1. Introduction
NhanEX.com ("NhanEX", "we", "us", or "our") is a Money Services Business (MSB) operated by NHAN ENTERPRISES. This Privacy Policy explains how we collect, use, share, and protect your personal information in connection with our money transfer services (the "Services").
We are committed to protecting your privacy and complying with all applicable laws, including:
- Gramm-Leach-Bliley Act (GLBA): Requires financial institutions to explain how they share and protect customer information
- California Financial Information Privacy Act (CalFIPA): California-specific privacy requirements for financial institutions
- California Consumer Privacy Act (CCPA): Consumer privacy rights for California residents
- Bank Secrecy Act (BSA): Requires recordkeeping and reporting for financial transactions
2. Information We Collect
Personal Identification Information
- Full legal name
- Date of birth
- Residential address
- Phone number
- Email address
- Government-issued ID (driver's license, passport, or state ID)
Financial Information
- Bank account details
- Payment card information
- Transaction history and amounts
- Recipient information (name, bank account details, phone number)
Technical Information
- IP address and location data
- Browser type and version
- Device information
- Cookies and usage data
- Referring website URLs
Information from Third Parties
We may obtain information from:
- Identity verification services
- Credit reporting agencies
- Government databases
- Fraud prevention services
3. How We Use Your Information
We use your information for the following purposes:
- Processing Transactions: To initiate, process, and complete money transfers
- Identity Verification: To verify your identity and comply with KYC/AML requirements
- Legal Compliance: To comply with BSA, USA PATRIOT Act, and other legal obligations
- Fraud Prevention: To detect, investigate, and prevent fraud and other illegal activities
- Customer Service: To communicate about your transactions, account, and our Services
- Service Improvement: To improve our Services and user experience
- Marketing: With your explicit consent, to send promotional offers and updates
4. Legal Basis for Processing
We process your personal information based on:
- Contractual necessity: To fulfill our obligations under our agreement with you
- Legal obligation: To comply with federal and state laws (BSA, AML requirements, recordkeeping)
- Legitimate interests: To prevent fraud, improve Services, and protect our business
- Consent: For marketing and optional features, where you have provided consent
5. Information Sharing and Disclosure
Service Providers
We may share information with third-party service providers who perform services on our behalf, including:
- Identity verification and KYC services
- Payment processing partners
- Data analysis and security providers
- Customer support platforms
These providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed .
Legal and Regulatory Disclosures
We may disclose your information to:
- Law enforcement agencies: In response to lawful subpoenas, court orders, or government requests
- FinCEN and regulatory authorities: For SAR, CTR, and other required filings
- OFAC: To comply with sanctions screening requirements
- Governmental agencies: As required by state money transmission laws
With Your Consent
We will share your information with nonaffiliated third parties for purposes not described above only after obtaining your explicit consent, as required by CalFIPA .
Important: No Sale of Information
We do NOT sell your personal information to third parties.
6. Your Rights
For All Users
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete information
- Deletion: Request deletion of your personal information, subject to legal retention requirements
- Opt-Out: Opt-out of marketing communications at any time
For California Residents (CCPA)
If you are a California resident, you have additional rights:
- Right to Know: Request disclosure of categories and specific pieces of personal information collected about you in the past 12 months
- Right to Delete: Request deletion of your personal information, subject to exceptions (e.g., for AML compliance, fraud prevention, or legal compliance)
- Right to Correct: Request correction of inaccurate personal information
- Right to Opt-Out: Right to opt-out of the sale or sharing of personal information (we do not sell your information)
- Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights
To exercise your rights, please contact us using the information in Section 11.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, including:
| Record Type | Retention Period | Legal Basis |
|---|---|---|
| KYC/CIP Records | Minimum 5 years after account closure | BSA / 31 CFR 1010.410 |
| Transaction Records | Minimum 5 years from transaction date | BSA / 31 CFR 1010.410 |
| SAR/CTR Records | 5 years from filing date | 31 CFR 1022.320 |
| Account Information | Until account closure + 5 years | Legal requirement and business need |
We securely delete or anonymize information when it is no longer needed for legal or business purposes.
8. Data Security
We implement and maintain administrative, technical, and physical security measures designed to protect your personal information, including:
- Encryption: Data is encrypted in transit (TLS/SSL) and at rest
- Access Controls: Restricted access to personal information on a need-to-know basis
- Monitoring: Regular security audits and monitoring for unauthorized access
- Training: Employee training on data protection and privacy
- Incident Response: Established procedures for responding to potential data breaches
9. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete it promptly.
10. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on this page
- Updating the "Last Updated" date at the top
- Providing additional notification as required by law (e.g., email)
Your continued use of our Services after any changes constitutes acceptance of the revised Privacy Policy.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
- Address: 19621 CLANCY LN, HUNTINGTON BEACH, CA 92646
- Email: contact@nhanex.com
- Compliance Officer: business@nhanex.com
Privacy Rights Requests: For privacy rights requests (access, deletion, correction), please email us with "Privacy Request" in the subject line. We will verify your identity before responding to any request.
12. California Privacy Rights Notice
Under CalFIPA, financial institutions must notify customers of their right to opt-out of certain information sharing. We may share your nonpublic personal information with service providers to process transactions and with regulators as required by law. We do not share your information with nonaffiliated third parties for their own marketing purposes. Therefore, no opt-out is required for such sharing .
California residents may request an annual disclosure of the categories of personal information we have shared with third parties for direct marketing purposes, if any. To make such a request, please contact us as described in Section 11.