Customer Privacy
Policy and Procedures
ABOUT THIS POLICY
This Privacy Policy ("Policy") applies to the websites under Hong Lan Services Inc, the Goitien247 mobile applications, and any other programs, websites, or applications owned and operated by Hong Lan Services Inc that reference this policy.
This Policy, along with our User Agreement (and any additional terms mentioned therein), governs your use of our Services.
Capitalized terms used in this Policy (such as Agreement, Profile, Services, and Transaction) have the same meanings as defined in our User Agreement unless otherwise specified in this Policy.
NOTICE TO RESIDENTS
Notice at Collection of personal information: We list the categories of personal information that we collect below under "What Personal Data Do We Collect." We collect personal information about you for business and commercial purposes as described below under "How Do We Use or Process Your Personal Data." For more information, including on how to opt-out of the sale or sharing of personal information, please see "US State Privacy Rights" section below.
1. About This Policy
2. Who Are We?
3. What Personal Data Do We Collect?
4. How Do We Collect Your Personal Data?
5. How Do We Use or Process Your Personal Data"
6. Who Do We Share Your Personal Data With?
7. What Are My Privacy Rights?
8. How Do We Protect Your Data?
9. How Long Do We Retain Your Data?
10. Changes To This Policy
11. Links To Third Party Websites and Services
12. Referral Program Privacy Notice
13. Children
14. Privacy Policy Translation
15. Complaints
16. Contact
17. Region Specific Privacy Terms
18. US Consumer Privacy Notice
19. Other Important Information
WHO ARE WE?
Any personal data provided to or gathered by our Services is controlled by Hong Lan Services Inc., located at 9113 Bolsa Ave Suite 122, Westminster, CA 92683.
WHAT PERSONAL DATA DO WE COLLECT?
The personal data we collect from you depends on your interactions with us and our products and services. "Personal data" or "personal information" refers to any information related to an identifiable person. We may collect the following categories and specific types of personal data:
• Basic Identifying Information: This includes your full name, postal address, email address, phone number, date of birth, occupation, username or social media handle, and other similar identifiers.
• Payment Information: This includes your financial instrument details (such as debit/credit card) or bank account details.
• Government Issued Identification or Records: This includes your driver's license, state or country issued identification card, passport (including a picture of yourself with your identification documentation), social security number (SSN), proof of address records, and evidence of how you will fund your transaction (e.g., bank statement or pay slip).
• Geolocation Data: This includes information about your device's location, such as data derived from your device (e.g., based on a browser or device's IP address).
• Transaction Information: This includes your transaction history/logs (including a unique transaction reference number), purpose of transfers, relationship with the recipient, and referral rewards.
• Recipient Information: This includes your recipient's full name, address, phone number, and, depending on the disbursement method selected, certain financial institution or financial account details such as bank account or mobile wallet account.
• Referral Information: This includes your contact's name and email address.
• User Generated Information or Content: This includes your communications with us and any other content you provide, such as social media profiles, photographs, images, videos, survey responses, comments, product reviews, testimonials, and information you provide for customer service (including chat) and other content.
• Technical Information: This includes the hardware and software you use to access our Services, network information, internet service provider, operating system, and the type of browser you use.
• Internet or Network Activity Information: This includes information on your interactions with our Services or Sites, or your browsing or search activity.
• Audio and Visual Information: This includes photographs, images, videos, and recordings of your voice (such as when we record customer service calls for quality assurance).
• Inferences: This includes information we may infer from the other information described above.
For California residents, please note that we may collect Sensitive Personal Information, including social security number, driver's license, state identification card, or passport number, and Protected Classifications under California and federal law, including gender and age.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect personal data about you from various sources. For example, we collect and obtain information:
Directly from You
We collect personal data you provide when you use our Services, create a profile, contact us (including via chat), respond to a survey, interact with us at events, participate in sweepstakes, contests, or other similar campaigns or promotions, post a review, or sign up to receive emails, text messages, and/or postal mailings.
From Other Sources
We may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, social media platforms or networks, fraud prevention or identity verification service providers, electronic databases, credit reporting agencies, vendors that provide services on our behalf, or publicly available sources.
HOW DO WE USE OR PROCESS YOUR PERSONAL DATA?
Comply with Legal Obligations
We use personal data to comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against legal claims.
Security and Fraud Prevention
We use personal data to detect, investigate, prevent, or take action against potential malicious, deceptive, fraudulent, or illegal activities. This includes fraudulent transactions, attempts to manipulate or violate our policies, procedures, and terms and conditions, security incidents, and any threats to the rights, property, or safety of Hong Lan Services Inc., our users, customers, employees, or others.
Comply with Applicable Laws
We use your personal data to adhere to applicable laws and regulations, such as those related to "know-your-customer" requirements, anti-money laundering laws, sanctions legislation, and associated regulatory rules and guidance. This includes activities related to risk investigation, risk scoring, fraud prevention, counter-terrorist financing, anti-money laundering, consumer protection, and complaint handling.
TO PERFORM A CONTRACT
To Provide Our Services
We use your personal data when you access or utilize our Services, including processing your Transactions, managing your account, delivering promotional offers or rewards (such as our referral program), and processing payments.
Communicating With You
We use your personal data to communicate with you, including responding to your requests, inquiries, issues, or feedback, and providing customer service.
CONSENT OR LEGITIMATE INTEREST
Marketing and Promotional Purposes
We use personal data for marketing and promotional activities, such as sending marketing, advertising, and promotional communications via email, text message, or postal mail; displaying tailored advertisements for products and services on social media and other websites; and administering new customer promotions, sweepstakes, contests, and similar campaigns.
Analytics and Personalization
We use personal data for research and analytics to enhance our services and products. This includes understanding your interactions with our websites, mobile apps, advertisements, and communications to improve our platforms and marketing efforts (business and marketing analytics). We also personalize your experience, saving you time during site visits, and customize the marketing and advertising content you see.
Other Business or Commercial Purposes
With your consent or direction, we may process specific personal data to fulfill other business or commercial purposes.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
In addition to the specific situations discussed elsewhere in this privacy policy, we disclose personal data under the following circumstances:
Corporate Affiliates
We may share personal data with our corporate affiliates, including our main office, affiliates, and agents. These corporate affiliates process personal data on our behalf to provide services or in other circumstances with your consent or as permitted or required by law.
Service Providers
We share certain personal data with third parties that provide services to support our core business functions and internal operations. This includes banks, disbursement providers, financial institutions processing your transfers or other financial service requests (including payment processors), identity verification or KYC service providers, third parties providing software and tools for postal mail, email, and text message communications, customer data analysis, marketing assistance, review administration, fraud investigation, customer surveys, and outsourced customer service providers.
Third Party Partners
We may share your personal data with third parties with whom we have partnered to jointly create and offer products, services, or joint promotions. Additionally, we may share your personal data with our banking or distribution partners if we suspect violations of our terms or fraudulent behavior related to our business. The use of your information by these parties is governed by their respective privacy policies, not by this privacy policy.
Social Media Platforms and Networks
Some of our websites feature plugins, widgets, or other tools provided by third parties that may collect or share information between us and the third party. For instance, if you use our referral feature to refer individuals via Facebook, YouTube, email, or SMS, their use of your information is governed by their own privacy policies, not by ours.
Legal Process
We may disclose personal data in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with applicable laws and regulations. We may also disclose information to establish, exercise, or defend legal rights, protect the safety and security of our visitors, detect and prevent fraud, and address potential illegal activities or violations of our policies.
Other Instances
We may seek your consent to share your information with third parties not described elsewhere in this Policy.
WHAT ARE MY PRIVACY RIGHTS?
Customers in certain regions around the world have specific data privacy rights under applicable privacy legislation, including U.S. federal or California state laws. We are committed to implementing robust privacy practices for all our customers.
Access Your Data & Data Portability
You can request a copy of your personal data held by us. We will provide this information promptly, subject to certain exceptions or limitations that may apply if providing such data adversely affects the rights and freedoms of others.
Correct Your Data / Data Rectification
You have the right to request corrections to inaccuracies in your personal data. You can update certain account information by logging into your account on our website or app.
Data Deletion/Erasure
You may request the deletion of your personal data, subject to applicable law. When you close your account, we will mark it as "Closed" in our database. Certain account information may be retained for a period to prevent fraud, comply with legal obligations, and assist law enforcement as necessary. Your personal data will not be used for further purposes or shared with third parties after account closure, except as required by law or outlined in this Policy.
Restrict Processing of Data Requests
You have the right to request restrictions or object to the processing or transfer of your personal data under certain circumstances.
Unsubscribe from Direct Marketing
You can request that we do not process your personal information for marketing purposes. You can exercise this right at any time by using the provided "unsubscribe" options. We respect your choice and will refrain from sending such communications. Please note, for compliance purposes, we maintain a suppression list of email addresses if you opt not to be contacted by email.
You may also manage how we use some of your personal data within our Services (such as communication preferences) by adjusting settings in your Profile. Note that certain communications, such as those required by law, cannot be opted out of entirely.
Automated Individual Decision-Making, Including Profiling
In certain jurisdictions, you have the right not to be subject to decisions based solely on automated processing of your personal data, including profiling, if such decisions have legal or significant effects on you. Exceptions may apply under relevant data protection laws.
Exercising Your Privacy Rights
To exercise any of the above privacy rights, please submit a request through one of the following methods:
• Sending us an email at customerservices@goitien247.com or
• Contacting us via Phone: (888)-880-8345
Identity Verification
For us to process some requests, we will need to verify your identity to confirm that the request came from you. We may contact you by phone or e-mail to verify your request.
HOW DO WE PROTECT YOUR DATA?
We adhere to industry-standard practices to safeguard the information you provide to us. Our measures include employing SSL (Secure Socket Layer) encryption technology to protect sensitive information like bank account numbers, credit card details, date of birth, and government identification numbers transmitted through our Site and/or App. Additionally, we require users to use security credentials (such as usernames and passwords) to access their information on our Site and/or App.
If you are provided with security credentials (e.g., a password) to access specific parts of our Service, it is your responsibility to keep these details confidential and secure. If you authorize access to our Services using your device's fingerprint (e.g., Apple Touch ID), do not allow others to register their fingerprint on your device to prevent unauthorized access, for which you may be held accountable. However, no method of transmission over the Internet or electronic storage is entirely secure. Therefore, while we strive to protect your personal information, we cannot guarantee absolute security, and any transmission of data is at your own risk. For security inquiries, please contact us at customerservices@goitien247.com .
HOW LONG DO WE RETAIN YOUR DATA?
We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including compliance with legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider factors such as:
Legal obligations and retention periods mandated by applicable laws or regulators
The volume, nature, and sensitivity of the personal data
Potential risks from unauthorized use or disclosure of personal data
The purposes for which we process your personal data and whether these purposes can be achieved through other means.
Please note, by using our Services, you explicitly consent to us retaining your personal data (including data related to your transactions and identity verification) for more than 5 years following the termination of your legal relationship with us. This extended retention period is essential for detecting and preventing fraud or other misuse of our Service.
CHANGES TO THIS POLICY
We reserve the right to modify this Policy at any time, and we will notify you of any changes by posting a revised version on our Site and App. Please review this Policy each time you conduct a transaction, as it may have been updated since you first registered for our Services or since your last transaction.
If you do not agree with any part of this Policy or any changes made to it, you have the option to terminate your agreement with us and close your Profile. You can do this by emailing us at customerservices@goitien247.com or contacting us by phone at (888)-880-8345.
LINK TO THIRD-PARTY WEBSITES AND SERVICES
Our Site and App may contain links to other websites with privacy practices that differ from those of Hong Lan. For instance, to verify your identity, we use IDology services. IDology verifies the validity of your identity documents and compares your photo with the photo on the documents. The results are shared with Hong Lan, and IDology uses your photo and ID documents to maintain, protect, and enhance its services. You can view IDology's privacy policy at https://www.idology.com/about-us/general-privacy-policy/.
If you provide personal information to any of these websites, your information is governed by their respective privacy policies. We do not accept responsibility or liability for these policies or for any personal information collected and processed through those websites or services (such as contact and location data). We encourage you to review the privacy policy of any website or software application you use or visit.
This Policy does not encompass the practices of third parties you engage with while using our Services, such as your mobile network operator or other users. Before providing any personal information to them, we recommend contacting them directly regarding their privacy policies.
REFERRAL PROGRAM PRIVACY NOTICE
When using our referral service via email to inform a friend about our Services, you will need to provide your friend's name and email address. Before giving us access to anyone else's details, you must obtain their prior consent to share their personal data with us, and we will inform them that you have provided their information to us.
If you have:
• Imported your contacts, upon your instruction, we will send an email invitation and, at most, one reminder email inviting them to visit our Site. We retain this information solely for the purpose of sending these emails.
• Referred a friend to us, we will automatically send your friend an email and, at most, one reminder email inviting them to visit our Site. We retain this information solely for sending these emails and tracking the success of your referral.
In both cases, your contact or friend may request at any time to have this information removed from our database, and we will comply with such requests. We will retain a copy of their email address on a "suppression list" to honor their request not to be contacted further. They are free to change their marketing preferences at any time.
CHILDREN
We request that individuals under the age of 18 (whom we classify as children and minors) refrain from using our Services or providing any personal information to us. Individuals under the age of 18 are not permitted to use our Services, and if we discover that someone under the age of 18 has registered a Profile with us, we will close it.
PRIVACY POLICY TRANSLATION
This Policy is written in English, and translations may be provided in other languages. You agree that in the event of any inconsistency between the English version and translated versions of this Policy in any dispute related to this Policy, the English version will prevail.
COMPLAINTS
If you have a complaint regarding our handling of your personal information, email customerservices@goitien247.com or contact us via phone: (888)-880-8345.
CONTACT
If you have any questions, comments, or requests regarding our privacy policy, you may reach out to customerservices@goitien247.com.
REGION SPECIFIC PRIVACY TERMS
We strive to uphold the highest privacy standards for all our customers, adapting to specific regional requirements where applicable. If you reside in certain regions, here are specific privacy rights that may pertain to you.
US STATE PRIVACY RIGHTS:
Explanation of Applicable Privacy Rights
If you are a California resident, you are entitled to the following privacy rights:
• Right to Know: You have the right to know what personal information we have collected about you, including the categories of personal information, sources from which it was collected, purposes for which it is used, categories of third parties with whom it is shared, and specific pieces of information collected about you.
• Right to Delete: You have the right to request deletion of personal information collected from you, subject to certain exceptions such as completing a transaction, detecting and preventing fraudulent or illegal activities, exercising legal rights, internal uses, or compliance with legal obligations.
• Right to Correct: You have the right to correct inaccurate personal information we may hold about you, with appropriate verification.
• Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the "sale" or "sharing" of your personal information as defined under California privacy laws.
If you reside in other states, you may have similar privacy rights, such as accessing, correcting, deleting, or obtaining a copy of your personal information. While we do not "sell" personal information, we may engage in "targeted advertising" as defined under Virginia law, and you have the right to opt-out of such sales or targeted advertising. You also have the right to challenge any denial of your privacy rights.
How to Submit a Request
To exercise your rights to know, delete, correct, or port your personal information under California or other state laws, or to appeal a denial of your privacy rights, please contact us via email at customerservices@goitien247.com or by calling us at (888)-880-8645. We may ask for specific information to verify your identity before processing your requests for access, deletion, correction, or portability.
We respect your privacy and will not discriminate against you for exercising your privacy rights.
DATA PROTECTION DISCLOSURES
What Categories of Personal Information Do We Collect and for What Purpose?
You can find a comprehensive list of the categories of personal information we collect in the "What Personal Data Do We Collect" section above. For information on the sources from which we obtain personal information, please refer to the "How Do We Collect Your Personal Data" section above. We collect and use personal information for the business or commercial purposes outlined in the "How Do We Use or Process Your Personal Data" section above.
Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
• Basic Identifying Information: Shared with Service Providers, Corporate Affiliates, Third Party Partners, advertising networks, and social media networks.
• Government Issued Identification or Records: Shared with Service Providers, Corporate Affiliates, and Third Party Partners.
• Device Information and Other Unique Identifiers: Shared with Service Providers, Third Party Partners, advertising networks, and social media networks.
• Internet or Other Network Activity: Shared with Service Providers, Third Party Partners, advertising networks, and social media networks.
• Geolocation Data: Shared with Service Providers, Corporate Affiliates, and Third Party Partners.
• Payment Information: Shared with Corporate Affiliates and applicable Service Providers engaged to assist in legal compliance related to risk scoring, fraud prevention, counter-terrorist financing, and anti-money laundering.
• Transaction Information: Shared with Service Providers, Corporate Affiliates, and Third Party Partners.
• Recipient Information: Shared with Service Providers, Corporate Affiliates, Third Party Partners, advertising networks, and social media networks.
• Referral Information: Shared with Service Providers, Corporate Affiliates, and Third Party Partners.
• User Generated Information or Content: Shared with Service Providers assisting in program administration, such as community or product reviews, and social media networks.
• Technical Information: Shared with Service Providers and Corporate Affiliates.
• Audio and Visual Information: Shared with Service Providers for customer service administration, identity verification for compliance with "Know Your Customer" regulations, and fraud prevention services.
• Inferences: Shared with Service Providers assisting in marketing and personalization efforts.
For more details on how your information is shared, please refer to the "Who Do We Share Your Personal Data With?" section. Additionally, we may disclose any of the above categories of information in response to Legal Process.
Our use of cookies or other tracking technologies may be considered a "sale" or "sharing" under applicable law. You may have the right to opt-out of having your personal data shared for targeted advertising purposes. We do not knowingly sell the personal data of consumers under 16 years of age.
Categories of Personal Information that may be considered a Sale or Sharing under California law: Basic Identifying Information, Device or Other Unique Identifier, Geolocation Data, Technical Information, and Internet or Network Activity Information.
Categories of third parties to whom the personal information was disclosed that may be considered a "sale" or "sharing" under California law: Certain Service Providers including advertisers, marketing partners, data analytics providers, and social media networks.
For further information regarding how your information is shared, please review the "Who Do We Share Your Personal Data With?" section, which provides additional insights into our Service Providers and Third Party Partners. Additionally, we may disclose any of the aforementioned categories of information in response to Legal Process.
US Consumer Privacy Notice
This Consumer Privacy Notice applies to individuals residing in the United States who use Hong Lan for personal, family, or household purposes.
What Does Hong Lan Do with Your Personal Information?
Why? Financial companies decide how they share your personal information. Federal law gives consumers the right to limit some, but not all, sharing. Federal law also requires us to disclose how we collect, share, and protect your personal information. Please carefully read this notice to understand our practices.
What? The types of personal information we collect and share depend on the products or services you have with us. This may include:
• Social security number and account information
• Transaction history and transaction information or instructions
How? All financial companies need to share customers’ personal information to conduct their everyday business. Below, we outline the reasons financial companies can share customers’ personal information, why Hong Lan chooses to share, and whether you can limit this sharing.
Reasons we can share your personal information | Does Hong Lan share? | Can you limit sharing? |
For our everyday business purposes— such as to process your transactions, maintain your account(s), or respond to court orders and legal investigations | Yes | No |
For our marketing purposes— to offer our products and services to you | Yes | No |
For joint marketing with other financial companies | Yes | No |
For our affiliates' everyday business purposes—information about your transactions and experiences | Yes | No |
For nonaffiliates to market to you | No | We do not share |
WHO ARE WE?
Hong Lan Services Inc.
WHAT DO WE DO?
How does Hong Lan protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We authorize our employees to access your personal information only when they need it to do their work, and we require companies that work for us to protect your information.
How does Hong Lan collect my personal information?
We collect your personal information, for example, when you:
• open an account or give us your contact information
• use Hong Lan to send or receive funds
We also collect your personal information from others, such as affiliates or other companies.
Why can't I limit all sharing?
Federal law gives you the right to limit only:
• sharing for affiliates’ everyday business purposes—information about your creditworthiness
• affiliates from using information to market to you
• sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
DEFINITIONS
Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf.
Joint Marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial companies and banks.
OTHER IMPORTANT INFORMATION
For California residents: If your Hong Lan account has a California mailing address, we will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account. We will limit sharing with our affiliates to the extent required by California law.
For other state residents: If your Hong Lan account has mailing address, we will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by other states law, unless you authorize us to make those disclosures.
QUESTIONS?
Contact us.