TRANSCASH SOLUTION INC. (TCS) PRIVACY NOTICE
1- Processing of Personal Data
This Privacy Notice explains how we process personal data ("Personal Data") when you use our services, including when you browse our website or mobile application ("Website/App"), conduct a transaction with us or visit our stores ("Services"), whether as a customer, visitor and/or user of our Website/App, or however you might interact with us (collectively, "you", "your" or "users"). In this Privacy Notice, we also describe how we use Personal Data and the mechanisms we have put in place to protect data.
It is very important that you regularly review this Privacy Notice and check for updates on the Website/App, as local law may sometimes require us to provide additional details in this Privacy Notice. Updates to this Privacy Notice will be posted on our Website/App, and by continuing to deal with us, you agree to this Privacy Notice and any future changes.
You can always contact us (Transcash Solution Inc.) regarding personal data by email: contact@transcashsolution.com,by phone 514-552-8630. We collect personal data necessary to provide you with a service, for contractual purposes, and to comply with applicable legislation. We retain personal data for as long as necessary or as required by applicable law. We share personal data with other company partners, legal authorities, and when necessary to meet legal requirements or contractual commitments to the company. When the collection of personal data is based on your consent, you can withdraw it at any time. TCS does not "sell" or "share" personal data, as these terms are defined in applicable law. We strive to store personal data in secure locations, with strict security measures. We take all necessary measures to comply with legal obligations and ensure an adequate level of security. We retain personal data for as long as reasonably necessary to provide the services and comply with our legal obligations.
2- Sources of data collection
TCS collects personal data from the following sources: by yourself, through our application, our website, advertising networks, social media, data analysis and service providers, government databases.
We collect personal data from you, which may include name, email address, telephone and/or fax numbers, residential and/or business address and other contact data ("contact details"), title, date of birth, gender, images, videos or signature.
3- Contractual Obligation
In order to provide customer service and record customer instructions, we will monitor and record (by automated means or transcriptions) our telephone calls, emails and chat conversations with you. We will use transcripts of these calls to confirm the instructions provided to us.
To manage your account(s) (i.e., registration, administration, maintenance, and servicing accounts).
To measure and evaluate your behavior using automated processing in order to provide you with a more personalized service.
Your participation in events or competitions: You may wish to participate in events organized by us or in a specific competition.
4- Retention of correspondence
To meet our legal record-keeping obligations, we retain correspondence, including emails, faxes, and any other type of electronic communication, as well as all documents relating to the customer's account. We also retain customer service letters and other communications between us and any company, as well as our partners and service providers.
In very limited circumstances, to conduct a credit check to verify the identity of the individual as part of KYC (Know Your Customer) activities to provide the services.
5- Financial Data and Professional or Employment-Related Information
We collect your personal financial data when you register to use our services. We collect financial data such as bank account information, payment card information, financial statements, reason for transfer, occupation (professional or employment-related information)
or other documentation evidencing the source of the funds you wish to transfer (such as payslips), in order to provide you with our services.
TCS will never ask you to provide your payment information (i.e., credit/debit card details) directly to an employee or agent. When payment information is required, TCS will ask the customer to enter it directly into the payment processing system.
You can always ask questions regarding TCS's processing of your financial information.
6- Behavioral and Technical Information
IP address, internet or other similar network, browsing or search activity, behavioral information (to understand how you behave when using our products and services), browser type and version, time zone setting, screen resolution settings, browser plug-in types and versions, operating system and platform.
- Performing analytics to measure the use of our website and services, including the number of visits, average time spent on the website/app, pages viewed, page interaction data (such as scrolling, clicks, and mouseovers), etc. and improve the content we offer you.
7- Verify and maintain the quality of the service.
- Undertake activities to verify or maintain the quality of the Service, and to improve, upgrade, or enhance it, including to administer the Website/App and for internal operations, including troubleshooting, data analysis, testing, research, statistics, and surveys.
- We collect information about your location when you use our Services.
- We provide the Services to our customers with a personalized experience on the App based on their location, such as displaying the local currency in the relevant location, including using the device's location to identify pickup locations and audio and video monitoring, image, video, and audio and voice recordings.
8- Security of Our Services
- In order to ensure the security of our Services, we may use CCTV to ensure the safety of customers in our stores or offices.
- We may collect Personal Data such as recipient contact information, bank account information, contact details, money send destination, and banking preferences. Depending on local regulations, we collect information such as occupation (professional or employment-related information), relationship to the recipient, reason for transfer, and additional documentation to prove the source of funds.
- To provide the Services, including to complete a transaction and for transaction-related compliance purposes, when strictly necessary, we may use sensitive or special personal data ("Sensitive Personal Data") to provide the Services and comply with our legal obligations. We may collect the following categories of Sensitive Personal Data: unique biometric information or identifiers (e.g., facial geometry and derived information); government identifiers (e.g., driver's license, state ID, or passport number); health information. If required by applicable law, we will obtain your consent or provide you with an opportunity to opt out of the processing of your sensitive personal data. We do not "sell" or "share" sensitive personal data, as those terms are defined by applicable law. We only use and disclose sensitive personal data for purposes permitted by applicable law. We retain sensitive personal data for as long as reasonably necessary to provide the services and comply with our legal obligations.
- We may use personal data to fulfill legal obligations, including for KYC (Know Your Customer) purposes, for security and fraud prevention purposes, and to verify your identification when you use our services.
- The personal data collected from you may vary depending on the country in which our services are offered. Not all of the data categories described above may apply to you. If you have any questions about the processing of your personal data, you can contact us at the following address: contact@transcashsolution.com
9- Use of Your Device
- When you use the app and to improve the usability, features, and your experience when using our app, we may need to access certain additional information and features from your device, such as your contact list. Before accessing this information, we will ask for your permission.
All data obtained by using these device features will be stored only on your device, never on our server or elsewhere.
- You can always choose to add your contacts' information by connecting your contacts from your device or your social media accounts to our app. If you choose to share your contacts with us, we will, in accordance with your instructions, access your contacts' information and store it in our app to make it easier to send money to your loved ones. Learn more about how we collect information about your contacts, how we use this information, and the controls available to you.
- When you allow the app to access your device's address book (contact list), the app downloads their names and phone numbers to your contact list within the app. This way, once you select a recipient, you can select a person from your contact list without having to include all their information digit by digit.
- You know, we will only access your device's contact list if you give us your consent. You can give us access during the registration process or anytime after creating your account in the settings option. If after allowing the app to access your contact list, you change your mind, you can always delete your contact list from the app. Please remember that the imported list of your contact details will never leave your phone and we will never store a copy of this data on our servers.
10- Biometric Data and KYC
We are legally required to verify your identity through a process known as KYC (Know Your Customer)(Know Your Customer) to uniquely identify you and prevent money laundering, terrorist financing, and fraud schemes, as required by anti-money laundering legislation. We will ask you to provide a valid photo ID, a video recording, and/or a selfie during the onboarding process when you sign up for TCS's online services on the TCS mobile app or web application. You will be asked to provide them directly on our service providers' platforms. This process and information help us identify suspicious activities. It also allows us to provide you with a better service.
- If we ask you: the selfie, video recording, and derived data such as the facial scan template may be considered biometric data or biometric information by the local legislation of the jurisdiction in which we operate. Depending on the country you live in, we may ask you to consent to providing us with your biometric data.
If you refuse to consent to the collection of your biometric data, you cannot use our service.
- We share biometric information with our service providers as part of legal and contractual obligations. Neither TCS nor our service providers sell, rent, or trade your biometric information. All providers with access to this data are contractually required to maintain security standards to ensure that your biometric information is secure and that the service provider will not use the data for any other purpose. This includes preventing unauthorized parties from accessing this data.
- Subject to applicable privacy legislation, your personal data protection rights also extend to biometric data, including the right to access this data.
Please contact us by email or telephone regarding our KYC process and the use of your biometric data, if you have any questions regarding this Data Privacy Notice.
- It is important to know that if you use our services in one of our stores, the KYC procedure may be different and the agent or one of our employees will ensure that the ID you provide matches your identity.
- When you use our signature pads in our stores or at an agent, we only collect the image of your signature as it appears on the signature pad, and no biometric data is collected.
11- Personal data of a beneficiary
As a beneficiary, we collect your personal data from our customers because it is essential for the performance of a contract between TCS and our customer. You are the person who will benefit from the payment transaction initiated by our customer.
Voici les types de données personnelles que nous pouvons obtenir à votre sujet sont les suivants :
Informations personnelles d'identification ; Données transactionnelles ; Données financières ;
La base juridique du traitement des données à caractère personnel d'un bénéficiaire est notre intérêt légitime à remplir nos obligations liées à la relation contractuelle que nous avons avec notre client.
A beneficiary's personal data is only processed to ensure the correct remittance service is identified and is not used for any other purpose. The same security measures are implemented to protect the personal data of both beneficiaries and customers.
If you have any questions regarding the processing of your personal data as a beneficiary, you can contact us at: contact@transcashsolution.com.
- We may obtain your personal data from other federal, state, or local government organizations to comply with local regulations and to ensure that our KYC mechanism is accurate and that we can provide you with the safest service.
- Personal data collected from third parties is processed only for identification purposes. We may verify the personal data you have provided to us with our third parties to ensure that your identity matches the information you have provided to us. The legal basis for this processing is our legal obligation and our legitimate interest.
- In the event that we process additional data obtained from a third party, we will inform you as soon as possible and obtain your consent if required by applicable law.
12- Updating your personal data
- It is important for us to commit to keeping your personal data accurate and up to date. We take reasonable steps to ensure the accuracy of your personal data by ensuring that the latest personal data we have received is recorded accurately and, when deemed necessary, we carry out periodic checks and ask you to update your personal data. From time to time, we may send you an email asking you to update your personal data.
It is our legal and legitimate obligation to maintain accurate and up-to-date information. If you find that your personal data is inaccurate, you can request a correction or update of your information by sending an email to contact@transcashsolution.com.
- Our main objectives in using machine learning within TCS is to support the digital KYC verification process required by anti-money laundering legislation. The biometric information you have uploaded is analyzed to determine whether the person who wishes to register for TCS's services is the same as the one appearing in the identification documents. The technology scans the images, translates them into computer language, i.e., into templates, and compares them with each other and with a database of other images. The technology approves or rejects the images as being those of the same person.
-We retain personal data for as long as necessary to provide the services requested by customers and to comply with applicable legal, accounting, or reporting obligations. The retention period is determined based on applicable requirements and obligations, which may include:
- Legal and regulatory requirements: Your personal data is retained for as long as necessary to comply with all of our legal obligations, including, but not limited to, commercial, tax, and anti-money laundering laws and regulations. We retain your personal data only to comply with our legal obligations; your personal data will be restricted so that it cannot be used for any other purpose. When restricted, it will only be accessible on a need-to-know basis. When we receive a deletion request, we also retain your personal data in accordance with our legal obligations.
13- Fraud Prevention
- TCS has developed its own machine learning methods to support its overall regulatory compliance efforts, such as identifying instances of transaction fraud. This analysis is intended to ensure we can provide you with the requested services and to comply with our legal obligations, in order to prevent money laundering and terrorist financing. The process involves analyzing transaction data and assigning values to specific pieces of information. These values are passed to the machine learning model to determine whether the transaction is likely to be fraudulent.
- All information collected through our machine learning process will only be used for legal purposes and will never be used for any other purpose. For more information on TCS's use of machine learning technology, please contact us at: contact@transcashsolution.com.
- When we use your personal data to pursue our interests, we strive to ensure that your personal data is only used within the limits permitted by law.
14- Disclosure and Sharing of Data
- Upon request from legal and regulatory authorities, we may disclose and share your personal data, including sensitive personal data, to enforce or apply our terms and conditions or any other agreement or arrangement we may have with you.
- We may share your personal data with strategic partners, professionals, advisors, lawyers, consultants, auditors for the purpose of providing services to you and to comply with our legal obligations, contractual obligations, and best practices, for example: Identification Data, transactional data, financial details, video surveillance.
15- Services to minors
- Our services are prohibited for minors under the age of 18, and we do not collect their personal data. We ask that you do not use the website/app or our offers and do not share any personal data with us. If anyone becomes aware that a person under the age of 18 has unlawfully provided us with personal data, please contact us at this email address: contact@transcashsolution.com
16- Data Security
We strive to protect your personal data and have implemented appropriate security systems to prevent any loss, misuse, and alteration of the information you have entrusted to us. At TCS, we will always strive to ensure that your personal data is well protected, in accordance with international best practices. We maintain this commitment to data security by implementing appropriate physical, electronic, and managerial measures to safeguard and secure your personal information.To protect our systems from illegal access, we use secure and state-of-the-art physical and organizational security measures that are continually improved to ensure the highest level of security in accordance with international best practices and cost-effectiveness. All personal data is stored in a secure location, protected by firewalls and other sophisticated security mechanisms, with limited administrative access. Personnel who have access to your personal data as well as to the processing activities of your personal data are contractually bound to maintain the confidentiality of your data and to adhere to the privacy policy we have implemented within our organization.
Our goal is to achieve the highest level of data protection by adopting industry-standard measures to protect your privacy. We are not responsible for your personal data in the event of a problem occurring on our internet platform.
- Sometimes we may use automated decision-making and profiling if permitted by law and necessary for the performance of a contract, to provide you with personalized information about our products and services. We analyze data to send you appropriate communications and advertising, including invitations to exclusive customer events that may be of interest to you, as well as recommendations for products and services that we believe may be suitable for you, for example, for money transfer services.
- We also make automated decisions in processes such as monitoring transactions to combat fraud in accordance with legal requirements related to the prevention of money laundering, terrorist financing, and financial services. Depending on where you live, you may have the right to request not to be subject to fully automated decision-making, including profiling, if such decision-making has legal effects or similarly significantly affects you.
This right may not apply if the decision-making is necessary to enter into or perform an agreement with you, if the decision-making is permitted by applicable data protection laws, or if we have received your explicit consent.
- We may contact you from time to time by email, SMS, letter, or telephone if necessary to provide you with targeted marketing about our services and/or products. You can always ask us to remove you from the list of emails, SMS, letter, or telephone calls by this email address: contact@transcashsolution.com.
- We may collect personal data for the TCS reward program. You can request to remove yourself from the reward program list at any time, to report suspicious or unauthorized activity on your account, or to edit your profile.
- You have the right: regarding personal data depending on your place of residence under applicable law, to know what personal data is collected, sold or shared and to whom, to request access to a copy of your personal data, to request the correction of inaccuracies in your personal data, to request the erasure of your personal data under certain conditions, to object to the processing of personal data for the purpose of targeted advertising, to object to the processing of personal data for the purpose of targeted advertising, to object to the processing of sensitive personal data,
to object to the processing of personal data for profiling purposes in the context of decisions producing legal or similarly significant effects for the data subject, to limit the use and disclosure of sensitive personal data to specifically authorized purposes, to restrict processing where certain conditions apply,to receive the personal data in a structured, commonly used and machine-readable format, to transmit the personal data to another controller under certain conditions, to object to the processing of personal data for marketing purposes, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects for the individual.
- You can send an email to contact@transcashsolution.com to exercise any of your rights. In order to protect your privacy and maintain security, we will take all necessary steps to verify your identity and ask you to provide further details before granting you access to your personal data or undertaking the modification of any personal data. In case we do not have a copy of your ID or any valid legal document proving your identity, we may not be able to respond to your request.
- You should be aware that some rights may not be applicable due to business necessity or legal obligations in providing the service.
- Your rights may be limited to comply with other legal obligations such as anti-money laundering obligations, contractual obligations, and compliance obligations. However, you will always be responded to when you exercise any of the above rights and/or any other rights you may have depending on your jurisdiction. If your right cannot be exercised, you will always receive an appropriate explanation.
- If you have a complaint regarding the processing of your personal data, you can always contact us at the following address: contact@transcashsolution.com
- Depending on applicable privacy legislation, you may have the right to lodge a complaint with a data protection authority or other regulatory body if you believe that we have not complied with our obligations under this Privacy Notice or applicable legislation.
17- Transcash Solution Inc. (TCS) is a money transfer company based in Canada in the province of Quebec, working in conjunction with agents and sub-agents in other countries to provide good service to customers. For all communications, please contact us by email: contact@transcashsolution.com. This privacy notice may be updated without prior notice.
18- Applicable Law and Jurisdiction
This Agreement and its interpretation are subject to the laws of the province of Quebec and the laws of Canada applicable therein, without giving effect to any principles of conflicts of law. The Parties shall irrevocably submit all disputes arising out of this Agreement to the courts of the district of Montreal, province of Quebec, including disputes concerning the interpretation of the Agreement and its effects.