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California Resident Privacy Notice

Western Union cares about the privacy of our California consumers and is committed to collecting, using, storing, protecting, disclosing and sharing your personal information in accordance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). This California Resident Privacy Notice (“California Notice”) is applicable to residents of California and, in conjunction with the Global Privacy Statement, is intended to address the requirements of the CCPA.

This notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals but does apply to personal information collected in the context of business-to-business (B2B) transactions.

Notice of Collection

This California Notice applies to “personal information” that we collect, meaning information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, or household (“Personal Information”). Personal Information under this California Notice does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We collect Personal Information to deliver the products and services you request, to save you time and money, to enhance your experience, and to support our business operations.

 

Categories of Personal Information Collected

In the 12 months prior to the most recent update of this California Notice, Western Union may have collected or received the Personal Information and Sensitive Personal Information (SPI) categories listed below. Not all categories of information will be collected for each individual.

Identifiers: Such as your name, postal address, e-mail address, and telephone number; social profile and network information; IP address; device identifier; mobile ad identifier; cookies; beacons; and pixel tags.

Device Information and Online Activity: Such as device and online identifiers, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information.

Biometric Information: Biometric information such as face geometry, voice prints, or fingerprints.

Commercial Information: Such as Transaction history information, credit or debit card numbers, and financial account numbers.

Communications: Communication details (such as the content of emails, text messages, or other communications), and call logs, where Western Union is a party to the exchange.

Demographic Information: Demographic information, such as age, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information.

Geolocation: Location information, such as geolocation information.

Sensitive Personal Information: Government-issued identifiers (such as social security, driver’s license, state identification card, or passport number), account log-in and financial information (such as payment card details), and precise geolocation.

Preferences and Inferences: Individual preferences and characteristics, such as inferences related to transfer patterns and behaviors, and aptitudes.

Sources of Personal Information

Western Union may have collected Personal Information about you from the following Categories of Sources:

  • You:we may collect information directly from you, for example, through transaction forms and your interactions with Western Union Agents and partners or through providing customer support or consultation, including using email, postal mail, call centers or live chat;
  • A device associated with you or your household:we may collect information from you or your device through your use of our Website or mobile applications, including online forms, registrations for loyalty and rewards programs or competitions, and other online Services we offer (some of which may be managed by third parties on behalf of Western Union) or through automated means such as communications protocols, e-mail communications and cookies or similar technologies as described in the Global Privacy Statement section titled “INTERNET TECHNOLOGIES”;
  • Affiliates, Subsidiaries or Vendors:we may collect information about you from our affiliates, subsidiaries, or vendors who provide services on our behalf;
  • Social Media Networks or Publicly Available Sources:we may collect information about you from social media or other public data sources; and
  • Advertising Networks:we may collect information about you from advertising networks so that we and/or other advertisers can serve you with advertisements which we believe may be of interest to you.

 

Purpose for Collecting Personal Information

Western Union may use your personal information for the purposes described in How Western Union Uses the Personal Information It Collects section of the Global Privacy Statement and as set for the below:

  • Auditing: related to our interactions with you and any concurrent transactions, including, but not limited to, counting ad impressions, verifying positioning and quality of ad impressions, and auditing compliance with applicable standards;
  • Security Purposes:detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging/Site Performance:debugging to identify and repair errors that impair the intended functionality of our systems or to improve the functionality of our systems;
  • Legal Obligations: to fulfill our legal obligations or conduct legal functions;
  • Short-term use:short term, transient use, including, but not limited to, for the contextual customization of ads shown as part of your interactions with us;
  • Performing the Services:in addition to the purposes described in the Global Privacy Statement, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
  • Internal R&D:undertaking internal research for technological development and demonstration; and
  • Quality Purposes:undertaking activities to verify or maintain the quality or safety of the our services and to improve, upgrade, or enhance our services.

Sale or Sharing of Personal Information

Western Union may sell or share Personal Information with third parties for various purposes including cross-context behavioral advertising or sharing among Western Union affiliates. These kinds of disclosures may be deemed selling or sharing Personal Information under California law, and you have the right to opt out of these disclosures. We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the last update of this California Notice) the following categories of Personal Information to the following categories of third parties:

 

Personal Information CategoryCategories of Third Parties with whom we may share your Personal Information
Identifiers∙   Service providers
·   Advertising and social networks
·   Data analytics providers
·   Our affiliates and subsidiaries
Device Information and Online Activity·   Service providers
·   Advertising and social networks
·   Data analytics providers
·   Our affiliates and subsidiaries
Commercial Information:·   Service providers
·   Advertising and social networks
·   Data analytics providers
·   Our affiliates and subsidiaries
Demographic Information:·   Service providers
·   Advertising and social networks
·   Data analytics providers
·   Our affiliates and subsidiaries
Geolocation·  Advertising and social networks
·  Data analytics providers
Preferences and Inferences·  Advertising and social networks
·  Data analytics providers

 

 

Western Union does not knowingly collect, sell or share (for cross-context behavioral advertising) the Personal Information of consumers under 16 years of age. For more information about Western Union’s marketing practices as they may relate to minors, please see the Global Privacy Statement.

To exercise your right to opt-out of the sale of your Personal Information, please follow this link: https://wuprod.service-now.com/wu_privacy or submit a Personal Information request as described above in the section of our Global Privacy Statement entitled Accessing, Deleting And Correcting Your Personal Information And Changing Your Choices.

 

Categories of Personal Information for Business Purposes

During the 12-month period prior to the Last Updated date of this California Notice, we may have disclosed your Personal Information with certain categories of third parties as described in the Who Western Union Shares Your Personal Information With  section of the Global Privacy Statement. The categories that may have been disclosed are:

  • Identifiers
  • Demographic information
  • Device Information and Online Activity
  • Commercial Information
  • Preferences and Inferences
  • Geolocation information
  • Biometric information
  • Sensitive Personal Information under California law

Retention of Your Personal Information?

We will keep the Personal Information we collect about you for as long as necessary to carry out the purposes set forth in the Global Privacy Statement and this California Notice, or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Western Union policy. We dispose of the information we collect in accordance with Western Union’s retention policies and procedures.

Your California Privacy Rights

As a California resident, you can make certain requests regarding your Personal Information, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

As stated in more detail below, you can request that we:

  1. Provide you with access to a copy of and certain details regarding the Personal Information we have about you.
  2. Delete your Personal Information.
  3. Stop selling your Personal Information or sharing your Personal Information for cross-context behavioral advertising.
  4. Correct your inaccurate Personal Information.
  5. Limit the use or disclosure of your sensitive Personal Information (SPI).

To exercise these rights, please follow this link Rights Requests or submit a personal information request as described above in the section of our Global Privacy Statement entitled “ACCESSING, DELETING AND CORRECTING YOUR PERSONAL INFORMATION AND CHANGING YOUR CHOICES”.

  1. Right to Know: You have the right to request access to the Personal Information we may have collected about you. To access your Personal Information, please follow this link: Rights Requests. Requests to access your Personal Information may be submitted up to two times in a rolling twelve-month period. In response, we will return to you the following categories of information, to the extent required by law:
  • The categories of Personal Information we have collected about you.
  • The categories of sources from which we collect your Personal Information.
  • The business or commercial purpose for collecting, selling, or sharing your Personal Information.
  • The categories of third parties to whom we disclose Personal Information.
  • The specific pieces of Personal Information we have collected about you.
  • A list of categories of Personal Information that we have sold or shared for cross-context behavioral advertising, along with the categories of third parties we sold it to or shared it with for cross-context behavioral advertising.
  • A list of categories of Personal Information that we have disclosed for a business purpose, along with the categories of third parties we disclosed it to.
  1. Right to Delete: You have the right to ask that we delete your Personal Information. Once we receive a request, we will delete the Personal Information (to the extent required by law) we hold about you as of the date of your request from our records. Choosing to delete your Personal Information may impact your ability to use our websites or applications, including closure of online accounts and if applicable, your loyalty account, and may limit use of retail location functionality that requires your Personal Information. To delete your Personal Information, please follow this link:  Rights Requests.
  2. Right to Stop Selling or Sharing: Western Union does not sell your Personal Information to third parties in exchange for money.  Western Union does participate in advertising, marketing and analytic programs from which we and third parties with whom we contract may derive value; such exchanges may constitute a “sale” under applicable law. You have the right to opt-out of the sale of your Personal Information or sharing of your Personal Information for cross-context behavioral advertising and can request that we stop by clicking this link: Rights Requests. After opting out of the sale of your Personal Information or sharing of your Personal Information for cross-context behavioral advertising, you may still receive ads from Western Union; however they will not be tailored to you.
  3. Right to Correct: You have the right to ask that we correct the Personal Information that we may have collected about you if that information is inaccurate. In processing such requests, we reserve the right to request identifying documentation from you, as permitted by law. To correct your Personal Information, please follow this link: Rights Requests.
  4. Right to Limit the Use and Disclosure of SPIYou have the right to ask that we limit our use and disclosure of your SPI to certain purposes permitted by law, to do so please follow this link: Rights Requests.

We will not discriminate against you for exercising your rights. If you choose to exercise your rights, we will not deny you services (unless you have requested that we delete certain data necessary for providing the services), charge different prices or rates, provide a different level of service or suggest that you might receive a different price or level of quality for services. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

Verifying Your Identity to Complete Your Rights Requests:

If you request access to, or the correction or deletion of, your Personal Information, we will, as a matter of security, verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

  • First name
  • Last name
  • Address
  • Email address
  • Phone number
  • Some form of government issued ID

You may be asked to log into your online account and complete a one-time passcode validation. In the event that additional documentation is necessary to verify your identity, we will notify you directly.

What If We Can’t Verify Your Identity?
If we can’t verify your identity, we will notify you, and your request(s) to access, rectify, or delete your Personal Information may not be processed. Requests may be denied if we have reason to believe that they are fraudulent.

Authorized Agent Requests
If you use an authorized agent to submit a request, we may require that the authorized agent provide us with proof that you gave the agent signed permission to submit the request. In addition, we may also require you to do either of the following: (1) verify your own identity directly with us; or (2) directly confirm with us that you have provided the authorized agent permission to submit the request on your behalf.

We may deny a request from an authorized agent if the agent cannot meet the above requirements. Further, before responding to a request from an authorized agent, we will still require the authorized agent to provide us with enough information so that we can verify your identity.

CCPA Metrics Report

The following summary provides California residents’ data request volumes for calendar year 2022:

Data requests received: 102

  • Access 10
  • Deletion 63
  • Opt-Out 29

 

Data Request complied with in whole or in part: 77

  • Access 2
  • Delete 47
  • Opt-Out 28

Data Requests Denied or Closed:

  • Access 8
  • Delete 16
  • Opt-Out 1

Average time (days) to respond:

  • Access 15
  • Delete 14
  • Optout 18

 

 

Notice of Financial Incentive

If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation, and we will provide you with directions on how to do so.

Deidentified Information

Where we maintain or use deidentified information, we will continue to maintain and use the deidentified information only in a deidentified fashion and will not attempt to re-identify the information.

For More Information

For questions or concerns about this California Notice, our Global Privacy Statement and privacy practices, please contact us wuprivacy@westernunion.com or as further specified in the Contacting Us section of the Western Union Global Privacy Statement.