Announcement

**Blowfish** · 12-31-2003, 09:53 AM

YIKES!

YIKES!

WESTERN UNION

ONLINE PRIVACY STATEMENT

Effective Date: 12/04/2003

OUR COMMITMENT TO PRIVACY

Western Union Financial Services, Inc. ("Western Union") is a subsidiary of First Data Corporation. Protecting consumer privacy is very important to us. This Online Privacy Statement is available to inform you about our collection and use of personal and non-personal information so that you can make informed choices about how your own information is collected and used. Currently, this Western Union Online Privacy Statement is only applicable to customers and visitors in the United States who visit our website. This Online Privacy Statement reflects the Western Union policies covering personal information collected by us on or after the effective date shown above.

We believe that information used responsibly benefits consumers and the economy, whether it is information we house on behalf of consumers conducting transactions or information we collect on behalf of our business clients. For example, we use consumer information every day to ensure fast and accurate processing of hundreds of thousands of money transfers. In addition, Western Union strives to better serve our customers by offering goods and services that we believe fit their needs and interests. When identifying an opportunity, Western Union may use consumer information it has collected in an effort to identify consumers who may be interested in that opportunity.

For more than 150 years, consumers and businesses have relied on Western Union for reliable service. The relationships we have developed through the years have been established based on mutual trust. Each day we and our thousands of employees and agents around the globe strive to reinforce our commitment to our clients and consumers. Central to that commitment is ensuring that we abide by a set of privacy policies, which are outlined below. These policies guide us in the collection and use of information as well as employee responsibilities in protecting your privacy. We use personal information about consumers only in a manner consistent with these policies.

COLLECTION OF INFORMATION

Western Union collects personal and non-personal information in order to offer or provide goods and services to consumers and our customers. We may obtain this information from a variety of sources:

Directly from customer applications, questionnaires and other materials submitted to us by customers;

From transactions in which Western Union and consumers are involved;

From clickstream activity on our web sites (including the use of "cookies" and or "web beacons," as discussed below); and

From a variety of third-party sources, such as our business customers, government repositories, consumer reporting agencies and other financial institutions.

USE OF COOKIES AND WEB BEACONS

A "cookie" is a small text file placed on your computer's hard drive by a web server and which is acknowledged by your web browser. "Web beacons" are transparent electronic images placed in the web code, also called "clear GIFs" or "Web bugs." We use cookies and/or web beacons for a variety of purposes, including, but not limited to, the following:

To assist us in providing our services to you;

To allow you to change pages during your visit to our website without repeatedly having to re-enter your password;

To track activity on our website;

To determine whether you came to our site from a banner ad or an affiliate website; or

To serve ads to you on this and other websites.

You can usually set parameters on your computer that allow you to elect to accept cookies or to have your browser notify you each time a cookie is offered. You can also usually delete cookies from your hard drive. Instructions on how to accept cookies, on how to be notified that a cookie is being offered and on how to delete cookies are available through your Internet Browser.

DISCLOSURE OF INFORMATION

Western Union does not disclose customer information to third parties without first giving customers an opportunity to opt-out of certain kinds of disclosures. There are some disclosures to third parties that are not subject to the opt-out, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud. In addition, Western Union may disclose customer information to companies that, like Western Union, are part of the First Data corporate family. Finally, Western Union may disclose information about former customers to third parties and companies with which Western Union is affiliated, as well as unaffiliated third parties. Those disclosures may consist of the following:

Financial background information describing a customer's financial status;

Identification information, such as name and address data;

Transaction information, such as account activity, debit activity or credit activity; and

Other information relating to financial matters.

RECIPIENTS OF INFORMATION

Western Union may disclose consumer information to companies affiliated with Western Union and to companies or other parties not affiliated with Western Union (subject to consumers'opt-out rights). These recipients include:

Financial institutions, such as banks, credit card companies and brokerage houses;

Retailers, such as home furnishers, clothing stores and florists;

Companies that process transactions or provide other services for us;

Government agencies; and

Catalogue companies and other direct marketers.

In addition, under federal law Western Union is permitted to disclose customer information to certain recipients, such as credit reporting companies.

WE ARE COMMITTED TO PROTECTING THE CONFIDENTIALITY OF PERSONAL CONSUMER INFORMATION.

Western Union limits access to personal information to those employees of Western Union and its affiliates who need it to fulfill their business responsibilities. Employees must adhere to Western Union privacy policies. Employees violating these policies may be subject to disciplinary action, up to and including dismissal. Vendors and other outside contractors we engage are subject to our contractual requirements to ensure that sensitive personal information is safeguarded.

WE USE APPROPRIATE SECURITY SAFEGUARDS.

At Western Union, security is a priority. We employ appropriate measures to protect consumer information against unauthorized access, disclosure, alteration or destruction. These may include, among others, encryption, physical access security and other appropriate technologies. Western Union continually reviews and enhances its security systems, as necessary.

WE MAINTAIN PROCEDURES TO ASSURE THE QUALITY OF INFORMATION WE COLLECT AND WHERE APPLICABLE, WE WILL INFORM CONSUMERS ABOUT HOW THEY CAN ACCESS THEIR PERSONAL INFORMATION AND MAKE CORRECTIONS, IF NECESSARY.

Western Union employs appropriate measures to assure the quality of information we collect directly from consumers. Where information is collected by Western Union directly from consumers or sources other than our business customers, we permit them, if possible, to dispute or correct any erroneous or out-of-date personally identifiable information. Of course, this correction would not be possible if the information is proprietary to one of our business customers, reflects historical transaction information or if correction would violate the privacy or legal rights of a third party. Where applicable, we abide by laws related to such information. You can access your registration information by clicking on the "Sign In/Register" button. You can correct factual errors in your personally identifiable information by sending us a written request that credibly shows error. Call the customer service number listed below for details. We reserve the right to independently verify claims made. To protect your privacy and security, we also will take reasonable steps to verify your identity before making corrections. We reserve the right to assess a service charge for providing you with any information in connection with your request.

THE WESTERN UNION� WEBSITE IS NOT DIRECTED AT CHILDREN UNDER THE AGE OF 13.

OOur website is not directed at children under the age of 13 and Western Union does not collect or maintain information at our website from those we actually know are under the age of 13.

WESTERN UNION'S WEBSITE MAY BE LINKED TO OTHER WEBSITES

Western Union may create links to third party websites. Western Union is not responsible for the content or privacy practices employed by websites that are linked from our website.

OPT OUT RIGHT (NON-VERMONT CONSUMERS)

Western Union may disclose consumer information to third parties as described earlier in this notice. Many of these disclosures are beneficial to consumers because they permit goods and services of interest to consumers to be offered to consumers at attractive rates. We strive to give consumers choices about how their data will be used. You have the right to opt-out of (direct us not to make) these disclosures when the consumer information is about you. Of course, there are some disclosures to third parties that are not subject to the opt-out, such as disclosures necessary to effect, administer or enforce a transaction requested by you, to companies that perform services for us or to prevent fraud.

If you wish to opt out, simply check the "opt out" box and submit your choice during the registration or transaction process, or call the customer service number listed below. You always have the right to change your mind. If you do not opt out, we'll assume that you have agreed that Western Union may use your personal information to determine what goods and services you may be interested in, offer you goods and services that we think meet your needs, disclose your personal information to third parties, and for the other purposes described herein.

Western Union maintains the information it collects on each transaction for a fixed time period. In the event you perform a transaction and exercise your right to opt out, your information and your opt out decision will be maintained for the fixed time period. In the event you do not perform another transaction during the fixed time period, your personal information, as well as your opt out election, will be removed from our records. After the removal of your information from our records, you will have to exercise your right to opt out again if you provide us with your information again.

VERMONT CONSUMERS

Western Union will not disclose nonpublic personal information about you to nonaffiliated third parties (other than as permitted by law) unless you authorize us to make that disclosure. Your authorization must be in writing, or, if you agree, in electronic form. If you wish to authorize us to disclose your nonpublic personal information to nonaffiliated third parties, you may either write to us at P.O. Box 66970, St. Louis, MO 63166-9882, or send us an email at [email protected]. Your written or electronic authorization must contain your name, address and signature and state that you authorize us to disclose your nonpublic personal information to nonaffiliated third parties. You may revoke your consent at any time by calling us at 1-800-562-2598, or by writing or emailing us at the addresses provided above.

PERMISSION MARKETING EMAILS

Beyond communications required as part of terms of service (order confirmations, shipping details, etc.), users will occasionally receive information on products, services, special deals, and/ or a newsletter via email. Users who no longer wish to receive from westernunion.com our email newsletter and promotional email communications may indicate such wish by updating your profile on www.westernunion.com (you can access your profile by clicking on the "Sign In/Register" button), by clicking on a designated URL supplied at the bottom of each email, by contacting us via email at [email protected] or by contacting our customer service center at 1-800-562-2598.

WE HOLD OURSELVES ACCOUNTABLE TO OUR PRIVACY PRINCIPLES.

Western Union is committed to meeting the highest standards for our privacy program. To that end, Western Union has appointed a senior official, who serves as the company-wide officer with responsibility for the administration and implementation of the Western Union privacy program.

The Western Union officer, working closely with individual business units, is responsible for:

Administering employee privacy training and employee compliance related to the Western Union Privacy Policies;

Conducting periodic assessments of Western Union's compliance with its Privacy Policies, as well as specific implementation policies and procedures; and

Ensuring that Western Union actively participates in appropriate privacy activities, including self-regulatory initiatives.

If you have any questions or comments about Western Union's Online Privacy Statement, or for some reason believe we have not adhered to our statement, please contact us at the customer service number listed below.

As stated above, this Western Union Online Privacy Statement is currently only applicable to our website customers and visitors in the United States. As we develop websites for international audiences, we may adopt additional rules and practices consistent with this statement to conform to the policies or requirements of those countries. We may alter this statement as needed for certain products and services and to abide by local laws or regulations around the world. Western Union reserves the right to amend or modify this statement from time to time. We urge you to review this statement whenever you visit in order to obtain the most current statement. You may change your choices at any time.

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