Consumer Privacy Policy

TeleGiro, Inc.

Effective Date: July 10, 2025

Our Privacy Commitment

TeleGiro, Inc. ("We," "Us" and "Our") is committed to respecting and protecting the privacy of Our consumers across all our digital financial services, including banking, payments, and remittances.

This privacy policy applies to personal information We collect about consumers when they:

Use our digital banking and wallet services
Initiate domestic or international payment transactions
Access our services through mobile applications or Our website
Otherwise provide personal information to Us

Privacy Statement

Our consumer privacy policy is summarized in this consumer privacy statement, copies of which are made available to consumers through Our website, mobile applications, and upon request.

What does TeleGiro do with your personal information?

Financial companies choose 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 tell You how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share

The types of personal information we collect and share depend on the product or service you have with us. This information can include (but is not limited to):

Contact Information:

Name, address, mobile and home telephone numbers
Email address
Emergency contact information

Identification Information:

Social Security Number
Driver’s license number, passport number or other government identification number
Date of birth
Citizenship and residency status

Financial Information:

Bank account information (including FBO accounts)
Debit and credit card information
Digital wallet account details
Payment history and preferences
Income and employment information

Transaction Information:

Transaction dates, amounts, and types
Sender and recipient information
Payment method details
International remittance details
ACH and wire transfer information

Digital Services Information:

Account credentials and authentication data
Digital wallet usage and preferences
Banking service selections
Enhanced wallet features usage

Technical Information:

Computer and mobile device information
IP address and geolocation data
Browser and operating system information
Mobile device identifiers
Log file information from website and app usage
Cookie data and similar technologies

Compliance Information:

Identity verification documents
Source of funds information
Beneficial ownership data
BSA/AML screening results
Risk assessment data

All financial companies need to share customers' and consumers' personal information to run their everyday businesses. In the section below, we list the reasons financial companies can share their customers' and consumers' personal information; the reasons TeleGiro chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

For our everyday business purposes:

Processing and Account Management:

Process your transactions including remittances, ACH transfers, checks, and wire transfers
Maintain your digital wallet and banking accounts
Provide access to FBO accounts through our banking partners
Validate your identity and creditworthiness
Enable payment processing through Checkbook Inc.

Service Enhancement:

Maintain your web-based and mobile application accounts
Gather information about service access, usage and performance
Enhance your consumer experience across all our financial services
Provide customer support in English and Spanish

Legal and Regulatory Compliance:

Cooperate with criminal or government investigations
Detect and prevent fraud, money laundering, and other illegal activities
Respond to court orders, subpoenas, and regulatory inquiries
Report to regulatory agencies including FinCEN as required under the Bank Secrecy Act
Comply with state money transmitter laws in Florida, New Jersey, and other jurisdictions
Meet requirements under the Gramm–Leach–Bliley Act and USA PATRIOT Act

Business Operations:

Share with our service providers, including:
- Checkbook Inc. (payment processing platform)
- Banking partners (FBO account services)
- Technology service providers
- Compliance and security vendors
In connection with a merger, acquisition or any form of sale of some or all of business
As otherwise permitted or required by law

Marketing and Communications:

Send you information about our products and services
Provide updates about your account and transactions
Send service notifications and alerts

Who is providing this notice?

TeleGiro, Inc., a Delaware corporation registered as a Money Services Business with the Financial Crimes Enforcement Network (FinCEN) and licensed as a money transmitter in:

Florida (License Number: FT230000431)
New Jersey (License Number: 2305779)

How does TeleGiro protect my personal information?

To help protect your personal information from unauthorized access and use, we use security measures that comply with federal law and industry best practices. These measures include:

Administrative Safeguards:

Employee training and access controls
Vendor management and oversight
Regular security assessments
Incident response procedures

Technical Safeguards:

Encryption of data in transit and at rest
Multi-factor authentication
Secure API connections with partners
Regular security updates and patches
Intrusion detection and prevention systems

Physical Safeguards:

Secured data centers
Access controls to facilities
Environmental controls
Secure disposal of records

We implement technical and organizational security measures designed to safeguard and protect your information from unauthorized access and improper use. We regularly review and enhance these measures as new technology becomes available.

In accordance with the FTC Safeguards Rule under the Gramm–Leach–Bliley Act, we maintain a comprehensive information security program that includes administrative, technical, and physical safeguards to protect customer information. This program is regularly tested and evaluated to ensure the security and confidentiality of customer records and information.

Despite our reasonable efforts, third parties may unlawfully intercept or access your transmissions to us or may wrongly instruct you to disclose information to them by posing as TeleGiro or by misinforming you about our services. Therefore, it is important that you always use good judgment when sending money and when using internet and mobile technologies.

How does TeleGiro collect my personal information?

We collect your personal information, for example, when you:

Account and Service Activities:

Open a digital wallet or banking account
Submit information on applications and forms
Link bank accounts or payment methods
Set up enhanced wallet features
Provide beneficiary information for remittances

Transaction Activities:

Send or receive money domestically or internationally
Use ACH, check, or wire transfer services
Make payments through our platform
Request transaction history or statements

Verification Activities:

Show a government issued ID
Complete identity verification processes
Provide proof of address or income
Answer security questions

Digital Interactions:

Use our online sites or mobile apps
Click on our online advertisements
Enter promotions or contests
Contact customer service

Third-Party Sources:

We also collect your personal information from a variety of sources, including:

Checkbook Inc. (our payment platform partner)
Banking partners and financial institutions
Consumer reporting agencies
Identity verification services
Government databases
Public records
Social media platforms (with your consent)

We may collect, track, and combine information across devices, platforms, and transaction channels to provide you with a seamless experience.

For how long does TeleGiro keep my personal information?

We retain your personal data for the period of time necessary to:

Satisfy the purposes outlined in this Privacy Policy
Comply with our record retention policies
Meet legal and regulatory requirements

As a regulated financial institution, we are required to maintain certain records for specific periods:

Transaction records: Up to 10 years following account closure
Identity verification records: 5 years after account closure
Customer communications: 5 years
Suspicious activity reports: 5 years
Other records as required by the Bank Secrecy Act, USA PATRIOT Act, and state regulations

Specific retention periods may vary depending on the type of information and applicable legal requirements.

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 your information to market to you
Sharing for non-affiliates 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.

Other Important Information

Children's Privacy

Our website, mobile applications, and financial services are not directed at persons under the age of 18. TeleGiro does not knowingly collect or maintain information from persons under the age of 18.

External Websites

Our website and applications may contain links to third-party websites, including:

Banking partner portals
Checkbook Inc. services
Government websites
Social media platforms

TeleGiro is not responsible for the content or privacy practices of websites that are linked to or from our website.

Online Activities

We use various technologies to enhance and secure your experience:

Session management for secure banking
Analytics to improve our services
Security monitoring to prevent fraud
Performance optimization

We do not honor "do not track" signals from web browsers. Other parties may collect information about your online activities when you use our services.

Cookies and Similar Technologies

We use cookies and similar technologies to:

Maintain secure banking sessions
Remember your preferences
Process transactions safely
Comply with regulatory requirements
Improve our services

For detailed information, please see our separate Cookie Policy available at www.telegiro.com/cookie-policy .

Data Security

We employ multiple layers of security to protect your information:

Encryption of sensitive data
Secure data centers with restricted access
Regular security audits and penetration testing
Employee background checks and training
Vendor security assessments
Incident response procedures

Third-Party Services

We work with carefully selected partners to provide our services:

Checkbook Inc.:

Provides payment processing platform
Maintains PCI-DSS compliance
Subject to their own privacy practices

Banking Partners:

Provide FBO account services
Subject to federal banking regulations
Maintain separate privacy policies

State-Specific Privacy Rights

California Residents

Under the California Consumer Privacy Act (CCPA), you have rights to:

Know what personal information we collect, use, and share
Request deletion of your personal information (subject to legal requirements)
Opt-out of the sale of personal information (we do not sell personal information)
Non-discrimination for exercising privacy rights

To exercise these rights, contact us at privacy@telegiro.com or (323) 546-9392.

New Jersey Residents

New Jersey residents may request information about:

Categories of personal information collected
How we use and disclose information
Your rights regarding your information

Contact: New Jersey Department of Banking and Insurance, Division of Banking
20 West State Street, PO Box 040, Trenton, NJ 08625-0040
Phone: (609) 292-7272

Florida Residents

Florida law requires us to inform you that we do not sell your personal information. For questions about our privacy practices:

Contact: Florida Office of Financial Regulation
200 East Gaines Street, Tallahassee, FL 32399
Phone: (850) 487-9687

Changes

TeleGiro reserves the right to modify this Privacy Statement. When we make material changes, we will:

Update the effective date
Notify you through our website or app
Provide notice via email for significant changes
Give you the opportunity to opt out of material changes in how we use previously collected information

You can always access the current Privacy Statement at www.telegiro.com/privacy.

Questions

Please contact TeleGiro with any questions regarding this Privacy Policy:

Phone: (323) 546-9392
Email: privacy@telegiro.com
Mail: TeleGiro, Inc., 100 Almeria Ave, Coral Gables, FL 33134

Data Protection Officer: dpo@telegiro.com

Compliance with Regulatory Requirements

As a registered Money Services Business, TeleGiro complies with:

Bank Secrecy Act (BSA) and USA PATRIOT Act:

Customer identification and verification
Suspicious activity monitoring and reporting
Currency transaction reporting
Record keeping requirements

Gramm-Leach-Bliley Act (GLBA):

Financial privacy protections
Safeguards Rule compliance
Annual privacy notices

State Regulations:

Florida and New Jersey money transmitter requirements
State-specific privacy laws
Data breach notification requirements

FinCEN Requirements:

MSB registration and reporting
Anti-money laundering program
Compliance officer designation