American Express Travelers Cheques

Sharing & Disclosure · Context

The table sets out which sharing American Express does and whether you can limit it

The notice says all financial companies need to share customers' personal information to run their everyday business. The table that follows lists the reasons financial companies can share, whether American Express shares for each reason ("Does American Express share?") and whether you can limit that sharing ("Can you limit this sharing?").

Supporting quotations

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 American Express chooses to share; and whether you can limit this sharing.

Reasons we can share personal information | Does American Express share? | Can you limit this sharing?

Qualifications & exceptions

• Each row below answers two separate questions in two columns; "Yes" under the first does not imply a choice under the second.

Sharing & Disclosure · Company practice

Shares for everyday business purposes; you cannot limit it

For its everyday business purposes the table says American Express shares personal information (Yes) and that you cannot limit this sharing (No). The row gives examples of such purposes: processing your transactions, maintaining your account(s), responding to court orders and legal investigations, or reporting to credit bureaus.

Supporting quotations

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No

Qualifications & exceptions

• The purposes are introduced by "such as", so they are examples, not a complete list.

Not stated here

• The row does not name who receives the information.

Sharing & Disclosure · Company practice

Shares for its own marketing; table says you cannot limit, with a separate marketing choice

For its own marketing purposes, to offer its products and services to you, the table says American Express shares personal information (Yes) and that you cannot limit this sharing (No), but points to the "To limit direct marketing" box for additional privacy choices.

Supporting quotations

For our marketing purposes – to offer our products and services to you | Yes | No (but please see the “To limit direct marketing” box below for information about additional privacy choices)

Qualifications & exceptions

• The additional choices are described in the "To limit direct marketing" box and concern offers communicated by mail, telephone and/or e-mail.

Not stated here

• The row does not say whether those additional choices stop the sharing itself or only the communications.
• The row does not name who receives the information.

Sharing & Disclosure · Company practice

Shares for joint marketing with other financial companies; you cannot limit it

For joint marketing with other financial companies the table says American Express shares (Yes) and you cannot limit this sharing (No). The definitions describe joint marketing as a formal agreement between nonaffiliated companies that together market financial products or services to you, and say American Express's joint marketing partners include financial companies.

Supporting quotations

For joint marketing with other financial companies | Yes | No

A formal agreement between nonaffiliated companies that together market financial products or services to you.

Our joint marketing partners include financial companies.

Qualifications & exceptions

• The definition says partners "include" financial companies, which does not limit them to that group.

Not stated here

• Partners are not named.

Sharing & Disclosure · Company practice

Shares transactions and experiences with affiliates; you cannot limit it

For its affiliates' everyday business purposes, the table says American Express shares information about your transactions and experiences (Yes) and you cannot limit this sharing (No). This is a different row from sharing creditworthiness information with affiliates, which you can limit.

Supporting quotations

For our affiliates' everyday business purposes – information about your transactions and experiences | Yes | No

Qualifications & exceptions

• The row is limited to information about your transactions and experiences.

Sharing & Disclosure · User right or choice

Shares creditworthiness information with affiliates; you can limit it

For its affiliates' everyday business purposes, the table says American Express shares information about your creditworthiness (Yes) and that you can limit this sharing (Yes). The notice adds that for an American Express account with a Vermont billing address, American Express will automatically treat the account as if you had directed it not to share creditworthiness information with affiliates.

Supporting quotations

For our affiliates' everyday business purposes – information about your creditworthiness | Yes | Yes

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• The Vermont paragraph applies to an account with a Vermont billing address.

Not stated here

• The notice does not say whether the Vermont paragraph reaches travelers cheque purchasers who have no American Express account with a billing address.

Cross-references

• qualified by (model-proposed): Vermont billing address: treated as a direction not to share creditworthiness information with affiliates — For accounts with a Vermont billing address, American Express treats the account as already directed not to share creditworthiness information with affiliates, which qualifies the table row that says it shares this information and you can limit it.

Sharing & Disclosure · User right or choice

Shares so affiliates can market to you; you can limit it

For its affiliates to market to you, the table says American Express shares personal information (Yes) and that you can limit this sharing (Yes). The notice repeats that federal law gives you the right to limit affiliates from using your information to market to you.

Supporting quotations

For our affiliates to market to you | Yes | Yes

affiliates from using your information to market to you

Not stated here

• The row does not describe how the limit works beyond the contact steps in the "To limit our sharing" box.

Sharing & Disclosure · Company practice

Does not share for nonaffiliates to market to you, apart from aggregated or de-identified data

For nonaffiliates to market to you, the table says No, with the parenthetical "although we may share aggregated or de-identified data", and answers the limit column with "We don't share personal information".

Supporting quotations

For nonaffiliates to market to you | No (although we may share aggregated or de-identified data) | We don't share personal information

Qualifications & exceptions

• The "No" is qualified by the parenthetical about aggregated or de-identified data.

Not stated here

• The notice does not define aggregated or de-identified data.
• The notice does not say who receives aggregated or de-identified data or for what use.

Cross-references

• contrast (model-proposed): Nonaffiliates include service providers acting on American Express's behalf — The table answers No to sharing for nonaffiliates to market to you, while the definitions say the nonaffiliates American Express shares personal information with include service providers such as direct marketers that act on its behalf. The notice does not explain how the two fit together; this is a reviewed tension in wording, not a finding that either is wrong.

Sharing & Disclosure · Company practice

Nonaffiliates include service providers acting on American Express's behalf

The definitions describe nonaffiliates as companies not related to American Express by common ownership or control, financial or nonfinancial. They say the nonaffiliates with which American Express shares personal information include service providers, for example direct marketers, that perform services or functions on its behalf.

Supporting quotations

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, including, for example, direct marketers, that perform services or functions on our behalf.

Qualifications & exceptions

• The list is introduced by "include" and "for example", so it is not exhaustive.
• The service providers act "on our behalf".

Not stated here

• The notice does not explain how sharing with direct marketers acting on American Express's behalf relates to the table's "No" for nonaffiliates to market to you.

Cross-references

• contrast (model-proposed): Does not share for nonaffiliates to market to you, apart from aggregated or de-identified data — The table answers No to sharing for nonaffiliates to market to you, while the definitions say the nonaffiliates American Express shares personal information with include service providers such as direct marketers that act on its behalf. The notice does not explain how the two fit together; this is a reviewed tension in wording, not a finding that either is wrong.

Sharing & Disclosure · Context

Affiliates are related companies, financial and nonfinancial

The definitions describe affiliates as companies related by common ownership or control, financial or nonfinancial. American Express's affiliates include companies with the American Express name, including financial companies such as American Express Travel Related Services Company, Inc. and nonfinancial companies, and may also include other related companies such as AMEX Assurance Company, a provider of American Express Card-related insurance services.

Supporting quotations

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Our affiliates include companies with the American Express name, including financial companies such as American Express Travel Related Services Company, Inc. and nonfinancial companies.

Affiliates may also include other companies related by common ownership or control, such as AMEX Assurance Company, a provider of American Express Card-related insurance services.

Qualifications & exceptions

• "Include" and "may also include" mean the named companies are examples.

Not stated here

• The notice does not list the nonfinancial affiliates.

Sharing & Disclosure · Company practice

New customers: sharing can begin 30 days after the notice; sharing continues after you leave

If you are a new customer, American Express can begin sharing your personal information 30 days from the date it sent the notice. When you are no longer a customer, American Express continues to share your personal information as described in the notice; you can still contact it at any time to limit its sharing.

Supporting quotations

Please note: If you are a new customer, we can begin sharing your personal information 30 days from the date we sent this notice.

When you are no longer our customer, we continue to share your personal information as described in this notice.

Qualifications & exceptions

• The 30-day period runs from the date the notice was sent.

Not stated here

• The notice does not say when a person stops being a customer of a travelers cheque product.
• The notice does not say how long sharing continues after a person is no longer a customer.

Sharing & Disclosure · User right or choice

Federal law lets you limit only three kinds of sharing; state law may add rights

The notice explains why you cannot limit all sharing: federal law gives you the right to limit only sharing for affiliates' everyday business purposes of creditworthiness information, affiliates using your information to market to you, and sharing for nonaffiliates to market to you. State laws and individual companies may give additional rights to limit sharing, and the notice refers to the "Other important information" section below, which includes California and Vermont paragraphs.

Supporting quotations

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 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.

Other important information

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Qualifications & exceptions

• The California and Vermont paragraphs apply to accounts with those billing addresses.

Not stated here

• The notice does not say what state-law rights apply beyond the California and Vermont paragraphs, or whether the state paragraphs reach travelers cheque purchasers without an American Express account.

Sharing & Disclosure · Permission or license

AMEX Assurance customers: information may be disclosed to detect fraud, verify coverage, and to regulators

For AMEX Assurance Company customers the notice says personal information may be disclosed by American Express to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, law enforcement or other governmental authority pursuant to law, or to a group policyholder for purposes of reporting claims experience or conducting an audit.

Supporting quotations

Personal information may be disclosed by us to detect fraud or misrepresentation, to verify insurance coverage, to an insurance regulatory authority, law enforcement or other governmental authority pursuant to law, or to a group policyholder for purposes of reporting claims experience or conducting an audit.

Qualifications & exceptions

• The statement is made for AMEX Assurance Company customers and uses "may".
• Disclosure to governmental authorities is stated as "pursuant to law".

Not stated here

• The notice does not say how often these disclosures happen or whether they apply to travelers cheques.

Sharing & Disclosure · Restriction or exception

California billing address: no sharing except as California law permits

For an American Express account with a California billing address, the notice says American Express will not share personal information except to the extent permitted under California law. The notice also says state laws may give additional rights to limit sharing.

Supporting quotations

California: If your American Express account has a California billing address, we will not share your personal information except to the extent permitted under California law.

State laws and individual companies may give you additional rights to limit sharing.

Qualifications & exceptions

• Applies to an American Express account with a California billing address.

Not stated here

• The notice does not say what California law permits or how this paragraph interacts with the Yes and No answers in the table.
• The notice does not say whether the paragraph reaches travelers cheque purchasers who have no American Express account.

Sharing & Disclosure · Restriction or exception

Vermont billing address: treated as a direction not to share creditworthiness information with affiliates

For an American Express account with a Vermont billing address, the notice says American Express will automatically treat the account as if you had directed it not to share information about your creditworthiness with its affiliates. The definitions describe affiliates as companies related by common ownership or control.

Supporting quotations

Vermont: If your American Express account has a Vermont billing address, we will automatically treat your account as if you have directed us not to share information about your creditworthiness with our affiliates.

Companies related by common ownership or control.

Qualifications & exceptions

• Applies to an American Express account with a Vermont billing address.
• Limited to information about creditworthiness.

Not stated here

• The notice does not say whether the paragraph reaches travelers cheque purchasers who have no American Express account.

Cross-references

• qualifies (model-proposed): Shares creditworthiness information with affiliates; you can limit it — For accounts with a Vermont billing address, American Express treats the account as already directed not to share creditworthiness information with affiliates, which qualifies the table row that says it shares this information and you can limit it.