Declaration of
Privacy Statement - BT24

Your personal data is processed under applicable laws and is processed, as controller, by Western Union Payment Services Ireland Limited, Unit 9, Richview Business Park, Clonskeagh, Dublin 14, Ireland.

The data we collect about you:

When you use our digital or retail services, contact us or join our loyalty programs, we collect your personal data (as defined in this form/our online application forms) and may use it along with other information collected or generated during our relationship with you. We collect your contact details, information about your money transfers, bill payments, membership of our loyalty programmes, previous use of our services and your purchasing choices. When you use our online digital services, we collect personal data about the domain and host through which you access the internet, your computer's IP address or device advertising ID, browser and operating system software, the date and time you access the websites, and the address of the website through which you accessed our website when you visited it. In order to make a money transfer, it is necessary for you to submit the information requested through the relevant form that you complete both to make the transfer and to enable us to comply with our legal obligations associated with money transfers. If you do not provide us with the necessary personal data, you will not be able to make a money transfer through us. In addition to the personal data we collect from you, we also collect data from the person to whom you send and/or from whom you receive money, as well as from our agents, service providers, business partners, identity verification companies, payment and fraud risk management companies, law enforcement agencies, and commercial and public data sources.

We use your personal data for the following purposes and on the following legal grounds:

To offer you our services:

This category includes the use of personal data necessary to make money transfers and deliver other products or provide other services to you as required by the contracts we have entered into with you.

For legal and compliance purposes:

This category includes the processing of your personal data to comply with legal obligations such as anti-money laundering and anti-terrorist financing. This includes the use of your personal data to confirm and establish your identity and the use of third parties to assist us in doing so.

For legitimate business purposes:

We use your personal data to analyze and improve the quality, speed and efficiency of our products, locations, services, support and operations, to perform administrative tasks necessary to provide our services, and to help manage security, fraud and identity risks, including detecting, preventing and tracking fraud and theft, and preventing illegal or prohibited use of our services. We conduct analysis of the data we hold to better understand our customers and their transactions, including conducting analytics to help us tailor our marketing activities, products and services and to help us anticipate your needs and requirements, as well as to administer our loyalty program.

Where we have permission:

Where you have consented to us using your personal data for a specific purpose or for certain activities. Subject to your choices under applicable laws and based on the contact information you provide, we will send you marketing communications and offers by email, phone, mail, SMS, social media and other communication channels.

We may disclose your personal data:

If there is a reasonable need to do so, for the purposes set out above, we will disclose your personal data to the following types of organisations and parties: Western Union group companies: our agents or business partners who facilitate certain services or money transfer transactions you have requested; service providers, payment processors, banking partners and data processors contracted to provide services to businesses and customers, including customer satisfaction research on our behalf; service providers and data processors contracted to help us confirm the accuracy of information you submit, to certify your identity and to manage security, fraud and identity risks. We also disclose your personal data globally, as required or permitted by applicable laws and regulations, to law enforcement and regulatory authorities, judicial authorities, central government authorities, local government authorities, to comply with legal compliance and obligations or to defend the rights and interests of Western Union or others.

International transfer:

We transfer your personal data to parties located in countries outside the European Economic Area (EEA), including but not limited to the U.S., as required by regulatory and law enforcement authorities and government agencies. In addition, when you send or receive money to or from another country, we will also be required to transmit certain data about you with that country as required or permitted by law. We transfer certain data about you to our data centers in the U.S. and process it to fulfill our legal and compliance obligations that apply to the services we provide. We also store in our US data center certain personal data that we collect based on your purchasing choices. Where your personal information is transferred to or accessed from the US or another country outside the EEA, in respect of which the European Commission has not issued an appropriate decision, it will be protected by appropriate contractual clauses or other appropriate mechanisms approved by the EU as required by law. You can request to see these mechanisms using the contact details below.

Withholding personal information:

Your personal data will be retained in accordance with the legal archiving deadlines contained in the regulations applicable to financial transactions, including anti-money laundering, anti-terrorist financing and other laws applicable to us. In other cases, we will retain your data only as long as necessary for the specific purposes for which it was collected, to answer any questions you may have, or as long as we need to retain it to exercise or defend our rights in court.

Your rights:

You have the right to know whether we are processing your personal data and to request a copy of the data we hold about you free of charge. You have the right to ask us for an organised and machine-processable copy of specific data you have submitted to us for the purposes you have consented to or where our use of it is necessary under the contract with you, and to ask us to forward this personal data to another controller. We may charge you a reasonable fee for providing this information or refuse your request if it is manifestly unfounded or excessive. You have the right to ask us to stop sending you marketing communications.

You have the right to ask us to correct personal data that is incomplete, inaccurate or out of date. You have the right, in certain circumstances, to ask us to delete certain data about you, to restrict certain uses of your personal data and also, where our use is for legitimate business purposes, to object to certain uses, including in relation to profiling activities. Where you have consented to the processing of your personal data, you have the right to withdraw your consent at any time.

You also have the right to address the competent supervisory authority if you consider that the processing of your personal data does not comply with the legal provisions in force. When we receive a request, we may ask you for additional information to verify your identity. To exercise these rights, please contact Western Union by calling 0800 801 044, emailing romania.customer@westernunion.com or via our website. We will endeavour to respond to your request within one month, but may be entitled to extend this period in certain circumstances. We will comply with your request to the extent required by applicable law. If you have a complaint about how Western Union has responded to your request under this section or how we handle your personal information, please send your complaint in writing to us at Unit 9 Richview Officer Park, Clonskeagh, Dublin 14, Ireland. We will investigate your complaint and generally respond to you in writing within 30 days of receipt. If you are not satisfied, you can complain to the supervisory authority in your country. You can also contact your Data Protection Officer at privacy@westernunion.com.

Copyright © 2018 WESTERN UNION HOLDINGS, INC. All rights reserved. Revised May 2018