Home > Privacy Policy
Overview
To provide you with our services we need to collect information about you. Our aim is not to be intrusive, and we will not ask you unnecessary questions. Any information we receive about you will be subject to strict controls to minimize the risk of misuse – including unauthorized access to, or disclosure of, your personal data.
Please read this notice carefully, together with our Terms and Conditions and any other documents referred to in it. Here we set out the basis on which any information we collect about you or from you, or that you provide to us, will be processed by us and other parties in providing you with the services accessed through the website, apps or over the phone (“Oten Global Ltd.”). Oten Global Ltd(“our”, “us” and “we”) commits to using your information only in accordance with the terms of this Privacy Policy.
For the purposes of this Privacy Policy, the term “information” means any confidential and/or personal data or other information related to users of Oten Global Ltd– including, but not limited to, corporate and individual customers and their connected parties.
By visiting this website, our partners’ websites, or providing your personal information to one of our employees, for example by telephone or email, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.
This includes consenting to the processing of any sensitive personal information you provide, as described below in section 2. It also includes information you provide when you browse our website, request a quote, register for an account, enter into a contract for the provision of services, and when you contact us for other reasons.
If you have concerns about any of the terms of this Privacy Policy, please call us so that we can provide further information.
A special note about children
Children are not eligible to use Oten Global Ltd. We respectfully ask that minors (persons under the age of 18) do not submit any information to us or use Oten Global Ltd.
What information we collect
Information we may collect from you
We may collect and process the following information about you:
Information you provide to us
You may provide us with information by filling in forms on our website, our partners’ websites or by talking with us by over the phone or corresponding with us via email or otherwise.
This includes information you provide when you browse our website, request a quote, register for an account, enter into a contract for the provision of services, and when you contact us for other reasons.
Initial information
To use Oten Global Ltd, you must provide your name, address, phone number, and email address – and we may ask you to provide identity document number(s) and copies of identification documents, for example your driving license or passport, or a utility bill.
You may be asked to provide debit card details (including the long number, start and expiry dates and the card verification value code (CVV/CVC)) and your destination bank details (account number, sort code, IBAN, SWIFT, ABA or routing number).
We may also ask you to choose two different security questions to answer (such as your city of birth or your pet’s name). If we ask you to set up these security answers, we will be unable to provide our services unless you provide this information.
Additional verification information:
We may ask you to send us additional information if:
The additional information may include a copy of your driver’s license, passport, and/or a recent utility bill, or other information verifying your identity and address, or to answer additional questions to help verify your information.
We may also ask for evidence of source of funds or wealth, for example bank statement, investment statement, business transaction summary, proof of property sale or probate documents.
When we communicate
When you communicate with us for customer service or other purposes, including by phone, email or using other methods, we retain that information and our responses to you.
We may record calls on our telephone lines for quality control purposes, as evidence of transactions and to fulfil regulatory requirements. Any information you disclose to us will be held on these recordings, with the exception of debit card numbers, which are not recorded to comply with The Payment Card Industry Data Security Standard. We also record any phone number used to call us where a call is identified, and the number is not withheld.
We ask that you do not disclose sensitive personal information, including the state of your health, in any communication, however if you should do so voluntarily, you consent for us to hold that information in our communication records and phone recordings (see further details below).
Information we collect when you use our website
When you arrive at or leave the Oten Global Ltd website, we do not collect any information.
Transaction information
When you use Oten Global Ltd Services, we ask you to provide information related to your transaction. This information includes the amount, currency, and type of the transaction, source of funds, exchange rate, recipient name and bank details, recipient address for some jurisdictions and, optionally, the recipient’s email address and phone number.
Connected Parties
If it is necessary for you to provide personal information about other individuals in the course of dealing with us, for example regarding directors and shareholders of a company, or the other party to a joint account, you should do so only where you are authorized by those individuals.
Recipients
When you engage an individual who is not a Oten Global Ltd customer in a transaction, e.g., by sending a payment to that individual, we will retain the information that you submit to us, including, for example, the other party’s name and/or bank details.
Privacy policy notification to 3rd parties
Although the information on Connected Parties and/or Recipients is stored for a certain period of time in compliance with applicable law, we will not use it to market to the non-registered person.
Additionally, these persons have the same rights to access and correct information about themselves as registered users of Oten Global Ltd Services. You should bring this Privacy Policy to their attention at the earliest opportunity so they aware of how their information will be processed by us and aware of their rights in relation to that information.
Information about you that we receive from third parties
Fraud prevention checks
To protect ourselves and our customers against fraud, we verify the information you provide with Anti-Fraud Agencies and Electronic Identity Verification Services. In the course of verification, we receive information about you from such services.
If you register a debit card or bank account with Oten Global Ltd, we will use card authorization and anti-fraud screening services to verify that your bank or card information and address match the information you supplied to Oten Global Ltd, and that the card has not been reported as lost or stolen.
Identity verification using Electronic Verification Providers
Any electronic identity check with a credit agency may leave a record on your credit file. By agreeing to the terms of this Privacy Policy, you agree that we may carry out such searches in the knowledge that it may leave a record on your credit history. If you are a joint account holder, in certain circumstances credit agencies may link your record with your spouse, partner or other financial associates.
Background checks
We conduct a background check on all our customers (and for business customers, also on the business’s directors, shareholders and partners). During this process we will obtain information about you and/or your business, its directors, shareholders and partners, from an identity verification provider.
Sensitive data
Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent.
Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.
To avoid infringing these restrictions, it Oten Global Ltd’s policy that we do not ask for or collect any of the above data from you or any other party, so we therefore ask that you please do not reveal any sensitive data about yourself or others in any communication with us.
If you do reveal sensitive data, for example by phone or in an email, you will be giving express consent for us to process that information by storing the recording of the telephone call, or the email or other communication.
How we use your information
Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient and customized experience. By submitting your information to Oten Global Ltd and using Oten Global Ltd Services you agree that we may use your information for the following purposes:
Fulfilling your requests
We will use your information to:
Compliance and risk management
Our policy is to carry out background checks on individuals, companies and connected parties, and to monitor ongoing transactions. This is to prevent fraud and money laundering, including to help protect your accounts from fraudulent activity and to allow us to alert you and/or relevant law enforcement agencies if we detect such fraudulent activity on your account.
We carry out checks to ensure we do not deal with countries, entities or individuals that are subject to sanctions, to comply with counter-terrorist financing and anti-money laundering regulations and to identify high-risk individuals where we need to add additional controls. We also conduct investigations into actual or suspected violations of our Terms of Use.
Communication and customer service
We communicate with our users on a regular basis via email, phone and SMS to provide requested services and help you manage your account. These activities include:
We use your email and physical address to:
Users cannot opt out of these communications, but they will be primarily service-oriented rather than promotional.
As we are obligated to send these communications to current customers, if you do not wish to receive these communications at all, then unfortunately you must close your account, however if you do not wish to receive them in a particular way, please contact us to advise us of your preferred communication method.
Marketing
We also use your email address to send you other types of communications that you can control, including newsletters, customer surveys, and special promotions. These communications are to:
You can choose whether to receive some, all or none of these communications and the methods by which you receive them when you request a quote, enquire or complete the registration process (or at any time thereafter) by logging in to your account on the Oten Global Ltd website, visiting your profile page and accessing the preference center – or by calling us and amending your preferences over the phone. We may also send you SMS messages for the same purposes.
Service improvements and account management
We will use your information to deliver and improve Oten Global Ltd Services and manage your account, including:
Device information
We will use this information to:
Location information / IP (Internet Protocol) address:
We will use information about your location, derived from your IP address:
Third party information
We will combine third party information with information you give to us and that we collect about you. We will use all of this information:
Questionnaires, surveys, and profile data
From time to time we may offer you optional questionnaires, and surveys. If you choose to answer these questionnaires, we may use your information to improve Oten Global Ltd Services, send you marketing or advertising information, and for such purposes as collecting demographic information or assessing users’ interests and needs. You will be given notice of how the information will be used prior to your participation in the questionnaire.
Accessing and changing your information
You can review the information you have provided to us and make any desired changes to your information or to the settings on your Oten Global Ltd account at any time by logging in to your account on the Oten Global Ltd website, visiting the profile page and changing your details.
Cookies
Our website does not collect or use cookies.
Sharing information with third parties
To support our business and provide services to you
Just like most banks and financial/payment service providers, Oten Global Ltd works with third-party service providers (including banking partners and banking intermediaries) who provide important functions that allow us to make our money transfer services easier, faster, and safer.
This includes business partners under contract with us who support our business operations, such as fraud prevention, bill collection, marketing, customer service, contract administration and technology services. We need to disclose user data to them from time to time so that the services can be performed. Our contracts dictate that these business partners only use your information in connection with the services they perform for us and not for their own benefit.
By accepting this Privacy Policy and maintaining an account with Oten Global Ltd, you expressly consent to the transfer of your data to those third parties for the purposes listed.
Banks and payment providers
When you ask us to process a currency or payment transaction, we will provide your information to the business partners who are contracted to Oten Global Ltd to complete this transaction, for example passing bank details to correspondent bank(s) or payment provider(s) involved in the transaction. Anti-fraud, anti-money laundering, sanctions, and risk management. To carry out the checks described in section 3, we will provide your information to our third-party business partners who carry out these checks, including photographs of yourself or your identity documents that you have provided to us.
Legal process
We may disclose or share your information in order to enforce or apply the Terms and Conditions – and other agreements – between you and us, or to investigate potential breaches to protect the rights, property, or safety of Oten Global Ltd, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and, if required, to obtain professional advice.
Where required by law
We may disclose necessary information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental, or supranational bodies, competent agencies, departments, regulatory authorities, self-regulatory authorities, or organizations, and other third parties, including Oten Global Ltd affiliated companies, where we are legally compelled and/or permitted to do so.
Mergers and acquisitions
As with any business, it is possible that in the future Oten Global Ltd could buy, merge with, or be acquired by another company. We may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If Oten Global Ltd or a substantial proportion of its assets are acquired by a third party, information held by us about our customers will be one of the transferred assets, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.
Analytics and search engine providers
We share your IP address with analytics and search engine providers that assist us in the improvement and optimization of our site, and also for 3rd party advertising on 3rd party websites. See also our Cookie Policy.
Affiliates
If you are referred to us by a third party –via our affiliate network– depending on the arrangement, we may notify them when you book a transaction.
We may also share your personal data, including transactional information, with certain partners who have referred you to us.
We have a select group of affiliates to whom we occasionally refer customers. If we think you may benefit from these services, we will ask you if you would like us to pass on your details. We will always name the affiliate and ask you for permission before we refer you, and we will pass on your details only where you give us permission to do so. If we refer you, we will typically pass on your name, email address and telephone number.
Third party websites
Our site may, from time to time, contain links to the websites of our business partners and affiliates.
If you request a quote directly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly through Oten Global Ltd’s website) may be shared with the owner of any such third-party website.
Please note that these websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any information to third party websites.
Platforms with which our services are integrated
Some of services are available through integration on third party e-commerce platforms to facilitate your use of those platforms. In order to do so, information we collect about you may also be shared with the operator of those platforms in accordance. Information that we may share includes: your bank account details, “know your customer” information, and information about your account with us including transactions.
Transferring data overseas
Oten Global Ltd is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the USA.
The information that we collect from you may be transferred to, and stored in, a country outside the USA. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Each time you attempt to make a money transfer using your Oten Global Ltd account, Oten Global Ltd may transfer your relevant information to the recipient and any intermediate banks or payment service providers, who may be located outside the USA, and any other service providers as described above, in order to process, execute or otherwise deal with and provide information about the payment.
By submitting your information and making use of Oten Global Ltd Services, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.
We will do our best to protect your information, however we cannot guarantee the security of your information transmitted to our site or sent to us by email or other non-secure electronic methods; any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorized access.
Data Retention Policy
We are obliged by financial markets laws to retain account data for five (5) years after the closure of an account. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.
Systems Security Policy
Oten Global Ltd has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only authorized employees of Oten Global Ltd and our business partners processing data on our behalf have access to your personal data. All Oten Global Ltd employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by Oten Global Ltd to ensure that any of their employees who have access to your personal data have signed non-disclosure agreements. Contracts with business partners acting as data processors for Oten Global Ltd involving personal data require an adequate level of security and require that personal data is processed only as instructed Oten Global Ltd.
System security and monitoring
To ensure data privacy, confidentiality and integrity, all information disclosed, shared, stored or used and any transactions performed by you through our website is encrypted.
To provide a secure environment for our website and app, we hold your data in secure data centers with high levels of physical and technical security, including using firewall systems, data encryption and anti-virus protection. We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems. External security experts conduct regular security reviews on our systems, and we work with them to keep abreast of information security technology developments and implement relevant enhancement.
Password security
To control access to our services, every customer is required to input a Username and Password. To help us protect your information, you are advised to do the following:
Customer responsibilities
We keep our security technology up to date to protect your information, but we do not have control over the devices you use to access Oten Global Ltd Services.
It is your responsibility to safeguard your online information and transactions by taking all reasonable measures which may include the following:
You have the following rights:
To ask us to correct any information we hold about you if it is incorrect.
While we endeavor at all times to keep your information accurate, we welcome your corrections. You can correct your profile at any time by logging onto your account via the Oten Global Ltd website, or you can call your account manager to make any changes. We may ask you for additional verification information if you are changing certain details such as your name or your address.
To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.
Our Data Retention Policy (see section 7) explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future, but we will use that information for no other purpose.
To ask us to return to you information you provided to us, also known as ‘data portability’.
You can ask us to send you in electronic format the information you provided to us under our Terms and Conditions or under consent.
To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.
If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.
You cannot object to processing that is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.
To ask not to be subjected to automated decision making and profiling.
Oten Global Ltd puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.
To ask for a copy of the information we hold about you.
We will endeavor to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.
To ask not to be subjected to automated decision making and profiling.
Oten Global Ltd puts the human factor at the heart of our customer service, so there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.
To ask us not to process your information for marketing purposes.
You can do this by checking or unchecking certain boxes on the forms we use to collect your information, or by logging onto your account and managing your contact preferences, or by clicking on the ‘unsubscribe’ link(s) at the foot of every marketing or promotional email.
You may exercise any of the above rights by contacting us at ordiinc@buzint.com or by calling your Account Manager.
Contacting us
The Data Controller
The Data Controller is Oten Global Ltd, located at 4590 MACARTHUR BLVD, SUITE 500,NEWPORT BEACH, CA 92660.
If you want to exercise your right to access your information or have any questions about this Privacy Policy, Oten Global Ltd’s information practices, or your dealings with Oten Global Ltd, you can contact us by using this form, or by calling the customer service number located on our website, or by writing to us Oten Global Ltd, 4590 MACARTHUR BLVD, SUITE 500,NEWPORT BEACH, CA 92660.
Complaints to the Data Protection Officer
If you believe that we have breached a privacy law with which we should comply, please send an email to otengltd@buzint.com . We aim to respond in a reasonable time, normally within 30 days. Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.
Changes to this Privacy Policy
We may amend this Privacy Policy at any time, as new features are added to the Oten Global Ltd Services or as we incorporate suggestions from our customers. Any changes we may make will be posted on Oten Global Ltd website so please check back frequently.
Your continued use of our website after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, you may close your account at any time.
Consumer Privacy Notice
What does Oten Global Ltd 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 depend on the product or service you have with us.
This information can include, without limitation:
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Oten Global Ltd. chooses to share; and whether you can limit this sharing.
Why can we share your personal information?
| Does Oten Global Ltd share?
| Can you limit this sharing?
|
For our everyday business purposes –such as to process your transactions; maintain your account(s); respond to court orders and legal investigations; report to credit bureaus; gather information about website access, usage and performance; enhance your consumer experience; validate your creditworthiness or your identity; or as otherwise permitted or required by law.
| Yes | No |
For our marketing purposes –to offer our products and services to you or to notify you about future events and promotions. | Yes | No |
Who is providing this notice?
You are receiving this notice from Oten Global Ltd(a California Corporation).
How does Oten Global Ltd protect my personal information?
To help protect your personal information from unauthorized access and use, we endeavor to use reasonable security measures. These measures can include physical, electronic and procedural safeguards such as computer safeguards and secured files and buildings. We also endeavor to limit personal information access to only employees and representatives that need to know. Despite our 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 Oten Global Ltd or by misinforming you about our services.
How does Oten Global Ltd collect my personal information?
We collect your personal information, for example, when you:
We also collect your personal information from others, such as credit bureaus, affiliates, third party sources such as our business clients or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
What happens when I limit sharing for a transaction, I enter into jointly with someone else?
Your choices will apply to everyone on your account.
Definitions
Other Important Information
ONLINE ACTIVITIES:
We do not honor any Web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. In addition, other parties may collect personally identifiable information about your online activities over time and across different websites when you use our website or any of our services.
CHILDREN’S PRIVACY: Our website is not directed at children under the age of 13. Oten Global Ltd does not knowingly collect or maintain information at our website from persons under the age of 13.
Oten Global Ltd is not a Money Transmitter or Money Services Business. Oten Global Ltd is an agent and provides Services to its Customers under a private agreement.
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