Western Union Online Limited
My WU Programme – Western Union International Limited

Effective Date: 24 October 2017

Western Union (alternately, “Western Union”, “we”, “us” or “our”) respects your privacy and is committed to complying with this privacy policy (“Privacy Policy”) which describes information we collect about you and how we process your personal information. This includes how we collect, use, and share your personal information and what choices you have regarding our use of your information. This Privacy Policy applies to information collected on our Philippines websites (“Website”), our Philippines mobile application (“Mobile App”), all interactive features, applications, widgets, social networks and social network “tabs”, and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, phone or other technology or any associated content, material, or functionality contained on the Website or Mobile Application and when your information is entered into our point of sale systems as part of a retail transaction (collectively, the “Services” and, together with the Website and the Mobile Application, the “System”). 

This Privacy Policy is incorporated into and is a part of the terms and conditions of the System (“Terms of Use”). By accessing and using the System, you agree that

(i) you have read and understand this Privacy Policy, and

(ii) in exchange for access to or use of the System, you accept and consent to all of the privacy practices described herein. 

INFORMATION WE COLLECT
Western Union collects Information about you from a variety of sources including but not limited to those listed below. You consent to the collection, transfer and storage of this Information by computers or other transfer or storage devices in countries including but not limited to the United States, whose laws on holding personal data may be less stringent.

We collect information when you: visit our Websites, Mobile App, use our System, ask us or one of our affiliated companies, Western Union agents or third-party service providers (collectively "Affiliates") to send or receive money or to provide other products or Services, submit information on applications, money transfer forms or other forms to us or our Affiliates, join our loyalty programme or you otherwise submit information to us, our Affiliates or others. We collect information about your transactions with us, our Affiliates or others. We collect information about you from a variety of third party sources such as our business customers, government authorities and consumer and credit reporting agencies and other suppliers of public information, and from third-party reference sources, vendors and clearinghouse services as part of the verification process or otherwise in connection with your use of the System and Services. We collect computer and mobile device information, such as the domain and host from which you access the Internet, your computer’s IP address,  mobile device geolocation, number and other information from and about your device (such as device properties, settings, applications, stored information, usage and carrier), the browser and operating system software you use, social profile and network information, the date and time you access our Website and Mobile App and the Internet address of the site from which you linked to our website when you visit us. We collect and retain your bank account or payment card details for use for future transactions, as well as other credit and payment history and information, account balances and transaction history. 

Other personal information we may collect includes, without limitation: first and last name, home, business or other physical address, email address, mobile and home telephone number, information about the form of identification used to send or receive a transaction (required by law in some instances and used by Western Union to prevent fraud and loss), relationship to receiver, transaction activity, your occupation and country of birth or residence. We may also collect government identification numbers and copies thereof, such as passport and visa information, driver’s license numbers, and tax identification numbers.

If you elected to subscribe to any online services provided via the System, including the ability to access any password-protected areas of the System, you will be required to submit some personal information for the purposes of verifying your identity and your authority to manage the account. This information will be used by Western Union, our agents, suppliers and third-party service providers for internal use, to grant you access to your account and to respond to your service requests. When submitting information, corresponding, making requests for information, and otherwise interacting with Western Union and its representatives through or in connection with the System, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. If you do not provide the required information, Western Union may be unable to provide you with the requested services. In some instances, you may be asked to provide more information if Western Union determines that more information is necessary to conduct a transaction. 

USE OF INFORMATION

Western Union and our third-party services providers collect and use the information to operate the System and deliver the Services, including to provide certain services and improve the user experience, address System integrity or security issues, and conduct research and analysis to maintain, protect, develop, and improve the System, offer products to you, and, additionally, use any information submitted by users as described below or elsewhere in this Privacy Policy or the Terms of Use. We may send you information that you request from us, promotional materials regarding Western Union or any third-party entity or individual affiliated with individual members of Western Union, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain information to facilitate and otherwise address certain inquiries or requests regarding the Services or the System, or respond to your questions or requests for information about or from Western Union.  We may also use information as necessary to ensure compliance with any Western Union policies and any applicable law, regulation or order. 

Except as set forth in this Privacy Policy, Western Union will not use, disclose, or transfer your information unless: 

  • You expressly authorize us to do so,
  • it is necessary to allow Western Union’s service providers, agents, or other third parties to provide products or services for or to Western Union,
  • it is necessary in order to provide the System or the Services
  • Western Union is sending you other information that may be useful to you,
  • subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on Western Union’s behalf or to other entities with whom Western Union has joint marketing agreements,
  • To store your preferences and other information and to track activity on our website;
  • it is necessary to protect the confidentiality or security of your records,
  • it is necessary in connection with other business purposes including, without limitation, verifying identity, age, and/or payment details, investigating complaints about the System, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution,
  • it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity; 
  • subject to applicable contractual or legal restrictions,
  • it is necessary in connection with a sale of all or substantially all of the assets of Western Union or the merger of Western Union into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Western Union is not the survivor, or
  • it is otherwise necessary for Western Union to disclose it as required or permitted by law.

COOKIES & INTERNET-BASED ADVERTISING

By placing a small file known as a "cookie" on your computer (or other device), Western Union’s and its third party service providers’ servers passively gather information about all visitors' use of the System for several reasons, including, but not limited to, the following: statistics collection and analysis, System optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party service providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the System, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof.  We, and/or our third-party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the System. This data helps us and our third-party service providers improve our respective product and services. 

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly.

GOOGLE ANALYTICS AND WEB BEACONS 

Our Website may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Website and how we can improve them. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to Western Union Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Western Union Website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Western Union Website to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Western Union Website, please review “How Google uses data when you use our partners' sites or apps,” (located here or any successor URL). 

Some of the areas of the System may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Western Union, and its third-party providers or affiliates, to count and track users who have visited certain portions of the System. Web beacons collect only limited information and do not collect any of your personal information.  Specifically, Western Union plans to use a type of web beacon known as a “retargeting pixel,” which will allow users to receive targeted advertising from Western Union via certain social media websites, including Facebook.com.

SHARING YOUR INFORMATION

Subject to your consent where required by law or as otherwise as permitted by law, we may disclose your information we collect to our affiliated legal entities, our agents, third party service providers and others as described below:

• To the Western Union group of companies including but not limited to Western Union International Limited; Western Union Financial Services Inc; Western Union Payment Services Ireland Limited; Western Union Payment Services UK Limited;

• To companies which help us run or improve our business(es) or third-party service providers which help us deliver products and services to you;

• To banks, financial institutions, payment card companies, and credit reference agencies;

• To comply with legal, regulatory, security and processing requirements, national and foreign governmental requirements applicable to us or our Affiliates or service providers, including but not limited to anti-money laundering, counterterrorism or anti-fraud; 

• To organizations which help us process transactions, validate or verify customer information and identification, and to prevent or investigate matters related to security, debt, fraud, theft or loss; 

• In connection with a sale of all or substantially all of the assets of Western Union or the merger of Western Union into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Western Union is not the survivor, and

• As permitted or required by law.

We may disclose information about current and former customers to perform marketing, business analysis and advertising services to unaffiliated companies with whom we have contractual or joint marketing arrangements upon notice that you have provided consent (opt-in) for the use of information for these purposes

CONFIDENTIALITY AND SECURITY
Western Union takes commercially reasonable and appropriate organisational, physical and technical measures to secure and protect information transmitted via or stored on the System. We also endeavor to restrict information access to our employees, agents and representatives only to those that have a legitimate need to access your information. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure. You agree to immediately notify us of any breach of System's security, this Privacy Policy, or the Terms of Use of which you become aware.

ACCURACY OF INFORMATION

If you have created an online account, you may also change your correspondence preferences by logging into your account. You may disable your online account access at any time; however, this will not necessarily result in the deletion of any information. You may request (by contacting us in the manner set out below) details of the information we hold and request us to correct or erase any erroneous or out-of-date information. We reserve the right to independently verify claims made. To protect your privacy, we also will take reasonable steps to verify your identity before making providing details or corrections. Where permitted by law, we reserve the right to assess a service charge for providing you any information in connection with your request.

EXTERNAL WEB SITES
Western Union's Web site may be linked to or from third party Web sites. Western Union is not responsible for the content or privacy practices employed by Web sites that are linked to or from our Web site. 

CHANGES
We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website and the Mobile Applications. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Policy. We expressly reserve the right to make any changes to this Privacy Policy at any time, without prior notice to you. The posted version of this Privacy Policy shall be the Privacy Policy applicable to your access and use of the System on that date, and on each respective date, when you visit the System. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you visited the System. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party other than Western Union.

CONTACT US
If you have any questions or queries about this Privacy Policy or need to report a concern about your personal information, please click on this link: mailto:privacy@westernunion.com.

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

BY MAIL:

Western Union Financial Services, Inc.,

Western Union Privacy Office

12500 East Belford Avenue

Englewood, CO 80112 USA

ATTN: Data Protection Officer

BY EMAIL: privacy@westernunion.com 

BY TELEPHONE: 02 888-1200 (for calls within Metro Manila) or

                           1-800-1-888-1200 (toll-free nationwide via PLDT Lines) or

                           1-800-9-888-1200 (toll-free nationwide via Globe Lines) or

                            +632 888-1200 (for calls from overseas).