Privacy Policy

CALGARY FOREIGN EXCHANGE LTD.

PRIVACY STATEMENT
Effective Date: October 1, 2013 This Privacy Statement describes how Calgary Foreign Exchange Ltd. (“Calforex”, “we”, “us” and “our”) collects, uses and discloses your personal information. “Personal information” is information about an identifiable individual, as more particularly defined or limited under applicable Canadian privacy legislation. This Privacy Statement applies to our collection, use and disclosure of personal information about our consumer and business customers and other individuals we deal with in Canada (“you” and “your”). This Privacy Statement does not apply to information about our employees or to information that is not personal information.

INFORMATION WE COLLECT
Calforex collects personal information about you from a variety of sources in the course of providing money transfer and payment services and related products and services we provide. Personal information we collect and the sources of such personal information include the following:

We collect personal information when you ask us to send or receive money or to provide other goods or services, provided by telephone, online at our website, through paper-based forms or at Calforex agent locations. This personal information may include identities and contact information of senders and recipients of money transfers or payments, credit card, banking or other billing information, birth dates and other personal identifiers, “out of wallet” questions used to verify your identity for security and fraud prevention purposes, identification number and amounts paid or transferred.

We collect personal information when you submit personal information on applications or other forms to us or our affiliates, including in connection with sending and receiving money transfers, through your enrollment and participation in loyalty programs and when you provide additional information we may reasonably request for fraud prevention purposes.

We collect information about your transactions with us, including transaction history, such as frequency of use and amounts transferred.

In connection with identify verification, fraud prevention and similar security purposes, we collect and/or confirm certain identity-related information, financial background and similar information through third parties sources such as our business customers, government agencies and consumer reporting agencies;

We collect information regarding your online activity as described in the section below titled “INTERNET TECHNOLOGY.”

We may collect personal information otherwise with your consent or as permitted or required by law.

HOW WE USE PERSONAL INFORMATION
Calforex Canada generally uses personal information in the course of its money transfer, payment and related services and products for the following purposes:

Authorizing and processing your transactions, including effecting and administering money transfers and payments and ensuring proper payment to the designated recipient of funds.

Collecting amounts owing to us, and otherwise enforcing and collecting on your accounts or agreements with us. Meeting legal, regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies in Canada, the United States or in other countries. For identity verification purposes, senders and recipients of money transfers or payments may be required to produce valid identification [or consent to verification by other means] before releasing funds.

For marketing and promotional purposes, unless you “opt out” or withdraw consent to this purpose, as described in the section entitled “Offers, Promotions and Opting Out” below.

We maintain business and transaction records for reasonable periods, and generally managing and administering our business. In connection with certain business transactions relating to Calforex business or assets, as further described in the section entitled “Information We Disclose” below. Meeting insurance, audit and processing requirements with your consent or as permitted or required by law.

INFORMATION WE DISCLOSE
We may disclose your personal information to our affiliates and to unaffiliated third parties in connection with the purposes described in this Privacy Statement as follows:

To provide services; in order to process and complete requested money transfers and payments, we may disclose personal information to the recipient of a money transfer or payment, to local Calforex affiliates at the sender’s or receiver’s location, as applicable, to authorized Calforex agents (both at the sender’s and the recipient’s location), and, if applicable, the recipient and any intermediary banks or other financial institutions or financial services companies involved in the transaction or our services.

For marketing purposes; we may disclose personal information to third parties for marketing and promotional purposes, unless you “opt out” or withdraw consent to this disclosure, as described in the section entitled “Offers, Promotions and Opting Out” below.

To service providers; Calforex Canada may transfer personal information to outside agents or service providers (including affiliates of Calforex acting in this capacity) that perform services on our behalf, for example marketing, information technology and/or data hosting or processing services. Some of these service providers or affiliates may be located outside of Canada, including in the United States, and your personal information may be collected, used, disclosed, stored and processed in the United States or elsewhere outside of Canada for the purposes described in this Privacy Statement. We take reasonable measures to ensure that personal information that may be processed by these service providers on our behalf is protected and not used or disclosed for purposes other than as directed by us, subject to legal requirements in Canada, the United States and other foreign countries applicable to Calforex Canada’s affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.

For business transactions; your personal information may be used by Calforex Canada and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets (including, for example, your service account with us), for purposes related to the evaluation and performance of these transactions, including:  permitting such parties to evaluate and determine whether to proceed or continue with the transaction, and fulfilling reporting, inspection or audit requirements or obligations to such parties.

Successors and assigns of Calforex and/or its business or assets may use and disclose your personal information for similar purposes as described in this Privacy Statement.

For Legal, Regulatory, etc. Calforex Canada may disclose your personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws). This may include lawful requirements to disclose personal information to government authorities in Canada and in foreign countries, for example disclosures in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations in Canada or in foreign countries.

OFFERS, PROMOTIONS AND OPTING OUT
Calforex Canada may use your contact details and information about your use of our services (e.g. frequency, value of money transfer, or destination country) for marketing and solicitation purposes to send you various offers, promotions or information about additional products and services of Calforex Canada and our affiliates that may be of interest to you. In addition, Calforex Canada may disclose your contact details to third parties to permit those organizations to offer and provide information about their products and services that may interest you. These third parties may include, as examples:

Calforex Canada’s Affiliates

Authorized Calforex Agents

You may “opt out” or withdraw consent to the use and/or disclosure of your personal information for the purposes described in this section at any time by checking the appropriate box on an online or offline form, if available, or by calling 1-800-769-2025 or otherwise by contacting us as described in “Contact Us” below. If you do not “opt out” or withdraw your consent as described above, we will assume that you consent to our use and disclosure of your personal information for marketing and solicitation purposes as described in this section.

INTERNET TECHNOLOGY
Some of Calforex services (for example money transfers) are made available using online forms at our website, www.calforexedge.ca. Personal information you provide on online forms or by other electronic means will be collected used and disclosed as described generally in this Privacy Statement.

In addition, when visit or use our websites, we collect information about the domain and host from which you access the Internet; your computer’s Internet address; the browser and operating system software you use; the date and time you access our website and the internet address of the site from which you linked to our website when you visit us. We use this information to diagnose, administer and optimize our websites and web-related services.

When registering or creating an account at our websites, we collect your password and login name and other information we may request in order to identify you, maintain security of our website and verify and control access to your account or online profile. If you make inquiries through the e-mail links, forms or other contact methods provided on our websites, these inquiries are forwarded to the relevant office or department, and are used to respond to your inquiry and maintain a record of correspondence.

We use internet technologies like cookies and web beacons to facilitate the services we provide on our websites and your use of our websites, including:

To assist us in providing services to you;

To allow you to change web pages during your visit without having to re-enter your password;

To store your preferences and other information and to track activity on our website;

To better understand the effectiveness of our promotional campaigns;

To determine whether you came to our site from a banner ad or an affiliate website;

To deliver Information specific to your interests on additional websites; and

To determine whether you’ve acted on our promotional messages

A “cookie” is a text file placed on your computer’s hard drive by a web server, which allows for personalization of certain aspects of your visit to that website. “web beacons” are transparent electronic images placed in the web code that collect non-personal data while visiting a web site. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies may limit the performance of Calforex Canada’s Web sites. If cookies are disabled, certain features of our websites may not function properly, and you may not be able to register or use your online account.

Children’s Privacy. Our websites are not directed at children under the age of 13. Calforex Canada does not knowingly collect or maintain personal information at our website from those we actually know are under the age of 13.

External Websites. Our websites may be linked to or from third party websites. These links are provided as a convenience only, and Calforex is not responsible for the content or privacy practices of websites that are linked to or from our website. You are advised to review the privacy policies of any third party websites you visit.

YOU’RE CONSENT
Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes described in this Privacy Statement, if applicable, or otherwise at the time of collection of your personal information.

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).

We may also be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

CONFIDENTIALITY AND SECURITY
We endeavor to maintain physical, electronic and procedural safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Authorized employees, agents, representatives and mandatories that require access to your personal information in order to fulfill their job requirements will have access to your personal information.

No data transmission over the Internet or the telephone can be guaranteed to be perfectly secure, and any personal information you submit to us or access electronically or over the telephone is done at your own risk, and Calforex Canada does not guarantee or warrant the security of information transmitted in these manners. You should be aware that third parties may unlawfully intercept your transmissions or may wrongly instruct you to disclose personal information to them while posing as Calforex and you should exercise caution when providing personal information to any person.

Calforex record retention policies dictate that we maintain information about you, including your opt-out choices, for a fixed time period. If you do not perform another transaction during the fixed time period, your Information, as well as your opt-out choice will be removed. If you perform another transaction or otherwise provide us with personal information thereafter, you will be afforded another opportunity to opt-out. ACCESS AND CORRECTION Calforex may establish and maintain a file of your personal information for the purposes described in this Privacy Statement, which will be accessible at the office of our affiliate, Calforex at 2300, 700 2 St SW Calgary, Alberta T2P 2W2 Canada. If you wish to request access or correction of your personal information in our custody or control, you may write to the mailing address provided below, attention Chief Privacy Officer. Your right to access or correct your personal information is subject to applicable legal restrictions. To protect your privacy and security, we may require additional information to verify your identity when requesting access or correction.

CHANGES
Calforex reserves the right to modify this Privacy Statement from time to time. You can get updated Privacy Statements by calling us at the telephone number listed above or by visiting our website at www.calforexcorp.com. We urge you to review this Privacy Statement frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Statement constitutes your acceptance of any such changes.

CONTACT US
To provide your personal choice or to change account information go to your profile page by clicking here. If you have questions about our privacy practices or Information we maintain about you contact us by clicking here and selecting ‘Consumer Privacy’ from the drop down menu.

We also accept questions by regular mail and by telephone at the locations identified below:

BY MAIL:
2300, 700 2 St SW
Calgary, Alberta T2P 2W2
Canada

BY TELEPHONE:
1-800-769-2025