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.
This policy together with our General Terms of Services apply to your:
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.
Understanding and meeting our customers’ needs is a central part of our business. We do this by providing the Services to you.
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 Such consent may be withdrawn at any time upon written notice.
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:
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:
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.
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.
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.
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.
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.
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.
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.
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.
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:
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.
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 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.
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.
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.
You have the right to contact us to:
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:
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.
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.
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
The Office of the Australian Information Commissioner Phone: 1300 363 992
Website: www.oaic.gov.au Email: [email protected]
This statement outlines some privacy issues specific to PayFar’s 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.
PayFar’s Website and Application has links to external third party websites that benefit the user.
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:
Further information may be obtained on privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.privacy.gov.au .