User Agreements

Privacy Policy

Effective and last updated as of March 23, 2023

Introduction

Pangea USA, LLC, its parents, subsidiaries, and affiliates operating under the Pangea brand (collectively “Pangea,” “we,” “our,” or “us”) respect the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website and the mobile application we offer (collectively, the “Site”), when you use our services through the Site, or when you use our services provided through a third-party platform (“Platforms”) (collectively the “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

If you have a financial product or service with us, we will use and share any information that we collect from or about you in accordance with our US Consumer Privacy Notice, which offers you certain choices with respect to the use and sharing of your personal information.

If you obtain financial services through a Platform that uses our Services, your personal data will be subject to additional privacy policies. The Platform you are using will provide you with a privacy policy explaining the personal data that it collects and how it uses and shares that personal data.

This Privacy Policy covers the following topics:

1. Information We Collect Online
2. How We Use Your Information
3. How We Share Your Information
4. Cookies and Other Tracking Technologies
5. “Do Not Track” Signals
6. Choices About Your Information
7. Security
8. Third Party Links
9. Children’s Privacy
10. Notice to California Residents
11. Accessibility
12. How to Contact Us

1. Information We Collect Online

We collect Personally Identifiable Information from you through your use of the Site and Services. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us in using our Site and Services. If you interact with a Platform that uses our Services, we will receive your Personal Data and process that Personal Data on behalf of the Platform.

• Register for an Account. To register for an account, you will provide us with your name, physical address, phone number, and you will create a password for future logins.
• Transfer Money. To transfer money, you will add recipient information to your account. You will provide us with the recipient’s name, physical address, phone number, email address, date of birth, driver’s license number or a government-issued identification card, and depending upon the type of transfer, the recipient’s bank account information or debit card information. To transfer money to the recipient you will provide us with your debit card information, including the number, CVV, and expiration date or banking details for ACH payments. We use third parties (including Vantiv and Wells Fargo) to process payments. Please review those third parties’ privacy policies for more information on their privacy practices.
• Identity Verification. To verify your identity when you use our Services, you will provide your name, email address, Social Security number (if applicable), and driver’s license or government-issued identification card (if applicable).
• External Bank Account Information. Depending on the Services you use, we may collect information regarding a bank account including the account name, account type, account number, and routing number.
• Contact Us. To contact us, you will provide us with your name, email address, and any other information you choose to provide.

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site, such as the following:

• Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
• Device Information. For example, hardware model, operating system, application version number, and browser.
• Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Location information from Site visitors on a city-regional basis.

Third Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, when you transfer funds to a third party, you will provide us with the third party’s information as described above. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

2. How We Use Your Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

• Provide the Services, perform obligations under our agreements, and carry out related business functions;
• Process your transactions and send money transfers to your recipients;
• Verify your identity;
• Process your debit card application and provide you with a debit card;
• Collect payment for your use of the Services;
• Allow our partners to fulfill their promotional obligations to you;
• Contact you regarding our products and services that we feel may be of interest to you;
• Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
• Provide customer support to you or the Platforms, including to help respond to your inquiries related to our Services;
• Maintain and improve our Site and Services;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our terms of use;
• Defend our legal rights and the rights of others;
• Efficiently maintain our business; and
• Comply with legal obligations, audit requirements, and applicable law, including relating to customer identification, “know-your-customer” procedures, and anti-money laundering and counter terrorism financing.

3. How We Share Your Information

We may share the information that we collect about you in the following ways:

• With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, and financial service providers who enable you to use certain features;
• With the bank we partner with to provide you with debit card services;
• With the recipients you transfer money to;
• With vendors to prepare, deploy and analyze advertising content;
• To the extent that we are required to do so by law;
• To protect you against actual or potential fraud, identity theft, unauthorized transactions, claims, or other liability;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
• With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personally Identifiable Information;
• With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding or in preparation for any of these events;
• With any other person or entity where you consent to the disclosure; and
• For any other purpose disclosed by us when you provide the Personally Identifiable Information or for any other purpose we deem necessary, including to protect the health or safety of others.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for marketing purposes.

4. Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

• Estimate audience size and usage patterns;
• Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
• Recognize when you return to the Site.

We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information, to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google, Facebook and other similar companies.

How You Can Opt Out of Cookies

You can block Cookies by changing your Internet browser settings to refuse all or some Cookies.  If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls 

You can opt out of Cookies set by specific entities by following the instructions found at these links:

• Google: https://adssettings.google.com
• Facebook: https://www.facebook.com/about/ads
• Microsoft: https://account.microsoft.com/privacy/ad-settings/

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

Hotjar

We use Hotjar to better understand our users’ needs and to optimize the service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our Site. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information, please view Hotjar’s privacy page by clicking here.

Other Types of Collecting Activities

The Site and Services may use cookies and similar technologies third-party vendors provide to collect information, such as IP address, device information (e.g., operating system), and information on user behavior (e.g., screens and pages visited, buttons and links clicked, limited information entered, and user taps and mouse movements). This information enables us to monitor and improve the user experience.

5. “Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

6. Choices About Your Information

Review and Request Changes to Your Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at privacy@gopangea.com.

Marketing Communications

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at privacy@gopangea.com.

7. Security

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security.

8. Third Party Links

The Site and Services may contain links that will let you leave the Site and Services and access another website. Linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired by us on this Site and Services. We accept no responsibility or liability for these other websites.

9. Children’s Privacy

The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you, and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

The CCPA’s privacy rights described below do not apply to Personal Information that we collect, process, sell, or disclose subject to the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Because we are subject to those laws and regulations, much of the Personal Information that we collect is exempt from the CCPA. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.

Finally, as described in the “Collecting and Using Information” section above, we collect certain Personal Information in our role as a service provider for other entities. If you would like to make any requests or queries regarding Personal Information that we process on behalf of Platforms, please contact those entities directly. Your rights under the CCPA will depend on our relationship with you.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated date of this Privacy Policy, have collected the following categories of Personal Information:

• Identifiers (name, alias, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number)
• Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
• Personal information described in California’s Customer Records statute (California Civil Code 1798.80(e) (telephone number, bank account number, debit card number, account information, as well as the categories listed in the “Identifiers” category above)
• Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
• Commercial information (records of products or services purchased, obtained or considered)
• Characteristics of protected classifications under California or federal law (age (40 and older)
• Sensitive Personal Information including Personal Information that reveals: your Social Security number, driver’s license, state identification card, or passport number

We collect Personal Information directly from California residents and from Platforms, consumer reporting agencies, identity verification providers, and publicly available sources. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “Collecting and Using Information” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
• Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with us, provided that the consumer’s personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with us
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with consumers
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service that is owned, or controlled by us, and to improve, upgrade, or enhance the service that is owned, or controlled by us
• Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Disclosure of Personal Information

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

We disclosed Personal Information for all the business and commercial purposes described above. We have not sold or shared Personal Information in the twelve (12) months preceding the Last Updated date of this Privacy Policy. We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age. We do not collect or process sensitive Personal Information or use it for purposes other than those allowed by the CCPA and its regulations.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

• The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
• The right to delete Personal Information that we collected from you, subject to certain exceptions;
• The right to correct inaccurate Personal Information that we maintain about you;
• If we sell or share Personal Information, the right to opt out of the sale or sharing;
• If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
• The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct by emailing us at privacy@gopangea.com or by calling us toll free at 1-866-858-9928.

As mentioned above, if you are a California resident who has a financial product or service with us, much of the Personal Information that we collect is exempt from the CCPA and, therefore, is not subject to the rights discussed in this “Notice to California Residents” section. Your choices and rights with respect to our use and sharing of that information are subject to our U.S. Consumer Privacy Notice.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request.

To verify your request, we will match the personal information you submit with the information we have about you. If we cannot conclude your information matches what we have, you may be directed to contact us with further instructions to assist us in responding to your request. To verify your request, you must submit:

• Your first and last name;
• Your mailing address;
• Your email; and
• Your date of birth.

11. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

12. How to Contact Us

To contact us for questions or concerns about our privacy policies or practices please email us at privacy@gopangea.com or write to us at:

Pangea USA, LLC
175 W. Jackson Blvd., Ste 600
Chicago, IL 60604