Effective date: June 1, 2017

The Tuyyo mobile application (“App”) is provided by BBVA Transfer Services, Inc. (“BTS”). This Privacy Policy describes our practices related to the use, storage and disclosure of information we collect from or about you in the course of providing the Service through our Mobile Application. We reserve the right to modify this Privacy Policy at any time and without prior notice. The privacy policy link within the Mobile Application will direct your device to the most recent version of this Privacy Policy. This Privacy Policy is not a contract and does not create any legal rights or obligations. Unless otherwise stated below, the terms used in this Privacy Policy shall have the same meaning as defined in the BTS Mobile Application Terms of Use. By using the App, you are consenting to our collection and use of information as set forth in this Privacy Policy.

Our Security Procedures

We maintain physical, technical and administrative safeguards that comply with federal standards to safeguard your “nonpublic personal information,” which is nonpublic information about you that we obtain in connection with providing a financial product or service to you. We also take steps to safeguard your information, and restrict access to your nonpublic personal information to those employees who need to know that information to provide products or services to you. Our employees who have access to your nonpublic personal information are trained in the proper handling of your information and required to fully comply with our Privacy Policy. When your account information is transmitted via our services, it will be protected using encryption technology.

While we take steps to protect your nonpublic personal information and keep it secure, you also play a role in protecting your information. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal information. You can help to maintain the security of your transactions by not sharing your Security Codes with anyone. If we receive instructions using your Security Codes we will assume that the instructions have been authorized by you.

Collection and Use of Information

We may collect nonpublic personal information about you from the following sources:

  • Information we receive from you when you register on our App, during the payment order process, on the payment order form or other forms. This information may include, but is not limited to: name, address, telephone number, employment information, social security number, birth date, income, information about persons or entities to whom you transfer funds using our services, log-in information such as a username and password, identity verification such as your photograph or government issued identification and answers to security questions, and information about any account you designate to be used for payment of your money transmissions.
  • Information about your transactions with us, members of our BBVA corporate family (“affiliates”) or others, and
  • Information we receive from a consumer or credit reporting agency.

We (or our service providers acting on our behalf) may automatically collect personal information about your use of our services. This information includes information that may identify you as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with your personal information. Information that we automatically collect in connection with your use of our services may include:

  • Device information such as your hardware model, operating system version, unique device identifiers, and mobile network information, including your mobile phone number. We may associate your device identifiers or mobile phone number with your account.
  • Log information from your devices, their software, and your activity using our services which may include:
    • The device’s Internet Protocol (“IP”) address;
    • Identification numbers associated with your devices;
    • Device event information, such as crashes, system activity, and hardware settings;
    • Location preferences;
    • Date and time stamps associated with transactions;
    • System configuration information; and other interactions with our Services.

We may use your nonpublic personal information internally for our own business purposes including for marketing purposes as described in this Privacy Policy. We may use aggregated data that does not identify you personally for research and commercial purposes. We may use your postal address or email address to contact you to respond to your inquiries or to provide information on our, our affiliates or third parties’ products or services to you.

Location Information

Unless you have opted-out through your device settings, the App may collect precise information about the location of your device. Location information may be accessed when you are registering for the Service or choose to use location-based services. We use your location information to verify the country in which your device is located and to provide requested location-based services, such as nearby ATMs and branches. Location information is obtained from various technologies like GPS, Wi-Fi, and cell tower proximity. You may at any time opt-out from allowing the App to have access to your location data through your device settings. We do not control your location information preferences from within the App. For more information, please see the section below regarding “opt-out rights.”

The App uses Google Places API to provide address suggestions to you. Use of Google’s APIs is subject to Google’s Privacy Policy.

Nonpublic Personal Information We Disclose

i. Disclosure applicable to all users.

We may disclose all of the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. We may disclose your public, aggregated, or otherwise non-personal information, such as usage statistics of our Services, to third parties.

We are also permitted to disclose nonpublic personal information about you to third parties without your consent in certain circumstances; for example, we may provide such information to third parties: (1) to assist us in processing your money transmittal or provide another service or product you have requested; (2) to comply with federal, state, or local laws, rules, and other applicable legal requirements; or to comply with a properly authorized civil, criminal, administrative, or regulatory investigation or subpoena or summons by federal, state, or local authorities; or to respond to judicial process or government regulatory authorities having jurisdiction over the financial institution for examination, compliance, or other purposes as authorized by law; (3) to consumer or credit reporting agencies., (4) in connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit if the disclosure concerns solely information about consumers of that business or unit, or (5)(A) to protect the confidentiality or security of our records pertaining to the consumer, the service or product, or the transaction therein; (B) to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; (C) for required institutional risk control, or for resolving customer disputes or inquiries; (D) to persons holding a legal or beneficial interest relating to the consumer; or (E) to persons acting in a fiduciary or representative capacity on behalf of the consumer.

As stated above, we may share your information collected by the App with our service providers who work on our behalf to provide services you request. For example, if you send text messages through the App, our service provider may collect and maintain the call data (e.g., receipts, phone numbers, size, time of transmission, confirmations, etc.) and other message transmission and conversion data, which may include personal information. For more information about our text message service provider’s privacy practices, please review its privacy policy here: https://www.nexmo.com/privacy-policy

If your relationship with us becomes inactive or is terminated, we will continue to adhere to the policies and practices described in this Privacy Policy, unless you consent to the change or it is legally permitted.

ii. Disclosures applicable if you reside in a state other than California or Vermont.

Unless you opt-out, BTS may share some of your nonpublic personal information with affiliates and other third parties to (i) provide you with special promotions on the App and related products and services, and (ii) to help improve the App as well as future products and services. The nonpublic personal information BTS shares with affiliates or other third parties includes your name, postal address, gender, email address, mobile number, and date of birth. Our affiliates and third parties may also share such information with their affiliates for marketing and analytic purposes. If you prefer that BTS not share your nonpublic personal information with any affiliates or third parties you can opt-out at any time by changing your preferences in the “Settings” section of the App.

iii. Disclosures applicable if you reside in California or Vermont.

If you consent, BTS may share some of your nonpublic personal information with affiliates and other third parties to (i) provide you with special promotions on the App and related products and services, and (ii) to help improve the App as well as future products and services. The nonpublic personal information BTS shares with affiliates or other third parties includes your name, postal address, gender, email address, mobile number, and date of birth. Our affiliates and third parties may also share such information with their affiliates for marketing and analytic purposes. If you prefer that BTS not share your nonpublic personal information with any affiliates or third parties you can opt-out at any time by changing your preferences in the “Settings” section of the App. Withdrawing your consent will apply to future sharing; any information already shared will not be affected.

Access to Your Information

After you register on our App, you may review your information and preferences by visiting the Profile page. There you may make any changes or corrections to your information or preferences. If you have any questions you may contact us as indicated in the “Contacting Us” section below.

Opt-Out Rights

You may refrain from using the App features that collect specific types of information. You can stop all collection of information by uninstalling the App. You may use the standard uninstall processes available as part of your mobile device or via the removal features provided in your mobile application store or network. Once you have uninstalled the App, any preferences that you previously set within the App are deleted, such as whether you allowed us to send you push notifications.

You may at any time opt-out from allowing the App’s access to your location information by disabling location tracking features in your device settings. Turning off your device’s location tracking features will prevent the App from performing any location-based services.

Cookies

We use cookies to personalize the App for you and to collect aggregate information about App usage by all of our users. A cookie is a text file that our App transfers to your mobile device for record-keeping purposes and to enhance the quality of your experience with the App. The cookie assigns a random, unique number to your mobile device. Our cookie records “clickstream” information (data reporting on your use of the App). We do not allow anyone else to access your cookie.

We may use persistent cookies that will log when you exit the App and that allow us to recognize you when you return to the App. We may also use session cookies which are deleted when you exit the App.

We may permit certain third parties to place cookies through our services to provide us with better insights into the use of our services and user demographics and to provide relevant advertising to you. These third parties may collect information about your online activities over time and across different websites when you use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services which Google uses to compile reports on website activity for us and to provide other related services. Google may identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or using our services, you consent to the placement of cookies on your devices as described in this Privacy Policy. Further general information about cookies and how they work is available at www.allaboutcookies.org.

Do Not Track Signals

We do not use technology that recognizes or responds to “do-not-track” signals from your web browser.

Data Retention

Our operational systems will store information you provide to us for as long as you use the Services. Please note that some or all of the information you provide may be required in order for the App to function properly, and we may be required to retain certain information by law. If you close your profile established to use the Services, we will retain certain account data, such as transaction history, for a reasonable time.

Protecting Children’s Privacy

The App is not designed nor intended to be attractive to use by children under the age of 18 (“Minors”). We do not knowingly collect information from or market to Minors. If you are under the age of 18, please do not submit any information to us.

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to our Services.

Revisions to our policy

BTS reserves the right to amend or modify this Privacy Policy at any time. As our Services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. The Privacy Policy link within the App will direct your device to the most recent version of this Privacy Policy. We post the effective date of our Privacy Policy so that you will know when it was last updated. We will notify you electronically of any material changes to our Privacy Policy in accordance with the Terms. Your use of the App following an update to this Privacy Policy means that you accept the updated Policy.

Contacting Us

If you have any questions regarding privacy while using the App, or have questions about our practices, you can write to us at 16825 Northchase Dr. Suite 1525 Houston, Texas 77060, call us at 1-844-683-5319 or you can email us at help@tuyyo.io.