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Privacy Policy

Last updated: 21 December 2015

peerTransfer Corp and its subsidiaries, doing business as Flywire (collectively “peerTransfer”, “we”, “us”, “our”) respect your privacy. This privacy policy describes our practices regarding the collection, use, storage, sharing and protection of your personal information and choices you can make about the handling of the information. We also describe how you can contact us about our privacy practices, including how you can make a complaint.

When using our services or providing us with your personal information, you accept this privacy policy. This privacy policy may be amended at any time by posting a revised version on our website.

In this privacy policy “personal information” has the meaning set out in applicable privacy legislation. Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.

A. Information We Collect

We may obtain information about you in a variety of ways. When you visit the peerTransfer website or use our online services, we collect information sent to us by your computer, mobile phone or other access device. We may obtain information from you in our role as a processor of payment transactions, or we may have a direct relationship with you and in the context of that relationship you may choose to provide personal information to us.

The information sent to us automatically includes your computer IP address, the pages you access, device identifiers, the type of operating system you are using, standard web log data, data associated with cookies and other information. Web log data includes the browser type you’re using and traffic to and from our site.

In addition to this information, in the event that you use our services and engage in making a payment transaction through peerTransfer we may collect the following types of information:

  • Contact information (such as name, physical address, phone number or email);
  • More detailed personal information, such as your date of birth, name of educational institution attended, year of graduation and Student ID;
  • If you are submitting a payment on behalf of a student, we may collect contact information (such as name, physical address, phone number or email) about you from the student;
  • Financial information, such as bank account numbers, names and routing codes (we do not directly handle credit card data);
  • Employment-related information such as your C.V., if you apply for a job with us;
  • Logs of our chat or other communication with you.

We may also collect information from you through other means, such as through your contact with our Support, Operations and Account Management teams.

In the course of processing your payment transaction we work with payment collection and banking partners. In doing so, a partner or bank may share with us information about the originating account such as account name, number, routing code and other identifying information to provide us with notification that a payment has been received.

B. How We Use The Information We Collect

We may use the information we obtain about you to:

  • Process your payment transaction and keep you informed about the status of your payment;
  • Comply with and enforce applicable legal requirements, industry standards and our policies;
  • Prevent potentially illegal or prohibited activities and enforce our Terms of Use;
  • Respond to your inquiries, resolve disputes and provide support;
  • Analyze, operate and improve our business (including enhancing our user experience, managing communication and functionality and developing new products and services);
  • Inform you of services we provide through targeted marketing messages, service updates and promotional offers based on your communication preferences;
  • Compare information for accuracy and verify it with third parties;
  • Further our business relationship with you, if we have collected your personal information in the context of an actual or potential business relationship;
  • Evaluate your application for employment and contact you regarding possible employment at peerTransfer, if you have applied for a job;
  • Fulfil other purposes to which you have consented, which would be reasonably expected by you or which are otherwise authorised or required by law.

We may use third-party Web analytics services on our site, such as those of Google Analytics. These service providers use cookies and web beacons to help us analyze how users use the site. The information collected by the technology (including your IP address) will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the site. To learn about opting out of Google Analytics, please click here.

To learn more about the use of cookies by us and third parties, including your opt out options, please visit our Cookie Policy.

C. Information We Share

We may share your information in connection with the purposes described in section B of this privacy policy. This includes sharing your information in the following ways:

  • We may share your information with service providers who assist us with our business. For example, to process your payment to an educational institution, we may share some of your personal information with the institution. In some cases, in order to execute the successful processing of your payment, we may share bank/payment receipt documents that you have sent to us with service providers or banking partners under contract whom we work with to assist with the reconciliation of that payment. Our contracts dictate that these service providers only use your information in connection with the services they provide to us and not for their own benefit;
  • peerTransfer Corporation is a United States corporation, which also operates several international affiliates and subsidiaries. We may share personal information with these, or future, affiliates;
  • If we are required to do so by law or legal process or to comply with the law, or when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity or to investigate violations of our Terms of Us and other agreements.

On our website, you may choose to use certain features which are provided by other entities. These features, which include social networking buttons (which will be prominently displayed on our webpage), are operated by third parties that are not affiliated with peerTransfer, and they may collect information directly from you. These third parties may use any personal information that you provide to them in accordance with their own privacy policies and practices. peerTransfer strongly suggests you review the third parties’ privacy policies before interacting with them.

D. Rights and Choices

You may have certain rights regarding the personal information we collect and maintain about you and how we communicate with you.

  • When we request information from you on our site, you may always choose not to provide us with that information. However, if you decline to provide us with certain information, we may not be able to provide you with the services offered;
  • You may opt-out of e-mail marketing communications by clicking on the unsubscribe link within marketing e-mails you receive from us or by contacting us;
  • If you are located in the European Economic Area or Switzerland, you may direct us not to share your personal information with third parties, except (i) with service providers under contract we have retained to perform services on our behalf, (ii) in the event we are acquired or we transfer all or a portion of our business or assets, (iii) if a legal process or law requires disclosure, (iv) at the request of law enforcement authorities, or (v) when we believe, in our sole discretion, that the disclosure of personal information is appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity;
  • Where required by law, peerTransfer obtains your prior opt-in consent at the time of collection for the processing of (i) personal information for marketing purposes and (ii) personal information deemed sensitive pursuant to applicable law;
  • Subject to applicable law, you may have the right to request access to and receive information about the personal information we hold about you, update and correct inaccuracies in your personal information, and have the information deleted, as appropriate. To request to exercise this right, contact us as described below (see section J of this privacy policy). Your right to access, update, correct or delete personal information may be limited in some circumstances by local law requirements.

E. Data Transfer

peerTransfer may store, process and/or transfer your personal information in or to countries other than the country in which the information was originally collected, such as the U.S. For example, we may disclose personal information to our overseas related companies, overseas service providers and to overseas educational institutions in order to process your payment. The countries in which these overseas parties are located will depend on the circumstances. In the ordinary course of business we commonly disclose personal information to parties located in the U.S, UK, Australia and the European Union. By using peerTransfer services or otherwise providing us with your personal information, you consent to our transferring of your information to countries outside your home country including the U.S. We will protect your information as described in this privacy policy.

We comply with the applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA or Switzerland. Our U.S. entity peerTransfer, Corp. is certified under the Safe Harbor program developed by the U.S. Department of Commerce, European Commission and Switzerland for the protection of personal data. Click here to view our Safe Harbor Privacy Policy. In addition, pending a possible update to the Safe Harbor program, international data transfers also are made via other legal bases recognized by the European Commission and applicable national laws.

F. How We Protect Your Personal Information

peerTransfer maintains appropriate safeguards combining technical and physical measures to provide protection to the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, interference, modification, disclosure or misuse.

We limit access to information you provide us to those employees who we believe reasonably need that information in order to do their jobs.

We use Secure Socket Layer (SSL) encryption on our website when transmitting information and use other commercially reasonable efforts to protect your information. We continue to assess new technology for protection of information and upgrade our information security systems where appropriate.

G. Links to Other Websites

Our site may include links to other websites. When you access another website, we strongly suggest you review the privacy policy or notices on those external websites. peerTransfer is not responsible for the content or privacy practices of external websites.

H. Changes to Our Privacy Policy

peerTransfer may amend this privacy policy periodically and without prior notice to you (by posting an updated version to our site) to reflect any changes in our information practices. We will indicate at the top of this privacy policy when it was most recently updated.

I. Questions, Comments and Complaints about Our Handling of Personal Information

If you have any questions, comments or complaints about our collection, use, storage or disclosure of personal information, or if you believe that we have not complied with this privacy policy or our obligations under applicable privacy laws, please contact us (see section J of this privacy policy).

When contacting us please provide as much detail as possible in relation to your question, comment or complaint.

peerTransfer will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

J. Contact Information

If you have any questions or concerns related to this privacy policy, or if you wish to request access to, or correction of, your personal information or make a privacy complaint you may contact us by clicking here or by writing to us at:

  • peerTransfer Corporation
  • Attn: Privacy Officer
  • 141 Tremont Street, 10th Floor
  • Boston, MA 02111, USA

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