Privacy Policy

1. Background

• Machnet Technologies Inc. (MACHNET) provides a Unified Software Platform for domestic and cross border payments solutions. Our privacy policy describes how we collect, store, use, and disclose your user’s Personal Data and protect their privacy when they use the platform. Our platform and our services (hereinafter referred to as the “Services”), as well as our Agreements, describes our roles as a “Data Controller” of such data. By visiting, interacting with our Platform, and/or accessing or using any of our Services, you agree that MACHNET can use such data in accordance with our privacy policy. If our practices and policies change, we will update this Privacy Policy and notify you via email.

• “Customer” means an individual or entity who is eligible to use your money transfer services, and has submitted transaction information required by us and PARTNERS to effectuate the money transfer;
• “Beneficiary” or “Beneficiaries” means an individual or entity to whom a Customer intends to transfer funds using your Money Transfer Services.
• “Money Transfer” or “Money Transfer Services” or “Services” means the money transfer services which you provide to your Customers via the Platform;
• “Customer Funds” means funds paid by customers in order to effectuate a money transfer or payments from the Platform, including the amount to be transferred to a Beneficiary, and any transaction fees or any other service fees;
• “Platform” means the online technology platform designed and developed by MACHNET, including API stacks for front-end user interfaces, back-end transaction management, and reporting systems. The Platform shall also enable you to operate online money transfer services including the “Marketing Program”.

2.Information Collect

• We collect personal information when your users request to send or receive money or to provide other goods or services, provided by telephone, online at your Website, through paper-based forms, or at your agent locations. This personal information may include identities and contact information of senders and recipients (collectively also referred to as “users”) 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 your users submit personal information on applications or other forms to us or our affiliates, including in connection with sending and receiving money transfers, through your enrolment and participation in loyalty programs, and when you provide additional information we may reasonably request for fraud prevention purposes.
• In case the user’s mode of payment is ACH Pull, we collect information relating to the user’s bank account such as account number and routing number which are obtained during the process of the user’s bank account verification. Such bank account verification is completed by the services such as, but not limited to, Plaid Inc in accordance with Plaid Inc’s end-user Privacy Policy (Available at www.plaid.com/legal ). However, in case the user’s mode of payment is Debit Card, we do not collect any information regarding the user’s debit card and such information is directly collected and held by third-party service providers.
• We collect information about your user’s transactions, including transaction history, such as frequency of use and amounts transferred.
• In connection with identity 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 service providers, government agencies, and consumer reporting agencies.

3. Information Use

• Authorizing and processing transactions, including effecting and administering money transfers and payments.
• 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 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 processing the funds.
• For marketing and promotional purposes, unless the user “opt-out” or withdraw consent to this purpose, as described in the section entitled “Offers, Promotions and Opting Out” below.
• Maintaining business and transaction records for reasonable periods, and generally managing and administering our business.
• In connection with certain business transactions relating to you, your business, or assets, as further described in the section entitled “Information Disclose” below.
• Meeting insurance, audit, and processing requirements.
• Otherwise with your consent or as permitted or required by law and our third-party service providers.
• Using user and transaction information as an input mechanism to strengthen our user verification and risk mitigation services to adapt to the dynamic nature of account takeover and fraud transaction attempts in the future.

4. Offers, Promotions, and Opting Out

• In order to process and complete requested money transfers and payments, we may disclose user’s personal information to the recipient of a money transfer or payment, to our local affiliates at the sender’s or receiver’s location, as applicable, to authorized 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.
• Some of our services or programs that you participate in are provided jointly with other third-party business partners, and certain personal information may be disclosed to these third party businesses for the purpose of administering the service or program.
• We may disclose user’s personal information to third parties for marketing and promotional purposes unless the user “opt-out” or withdraw consent to this disclosure, as described in the section entitled “Offers, Promotions and Opting Out” below.
• Our Platform may transfer personal information to outside agents or service providers (including affiliates) that perform services on your behalf, for example, marketing, information technology and/or data hosting, user verification, and risk assessment or processing services. Some of these service providers or affiliates may be located outside of the United States, and user’s personal information may be collected, used, disclosed, stored, and processed in the United States or elsewhere outside of The United States 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 the United States and other foreign countries applicable to us, affiliates, agents and service providers, for example, lawful requirements to disclose personal information to government authorities in those countries.
• User’s personal information may be used by our Platform and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment, or other disposals 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 our Platform and/or our business or assets may use and disclose user’s personal information for similar purposes as described in this Privacy Statement.
• Our Platform may disclose user’s 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 the United States and foreign laws). This may include lawful requirements to disclose user’s personal information to government authorities in the United States 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 the United States or in foreign countries.

5. 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 mandataries that require access to user’s 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 users submit or access electronically or over the telephone is done at your own risk, and our Platform 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 this our Platform and you should exercise caution when providing user’s personal information to any person. Our Platform’s record retention policies dictate that we maintain information about you, users, including user’s opt-out choices, for a fixed time period. If users do not perform another transaction during the fixed time period, the user’s information, as well as their opt-out choice will be removed. If users perform another transaction or otherwise provide us with personal information thereafter, users will be afforded another opportunity to opt-out.

6. Changes

• Our Platform reserves the right to modify this Privacy Statement from time to time. You can get updated Privacy Statements by emailing us at help@machnetinc.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.