Privacy Policy

The Gramm-Leach-Bliley Act (GLB Act or GLBA) is also known as the Financial Modernization Act of 1999. It is a United States federal law that requires financial institutions to explain how they share and protect their customers’ private information. To be GLBA compliant, financial institutions must communicate to their customers how they share the customers’ sensitive data, inform customers of their right to opt-out if they prefer that their personal data not be shared with third parties, and apply specific protections to customers’ private data in accordance with a written information security established by any institution.

The Gramm Leah Bliley Act (GLBA) requires institutions that collect nonpublic personal information to retain that information secure. Additionally, privacy notices must be distributed in the event that consumers’ information is released (except as permitted by law). Similar to anti-money laundering requirements, a Compliance Officer must be designated and procedures for complying with this act must be documented.

Maxitransfers has established procedures to comply with the Gramm-Leach-Bliley Act ensuring the security and privacy of information and records of our customers and consumers. Maxi discloses to customers any Maxitransfers policies related to the disclosure of non-public personal information to non-affiliated third parties.

Non-Public Personal Information (“NPI”)

• Provision of a clear and obvious notice that reflects your privacy practices and policies.
• • For Clients, when a customer relationship is established.
  • For Consumer, before disclosing any Non-Public Information (NPI) to a non-affiliated third party, except when otherwise permitted.
  • Share Information with affiliated entities, covered by Fair Credit Reporting Act.

Limit of Use

Maxi is committed to protecting our customer’s privacy and security, Maxi does not disclose any nonpublic personal or financial information about its customers to third parties except when permitted by law and if necessary, in order to complete the consumer transaction as requested and authorized.

Recommendations to comply with GLBA

• Provide a privacy notice at all points of the online application.
• Ensure that notices and waiver mechanisms are available at certain points of information collection online.
• Implement security guarantees for the collection of financial information online.
• Make sure that personal financial information is not passed on to third parties, which would be a violation of the sharing rules.
• Protect the security or integrity of customer records from any threat or anticipated risk.
• Protect these records or information against unauthorized access or use that may cause significant damage or inconvenience to customers.

Other tips include, but are not limited to, the following:

• Avoid referring to identification data aloud, such as addresses, phone numbers, social security numbers, etc., when other people can hear what you say
• Never show the Maxi system monitor screen to any customer.
• Any note, form, diary or other document containing the client‘s non-public personal information must be destroyed before proceeding to dispose of the document.

General Maxitransfers Privacy Policy

We at Maxitransfers LLC (Maxitransfers) take our responsibility to protect the privacy and confidentiality of consumer information from unlawful use and disclosure very seriously. Since maintaining our consumer’s trust and confidence is a high priority to us, we have developed a Privacy Policy to communicate our privacy commitment to our consumers and to better serve their privacy needs.

I. OUR SECURITY PROCEDURES

We maintain administrative, physical, electronic and procedural safeguards that comply with federal, state and local legal requirement to store and secure information about the consumer non-public personal information from unauthorized access, alteration and destruction. Maxitransfers employees are trained in the proper way to keep the consumer information safe and protected in compliance with this Privacy Policy. We only engage reputable companies to provide support services and work with them to control confidentiality, security and integrity of the consumer non-public personal information. All of our service providers must implement appropriate measures to have a security program in place that complies with federal, state and local legal requirements as well as with our security procedures.

II. COLLECTION OF INFORMATION

We limit the collection and use of non-public personal information to the minimum necessary to deliver superior service to consumers. Maxitransfers collects your nonpublic personal information directly from the payment order application submitted to us at the time of the transaction. This information may include name, address, telephone number, employment information, social security number, birth date and income.

III. NON-PUBLIC PERSONAL INFORMATION WE MAY DISCLOSE WITHIN THE MAXITRANSFERS CORPORATE LLC.

Maxitransfers may share collected non-public personal information with our service providers (bill payment services) and foreign payees to process and complete the service transactions that the consumer requests or authorizes.

IV. NON-PUBLIC PERSONAL INFORMATION WE MAY DISCLOSE OUTSIDE THE MAXITRANSFERS LLC.

Our policy is not to share or disclose your non-public personal information with third parties outside the Maxitransfers LLC. except as permitted by law and as necessary in processing and conducting the transaction the consumer has requested and authorized. These companies include payment order processors.

V. ABOUT YOUR PRIVACY RIGHT

Maxitransfers will not be able to process your transaction unless you allow us to share your collected non-public personal information among our service providers (bill payment services) and foreign payees. Your personal information shared within Maxitransfers LLC, however, will be treated with the utmost confidentiality. We do not share or disclose any non-public personal information for marketing purposes with any non-affiliated third parties.

VI. INTEGRITY OF INFORMATION

We have established procedures to ensure that your information is accurate, current and complete in accordance with industry standards.

VII. NON-RECURRENT CONSUMERS

All of our consumers are a priority to our organization. If you are a one-time or a repeat consumer, we will always maintain your non-public personal information in a secure and confidential manner as described in this notice.

VIII. REVISIONS TO OUR POLICY

Maxitransfers reserves the right to amend or modify this Privacy Policy at any time.

Other applicable Privacy Requirements

State of California

Division 1.4. California Financial Information Privacy Act

4051.

(a) The Legislature intends for financial institutions to provide their consumers notice and meaningful choice about how consumers nonpublic personal information is shared or sold by their financial institutions

(b) It is the intent of the Legislature in enacting the California Financial Information Privacy Act to afford persons greater privacy protections than those provided in Public Law 106-102, the federal Gramm-Leach-Bliley Act, and that this division be interpreted to be consistent with that purpose.

4051.5

(a) The Legislature finds and declares all the following:

(1) The California Constitution protects the privacy of California citizens from unwarranted intrusions into their private and personal lives.

(2) Federal banking legislation, known as the Gramm-Leach-Bliley Act, which breaks down restrictions on affiliation among different types of financial institutions, increases the likelihood that the personal financial information of California residents will be widely shared among, between, and within companies.

(3) The policies intended to protect financial privacy imposed by the GrammLeach-Bliley Act are inadequate to meet the privacy concerns of California residents.

(4) Because of the limitations of these federal policies, the Gramm-Leach-Bliley Act explicitly permits states to enact privacy protections that are stronger than those provided in federal law.

(b) It is the intent of the Legislature in enacting this division:

(1) To ensure that Californians have the ability to control the disclosure of what the Gramm-Leach-Bliley Act calls nonpublic personal information.

(2) To achieve that control for California consumers by requiring that financial institutions that want to share information with third parties and unrelated companies seek and acquire the affirmative consent of California consumers prior to sharing the information.

(3) To further achieve that control for California consumers by providing consumers with the ability to prevent the sharing of financial information among affiliated companies through a simple opt-out mechanism via a clear and understandable notice provided to the consumer.

(4) To provide, to the maximum extent possible, consistent with the purposes cited above, a level playing field among types and sizes of businesses consistent with the objective of providing consumers control over their nonpublic personal information, including providing that those financial institutions with limited affiliate relationships may enter into agreements with other financial institutions as provided in this division, and providing that the different business models of differing financial institutions are treated in ways that provide consistent consumer control over information-sharing practices.

(5) To adopt to the maximum extent feasible, consistent with the purposes cited above, definitions consistent with federal law, so that in particular there is no change in the ability of businesses to carry out normal processes of commerce for transactions voluntarily entered into by consumers.

California Consumer Privacy Act (2020)

The California Consumer Privacy Act of 2020 (CCPA) applies to Maxitransfers business activities with California consumers. In order to comply with the requirements of the CCPA, Maxitransfers has developed the following policies and procedures:

Maxitransfers will implement the following procedures in order to comply with the CCPA:

Maxitransfers in compliance with the CCPA Section 1798.100 (b) shall post disclosures at its California authorized agent’s locations informing its consumers that in order to process the transaction and based on transaction amounts will collect as following:

• Maxitransfers will limit the collection and use of non-public personal information to the minimum amount necessary to deliver superior service to its consumers, which includes advising consumers about our products, services, opportunities, and management of consumer relationships.
• Maxitransfers collects non-public personal information about consumers directly from the payment order application at the time of the transaction. This information may include sender and recipient name, sender and recipient address, sender and recipient telephone number, employment information, social security number, birth date and income.

CCPA Consumer Privacy Right

Maxitransfers will not be able to process a consumer transaction unless he/she allows us to share their collected non-public personal information among our parent company, its affiliates, and its subsidiaries. The consumer personal information shared within the Maxitransfers Family, however, will be treated with utmost confidentiality.

We do not share or disclose any non-public personal information for marketing purposes with any non-affiliated third parties

California Residents

Maxitransfers will disclose information about consumers with a California mailing address only with their written authorization, unless otherwise permitted by applicable law. For instruction on how to deliver your consent, California residents should contact us at Maxitransfers LLC, 222 Las Colinas Blvd. W., Suite 2000 N. Tower, Irving TX 75039 at (866) 216-2852 or customerservice@maxillc.com

Your Rights:

• You have the right to know what personal information is being collected about you;
• You have the right to know whether your personal information is sold or disclosed and to whom;
• You have the right to say no to the sale of your personal information;
• You have the right to access your personal information; and
• You have the right to equal service and price, even if you exercise your privacy rights.

California Privacy Act

• You have the right to request what personal information is collected about you and the purposes for which your personal information is used;
• You have the right to request deletion of your personal information collected; however, we reserve the right to maintain personal information if deemed necessary;
• You have the right to request and receive information about what personal information has been collected, sold, or disclosed to third parties;
• You have the right to opt-out of the sale of your personal information; and
• You have the right to not be discriminated against due to the exercise of any right established.

State of Oklahoma

Chapter 6 - Financial Privacy Act

Section 2203 - Financial Institutions Prohibited from Disclosing Financial

Records Unless

A financial institution is prohibited from giving, releasing or disclosing any financial record to any government authority unless:

(a) it has written consent from the customer for the specific record requested; or

(b) it has been served with a subpoena issued pursuant to Section 4 for the specific record requested

Section 2208 - Release of Records - Disclosure of Financial Records

A. A financial institution shall not release the records of a customer until the government authority seeking the records certifies in writing that it has complied with the applicable provisions of the Financial Privacy Act.

B. Any financial institution or employee thereof that discloses the financial records of a customer pursuant to the Financial Privacy Act in good faith reliance upon a certificate of the government authority shall not be liable to the customer for the disclosure under any law or regulation