Top Connect Limited is strongly committed to protecting your privacy and complying with your choices. Both personal and non-personal information collected is safeguarded according to the highest privacy and data protection standards adopted worldwide. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles.
Money Transfer Services from USA. Top Connect Ltd partners with Golden Money Transfer, Inc. to offer money transfer services form USA. By using or attempting the use of Top Connect money transfer service from USA,
You the user are authorizing us to share your identity and personal information with Golden Money Transfer Inc, a company having registered at 45 Prospect Street, Suite 201, Cambridge, MA 02139 (“GMT”) and the person or entity accepting this Agreement (“User”) as of the date on which it is accepted by the User (the “Effective Date”). You are also agreeing to the terms of GMT’s privacy policy. It is your responsibility to make sure data you provide us is accurate and complete, which is necessary for Golden Money Transfer Inc, to process money transfers on your behalf. GMT’s terms may be modified from time to time, and the governing versions are incorporated by reference into this privacy.
The privacy policy set out below along with any forms, receipts, acknowledgements, or other documentation completed or used in connection with User use of GMT services, including any pre-transaction or post-transaction disclosures, constitute the entire agreement between User and GMT (the “Agreement”).
At Golden Money Transfer, Inc. (“GMT” “Company”, “we”, “us”, “our”), we are committed to protecting your personal data and respecting your privacy. In this Privacy Policy, which applies to anyone using our service or otherwise interacting with GMT via the GMT mobile application and/or website (the “App” and “Website”), we describe how we collect and process your personal data. The Privacy Policy describes your rights towards us and how to exercise them. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@gmtnorthamerica.com.
We appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website or any website offered via our Affiliates), as well as, any related services through www.gmtnorthamerica.com.
REPRESENTATION
- The service (this website) is powered and hosted by GMT. During the registration in the website, you are registering with GMT.
- Your funds are controlled at all times by GMT. The funds for your money transfer will be deducted and processed by GMT.
- The website is being operated by Affiliate who is an authorized marketing affiliate of this service. Affiliate does NOT at any point of time hold your funds in its account or wallet including your personal information.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
INFORMATION WE COLLECT
This website 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 that you voluntarily provide to us when you express an interest in obtaining information about us or our Products and Services, when you participate in activities on the Website or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:
A. Personal Information Provided by You. We may collect names; phone numbers; email addresses; mailing addresses; job titles; usernames; passwords; billing addresses; contact or authentication data; contact preferences; debit/credit card numbers; source of funds (description of document); copy of identification (document); unique governmental identification number; IP address; place of birth; date of birth; full residential address; transaction: origin currency; transaction: original payment method (description only); transaction: destination currency; transaction: service type; transaction: net amount; transaction fees (can be $0.00); transaction: exchange rate; transaction: receiving amount; beneficiary: full name, address and county; beneficiary: bank, bank code, account number and account type.; and other similar information.
B. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. - We collect personal information when you submit personal information on applications or other forms to us or 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.
- In case your mode of payment is ACH Pull, we collect information relating to your bank account such as account number and routing number which are obtained during the process of your bank account verification. Such bank account verification is completed by GMT using the services of its partner viz. Plaid Inc in accordance with Plaid Inc’s end user Privacy Policy (Available at www.plaid.com/legal)
- We collect information about your transactions with us, 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 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
This website 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 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.
- Maintaining business and transaction records for reasonable periods, and generally managing and administering our business.
- In connection with certain business transactions relating to GMT, its business or assets, as further described in the section entitled “Information We Disclose” below.
- Meeting insurance, audit and processing requirements.
- Otherwise with your consent or as permitted or required by law.
INFORMATION WE DISCLOSE
We may disclose your personal information to our affiliates including Affiliate 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 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.
- Business Partners. 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.
- 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.
- Service Providers. This website may transfer personal information to outside agents or service providers (including affiliates of GOLDEN MONEY TRANSFER like Affiliate 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 in the United States, and your 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 this website, affiliates, agents and service providers, for example lawful requirements to disclose personal information to government authorities in those countries.
- Business Transactions. Your personal information may be used by this website 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 this website and/or its business or assets may use and disclose your personal information for similar purposes as described in this Privacy Statement.
- Legal, Regulatory, etc. Legal, Regulatory, etc. this website 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 the United States and foreign laws). This may include lawful requirements to disclose 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.
More specifically, we may need to process your data or share your personal information in the following situations:
▪ Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
▪ Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
▪ Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
▪ Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
OFFERS, PROMOTIONS AND OPTING OUT
This website 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 offers, promotions or information about additional products and services of this website and our affiliates that may be of interest to you. In addition, this website 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:
- GMT Affiliates including Affiliate
- This website
- Authorized GMT agents
- Financial services companies, such as banks, credit card companies, brokerage houses, mortgage lenders and mortgage originators
- Non-financial companies such as retailers, home furnishers, clothing stores, catalogue companies, florists, direct marketers, telephone companies, airlines, publishers and other providers of goods and services.
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 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.
DELETION OF ACCOUNT
Upon your request for deletion of your account, we will process the request and delete your account along with all of your records and information regarding your identification and transactions. In accordance with Federal and State regulations pertaining to money transfers, we will retain your records in archive to adhere with our record keeping obligations. We will only utilize the archive for limited purpose such as to fulfil our regulatory obligations or to adhere to any request from a regulatory body having jurisdiction over our activities.
INTERNET TECHNOLOGY
Some of this website services (for example money transfers) are made available using online forms at this website. 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 you visit or use this Web site, 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 this Web site and the Internet address of the site from which you linked to this Web site when you visit us. We use this information to diagnose, administer and optimize this Web sites and web-related services.
When registering or creating an account at this Web sites, we collect your password and login name and other information we may request in order to identify you, maintain security of this Web site 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 this Web sites, 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 this Web site and your use of this Web sites, 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 Affiliate Web site;
- To deliver Information specific to your interests on additional web sites; 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 Web site. “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 this website. If cookies are disabled, certain features of our Web sites may not function properly, and you may not be able to register or use your online account.
Children’s Privacy. This Websites are not directed at children under the age of 13. This website does not knowingly collect or maintain personal information at our Web site from those we actually know are under the age of 13.
External Web sites. This Website may be linked to or from third party Websites. These links are provided as a convenience only, and this website is not responsible for the content or privacy practices of Websites that are linked to or from this Website. You are advised to review the privacy policies of any third party Websites you visit.
YOUR CONSENT
- Generally, by providing us with your information including personal and bank account related 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. In using this service, you also consent to entering your bank account related information (e.g. internet banking credentials and MFA responses) in order to enable GMT and its partners to verify the ownership of such bank accounts. Such verification will be completed by GMT using the services of its partner viz. Plaid Inc. You accept the terms and conditions of Plaid Inc. as mentioned in its end user Privacy Policy (Available at www.plaid.com/legal)
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 The United States 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 mandataries 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 this website 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 website and you should exercise caution when providing personal information to any person.
This website 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.
HOW LONG DO WE KEEP YOUR INFORMATION?
Personal Data is used for different purposes and is subject to different standards and regulations. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
ACCESS AND CORRECTION
This website 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 in the Contact Us section below. 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.
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. We may share your personal information for our everyday business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. We may also share personal information as stated above in Section 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE? You may not limit sharing of this information. GMT does not share any personal information for marketing purposes. Certain states may have additional rights. To contact Us related to this matter you can email us at info@gmtnorthamerica.com.
CHANGES
This website 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 this website. 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.
Golden Money Transfer, Inc.
45 Prospect Street, Suite 201
Cambridge, MA 02139
Email: info@gmtnorthamerica.com
Phone Number: 1-888-702-5656
We will respond to your request within 30 days.
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
While the California Consumer Privacy Act of 2018 (“CCPA”) generally applies to Personal Information that identifies, relates to, or could reasonably be linked with a particular California resident, it may not apply to certain Personal Information that is subject to the Gramm-Leach-Bliley Act (“GLBA”). GMT is subject to GLBA as a provider of money transfer services, as such certain Personal Information will not be subject to CCPA.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category | Examples | Collected |
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information | YES |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | YES |
| D. Commercial information | Transaction information, purchase history, financial details and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements | NO |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | YES |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
▪ Receiving help through our customer support channels;
▪ Participation in customer surveys or contests; and
▪ Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@gmtnorthamerica.com, by calling toll-free at 1-888-702-5656, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.
Golden Money Transfer Inc. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
▪ Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.
▪ Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.
▪ Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
▪ Category D. Commercial information, such as transaction information, purchase history, financial details and payment information.
▪ Category G. Geolocation data, such as device location.
▪ Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.
▪ Category K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “Section 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE.”
Your rights with respect to your personal data:
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, including but not limited to the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed – Request to know
Depending on the circumstances, you have a right to know:
▪ whether we collect and use your personal information;
▪ the categories of personal information that we collect;
▪ the purposes for which the collected personal information is used;
▪ whether we sell your personal information to third parties;
▪ the categories of personal information that we sold or disclosed for a business purpose;
▪ the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
▪ the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
▪ you may object to the processing of your personal data.
▪ you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
▪ you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
▪ you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at info@gmtnorthamerica.com, by calling toll-free at 1-888-702-5656, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.