First Global Data Corp.

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1 First Glbal Data Crp. Privacy Plicy As f February 23, 2015 Ding business with First Glbal Data Crp. ("First Glbal", First Glbal Mney, "we" r "us", which includes First Glbal Data Crp. s subsidiary, First Glbal Mney Inc. and their respective directrs, fficers, emplyees, cnsultants, affiliates and assignees) and using the "First Glbal Website" (which term includes and any and all First Glbal branded URLs which may be used by us frm time t time and all cmpnents theref) invlves prviding infrmatin abut yurself. We take yur privacy very seriusly and yu have cntrl ver hw yur infrmatin is cllected, used and disclsed by us. We als recgnize that the grwth f n-line services, including Internet services, has created additinal privacy cncerns, particularly fr cnsumers. First Glbal maintains strict privacy plicies in an effrt t safeguard persnally identifiable infrmatin ( PII ) and cmmunicatins frm unauthrized intrusins. Online privacy cncerns fcus primarily n the prtectin f PII which an individual r ther custmer reasnably expects t be kept private. As the term suggests, PII is infrmatin that, when assciated with an individual identifies that individual, fr example, a custmer s name, address, telephne number, address r credit card number. Thrugh the First Glbal Website (which term includes and any and all First Glbal branded URLs), Users can, amng ther things, send mney t thers. Fr the purpses f this Terms f Use Agreement, the services ffered by First Glbal include the First Glbal Website (and all cmpnents theref) and all gds and services ffered nw r in the future by First Glbal n r thrugh the First Glbal Website, including but nt limited t mneys transfers (cllectively, the "Services"). The fllwing is First Glbal s privacy plicy (this "Privacy Plicy"), which frms part f the First Glbal Terms f Use Agreement (the "Terms f Use Agreement") and is an integral part theref. By using the Services (including but nt limited t brwsing the First Glbal Website and/r registering with First Glbal as a Member), yu agree t be bund by this Privacy Plicy and the First Glbal Terms f Use Agreement. Terms nt therwise defined in this Privacy Plicy have the meanings ascribed t them in the First Glbal Terms f Use Agreement. What this Privacy Plicy Cvers This Privacy Plicy cvers First Glbal s treatment f the infrmatin we cllect when yu visit the First Glbal Website and/r when yu use the Services. This Privacy Plicy des nt apply t the practices f cmpanies that First Glbal des nt wn r cntrl r t peple that First Glbal des nt emply r manage, including withut limitatin, any f First Glbal s affiliates and business partners.

2 Infrmatin Cllectin and Use When yu create a Member Accunt and/r therwise use the Services, we require certain infrmatin, including but nt necessarily limited t yur name, phne number and address. We may autmatically receive and recrd nn-pii (i.e. infrmatin that des nt identify yu persnally) n the First Glbal Website server lgs frm yur brwser, including yur IP address, ckie infrmatin and the page yu requested. (User IP addresses may be recrded fr security and mnitring purpses.) We may use infrmatin fr the fllwing general purpses: t fulfill yur requests fr certain services, infrmatin and/r materials; and t prtect yu, First Glbal and/r ther Users frm errr, fraud and unauthrized access t and/r use f the Services. T help fight the funding f terrrism and mney laundering activities, Canadian law requires that we btain, verify, and recrd infrmatin abut Users. We may cllect PII fr that purpse frm yu frm time t time. Yu authrize First Glbal, directly and/r thrugh third parties, t make any inquiries we cnsider reasnable and/r necessary t validate the infrmatin that yu prvide t us. This may include asking yu fr additinal infrmatin, requiring yu t take steps t cnfirm wnership f yur address r financial instruments, verifying yur infrmatin against third party databases and/r thrugh ther surces. In additin t the freging, frm time t time we may be required t cllect infrmatin as may be required by law. Fr example, Canadian Users are directed t the Financial Transactins and Reprts Analysis Centre f Canada s website fr infrmatin cncerning Canadian requirements. Infrmatin Sharing and Disclsure by First Glbal First Glbal will nt share PII abut yu t ther cmpanies r persns except when: we have yur cnsent t share the infrmatin; we need t share the infrmatin with individuals and/r cmpanies wh wrk with and/r n behalf f First Glbal t prvide services t yu that yu have requested; we reasnably believe it is necessary t share PII: t investigate, prevent r take actin regarding ptentially illegal activity r activity that threatens the netwrk r therwise vilates the First Glbal Terms f Use Agreement, t investigate, prevent r take actin regarding situatins invlving ptential threats t the physical safety f any persn, r fr risk management purpses; we are required t disclse PII by reasns f a curt rder, subpena, search warrant, r ther legal prcess r in the case f imminent physical harm t the custmer r thers, r

3 t establish r exercise First Glbal s legal rights r defend against legal claims. Ckies and Usage Data When yu access the Internet, the cmputers that hst websites yu visit ( web servers ) autmatically receive sme annymus infrmatin. This usage data may include a recrd f which pages a web brwser has visited. The First Glbal Website's servers receive usage data when users visit the Website and pssibly when users visit ther sites as well. First Glbal and its advertisers may use varius kinds f sftware devices t cllect infrmatin abut Internet use. First Glbal may use ckies and ther tls t custmize the cntent and advertising yu receive based n the infrmatin yu prvide t First Glbal. The infrmatin used fr this feature des nt prvide yur PII r identify yu as an individual t third parties, but will invlve the prcessing f certain related data such as IP addresses. Small files called ckies may be attached t yur Web brwser and yur cmputer. Yu may be able t cnfigure yur brwser t accept r blck all r sme ckies, r ntify yu when a ckie is set. Each brwser is different, s check the "Help" menu f yur brwser t learn hw t change yur ckie preferences. Nte: Disabling ckies may mean that we wn't be able prvide certain services, which may be f use t yu. First Glbal may als use "web beacns" t access First Glbal's ckies inside and utside the First Glbal Website and in cnnectin with the Services. Links & Third Party Applicatins First Glbal may prvide, and the First Glbal Website may cntain links t ther websites. Althugh we strive t nly link t websites that share First Glbal s high standards and respect fr privacy, we are nt respnsible fr the cntent r practices emplyed by ther websites r parties. Third party applicatins (such as widgets) created by third party develpers may als be available n the First Glbal Website. Third party applicatins are small bits f sftware, ften with interactivity, that can be installed int prfiles r shared with ther Users. First Glbal des nt cntrl third party develpers and cannt dictate their actins. When yu engage with a third party applicatin, yu are interacting with the third party develper, nt with First Glbal. We strngly encurage yu t nt prvide PII t any third party unless yu knw the third party with whm yu are interacting. If yu g t anther web site, including an advertiser s web site (fr example by clicking n an advertisement), r request infrmatin r enter a cntest, be aware that yu may be authrizing anther cmpany, including an advertising cmpany, t use infrmatin yu supply. An advertiser's cllectin and use f infrmatin is subject t its wn privacy plicies, nt this ne. When yu leave an First Glbal Website via a link, access a third party applicatin (such as a widget) r click n an advertisement, yu shuld check the applicable privacy plicy f the third party r advertiser t determine, amng ther things, hw they will handle any PII they cllect frm yu.

4 Editing and Deleting Infrmatin Yu have the right t access, verify and update yur PII at any time, including whether yu want First Glbal t cntact yu abut specials and new services. Yu may mdify r remve any f yur PII (except fr yur name) at any time by ing us at First Glbal hnurs requests frm users t review all PII maintained in reasnably retrievable frm, and will crrect any such infrmatin which may be inaccurate. Yu may als verify that apprpriate crrectins have been made. Cnfidentiality and Security We have safeguards t prtect yur PII and we use cmmercially reasnable measures t safeguard PII in First Glbal s pssessin against lss, theft and unauthrized use, disclsure r mdificatin. Fr example: First Glbal Mney is secured by third party SSL Certificate, which means all PII and financial infrmatin is encrypted befre being transmitted thrugh the Internet. Infrmatin input in the First Glbal Website is als encrypted and secured with Third Party SSL Certificate. In rder t prtect against the lss, misuse and alteratin f the infrmatin under First Glbal's cntrl, First Glbal's database resides behind firewalls. The physical server where yur data is stred is prtected physically and electrnically. We maintain a replicatin f yur data, which is stred in a server in a different lcatin than ur main server, als prtected physically and electrnically. We peridically audit ur security plicy fr ensuring the prtectin f yur infrmatin. First Glbal uses reasnable methds t make sure that PII is accurate, up-t-date and apprpriately cmplete. We limit access t PII abut yu t peple wh, as part f their jb, we believe need t cme int cntact with that infrmatin t prvide services t yu. Despite First Glbal's high standards, n claim is made as t the impenetrability f the system under unusual circumstances r its resilience t future attacks. We wrk with majr banks and trusted retailers wrldwide t transfer yur mney directly t the Recipient s bank accunt(s) and/r facilitate cash pick up at retailers and bank branches. Verified by TRUSTe: TRUSTe Privacy Seal Prgram has certified First Glbal which means we fllw guidelines, reviewed by TRUSTe, fr safeguarding yur persnal infrmatin with highest level f industry standard. VeriSign Secure: First Glbal is secured by VeriSign SSL Certificate, which means all persnal infrmatin like yur User Name and Passwrd, and the infrmatin abut yur transactins are encrypted befre being transmitted thrugh the internet.

5 In the event that yu believe that yur persnal safety is at risk r if yu believe that yu may be the victim f identity theft r ther illegal cnduct, please cntact the apprpriate federal, prvincial r lcal law enfrcement agencies directly. Changes t this Privacy Plicy First Glbal will keep this Privacy Plicy current and as such may amend this Privacy Plicy frm time t time. First Glbal will infrm yu f any changes we make by sending a ntice t yu via and/r by psting an annuncement n the First Glbal Websites (as applicable). Questins / Suggestins / Cncerns If yu have questins, cncerns r suggestins abut First Glbal, the First Glbal Website r any First Glbal services, please feel free t us at If yu have questins, cncerns r suggestins abut this Privacy Plicy r its implementatin, please us at If yu ntice any unauthrized activity in yur Member Accunt, please immediately call ur tll free number +1(877) r us at We will take actin t secure yur Member Accunt and cnduct an investigatin and if it is determined that yur Username r passwrd was stlen resulting in an unauthrized use f yur Member Accunt we will refund yu the full amunt f the unauthrized Transactin. DO NOT BE MISLED BY S THAT APPEAR TO BE FROM US AND ASKYOU RE YOUR PERSONAL INFORMATION. IF YOU RECEIVE A SUSPICIOUS REQUESTING YOUR PERSONAL INFORMATION, PLEASE FORWARD THE IMMEDIATELY TO SO THAT WE CAN INVESTIGATE THE AND, IF NECESSARY, PROVIDE A SECURITY ALERT TO OUR USERS. PLEASE DO NOT SEND CONFIDENTIAL PERSONALLY IDENTIFIABLE INFORMATION SUCH AS PASSPORT NUMBERS, GOVERNMENT IDENTIFICATION NUMBERS, OR ACCOUNT NUMBERS TO FIRST GLOBAL VIA AN UNSECURED MESSAGE. YOU MAY SEND CONFIDENTIAL PERSONALLY IDENTIFIABLE INFORMATION TO FIRST GLOBAL VIA POSTED MAIL, PHONE OR USE THE CONTACT US LINK AVAILABLE ON OUR WEBSITE.

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