Is an initial privacy notice needed for isolated transactions, such as purchasing traveler's checks?

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An initial privacy notice is generally not required for isolated transactions like purchasing traveler's checks. This is because privacy notices are typically designed to inform consumers about how their personal information will be collected, used, and shared over time, especially in contexts involving ongoing relationships or services. Isolated transactions, on the other hand, are usually one-time events that do not create an ongoing data collection scenario.

In regulatory terms, privacy notices are often mandatory in situations where a financial institution engages in a broader scope of data collection and sharing practices over time, which is typically not the case for single, one-off transactions. Thus, for a simple purchase of traveler's checks that does not involve establishing a continuous service or relationship, the requirement for an initial privacy notice does not apply.

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