevideo 825, (1019) City of Buenos Aires, Argentina
Red Global S.A.Montevideo 825, (1019) City of Buenos Aires, Argentina
Servicio Electrónico de Pago S.A.Montevideo 825, (1019) City of Buenos Aires, Argentina
Western Union Financial Services Argentina S.R.L.Montevideo 825, (1019) City of Buenos Aires, Argentina
Western Union Financial Services (Australia) PTY. LTD.Level 7

400 George Street

Sydney, NSW 2000 Australia

Western Union International Bank GmbH (Austria)1, 2The ICON Vienna: Turm 24, 11th Floor, Wiedner Gürtel 13,
1100  Vienna, Austria
Western Union Retail Services BelgiumPlace Louise 6, 1060 Saint-Gilles, Belgium, Belgium
Western Union Financial Services (Canada), Inc.925 Marine Dr, North Vancouver, V7P 1S2 Canada
Western Union Network (Canada) CompanySuite 900, 1959 Upper Water Street, Halifax, NS, Canada B3J 3N2
Western Union Chile SpAVitacura 2939, Piso 8, Las Condes, City of Santiago de Chile, Chile
Western Union Retail Services Germany GmbH3

 

C/o Design Offices, Budapester Strasse 35, 10787 Berlin, Germany.

 

Western Union Payment Services GB Limited4 Third Floor, Offices Manning House, 22 Carlisle Place, London SW1P 1JA

 

Western Union Payment Services Ireland Ltd (Ireland) 1, 2The Loft, Level 2

Dundrum Town Centre

Sandyford Road, Dundrum, Dublin 16 D16 F2K1

Western Union International Limited (Ireland)The Loft, Level 2

Dundrum Town Centre

Sandyford Road, Dundrum, Dublin 16 D16 F2K1

Western Union Network (Ireland) LimitedThe Loft, Level 2

Dundrum Town Centre

Sandyford Road, Dundrum, Dublin 16 D16 F2K1

Western Union Japan KKMetro City Kamiyacho 7f, 1-5, Toranomon 5-Chome, Minato-Ku Tokyo, Japan
Western Union Retail Services Belgium (Netherlands Branch)5Kinkerstraat 232 Hm, 1053 EN Amsterdam, Netherlands
Western Union Payments (Malaysia) Sdn Bhd16th Floor, Wisma Sime Darby, Jalan Raja Laut, 50350 Kuala Lumpur, Malaysia
Grupo Dinámico Empresarial S.A. de C.V., Servicios de Apoyo GDE SA de CV, Operaciones Internacionales OV S.A. de C.V. and Servicio Integral de Envíos, S.A. de C.V.Av. Paseo de la Reforma No. 505, piso 17, Colonia Cuauhtémoc, Delegación Cuauhtémoc, C.P. 06500, Ciudad de México
Western Union MT East (Russia)16A Bldg, Leningradskoe shosse

125171, Moscow, Russia

Western Union Money Exchange SAc/Princesa, 5, 4 planta 28.008 – Madrid (España)
 Western Union (Switzerland) LLC, Dover (Delaware/USA) Zweigniederlassung Zürich6Werdstrasse 2, Postfach 2063, 8021 Zürich, Switzerland
Western Union Turkey Ӧdeme Hizmetleri A.Ş. (Turkey)Maslak Mahallesi Ahi Evran Cad. No: 21

Polaris Plaza K:5 34398 Sarıyer, Istanbul, Turkey

Western Union Financial Services, Inc. (USA)7001 E Belleview Avenue, Denver, CO
1 Western Union is gradually transitioning data controllership of certain digital services in Europe from Western Union International Bank GmbH (“WUIB”), with a registered address in Austria, to Western Union Payment Services (Ireland) Limited (“WUPSIL”), with a registered address in Ireland. The transition will commence for certain digital services in Sweden, Norway, Finland and Denmark from 1 November 2026 and may be extended to additional European markets over time. During this transition, references to both companies may appear across our websites, applications, and communications. The company providing your service and acting as the data controller of your personal data in relation to that service is identified in the applicable Terms and Conditions . Please contact us if you require any further clarification regarding this matter at wuprivacy@westernunion.com.

2 Data controller for in-person retail services in Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Faroe Islands, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia (Slovak Republic), Slovenia, Spain, and Sweden..

3Data controller for services provided.

4 Data controller for Services as described in this Statement, including digital and in-person retail services, in the United Kingdom.

5Data controller for services provided.

6 Data controller for in-person retail services in Switzerland.

 

CONTACTING US

If you have a question or complaint about how we handle your personal information, we ask that you put your inquiry in writing. We will investigate your inquiry and generally respond to you in writing within 30 days of receipt. You can also contact us, including our Data Protection Officer, at wuprivacy@westernunion.com.

For inquiries not related to this Privacy Statement, please visit our “Contact Us” page to find the appropriate contact information for your region.

CHANGES

We may modify this Global Privacy Statement from time to time, and updated privacy statements will be posted on this Website when amendments occur. We encourage you to review this Global Privacy Statement when you visit to obtain the most current statement.

NOTICE AT COLLECTION FOR UNITED STATES RESIDENTS (INCLUDING CALIFORNIA RESIDENTS)

We care about the privacy of our consumers and are committed to collecting, using, storing, protecting, disclosing and sharing your personal information in accordance with the applicable U.S. state comprehensive privacy laws, including those in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Texas, Tennessee, Utah, Virginia, or any other state with an applicable privacy law (“U.S. Privacy Laws”). This U.S. Resident Addendum to the Global Privacy Statement (“Addendum”) is applicable to residents of states with U.S. Privacy Laws and, in conjunction with the Global Privacy Statement, is intended to address the requirements of U.S. Privacy Laws.

When you use our Services, we collect personal information about you as permitted by applicable laws and regulations (including but not limited to the Graham Leach Bliley Act). The Categories of Personal Information described below are subject to U.S. Privacy Laws. For more information about the personal information that may have been collected about you, please follow this link to the Global Privacy Statement. In the event of a conflict between the information in this Addendum and that described in the Global Privacy Statement, the information in the Global Privacy Statement shall prevail.

COLLECTION OF PERSONAL INFORMATION

In the 12 months prior to the effective date of the Global Privacy Statement, Western Union may have collected the below Categories of Personal Information from the indicated Categories of Sources; this information may have been sold to (see section “SALE OF PERSONAL INFORMATION” below) or shared with the described Categories of Third Parties for the specified Business and Commercial Purposes. Categories of Sources, Categories of Third Parties, Commercial Purposes and Business Purposes are further defined in the Global Privacy Statement and below.

Categories of Personal InformationCategories of SourcesBusiness and Commercial PurposesCategories of Third Parties
Identifiers: contact information provided for example your name, postal address, e-mail address, and telephone number; date of birth provided; social profile and network information; IP address; device identifier; mobile ad identifier; cookies; beacons; and pixel tags.·   You

·   Our Website

·   Affiliates, Subsidiaries or Vendors

·   Other Third Party Data Sources

·   Mobile Applications

·   Auditing

·   Security Purposes

·   Performing the Services

·   Quality Purposes

·   Authentication

·   Analytics

·   Web Traffic Analysis

·   Advertising

·   Analysis of Promotions

·   Safety

·   Government entities

·   Professional services organizations

·   Advertising and social networks

·   Data analytics providers

·   Our affiliates and subsidiaries

Personal Information Categories Listed in the California Customer Records Statute: Social Security number, driver’s license number, financial account number, and credit/debit card information.·   You

·   Our Website

·   Affiliates, Subsidiaries or Vendors

·   Mobile Applications

·   Performing the Services

·   Auditing

·   Security Purposes

·   Safety

·   Government entities

·   Professional services organizations

·   Data analytics providers

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Characteristics of Protected Classifications Under California or Federal law: age, gender, marital status.·   You

·   Our Website

·   Affiliates, Subsidiaries or Vendors

·   Mobile Applications

·   Social Media Networks or Publicly Available Sources

·   Advertising Networks

·   Performing the Services

·   Quality Purposes

·   Auditing

·   Security Purposes

·   Short-term use

·   Safety

·   Government entities

·   Professional services organizations

·   Advertising and social networks

·   Data analytics providers

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Commercial Information: information about your transactions or purchase history.·   You

·   Our Website

·   Mobile Applications

·   Performing the Services

·   Quality Purposes

·   Auditing

·   Security Purposes

·   Short-term use

·   Internal R&D

·   Safety

·   Government entities

·   Professional services organizations

·   Advertising and social networks

·   Data analytics providers

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Biometric Information: information including fingerprints or facial geometry used to uniquely identify you.·   You

·   Our Website

·   Mobile Applications

·   Performing the Services

·   Security Purposes

·   Safety

·   Government entities

·   Professional services organizations

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Internet and Other Electronic Network Activity Information: including the host from which you access the Internet, information about your device (such as device properties, settings, applications, storage and usage information), mobile application, browser and operating system software, the date and time you access our websites and the address of the site from which you linked to our website when you visit us.·   Your Use of Our Website

·   Affiliates, Subsidiaries or Vendors

·   Your Use of Mobile Applications

·   Social Media Networks or Publicly Available Sources

·   Advertising Networks

·   Auditing

·   Security Purposes

·   Debugging

·   Short Term Use

·   Performing the Services

·   Internal R&D

·   Quality Purposes

·   Authentication

·   Analytics

·   Web Traffic Analysis

·   Advertising

·   Analysis of Promotions

·   Safety

·   Government entities

·   Professional services organizations

·   Advertising and social networks

·   Internet service providers

·   Data analytics providers

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Geolocation Data: may be collected from your devices only if enabled. You can disable the collection of  your Geolocation Data at any time by changing the settings on  your device.·   Your Use of Mobile Applications·   Auditing

·   Security Purposes

·   Short-term use

·   Internal R&D

·   Quality Purposes

·   Safety

·   Advertising and social networks

·   Data analytics providers

·   Operating systems and platforms

Sensitive Personal Information: biometric information used to uniquely identify you, financial account information, government issued identifiers including Social Security number and driver’s license number, citizenship or, and contents of communications.

We do not use or disclose such Sensitive Personal Information for the purpose of inferring characteristics about you or for any purpose other than the limited permissible purposes set forth in applicable law.

·   You

·   Our Website

·   Affiliates, Subsidiaries or Vendors

·   Mobile Applications

·   Performing the Services

·   Auditing

·   Security Purposes

·   Safety

·   Government entities

·   Professional services organizations

·   Data analytics providers

·   Operating systems and platforms

·   Our affiliates and subsidiaries

Categories of Sources: in the 12 months prior to the effective date of the Global Privacy Statement, Western Union may have collected Personal Information about you from the following Categories of Sources:

  • You: we may collect information directly from you, for example, through transaction forms and your interactions with Western Union Agents and partners or through providing customer support or consultation, including using email, postal mail, call centers or live chat;
  • Your Use of Our Website: we may collect information from you or your device through your use of our Website, including online forms, registrations for loyalty and rewards programs or competitions, and other online Services we offer (some of which may be managed by third parties on behalf of Western Union) or through automated means such as communications protocols, e-mail communications and cookies or similar technologies as described in the Global Privacy Statement section titled “INTERNET TECHNOLOGIES”;
  • Affiliates, Subsidiaries or Vendors: we may collect information about you from our affiliates, subsidiaries, or vendors who provide services on our behalf, including payment processors, identity verification providers, intermediaries, etc.;
  • Other Third Party Data Sources: we may collect information about you from other third parties, such as data enrichment providers and data brokers;
  • Your Use of Mobile Applications: we may collect information from you or your device through your use of mobile applications (some of which may be managed by third parties on behalf of Western Union);
  • Social Media Networks or Publicly Available Sources: we may collect information about you from social media or other public data sources; and
  • Advertising Networks: we may collect information about you from advertising networks so we can serve you with advertisements we believe may be of interest to you.

Business and Commercial Purposes: in the 12 months prior to the effective date of the Global Privacy Statement, Western Union may have shared your Personal Information for the following Business Purposes:

  • Auditing: related to our interactions with you and any concurrent transactions, including, but not limited to, counting ad impressions, verifying positioning and quality of ad impressions, and auditing compliance with applicable standards;
  • Security Purposes: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging: debugging to identify and repair errors that impair the intended functionality of our systems;
  • Short-term use: short term, transient use, including, but not limited to, the contextual customization of ads shown as part of your interactions with us;
  • Performing the Services: in addition to the purposes described in the Global Privacy Statement,  maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
  • Internal R&D: undertaking internal research for technological development and demonstration; and
  • Quality Purposes: undertaking activities to verify or maintain the quality or safety of the Services and to improve, upgrade, or enhance the Services.

Categories of Third Parties: in the 12 months prior to the effective date of the Global Privacy Statement, Western Union may have sold or shared your Personal Information with the following Categories of Third Parties:

  • Government entities: government entities including law enforcement agencies;
  • Professional services organizations: professional services organizations, such as law firms and independent auditors;
  • Advertising and social networks: advertising and social networks (who may combine your personal information with their own records, and records available from other sources for their own marketing purposes);
  • Internet service providers;
  • Third-Party data aggregators and data brokers;
  • Data analytics providers;
  • Operating systems and platforms; and
  • Our affiliates and subsidiaries.

SALE OF PERSONAL INFORMATION

Western Union does not sell your personal information to third parties in exchange for money.  Western Union does participate in advertising, marketing and analytic programs from which we and third parties with whom we contract may derive value; such exchanges may constitute a “sale” under applicable law. While participating in the above programs, in the 12 months prior to the effective date of the Global Privacy Statement, Western Union may have “sold” your personal information to a third party including:

  • Identifiers: contact information, for example your name, e-mail address, and telephone number; and
  • Internet and Other Electronic Network Activity Information: including the host from which you access the Internet, your IP address or device advertising ID, information about your device (such as device properties, settings, applications, storage and usage information), mobile application, browser and operating system software, social profile and network information, the date and time you access our websites and the address of the site from which you linked to our website when you visit us.

CALIFORNIA RESIDENT RIGHTS

UNITED STATES PRIVACY RIGHTS

To exercise the rights provided by U.S. Privacy Laws, please review the ACCESSING, DELETING, AND CORRECTING YOUR PERSONAL INFORMATION AND CHANGING YOUR CHOICES section of our Global Privacy Statement above. Residents of states with applicable U.S. Privacy Laws also have the following additional rights:

Residents of states with applicable U.S. Privacy Laws have the right to request that their personal information not be sold/shared to third parties or used for targeted advertising. To exercise your right to opt-out of the sale or sharing of your personal information or targeted advertising, please follow this link [http://www.westernunion.com/datasubjectrights] or submit a personal information request as described above in the section of our Global Privacy Statement entitled “ACCESSING, DELETING AND CORRECTING YOUR PERSONAL INFORMATION AND CHANGING YOUR CHOICES”. You may also choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”).  We will process the GPC signal as a request to opt out. Western Union cannot connect individual consumers to passive website visits, which may affect our ability to respond to certain requests. Western Union  has implemented the capability for you to manage cookies on our websites and will only read or write cookies based on your preference level. When you visit our website, you will be presented with a banner instructing you how to manage your preferences.

In addition, if you are a resident of a state with an applicable U.S. Privacy law, you have the right to request, twice in a 12-month period, the categories of personal information we have collected about you during the past 12 months and, for each category of personal information, the following information:

  • the categories of sources from which we collected that information;
  • our business or commercial purpose(s) for collecting that information;
  • the categories of third parties to whom that information was sold or disclosed for a business purpose; and
  • the business or commercial purpose(s) for which we sold or disclosed that information.

To exercise these rights, please visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section titled “CONTACTING US”.

We will respond to your requests in accordance with applicable law. Please note that, where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify  your identity (or an agent’s authority to make the request) and confirm the personal information we maintain relates to you. Submitting a privacy rights request does not require you to create an account with us.

You may also designate an authorized agent to make a personal information request on your behalf. If you choose to designate an agent, you may be required to provide the authorized agent with written permission to make your request and verify your own identity directly with us. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

You have the right not to be discriminated against because you exercise any right described in the Global Privacy Statement or this Addendum.

If you have previously transacted with Western Union, you have rights separate from those described above which are explained here.

CONTACT

Contact for More Information: for questions or concerns about our Global Privacy Statement and privacy practices, please contact us as specified in the “Contacting Us” section of the Global Privacy Statement.

CCPA REPORT METRICS

The following summary provides California residents’ data request volumes for calendar year 2024:

Data requests received: 209

  • Access 3
  • Deletion 53
  • Opt-Out 139

Data Request complied with in whole or in part: 166

  • Access 0
  • Delete 49
  • Opt-Out 111

Data Requests Denied or Closed:

  • Access 3
  • Delete 4
  • Opt-Out 28

Average time (days) to respond:

  • Access 3
  • Delete 15
  • Optout 5

FINANCIAL PRIVACY NOTICE TO UNITED STATES CONSUMERS (INCLUDING CALIFORNIA RESIDENTS)

 

FACTSWHAT DOES WESTERN UNION DO

WITH YOUR PERSONAL INFORMATION?

 

Why?Financial companies choose how they share your personal information, whether you send money, receive money, or we otherwise collect information about you. 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.

 

What?The types of personal information we collect and share depend on the product or service you use with us. This information can include, without limitation:

·    Government identification numbers, such as driver’s license, state identification, passport, visa, Social Security, or tax identification

·    Name, address, email address, mobile and home telephone number, age, date of birth, gender, citizenship, occupation, and marital status

·    Account balances, transaction and payment history, loyalty program information, wire transfer instructions, credit information, debit and other bank account information

·    Computer and mobile device information, such as domain, IP address, location information, device properties, settings, applications, stored information and usage, carrier information, browser information and history, operating system, social profile and network information, date and time you access our website or applications, and cookie information

You consent to our collection, transfer, and storage of information by computers or other transfer or storage devices in the United States and elsewhere.

How?All financial companies need to share customers’ and consumers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ and consumers’ personal information, the reasons Western Union chooses to share, and whether you can limit this sharing.

 

 

Reasons we can share your personal informationDoes Western Union share?Can you limit
this sharing?
For our everyday business purposes such as to process your transactions; manage our consumer relationships; provide requested products and services; maintain your account(s), if applicable; respond to court orders and legal investigations; report to credit bureaus; gather information about website and application access; usage and performance; enhance your consumer experience; validate your creditworthiness or your identity; provide in connection with a merger, acquisition or sale of the company or any of its assets; make risk decisions; detect and prevent fraud and other illegal activity; or as otherwise permitted by lawYesNo
For our marketing purposes such as to offer our products and services to you or notify you about future events and promotionsYesYes
For joint marketing with other financial companiesYesNo
For our affiliates’ everyday business purposes such as information about your transactions and experiencesYesNo
For our affiliates’ everyday business purposes such as information about your creditworthinessYesYes
For our affiliates to market to youYesYes
For nonaffiliates to market to you No We do not share

 

To limit our sharing·      Call 1-800-562-2598—Our menu will prompt you through your choices(s)

·      For registered users, visit us online: www.westernunion.com, log into your profile and edit your profile settings.

·      Email wuprivacy@westernunion.com

·      Submit a Data Privacy Request Form at https://wuprod.service-now.com/wu_privacy

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we can continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions?Call 1-800-562-2598 or go to www.westernunion.com and click on the “Contact Us” link at the bottom of the page

 

Who we are
Who is providing
this notice?
Western Union Financial Services, Inc., Western Union International Services, LLC.

 

What we do
How does Western Union protect my personal information?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 also endeavor to limit access to personal information only to employees, Agents and representatives that need to know.
How does Western Union collect my personal information?We collect your personal information, for example, when you:

·       Send or receive money, tell us who receives the money, tell us where to send the money, complete a payment, or use or request other products or services from us or other financial companies

·       Use your credit or debit card or pay us by check

·       Register with us or submit information to us, our Agents or other third parties on applications, forms, and by other means

·       Give us your contact information

·       Show your government issued ID or driver’s license

·       Use or visit our or other online sites or mobile applications

·       Enter a promotion, register for email alerts or marketing communications, or join a loyalty program

We also collect your personal information from companies, government agencies, and consumer reporting agencies.

Why can’t I limit all sharing?Federal law gives you the right to limit 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. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?Western Union does not provide individual or joint accounts.

 

Definitions
AffiliatesCompanies related by common ownership or control. They can be financial and non­financial companies.

Our affiliates include companies with a Western Union or Custom House name and financial companies such as Western Union Financial Services, Inc.

NonaffiliatesCompanies not related by common ownership or control. They can be financial and non­financial companies.

 

 

Joint marketingA formal agreement between nonaffiliated financial companies that together market financial products or services to you.

 

Our joint marketing partners may include banks, credit card companies, brokerage houses, mortgage lenders, mortgage originators, and other financial companies.

 

Other important information
VERMONT, CALIFORNIA, AND NORTH DAKOTA CONSUMERS

Western Union will disclose information about consumers with a Vermont, California, or North Dakota mailing address only with your written authorization (“consent”), unless otherwise permitted or required by law. Written authorizations from Vermont consumers may be delivered to us at the email or mailing address below and must contain your name, address, signature and your consent.

You may revoke your consent at any time by calling us at 1-800-562-2598, or by writing or emailing us at the addresses below. California consumers should contact us at the mailing address below for instructions on how to deliver their consent.

Email: wuprivacy@westernunion.com
Mail to:

Western Union Financial Services, Inc.

Western Union Privacy Office

7001 East Belleview Avenue

Denver, CO 80237

 

 

TEXAS CONSUMERS

If you have a complaint, first contact the consumer assistance division of Western Union Financial Services, Inc. at 1-800-562-2598. If you still have an unresolved complaint regarding the company’s money transmission or currency exchange activity, please direct your complaint to: Texas Department of Banking, 2601 North Lamar Boulevard, Austin, Texas 78705,1-877-276-5554 (toll free), www.dob.texas.gov.

 

NEVADA CONSUMERS

If you prefer not to receive marketing calls, you may be placed on our internal opt-out list by calling us at 1-800­562-2598 or you may also contact the Nevada Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Ste 3900, Las Vegas, NV 89101; telephone 702-486-3132;

email: BCPINFO@ag.stcrte.nv.us.

 

CHILDREN’S PRIVACY

Our website is not directed at children under the age of 13.

CA NOTICE OF FINANCIAL INCENTIVE / CO BONA FIDE LOYALTY PROGRAM NOTICE

Western Union® Rewards Program (“Rewards”), our loyalty program, is one way in which Western Union endeavors to reward and thank loyal customers for patronizing our business and utilizing Western Union services.  Rewards members opt in by signing up for Rewards at participating retail locations, online or through the Western Union App, and are able to earn and accumulate Rewards points with each completed money transfer that can be redeemed for discounted transfer fees on money transfers. If you would like to become a Western Union Rewards member, please see the Western Union Rewards Program Terms and Conditions for more information and/or click here to sign up.

Western Union collects and uses the categories of personal information described in the “PERSONAL INFORMATION WESTERN UNION COLLECTS,” “HOW WESTERN UNION COLLECTS PERSONAL INFORMATION,” and “HOW WESTERN UNION USES THE PERSONAL INFORMATION IT COLLECTS” sections of our Global Privacy Statement, including information you voluntarily provide us (such as your name and email), information we collect automatically, and information from other sources to operate the Rewards loyalty program, including to provide you promotions, content, and special offers and the other uses described in the Global Privacy Statement.  We work with service providers and business partners to offer benefits for our Rewards loyalty program.  Those partners may fall into the following categories: vendor partners, Western Union agents, subsidiaries, and affiliates, and/or service providers and business partners.  You can learn about the business partners with whom we share your information by referring to the “WHO WESTERN UNION SHARES YOUR PERSONAL INFORMATION WITH” section of the Global Privacy Statement.

Based on our reasonable and good faith estimate, we receive value from the Western Union® Rewards Program in increased customer loyalty and patronage, though any value will vary by Rewards member depending on the number of money transfers completed, which offers and discounts a member takes advantage of, and other factors.

The value of the Rewards program is reasonably related to the value of any personal information you provide to us. We estimate the value of your personal information by considering, without limitation, the expenses we incur from collecting your personal information and/or providing the Rewards, the revenue generated by your use of the Rewards, and any improvements we can make to our products and services based on aggregating information obtained through the Rewards program.

You may opt out of receiving promotional emails at any time by adjusting your Western Union online account settings, or by clicking the “unsubscribe” link included within any promotional emails we send you, though you will still receive service messages related to your Rewards account. Participation in Rewards is voluntary, and you may withdraw from the Rewards loyalty program by visiting the account or settings section in the Western Union App or your online profile, by requesting deletion of your information by filling out this form, or by contacting Western Union Customer Service. Please note that by withdrawing from Rewards, you will no longer have access to your Rewards account, but you can otherwise continue to use Western Union digital and retail platforms. All points and rewards you have earned until the time of withdrawal will no longer be available.  As previously shared, to communicate and provide services to you through the Rewards loyalty program, we need to use your personal information. Therefore, if you choose to delete your personal information from the Rewards loyalty program, or if you choose to exercise a general deletion request, we can no longer provide you with services and benefits through this Rewards loyalty program.

Should a Rewards member choose to opt-out of the share of their personal information, no loss of benefits for use of rewards points will occur for the Rewards program member for as long as they remain a member of the Rewards program. Opting out of the share of personal information may result in receiving fewer personalized offers and services, including any offers from third party partners participating in the Rewards program.

If you are a California or Colorado resident and opted out of our “share” of your personal information before you joined Rewards, you will need to opt out again once you are a member, if you do not wish for Western Union to “share” personal information. To do so, click here or contact Western Union Customer Service.

APPENDIX TO THE WESTERN UNION GLOBAL PRIVACY STATEMENT FOR USERS IN MEXICO

WHAT PERSONAL DATA DO WE COLLECT?

See Section PERSONAL INFORMATION WESTERN UNION COLLECTS in Global Privacy Statement for more information.

In addition to the personal data referred in the Global Privacy Statement, we also inform you that at the moment you decide to hire the Western Union Money Transfer Service through our mobile application, the Responsible Party will also collect and process your biometric data, which refer to your physical and physiological characteristics, such as your face for facial recognition and fingerprints. Said biometric data, together with the photograph of their official identification and electronic signature, will be sent by the Responsible Party to the competent authorities in Mexico for their respective validation.

With the validation of your biometric information and the official identification presented, the Responsible Party complies with the obligation to know and verify the identity of you as a sender of a money transfer in Mexico, in accordance with the regulation that is applicable as Money Transmitter.

HOW WESTERN UNION PROCESSES YOUR PERSONAL INFORMATION

We process your personal information for the following Primary Purposes:

  • To provide our services to you: such as conducting money transfers, payment services, and loyalty programs; sending you important service-related, administrative or transaction-related communications; and perform existing contracts with you or enter into additional Western Union-branded products or services with you.
  • For legitimate business purposes: such as the running of our websites and apps; providing you with customer services; and helping to protect the security and integrity of our technology, systems, and services.
  • For Identification and Authentication purposes: to verify the data contained in your official identification document and your biometric data to verify your identity against the records managed by the National Electoral Institute and the National Population Registry, in order to comply with the applicable legal regulation.
  • For legal and compliance purposes: such as complying with legal and regulatory duties related to anti-money laundering and counter-terrorist financing; detection, prevention and prosecution of fraud and theft as well as preventing illegitimate or prohibited use of our services or other illegal or wrongful activity. This may also include establishing, exercising, or defending legal rights and claims of the Responsible Parties and others, and monitoring and reporting compliance issues as well as using your Personal Data to validate and authenticate your identity, and utilizing third parties to help us do so. In certain cases, such as performing money transfer services, we may be unable to provide you with our Services unless you provide the necessary Personal Data.

 

We also process your personal information for the following non-essential, Secondary Purposes:

  • For marketing purposes: such as, subject to your consent, notifying you of offers, promotions and updates regarding our products and Services. These may include offers by email, telephone, postal mail, SMS, social media and other communication or digital channels. You can opt out of receiving these marketing communications at any time. If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by following the instructions in the relevant electronic communication or by contacting us as described in the “CONTACTING US” section in the Global Privacy Statement. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important service, administrative or transaction-related communications.
  • To measure marketing returns on investment and brand satisfaction (including by conducting market research surveys);
  • To assist us in providing our Services to you and help you to receive a personalized experience and assist you in carrying out transactions and accessing account information;
  • To recognize you and allow you to remain signed-in during your use of our websites and/or applications without having to re-enter your password;
  • To perform analytics on understanding our customers, improving their experience;
  • To analyze and improve your experience regarding our products, locations, services, and operations;
  • To determine if you reached the money transfer service of the Western Union brand from a banner ad or an Affiliate;
  • To deliver information specific to your interests not related to the money transfer service of the Western Union brand;
  • To better understand the effectiveness of our promotional campaigns and whether you acted on our promotional messages;
  • To promote safety, reduce financial risk and combat fraud.

 

The Responsible Parties will not collect or use your sensitive personal information while we provide our Services to you without your consent.

 

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

See Sections WHO WESTERN UNION SHARES YOUR PERSONAL INFORMATION WITH and INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION in the Global Privacy Statement for more information.

HOW CAN YOU LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA?

See Section ACCESSING, DELETING AND CORRECTING YOUR PERSONAL INFORMATION AND CHANGING YOUR CHOICES in the Global Privacy Statement for more information.

Additionally, if you do not agree that your Personal Data and/or the Personal Information Generated be used for purposes other than those that are necessary for the legal relationship between the Responsible Parties and You, we would be grateful if you could inform in writing to the Personal Data Department of the Responsible Parties located at Avenida Paseo de la Reforma number 505,  piso 17, Col. Cuauhtémoc, Alcaldía Cuauhtémoc, C.P. 06500, Mexico City or by e-mail wuprivacy@westernunion.com (the “Address”). In the event that the Global Privacy Statement and this Addendum has not been delivered to you directly or personally, you will have 5 (five) business days from the date it is made known to you, so that, if applicable, you may express your refusal to the management for the processing of your Personal Data with respect to the purposes that are not necessary nor did they give rise to the legal relationship with the Responsible Parties.

In the event that you wish to limit or suspend the processing of your Personal Data for use for advertising or promotional purposes, you may also register in the Public Registry to Avoid Advertising (REPEP) of the Federal Consumer Protection Agency (PROFECO) through its website https://repep.profeco.gob.mx

 

USE OF COOKIES, WEB BEACONS, AND INTERNET TECHNOLOGIES

See Section INTERNET TECHNOLOGIES in the Global Privacy Statement for more information.

EXERCISING YOUR ARCO RIGHTS

As owner of the personal information, you may at any moment exercise your rights to access, rectify, cancel and/or oppose the processing of your personal information (the “ARCO Rights”) as well as to revoke your consent regarding the processing of any personal information which violates the terms of the Global Privacy Statement and this Addendum, via a written request to our Data Privacy Department at wuprivacy@westernunion.com, insofar as the requested opposition and/or revocation poses no harm to third parties’ rights and in accordance with article 34 of the Law.

Your request must include: i) the name of the owner of the personal information, ii) an address whereby the request may be answered, iii) official documents that establish the identity of the data owner, or, where applicable, proof of legal representation of the Personal Data’s owner, and iv) a clear and precise description of the personal information for which you wish to exercise your ARCO rights.

Requests for rectification of personal information must include the modifications which you wish to be made and evidence to support such petition; requests regarding the revocation of your consent must communicate in a clear manner that you wish to revoke your consent regarding the processing of certain personal information, and where applicable, the reasons for such revocation.

Upon receipt of your request, we shall have a term of 20 (twenty) business days to inform you of the relevant solution, with such solution being effective as of 15 (fifteen) business days following the date on which such resolution was informed to you in writing or via e-mail. The aforementioned terms may be extended once, insofar as proper justification for the extension is given.

MODIFICATIONS TO THIS ADDENDUM

See Section CHANGES in Global Privacy Statement for more information.

PERSONAL DATA TREATMENT CONSENT

You, as the owner of the Personal Data, declare having read and agree to the terms and conditions provided of the Global Privacy Statement and this Addendum that is available for you, knowing the purpose of the collection and treatment of your Personal Data, as well as the procedure to exercise your ARCO rights and the revocation of your consent.

I consent and authorize that my Personal Data, including biometric data, be collected and processed by Responsible Parties and third parties detailed in Section WHO WESTERN UNION SHARES YOUR PERSONAL INFORMATION WITH of Global Privacy Statement, in accordance with the provisions of the Global Privacy Statement and this Addendum.

The National Institute for Transparency, Access to Information, and Personal Data Protection (INAI) is the competent authority to resolve any conflicts arising from the application of the Federal Law on the Protection of Personal Data in Possession of Private Parties and its Regulations.

Your Personal Data will be treated in compliance with the safeguard levels required by Law.

Appendix on Western Union’s Global Privacy Statement for users of the Western Union Digital Account (IFPE) in Mexico

We care about the privacy of our users and customers in Mexico and are committed to collecting, using, storing, protecting, disclosing and, if applicable, share your personal information in accordance with the Federal Law on the Protection of Personal Data Held by Individuals of Mexico (“LFPDPPP” or the “Law”). This Appendix supplements the Western Union Global Privacy Statement and applies exclusively to individuals who apply for, contract or use the Western Union Mexico Digital Account and other associated financial services provided by LanaPay de México, S.A. de C.V., electronic Payment Funds Institution (“LanaPay”) A subsidiary of Western Union. In the event of a conflict between this Appendix and the Western Union Global Privacy Statement regarding the processing of data related to the Western Union Mexico Digital Account, the provisions of this Appendix shall prevail.

In Mexico, for the purposes of the services associated with the Digital Western Union Mexico Account, the controller of your personal data is LanaPay de México, S.A. de C.V., Institución de Fondos de Payment Electronica (“LanaPay”) (the “Holder”) a subsidiary of Western Union, as applicable. Lanapay has its legal address at Av. Paseo de la Reforma No. 505, piso 17, Colonia Cuauhtémoc, Delegación Cuauhtémoc, C.P. 06500, Mexico City.

Lanapay informs you that your information is treated strictly confidential and based on the principles of legality, motives, loyalty, consent, quality, proportionality, information and responsibility enshrined in the LFPDPP.

WHAT PERSONAL DATA DO WE COLLECT?

See PERSONAL INFORMATION COLLECTED by WESTERN UNION in the Western Union Global Privacy Statement for more information.

In addition to the personal data mentioned in the Western Union Global Privacy Statement, we also inform you that when you decide to contract any of Lanapay’s services through our mobile application, in order to know and verify your identity in accordance with applicable regulations, Lanapay may collect and process: (i) identifying data, including information contained in official IDs, the Unique Population Registry Key (CURP) and the Federal Taxpayer Registry (RFC); (ii) geolocation data of the device used to access the Services; (iii) photographs, images or digital copies of identification documents; (iv) biometric data used for identity validation and authentication; (v) information related to the origin and destination of funds and transactions performed through the account; and (vi) any other information necessary to comply with applicable legal and regulatory obligations, including those related to the prevention of money laundering and terrorist financing.

Lanapay does not process “sensitive personal data”, that is, personal data that affects the most intimate sphere of the data subject, or whose misuse may lead to discrimination or pose a serious risk to the data subject. Sensitive data are personal data that may reveal aspects such as racial or ethnic origin, present or future health status, genetic information, religious, philosophical and moral beliefs, political opinions and sexual preference.

HOW WESTERN UNION PROCESSES YOUR PERSONAL INFORMATION

Your personal data is processed for the purpose of providing you with our services to the highest possible quality and in strict compliance with the legal framework applicable to Lanapay (“Essential Reasons”). If you do not wish your personal data to be processed for these essential reasons, Lanapay will not be able to provide its services to you. See the section on HOW WESTERN UNION USES THE PERSONAL INFORMATION IT COLLECTS in the Western Union Global Privacy Statement.

The timeliness of the processing of the personal data collected will depend on the obligations required by the applicable legislation applicable to Lanapay corresponding, which obliges it to keep them for the entire duration of the legal relationship with you and, once this is terminated, for a period not less than ten years. If you do not want your personal data to be processed during this time, we will not be able to provide you with our services. In addition, please refer to the PERSONAL INFORMATION RETENTION section of the Western Union Global Privacy Statement. In the Western Union Global Privacy Statement.

If you do not wish your personal data to be processed for reasons other than those necessary and which give rise to the legal relationship between Lanapay and you (for example, receiving advertising for our products and services), you can, at any time, declare your refusal, object or revoke your consent, without retroactive effect, by following the instructions contained in the relevant electronic communication or by contacting us as described in the “CONTACT US” section of the Western Union Global Privacy Statement. Your refusal or revocation of the use of your personal data in respect of these reasons will not constitute a reason to stop providing Lanapay services to you.

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

To comply with legal and regulatory obligations, LanaPay may share personal data with: CNBV; Banco de México, when applicable; Tax Administration Service (SAT); National Population Registry (RENAPO); National Electoral Institute (INE); Financial Intelligence Unit and other competent authorities; and suppliers that participate in processes of identity validation, fraud prevention, regulatory compliance or technological services linked to the operation of the Western Union Mexico Digital Account.

LanaPay may also share personal data with other Western Union group entities and service providers involved in the provision, operation, administration, compliance, fraud prevention, and other services. security, identity authentication, technology support and other activities necessary for the operation of the Western Union Mexico Digital Account, as described in the Western Union Global Privacy Statement.

In the event that in the future there is any other reason for the transfer of your personal data to third parties, we will inform you through this privacy notice. It should be noted that Lanapay may transfer your personal data without your consent in the following cases:

  • That the transfer is provided for in a law or treaty to which Mexico is a party, including financial authorities that regulate and supervise Western Union in accordance with the applicable legal framework.
  • The transfer is necessary for prevention or medical diagnosis, provision of medical care, medical treatment or management of health services.
  • The transfer is made to controlling companies, subsidiaries or affiliates under the common control of Lanapay, or to a parent company or to any company in the same Lanapay group operating under the same internal processes and policies.
  • That the transfer is necessary under a contract concluded or to be concluded in the interest of the Holder, by the responsible party and a third party.
  • The transfer is necessary or legally required in order to safeguard the public interest, or for the application or administration of justice.
  • The transfer is necessary for the recognition, exercise or defense of a right in a judicial proceeding.
  • That the transfer is accurate for the maintenance or fulfillment of the legal relationship between you and the responsible party.

In addition, please see the sections WITH WHOM WESTERN UNION SHARES YOUR PERSONAL INFORMATION, THE LEGAL GROUNDS ON WHICH WE RELY TO USE YOUR PERSONAL INFORMATION, and INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION in the Western Union Global Privacy Statement for more information.

HOW CAN YOU LIMIT THE USE OR DISCLOSURE OF YOUR PERSONAL DATA?

ARCO RIGHTS AND REVOCATION OF CONSENT FOR THE PROCESSING OF YOUR PERSONAL DATA

At any time, you can exercise the ARCO Rights free of charge (access, correction, cancelation and opposition), as well as the revocation of your consent to the processing of your personal data; see the ACCESS, DELETING, And CORRECTING YOUR PERSONAL INFORMATION and CHOICE CHANGES sections in the Western Union Global Privacy Statement for more information.

For the above reasons, visit http://www.westernunion.com/datasubjectrights or contact Western Union through the section entitled “CONTACT US”, or send an email to wuprivacy@westernunion.com or in writing to the Western Union Personal Data Department, located at Avenida Paseo de la Reforma number 505, Piso 17, Col. Cuauhtémoc, Alcaldía Cuauhtémoc, C.P. 06500, Mexico City.

The request must contain the following requirements: (i) name of the owner of the information, address and email or other means of notifying him of the response; (ii) documents that prove his identity or legal representation; (iii) clear and accurate description of the personal data in respect of which you wish to exercise any of the rights of ARCO or the rights of revocation or limitation; and (iv) any other element that facilitates the location of the personal data.

If you request a correction, include the modifications you want to make and the documents supporting your request. If you request to revoke your consent or limit the use of your personal data, you must specify this clearly. Once we receive your request, we will respond within 20 business days from the date of receipt informing you of the decision taken so that, in your case, it becomes effective within 15 business days from the date on which you are answered. These periods may be extended only once, provided that this is justified.

However, if you wish to revoke your consent, limit the use or exercise your right to object to the processing of your personal data according to the essential reasons, or exercise your right to cancel, this will mean that LANAPAY will not be able to continue to provide its services to you. Likewise, the revocation of consent, the limitation of use or the exercise of the rights of objection and cancelation will not have retroactive effect and may not be effective immediately, due to Lanapay’s legal obligations to retain the information described above.

We may deny access, correction, cancelation and objection in the following cases: (i) you are not the data holder or have no valid legal representation; (ii) your data is not in our database; (iii) providing access would affect the rights of a third party; (iv) the law or a competent authority prevents access, correction, cancelation or objection; and (v) the correction, cancelation or objection requested has already been made. If your request is denied in whole or in part, we will inform you of the reasons for such refusal and provide you with the corresponding evidence to support it.

USE OF COOKIES, WEB BEACONS AND INTERNET TECHNOLOGIES

See the Internet TECHNOLOGIES section of the Western Union Global Privacy Statement for more information.

AMENDMENTS TO THIS APPENDIX

See the CHANGES section in the Western Union Global Privacy Statement section for more information.

APPLICABLE JURISDICTION

The competent authority for the protection of personal data in Mexico is the Secretariat of Anti-Corruption and Good Governance (Secretariat). If you believe that your rights have been violated due to the response received or failure to respond to your requests under the LFDPPP, you may contact the Secretariat for further information and assistance.

This Privacy Notice is governed by current and applicable legislation in the United Mexican States. Any dispute arising from your request must be resolved before the Registry or the competent courts of Mexico City.

BRAZILIAN CITIZEN PRIVACY NOTICE

We value and respect the privacy of Personal Data Holders who are in Brazil, and are committed to the Treatment of their Personal Data in accordance with the General Data Protection Law (“LGPD”) and other applicable Brazilian laws and regulations. This Addendum to Western Union’s Global Privacy Statement for Holders who are in Brazil (“Addendum”) is applicable to Holders residing in Brazil and other Holders who may be in the country at the time of Personal Data collection (collectively, “Brazilian Holders”), and, together with the Global Privacy Statement, aims to provide transparency on the main information related to the Treatment of your Personal Data. In the event of a conflict between the information in this Addendum and that described in the Global Privacy Statement, the information in the Global Privacy Statement shall prevail.

In Brazil, the Western Union entities responsible for the Treatment (the Controllers of Personal Data) are: Western Union Corretora de Câmbio SA, a closed corporation, headquartered at Rua Iguatemi, 151, 9th floor, set 91, São Paulo / SP, CEP 01451-011, registered with CNPJ / ME under nº 13.728.156 / 0001-35; and Banco Western Union do Brasil SA, a closed corporation, headquartered at Rua Iguatemi, nº 151, 7th floor, set 72, São Paulo / SP, CEP 01451-011, registered with CNPJ / ME under nº 13.720.915 / 0001-13.

PERSONAL DATA WESTERN UNION COLLECTS

For Brazilian Holders, the same Personal Data described above is collected, except for the following:

  • In Brazil, no information is collected regarding participation in loyalty programs.

HOW WESTERN UNION COLLECTS PERSONAL DATA

In addition to the ways described above, Western Union may still collect your Personal Data at the following points:

  • Lists sent by public bodies and authorities, such as COAF;

Judicial or extrajudicial notifications received electronically or by mail.

HOW WESTERN UNION PROTECTS YOUR  PERSONAL DATA

In addition to reasonable organizational, technical and administrative protections that comply with applicable governmental laws and regulations in order to protect your Personal Data, we also take institutional measures with the same intent, so that we have a Privacy and Data Protection Governance Program Personal Data applied to our activities, constantly reviewed and updated.

Access to the information collected is restricted to employees and authorized persons and only when strictly necessary.

HOW WESTERN UNION USES PERSONAL DATA COLLECTED

Western Union uses the personal information it collects to:

  • Help us provide Services to you and help you receive a personalized experience, including the use of personal information necessary to conduct money transfers, payment services or prepaid cards;
  • Recognize you and allow you to stay connected to your section during the visit without having to enter your password again;
  • Conduct analyzes on how to understand our customers, improving their experience, including the use of personal information to analyze and improve our products, locations, services, operations, the functioning of this website and their customer experience, in addition to any market research;
  • Determine whether you came to Western Union from a banner or an Affiliate’s website;
  • Provide information specific to your interests on non-Western Union websites and applications;
  • Better understand the effectiveness of our promotional campaigns and whether you have taken any action based on our promotional messages, as well as to measure the return on investment in marketing and brand satisfaction;
  • Promote security, reduce financial risks and fight fraud in our Services;
  • Meet the legal obligations to which Western Union is subject, in addition to meeting the regulations of regulatory bodies such as BACEN and CVM, especially when related to combating money laundering and anti-terrorist financing; detecting, preventing and prosecuting fraud and theft, as well as preventing the illegitimate or prohibited use of our services or other illegal or illicit activities; and
  • Responding to judicial and extrajudicial notifications, as well as exercising our defense in judicial, administrative or arbitration proceedings.

When Western Union carries out Personal Data Treatments based on a legitimate interest, this will always occur within the limits of your expectations, and never to the detriment of your fundamental interests, rights and freedoms.

It is important to note that, despite being informed in the Global Privacy Statement above, Western Union does not collect consent in the Treatment of Personal Data under the scope of this Addendum, using other legal bases provided for in the applicable legislation, except as described in the item INFORMATION ABOUT CHILDREN’S PERSONAL DATA.

Also, note that not necessarily all of the purposes described here will apply to all customers. This will depend on the product / service actually hired. To learn more about the purposes that apply to you, enter into a contract with our Supervisor through the channels indicated in the “HOW TO CONTACT” section of this Declaration.

INFORMATION ABOUT CHILDREN’S PERSONAL DATA

Please see the section “INFORMATION FROM CHILDREN” in the Global Privacy Statement.

WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM

According to Brazilian law, you can exercise the following rights with respect to your Personal Data:

a) Confirm the existence of the Treatment by Western Union or by any group company;

To exercise this right, access our Request Portal, and after identifying yourself (Customer, Agent or Employee) click on “Access to Data”, also informing us in the “Request Description” that you intend to exercise the right to confirm the existence of Treatment.

b) Request access to Personal Data processed by Western Union or any company in the group;

To exercise this right, access our Application Portal, and, after identifying yourself (Customer, Agent or Employee) click on “Access to Data”, also informing us in the “Request Description” that you intend to exercise the right to access the data.

c) Correct, update and / or complete your Personal Data;

To exercise this right, access our Request Portal, and, after identifying yourself (Customer, Agent or Employee) click on “Data Correction”, also informing us in the “Request Description” which Data you want rectify.

d) Request the anonymization, blocking or elimination of unnecessary, excessive or illegally processed data;

To exercise this right, access our Application Portal, and after identifying yourself (Customer, Agent or Employee) click on “Restrict Processing” or on “Data Delete” and also inform us in the “Request Description” , because we are treating the data in an unnecessary, excessive or illicit way.

  1. e) Revoke your consent, when your Personal Data is treated under this hypothesis;

To exercise this right, access our Requests Portal, and, after identifying yourself (Customer, Agent or Employee) click on “Marketing Deactivation”, if applicable, or on “General Privacy Inquiry” and also inform us on the “Application Description”, which is the activity whose consent you intend to revoke.

  1. f) Request the portability of Personal Data to another service or product supplier, upon express request;

To exercise this right, access our Application Portal, and after identifying yourself (Customer, Agent or Employee) click on “Data Portability”.

  1. g) Know with whom we share your Personal Data; and

To exercise this right, access our Application Portal, and, after identifying yourself (Customer, Agent or Employee) click on “Access to Data”, also informing us in the “Request Description” that you intend to obtain information about who your data is shared by Western Union.

  1. h) Request the review of automated decisions.

To exercise this right, access our Request Portal, and after identifying yourself (Customer, Agent or Employee) click on “Deactivation (automated decision making/profile creation”, also informing us of the automated decision object of the review request.

Registered users can also access the website https://www.westernunion.com/br/pt/home.html and edit their Profile settings.

You also have the right to file a complaint with the National Data Protection Authority or another body described in the LGPD (such as those for consumer protection).

When we receive a request, we may ask for additional information from you to confirm your identity. In some situations, we may refuse to act or we may impose limitations on your rights as permitted by applicable law, and we will explain the reasons that justified the failure to comply with your request, such as requests involving Personal Data and / or documents from other Owners.

To exercise such rights, access http://www.westernunion.com/datasubjectrights or contact Western Union through the section entitled “HOW TO CONTACT US”. We will endeavor to respond to your request immediately, if required, or within 15 days. Depending on the complexity of your request, we may extend this period to serve you accordingly.

 

HOW TO CONTACT US

If you have any questions or complaints about how we treat your Personal Data, we ask that you register your request in writing. We will review your query and will usually respond in writing within 15 days of receipt. You can also contact us, including our Person in Charge of the Processing of Personal Data:

Western Union’s Data Protection Officer

email: wuprivacy@westernunion.com

To contact us via a toll-free or local phone number, click this link to Talk to WU Customer Service: https://www.westernunion.com/br/pt/contact-us.html.

JAPANESE CITIZEN PRIVACY NOTICE

For consumers resident in Japan, notwithstanding any other provisions contained in this Global Privacy Statement, we will treat your Japanese Personal Identification Number (“My Number”) and its supporting documents in compliance with any applicable laws and regulations as described in this section. In the event of a conflict between the information in this Addendum and that described in the Global Privacy Statement, the information in the Global Privacy Statement shall prevail.

We collect your My Number and supporting documents designated by us solely for the purpose of confirming your My Number as required by and in compliance with the Act on Submission of Statement of Overseas Wire Transfers for Purpose of Securing Proper Domestic Taxation of Japan (Act No. 110 of 1997, as amended).