Privacy Policy
PAYFAR INTERNATIONAL LIMITED

We are committed to protecting your privacy

This document outlines the policy on handling the personal information that PayFar International Limited (hereafter "PayFar" or "we") and its related companies collect about individuals including customers and potential customers.

PayFar recognises the importance of privacy and we are committed to protecting your personal information. We are required to comply with the Privacy Act 1988 (Cth) which provides for the fair handling of personal information, and sets standards for the collection, access, storage and use of personal information. Our policy for dealing with any personal information that you disclose to us is explained below.

ABOUT THIS PRIVACY POLICY

This Privacy Policy outlines how we manage your personal information. It also describes generally the types of personal information held, for what purposes, and how that information is collected, held, used and disclosed.

This policy together with our General Terms of Services apply to your:

  1. Use of our website at (www.payfar.com) ("Website");
  2. Use of the PayFar Mobile App ("Application") once you have downloaded a copy of the Application onto your mobile device or handheld device ("Device");
  3. Use of any of the services accessible through the Application or the Website (the "Services"); and
  4. Dealings with us in writing or in person.

By dealing with PayFar, you consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. We encourage you to check our website regularly for any updates to our Privacy Policy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us.

WHY DOES PAYFAR NEED YOUR PERSONAL INFORMATION?

Understanding and meeting our customers’ needs is a central part of our business. We do this by providing the Services to you.

PayFar collects, holds, uses and discloses its customers’ personal WHY DOES PAYFAR NEED YOUR PERSONAL INFORMATION?

information to establish, manage and provide these services. We may also use and disclose personal information for related purposes, such as arranging for services to be provided by third parties and enhancing our customer service and product options (see the section ‘Will my personal information be used for Direct Marketing?’).

In addition, we are required by law to collect some personal information. Such laws include (but are not limited to) the Anti- Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth), the National Consumer Credit Protection Act 2009 (Cth), the U.S Foreign Account Tax Compliance Act, Financial Sector (Collection of Data) Act 2001 (Cth) and other regulatory legislation, and the Taxation Administration Act 1953 (Cth), the Income Tax Assessment Act 1936 and 1997 (Cth) and other taxation laws and regulations.

Generally, the purpose for which PayFar collects personal information will be apparent from the way in which we collect it, or will be disclosed at the time of collection. If at any time the purpose for which we are collecting your personal information is unclear, please raise your concerns initially with the person you are dealing with or direct your concern to our Privacy Officer.

By retaining our services, you provide your consent to PayFar collecting and handling your Personal Information in accordance with this policy. Such consent may be withdrawn at any time upon written notice.

HOW AND WHAT TYPES OF PERSONAL INFORMATION DOES PYAFAR COLLECT?

We may ask for a range of personal information to assist us in providing you with relevant Services. PayFar will not collect personal information unless the information is reasonably necessary for one or more of our functions or activities. How we collect personal information also depends on the nature of your dealings with us. PayFar will collect your personal information directly from you whenever it is reasonable and practical to do so.

We will collect and process the following information and data about you:

  1. ("Provided Information") Information and details you provided Payfar: This is information you give us by filling in forms on the Application and/or on the Website, or by corresponding with us (for example by email, or via the support chat functions on the Application or on the Website). It includes information you provide when you register to use the Application, download or register the Application, subscribe to any of our Services, enter into any transaction on the Application or the Website, participate in discussion boards or other social media functions on the Application or the Website, enter a competition, promotion or survey and when you report a problem with the Application, the Services, or the Website. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, International Bank Account Number, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, driving licence and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services and any Know Your Customer requirements.
  2. ("Device Data") Information we collect about you and your device: Each time you visit the Website or the Application we will automatically collect the following information:
    1. technical information, including the internet protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting;
    2. information about your visit, including the full uniform resource locators ("URL"), clickstream to, through and from our Website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
    3. transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or the third party associated with the transaction, IP address of sender and receiver, sender's and receiver's name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used;
    4. information stored on your Device, including if you allow and provide PayFar access to contact information from your address book, login information, photos, videos or other digital content and check ins. The Application will periodically recollect this information in order to stay up-to-date; and
    5. details of your use of our Application or your visits to our Website including transaction details relating to your use of our Services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
  3. ("Location Data") Information about your geographical location: We use Global Positioning System (“GPS”) technology and your IP address to determine your location – this may be used when the Application is running in the foreground and the background of your Device. This is used to prevent fraud, (for example if your Device is saying that you are based in Australia but your Device is being used to enter into a transaction at point of sale purchase in England, we may not allow that transaction to be processed). Our fraud-prevention measures require this personal data for the feature to work. You can withdraw your consent to providing Location Data at any time by disabling location permission for the Application within your device settings.
  4. ("Third Party Data") Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, people authorised by you (such as lawyers and accountants), credit providers, public sources of information 9such as public directories), market research organisations search information providers, credit reference agencies, credit reporting bodies, fraud prevention agencies, government organisations, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions. Please see the 'Disclosure of your Information' section for more information.

HOW WILL PAYFAR USE THE INFORMATION PROVIDED

In this section PayFar provides an overview of the key types of information and data that we use as part of providing the Services.

PayFar uses the information held about you in the following ways:

  1. We will use Provided Information:
    1. to carry out our obligations arising from any transactions you enter into with us, for example transfer of funds, top up or reduction of funds, electronic money exchanges, point of sale transactions and to provide you with the information, products and services that you request from us;
    2. to provide you with information about other Services we offer that are similar to those that you have already purchased or enquired about;
    3. to provide you, or permit selected third parties to provide you, with information about services we may feel interest you;
    4. to verify your identity to protect against fraud, comply with financial crime laws, anti-money laundering legislation, AUSTRAC requirements , and to confirm your eligibility to use our Services.;
    5. to inform you of any changes to our Services;
    6. to facilitate social interactions through our services and to make you aware if any of your contacts who are users of PayFar services and have location services enabled, are in the same area as you.
    7. to ensure that content from our site is presented in the most effective manner for you and for your computer and your Device.
  2. We will use Device Information:
    1. to administer our Website and the Application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    2. to improve our Website and Application and to ensure that content is presented in the most effective manner for you and for your computer and your Device;
    3. to allow you to participate in interactive features of our Services;
    4. as part of our efforts to keep our Website and Application secure and safe;
    5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    6. to make suggestions and recommendations to you and other users of our Application and Website Site about the goods or services that may interest you or them;
    7. to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and Services; and
    8. to comply with our regulatory obligations.
  3. We will use Location Information:
    1. to deliver relevant advertising to you, for example, information on nearby merchants, or our partners;
    2. to protect against fraud; and
    3. to make you aware if any of your contacts, who are PayFar users and have location services enabled, are in the same area as you. You can switch off location services in relation to this feature in the privacy settings of the Application.
  4. We will combine Third Party Data with information you give us and information we collect about you. We will use this information and the combined information:
    1. to help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your PayFar account;
    2. for the purposes set out above (depending on the types of information we receive).

We may associated any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

WILL MY PERSONAL INFORMATION BE USED FOR DIRECT MARKETING?

We may also use and disclose your personal information to keep you informed about the range of services offered by PayFar. Personal information of individuals is only used to market relevant products and services specific to that individual.

You can opt out of receiving direct marketing from us at any time (see the ‘How can you contact PayFar about privacy’ section below).

We may use your personal data (such as your Provided Information, Location Data, or transaction data) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

PayFar will not disclose your personal information to a third party for the purposes of direct marketing unless you have given your express consent for such disclosure and use. However, we may provide them with aggregate information about you. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users.

WHAT HAPPENS IF I DO NOT PROVIDE INFORMATION THAT HAS BEEN?

It is your choice whether to provide your personal information. However, if you don’t, we may be unable to fulfil your request for a specific Service or may affect our ability to properly analyse your personal circumstances to effectively perform the Services offered by PayFar.

DOES PAYFAR COLLECT SENSITIVE INFORMATION?

We sometimes need to collect and use sensitive information. Sensitive information may include information or an opinion relating to a person’s racial or ethnic origin, political views or memberships, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices and criminal record. It also includes information about a person’s health and medical history.

The Australian Privacy Principles set out circumstances in which sensitive information may be collected and used.

Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.

DEALING WITH UNSOLICITED PERSONAL INFORMATION

Where it becomes apparent that a communication contains unsolicited personal information that would not otherwise be lawfully requested or used, PayFar will make reasonable efforts to delete, destroy or de-identify the record of such personal information.

Where it is impracticable to delete, destroy or de-identify (for example, where the unsolicited information is combined with necessary information) the record will be retained. PayFar will take all reasonable steps to protect the personal information against loss, unauthorised access, use, modification or disclosure, and against other misuse.

CAN YOU REMAIN ANONYMOUS OR USE A PSEUDONYM WHEN DEALING WITH US?

We understand that anonymity is an important element of privacy and some members of the public may wish to be anonymous when interacting with us. We also understand some members of the public may wish to use a pseudonym. If you wish to remain anonymous or to use a pseudonym when dealing with us, we may be able to provide you with limited information or Services, such as general details about our service offerings.

However, in many cases it will be impractical for us to assist you if you wish to remain anonymous or use a pseudonym. For example, we are generally not permitted to issue allow a funds transfer or foreign exchange transaction to a person without first collecting their personal information. Further, the provision of many Services we provide are highly personalised.

Because of this, if you choose not to identify yourself or wish to use a pseudonym, we may be unable to provide you with the specific Service you want. It may also affect our ability to properly analyse your personal circumstances, so our recommendations may not be completely appropriate or suitable for you.

HOW DOES PAYFAR PROTECT YOUR PERSONAL INFORMATION?

PayFar is committed to keeping your personal information secure. Whether your personal information is gathered through the Website, the Application, face to face meetings or by interacting with us via mail, internet or other methods, we take reasonable steps to store your information securely. We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats.

The data that we collect from you will be transferred to, and stored at, a destination inside Australia. As we provide an international service your data may be processed outside of Australia in order for us to provide our Services. We will need to process your personal data in order for us, for example, to action a request made by you to execute an international payment or transfer, process your payment details, provide global anti-money laundering and counter terrorist financing solutions and provide ongoing support services. We will take all steps to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Application or our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We take a number of steps to protect personal information from misuse, interference and loss, unauthorised access, modification or improper disclosure. These include instructing our staff and consultants who handle personal information to respect the confidentiality of customer information and the privacy of individuals.

All staff receive regular training regarding the obligation of PayFar and its offices, obligations to observe the Australian Privacy Principles in their day to day practices and are provided with our privacy procedure that details what information is to be stored, disclosed or otherwise handled.

While PayFar uses all reasonable endeavours to ensure that you provide personal information in a secure environment, no data transmission over the internet can be guaranteed as totally secure. Whilst PayFar maintains regular and up to date security checks, it does not accept responsibility for the security of information transmitted to us over the internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. PayFar’s Website and Application may contain links or plug-ins to other websites and applications. We are not responsible for the content of or the privacy practices or policies of those sites.

If you chose to use our chat or forum features, ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

WHO DOES PAYFAR SHARE PERSONAL INFORMATION WITH?

From time to time we may share your personal information with other entities both within and outside of PayFar. The entities that we might share your personal information with vary according to the product or service involved, but could include:

  1. other areas and organisations within PayFar providing our Services;
  2. external consultants, contractors, merchants and other parties authorised by PayFar;
  3. service providers and specialist advisers we engage to provide us with the Services such as administrative, financial or research services, some of whom may contact you on our behalf;
  4. other insurers, including insurance companies and credit providers;
  5. courts, tribunals and other dispute resolution bodies in the course of a dispute;
  6. credit reporting or reference agencies or insurance investigators;
  7. employers contributing to superannuation plans;
  8. anyone authorised by you or to whom you have provided your consent (either expressly or impliedly), including but not limited to other financial service providers that we may need to deal with on your behalf;
  9. anyone to whom we, or our service providers, are required or authorised by law to disclose your personal information for example, law enforcement agencies, and national and international government and regulatory authorities including but not limited to the Australian Taxation Office, AUSTRAC the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission; and
  10. other financial services institutions – in order to detect, investigate or prevent actual or potential fraud in connection with the products or services we provide to you.

In the event that PayFar believes that the use or disclosure of the personal information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of an enforcement body, PayFar will make a written note of such use or disclosure.

IS PAYFAR LIKELY TO DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?

PayFar may share information with international recipients located in, or have operations in, other countries. In these circumstances and under strict control, PayFar may authorise access to personal information by restricted persons in an overseas location for the purposes of providing you with services or in connection with the administration of PayFar. Such countries might include, but are not limited to New Zealand, the United Kingdom, France, Germany, the United States of America, Papua New Guinea, China ,Hong Kong, India, the Islamic Republic of Iran, South Africa, Gulf Arab States and Canada.

We take active steps to ensure that any external organisations with whom we share your personal information are subject to compliance with the Australian Privacy Principles or a commensurate policy and commitment to protect personal information.We take active steps to ensure that any external organisations with whom we share your personal information are subject to compliance with the Australian Privacy Principles or a commensurate policy and commitment to protect personal information.

Some advisers of PayFar may enter their own outsourcing arrangements to other countries. Those arrangements will be disclosed separately by the adviser to their respective clients. Please also note that personal information collected by one part of PayFar may be shared with other companies in the PayFar group for reasonable business purposes.

PAYFAR’S ADOPTION, USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

PayFar may request, record and use government identifiers for legitimate purposes in the conduct of its business as permitted by law.

For example, an individual’s tax file number may be sought, recorded and used to validly discharge taxation obligations. However, government identifiers will not be adopted as PayFar’s own identifier in respect of that individual.

HOW DOES PAYFAR UPDATE PERSONAL INFORMATION?

We realise that your personal information changes frequently – people move house, change jobs and update other personal circumstances on an ongoing basis. PayFar will take all reasonable steps to ensure that the personal information we hold is accurate, up-to-date, complete and relevant. Where PayFar holds personal information about you and it is found that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading, or you request that PayFar correct the information, PayFar will take such steps as are reasonably necessary to correct that information and to ensure that it is accurate, up to date, complete, relevant and not misleading.

Similarly, if PayFar corrects personal information about you that was previously disclosed to a third party, PayFar will take all reasonable steps to give notification to the third party of the correction.

If we believe the information we hold is incomplete or out of date, we may also seek to correct or complete our records by gathering data from other sources such as public records and other organisations.

In the event that PayFar refuses to correct the personal information that you have requested, PayFar will give written notice as to the reasons for refusal and mechanisms available for complaint.

HOW LONG WILL PAYFAR KEEP YOUR INFORMATION?

We may be legally required to maintain some of your records for a significant period of time. However, once we believe information held by us is no longer needed we may remove any identifying details or destroy the records entirely.

In Australia, pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF 06) as a designated service provider, we must retain personal data about you and your PayFar transactions for a period of ten years.

HOW CAN YOU CONTACT PAYFAR ABOUT PRIVACY?

You have the right to contact us to:

  • seek more information about anything contained in this policy, or to request a copy of this policy in a different format;
  • update or correct your personal information;
  • opt out of receiving direct marketing material;
  • ask about accessing or correcting the personal information we hold about you; or
  • • making a privacy related complaint, in one of the following ways:

HOW DO I FIND OUT ABOUT AND/OR ACCESS THE PERSONAL INFORMATION PAYFAR HOLDS ABOUT ME?

Under the Privacy Act you have the right to access the personal information we hold about you, with some exceptions. You can also request for us to correct any inaccurate, incomplete or out-of-date personal information. For security reasons, an access form outlining what information you require must be completed. Access forms can be obtained by contacting us as set out above.

PayFar is permitted to refuse access to personal information in certain situations. Examples include (but are not limited to) where:

  • giving access would have an unreasonable impact on the privacy of other individuals;
  • giving access would be unlawful, or where denying access is required or authorised by and Australian law or a court order;
  • information relates to existing or anticipated legal proceedings (and would not be accessible through process of discovery);
  • request for access is frivolous or vexatious;
  • giving access would prejudice enforcement body related activities;
  • giving access would reveal commercially sensitive information;
  • both of the following apply;
    • we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in; and
    • giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
  • giving access is likely to interfere with law enforcement activities.

PayFar will respond to a request for access within a reasonable period after the request is made and will give access to the information in the manner requested by the individual if it is reasonable and practicable to do so. Before providing the requested information we reserve the right to give you an estimate of any potential costs that would reasonably be incurred by PayFar in retrieving archived data.

Upon PayFar declining access to information because of one of the above conditions, it will take such steps as are reasonable in the circumstances to give access in a way that meets the needs of the entity and the individual. Similarly, PayFar will provide reasons for the refusal and the mechanisms available for complaint.

WHAT SHOULD I DO IF I HAVE A COMPLAINT?

Your privacy is important to PayFar and we will make every effort to resolve your concerns.

To raise any concerns you might have in relation to privacy, please contact us via the contact channels listed below this section. If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you can ask for your concerns to be escalated to PayFar’s Privacy Officer.

We take privacy-related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest and fair in dealing with your concerns. In most cases, we’ll contact you within (14) working days of receiving your complaint to let you know what actions we are taking regarding the matter. If you are not satisfied with our handling of your complaint or we have not replied to you within a reasonable period of time, then you may be entitled under applicable law to make a complaint to the relevant regulator.

CONTACT CHANNELS

In writing: The PayFar Privacy Office

If you still have concerns, further assistance may be available from:

Australian Financial Complaints Authority (AFCA) Online: www.afca.org.au
Email: [email protected] Phone: 1800 931 678 (free call)
Mail: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001
or
The Office of the Australian Information Commissioner Phone: 1300 363 992
Website: www.oaic.gov.au Email: [email protected]

WHAT ABOUT PRIVACY AND THE INTERNET?

This statement outlines some privacy issues specific to PayFar’s website.

WHAT IS A COOKIE AND HOW DOES PAYFAR USE COOKIES?

We use cookies to monitor your use of our website, to observe behaviour, compile aggregate data and provide you with a more effective service. Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on the website, when you return to the website, where you came from, and to ensure your information is secure. The purpose of this information is to provide you with a more relevant and effective experience on PayFar’s Website, including presenting web pages according to your needs or preferences.

We use cookies to give you access to certain pages of the Website without having to log in each time you visit. PayFar may also use external service providers to track the traffic and usage on the website.

Cookies are frequently used on many websites and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of PayFar’s Website if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website. We therefore recommend you enable cookie acceptance to benefit from all the services on the website.

LINKS TO THIRD PARTY WEBSITES

PayFar’s Website and Application has links to external third party websites that benefit the user.

ABOUT THIS POLICY

Any information we hold is governed by the most current PayFar Privacy Policy. The policy is available via our website www.payfar.com, or you can contact us about obtaining the policy in different formats (see the ‘How can you contact PayFar about Privacy’ section).

This policy is reviewed from time to time to take account for new laws and technology, and changes to our operations and practices, and to make sure it remains appropriate in the changing environment.

This policy applies to all PayFar entities operating in Australia. These include:

  • PayFar Australia

Certain PayFar entities may adopt additional procedures relating to the collection and handling of personal information. Such documentation does not detract from the PayFar Privacy Policy and any intra-related procedures between the PayFar entities intended to be read together.

FURTHER INFORMATION ON PRIVACY

Further information may be obtained on privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.privacy.gov.au .

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