RELAYPAY– PRIVACY POLICY

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our services and website (Services). In this Privacy Policy we, us or our means RelayPay Pty Ltd ACN 630 143 823.

PERSONAL INFORMATION

Providing our services

The types of personal information we may collect about you, whether directly from you or from third parties, when providing our services to you include:
  • your full name;
  • your email;
  • a password for your account with us;
  • your mobile number if you choose to use our ATM withdrawal service;
  • your credit card, bank account or payment details for the purpose of providing our Services;
  • details of your bills where you wish to use our ‘pay a bill’ feature;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you; and
  • your sensitive information as set out below.

Verifying your identity

We are regulated by AUSTRAC and are required to take steps to comply with anti-money laundering and counter-terrorism financing laws. Accordingly, all users of our Service may be subject to Know Your Customer or Know Your Bank processes (as applicable). This requires that we verify your identity. We use a third party provider who is a registered identity service provider to perform this identity verification for us. For this purpose, the types of personal information we/our third party identity service provider may collect include:
  • your full name;
  • your date of birth;
  • your street address and/or mailing address; and
  • your identification documents, such as copies of your driver’s licence or passport, which may include images of you and/or sensitive information.
Sensitive information: Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Some of the above information is considered sensitive information as it may relate to your ethnicity or religion, if identified in your identification documentation.
How we handle sensitive information: Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including handling this information to verify your identity. Sensitive information may also be used or disclosed if required or authorised by law, including notably, anti-money laundering and counter-terrorism financing laws.

Via our website

The types of personal information we may collect about you, whether directly from you or from third parties, when providing our website to you include:
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; and
  • additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications and/or accounts from which you permit us to collect information.
Cookies:We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.
Web beacons: We may use web beacons on our website from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Google Analytics:We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please seehttps://policies.google.com/technologies/partner-sitesor any other URL Google may use from time to time.

COLLECTION AND USE OF PERSONAL INFORMATION

We may collect, hold, use and disclose personal information for the following purposes:
  • to enable you to access and use our Services and any associated applications;
  • to verify your identity;
  • to contact and communicate with you about our Services;
  • for internal record keeping, administrative purposes, invoicing and billing purposes;
  • to minimise risks and identify illegal activities;
  • for analytics, including to operate and improve our Services and any associated applications;
  • to offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • for any other reason permitted or required by law.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We may disclose personal information to:
  • service providers:third party service providers for the purpose of enabling them to provide their services o us, including (without limitation) identity verification service providers, IT service providers, data storage, web-hosting and server providers, maintenance or problem-solving providers, marketing or advertising providers and professional advisors;
  • our staff:our employees, contractors and/or related entities;
  • businesses we work with:our existing or potential agents or business partners;
  • financial institutions:banks or other financial institutions, for example if we need to investigate a payment;
  • a potential purchaser:anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies,
  • legal bodies:courts, tribunals and regulatory authorities;
  • regulatory bodies or law enforcement:regulatory authorities and law enforcement officers; organisations that help identify and prevent illegal activities; and
  • data processors:third parties to collect and process data, such as Google Analytics. This may include parties that store data outside of Australia.
Disclosure outside Australia: By providing us with personal information, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy law. You acknowledge that some overseas third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any third party engages in any act or practice that contravenes the Australian Privacy Principles, we will not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

RETENTION OF YOUR PERSONAL INFORMATION

We aim to keep your personal information only for as long as we need it. We may need it for business reasons or for legal reasons. We have an obligation under anti-money laundering and counter-terrorism financing laws to retain personal information collected for the purpose of providing our Services for 5 years after termination of the provision of our Services to you and to retain any personal information used to verify your identity for 7 years after termination of the provision of our Services to you.
Where we no longer need your personal information, we will take reasonable steps to destroy or de-identify it.

YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Services.
Anonymity:Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. You may also unsubscribe from our e-mail database or opt-out of marketing communications by using the opt-out facilities provided in the communication.
Access:You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.
Correction:If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints:If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the relevant authority.

STORAGE AND SECURITY

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

LINKS TO OTHER WEBSITES

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

AMENDMENTS

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at:

RelayPay Pty Ltd ACN 630 143 823

Email: email-adress

Last update: 10 December 2019