We take your privacy seriously. We do not sell your information to third
parties for marketing purposes. In the event your information is shares with
third parties; it is with good reason to insure compliance with regulations for
your investment. We will always take all reasonable precautions to ensure they
do not abuse your data and or sell it for any purposes.
This Privacy Policy is effective as of January, 2017.
Direct Transfer, LLC – d/b/a: Transferly (“Transferly”) is committed to
protecting your privacy and earning your trust. This Privacy Policy discloses
our privacy practices for personal information we collect when you use or
access our products, services, features, or content through any website,
application, or service (“Transferly Services”), even if you have not opened a Transferly
account or visited our website Transfer.ly, or (“Transferly Sites”). We may, in
our sole discretion, change this Privacy Policy from time to time by posting a
revised version at
Transfer.ly.com/privacy.
If we make any material change, we will notify you by email (as listed in your
account profile) or by means of a notice on
Transfer.ly.com/privacy prior to the change becoming
effective. If you have questions or complaints regarding our Privacy Policy or
practices, please contact us at:
ops@Transfer.ly.
If you use or access Transferly Services, or open a Transferly account,
we may collect the following personal information:
Contact and identification information, such as your name, phone, email,
Social Security Number or tax identification number, organizational documents
(if you are a business) and other similar information, such as identification
questions and answers.
Financial information, including, but not limited to (i) your bank
account and routing numbers, (ii) bank credentials and security questions;
and/or (iii) other information relating to your bank account. If you choose to
use it with Transferly Services.
Your Public or uploaded photo or “avatar” that you choose to add to your
profile. Be advised other users of Transferly Services may be able to view your
photo. You may change your photo at any time in your account settings.
Information that you provide to Transferly or our merchants when
interacting with customer support team or other team members via phone, email,
online form, or other correspondence.
Personal information stored with third parties that you choose to
provide to Transferly or made available to the public, such as social media
account information and your social media contacts. By linking your third party
accounts or using third party sign-in services, you authorize Transferly to
have access to this information and you agree that Transferly may collect and
use this information in accordance with this Privacy Policy.
Personal testimonial information or endorsements that you voluntarily
provide to us and which we may display with your name on Transferly Sites with
your consent. To update or delete your testimonial, contact us at hello@Transferly.com.
We also collect the following information (“Web Browser Information”)
from your device when you use Transferly Services: your IP address, web-based
device fingerprint, the type of device you use, your device identifier, your
operating system version, the type of browser you use, your location, and the
URL that you came from and the next URL that you visit.
We collect your personal information to:
Provide Transferly Services to issuers you might invest in using our Services.
Notify you about your account activity.
Process transactions and collect fees based on your investment and or
instruction.
Provide customer support and resolve disputes.
Verify your identity and account information.
Identify, prevent, and report potentially prohibited, fraudulent or
illegal activities.
Provide transaction, risk mitigation and “KYC - Know Your Customer”
reports to our Financial Institution Partner(s) and/or merchants.
Customize and improve your Transferly experience and Transferly
Services.
Contact you at your telephone number by voice or SMS to validate the
telephone number or your Transferly account.
Notify you about important changes to Transferly Services and/or Transferly’s
terms and conditions.
Provide you with news, offers and information about Transferly Services
based on your communications preferences.
Any other purpose that we disclose to you in the course of providing Transferly
Services to you.
We may share your personal information as follows:
When you send or transmit money using the Transferly Services, we will
provide the issuer approved with Transferly, with your registered name, investment
amount, type, sub-docs, signatures and your avatar photo as applicable.
If your investment in the Transferly Service fails, we may provide that
issuer with details of the unsuccessful investment.
With third parties to provide, maintain and improve Transferly Services,
including fraud prevention, identity verification, analytics services, and
financial institutions and other partners that are part of the payment process.
With third parties to mitigate risk of Users and their transactions.
With third parties upon your request if for example, you ask Transferly
to confirm your status as a Transferly user with a third-party merchant.
If we believe disclosure is reasonably necessary (i) to comply with any
applicable law, legal process or government request; (ii) to investigate or
bring legal action against someone who may be violating our rights, our terms
and conditions, or the rights of others; or (iii) to protect the safety and
security of Transferly, our users, or the public.
With a third party if we are involved in a merger, acquisition, or sale
of all or a portion of our stock or assets. If this occurs, you will be
notified of any change to this Privacy Policy, as well as any choices you may
have regarding your personal information.
We may share aggregated, non-personally identifiable information with
third parties. Other than as stated in this Privacy Policy, Transfer.ly does
not disclose or sell any of your personal information to third parties without
your consent. Please note that third parties, such as merchants that you pay
and third party websites that you visit, have their own privacy policies. Transfer.ly
is not responsible for the policies and practices of such third parties.
Cookies, fingerprints and web beacons are technologies that Transferly
and our third-party service providers use to collect Web Browser Information in
order to track how Transferly Sites and Transferly Services are used. Cookies
are small data files that are stored on your computer’s hard drive and web
beacons are tiny graphics embedded on webpages. Fingerprints are a unique
device identifier. These technologies allow us to: provide you with a
personalized experience by recognizing you when you return to Transferly Sites;
better understand our users by tracking how they use Transferly Services;
improve the design and content of Transferly Sites by tracking how users
interact with Transferly Sites; and identify and prevent fraudulent activity.
We may link Web Browser Information to any personal information that you submit
while on Transferly Sites. Our third-party service providers may use cookies
and web beacons to provide analytics services to Transferly, or to serve you
advertisements in connection with Transferly Services. You can change your
browser settings to refuse cookies, but this may interfere with your use of Transferly
Sites. Third parties, with whom we partner to provide some content such as
video clips, use Flash cookies which cannot be removed using your browser
settings. To learn how to manage your Flash cookie preferences, visit the Flash
Player Settings Manager Help page here. This Privacy Policy does not apply to
third party cookies, web beacons, social media features and widgets (such as
the Facebook Like button), or other tracking technologies used by third
parties. Transferly is not responsible for the privacy policies and practices
of such third parties.
We have security measures in place to protect your personal information,
including the use of industry-standard data encryption technology and internal
policies and restrictions regarding the storage of and access to your personal
information. Please note that while we uphold ourselves to high security
measures, no data transmission over the Internet or method of electronic
storage can be guaranteed to be 100% secure. Transferly’s servers and business
operations are entirely located in the United States.
By using our service, visiting our site or using our applications you
are consenting to the terms of this Privacy Policy.
If your personal information changes, you can update or correct it in
your account settings by logging into your account on the apps. We will retain
your information for as long as your account is active or as needed to provide
you Transfer.ly Services. If you wish to close your account or request that we
no longer use your information to provide you Transfer.ly Services, contact us
at ops@Transfer.ly. We will retain and use your information as necessary
to comply with our legal obligations, resolve disputes and enforce our terms
and conditions.
Transferly sites may offer publicly accessible blogs or community
forums, which may require creation of an account with a third party. Any
information you provide in these areas may be visible to the public, so we
recommend that you avoid disclosing personal information. To request removal of
your personal information from these areas, contact us at ops@Transfer.ly. In
some cases, we may not be able to remove your personal information, in which
case we will let you know if we are unable to do so and why.
If you have any questions regarding Transferly Privacy Policy, please
contact us at
ops@transfer.ly.
