Privacy Policy
How we collect, use, and protect your information.
Effective Date: March 19, 2026. This Privacy Policy describes how Touswit collects, uses, and shares your personal information when you use our remittance services. Please review this policy carefully before using our services.
Contents
1. Information We Collect
We collect personal information necessary to provide remittance services and comply with federal and state money transmission regulations. This includes: (a) Personal identifiers such as your full legal name, residential address, date of birth, email address, and telephone number; (b) Government-issued identification documents including driver's license, passport, or state ID for identity verification purposes; (c) Financial information including payment card details, bank account information, and transaction history; (d) Recipient information necessary to complete transfers, including names and mobile wallet account details; (e) Device and usage information including IP address, browser type, operating system, and how you interact with our services; and (f) Information from third-party sources such as identity verification services and fraud prevention databases to ensure compliance with anti-money laundering regulations.
2. How We Use Your Information
We use the information we collect to: (a) Process and complete money transfers to Haiti, including routing funds to mobile wallets, schools, and businesses; (b) Verify your identity and comply with Know Your Customer (KYC) requirements under the Bank Secrecy Act and USA PATRIOT Act; (c) Prevent, detect, and investigate fraud, money laundering, and other illegal activities through transaction monitoring systems; (d) Comply with legal obligations including reporting suspicious activities to FinCEN and maintaining records as required by state and federal regulators; (e) Communicate with you about your transactions, account status, security alerts, and customer support inquiries; (f) Improve our services through analysis of usage patterns and customer feedback; and (g) Send you marketing communications about our services, which you may opt out of at any time.
3. Information Sharing and Disclosure
We share your personal information with: (a) Our partner institutions in Haiti, including Le Levier Federation, who facilitate local disbursement to recipients; (b) Payment processors and financial institutions that process your card or bank payments in the United States; (c) Identity verification and fraud prevention service providers who help us comply with regulatory requirements; (d) Technology service providers who host our infrastructure and provide security services; (e) Law enforcement, regulatory authorities, and government agencies when required by law or to comply with legal process, including suspicious activity reports to FinCEN; (f) Professional advisors including lawyers, accountants, and auditors who assist with our compliance programs; and (g) In connection with a merger, acquisition, or sale of assets, in which case the acquiring party will be bound by this Privacy Policy. We do not sell, rent, or share your personal information with third parties for their own marketing purposes.
4. Data Security
We implement industry-standard security measures designed to protect your information from unauthorized access, use, or disclosure. These measures include: (a) Encryption of data in transit using TLS 1.2 or higher; (b) Encryption of sensitive data at rest using AES-256 encryption; (c) Multi-factor authentication for account access; (d) Regular security assessments and penetration testing; (e) Access controls limiting employee access to personal information on a need-to-know basis; (f) Secure data centers with physical and environmental controls; (g) Monitoring and logging of system access and activities; and (h) Incident response procedures for security breaches. While we strive to protect your information, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.
5. Data Retention
We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specifically: (a) Transaction records are retained for at least five years as required by federal money transmission regulations; (b) Identity verification documents are retained for the duration of the business relationship and five years thereafter; (c) Communications and support records are retained for three years; (d) Marketing preferences are retained until you opt out or close your account; and (e) Account information is retained for seven years after account closure to comply with regulatory record-keeping requirements. After the applicable retention period, we securely delete or anonymize your information.
6. Your Rights
You have certain rights regarding your personal information: (a) Access: You may request a copy of the personal information we hold about you; (b) Correction: You may request correction of inaccurate or incomplete information; (c) Deletion: You may request deletion of your information, subject to our legal obligations to retain certain records; (d) Objection: You may object to processing of your information for direct marketing purposes; (e) Restriction: You may request restriction of processing in certain circumstances; (f) Portability: You may request transfer of your information to another service provider in a structured, commonly used format; and (g) Withdrawal of consent: Where we rely on consent, you may withdraw it at any time. To exercise these rights, contact us at hello@touswit.com. We will respond to your request within 30 days. Note that we may need to retain certain information to comply with legal obligations or complete transactions you have requested.
8. Third-Party Links and Services
Our website may contain links to third-party websites, including payment processors, social media platforms, and informational resources. We are not responsible for the privacy practices or content of these third-party sites. When you click on a third-party link, you leave our website and are subject to that site's privacy policy. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies only to information collected by Touswit.
9. Children's Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you are under 18, do not use our services or provide any information to us. If we learn that we have collected personal information from a child under 18 without parental consent, we will delete that information promptly. If you believe we may have information from a child under 18, please contact us at hello@touswit.com.
10. International Data Transfers
Your information is processed in the United States and may be transferred to Haiti for purposes of completing remittance transactions. By using our services, you consent to the transfer of your information to these jurisdictions, which may have different data protection laws than your country of residence. We ensure appropriate safeguards are in place, including: (a) Contractual obligations with our partners in Haiti requiring protection of personal information; (b) Compliance with applicable data protection regulations; and (c) Security measures consistent with this Privacy Policy. Our partner, Le Levier Federation, operates under Haitian regulatory oversight and maintains appropriate security controls.
11. California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA): (a) Right to know what personal information we collect, use, disclose, and sell; (b) Right to request deletion of your personal information; (c) Right to opt-out of the sale of personal information (note: we do not sell personal information); (d) Right to non-discrimination for exercising your privacy rights. To exercise these rights, contact us at hello@touswit.com or call us toll-free. We will verify your identity before processing your request and respond within 45 days.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by: (a) Posting the updated policy on this page with a new 'Last Updated' date; (b) Sending an email notification to the address associated with your account; or (c) Displaying a prominent notice on our website. We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes are posted constitutes acceptance of the updated policy.
13. Contact Us
If you have questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us at: Touswit, Inc., Email: hello@touswit.com, Address: Miami, Florida. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy. If you have an unresolved privacy concern that we have not addressed satisfactorily, you may contact your local data protection authority or the Federal Trade Commission.
Important Note: This Privacy Policy should be reviewed by qualified legal counsel before final deployment. It is provided as a framework for MVP demonstration purposes.