WorldRemit Pty Limited - Australia Privacy Policy
Effective Date 1 December 2020
Introduction
Your privacy and keeping your personal information secure are extremely important to us. At WorldRemit, we are committed to protecting and respecting Your privacy and handling Your information in an open and transparent manner.
This Privacy Policy ("Policy") explains among other things: what we do with your personal information; what we do to keep it secure; with whom we share your information; your rights in relation to the personal information we hold about you; and who you can contact for more information.
We will regularly amend or update this Policy to reflect changes in our practices with respect to the processing of personal information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
For our customers located in the European Union
From 25 May 2018, the General Data Protection Regulation (GDPR) regulates the processing of personal information under European Union (EU) law. The GDPR aims to protect the information relating to individuals in the EU and harmonise data protection laws across EU Member States.
Our collection, use, disclosure and processing of your personal information is regulated by the GDPR if:
you interact with WorldRemit in the UK or EU;
we offer products or services to you whilst you are located in the EU; or
we monitor your behaviour whilst you are located in the EU.
Please refer to our privacy policy on WorldRemit Limited UK Privacy Policy for information about how we manage your personal information under GDPR.
If you don't want to read all the details. Here are the highlights that you may really wish to know:
WorldRemit is an online payments business that helps its customers transfer money globally.
We are bound by the Privacy Act 1998 (the 'Act'), which requires we protect your information and inform you about how we handle your personal information.
Where appropriate we share your personal information with our affiliates, partners and other companies. Upon request or where we are legally obliged, we may share your information with public agencies.
We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers). In providing this information you confirm to us that you have their permission to do so.
We use some third parties to process your personal information on our behalf to perform our services for you, and due to the international nature of our business some of them are based outside Australia.
You have several rights over your personal information and the manner in which you can exercise those rights are contained in this Policy.
We will send you direct Marketing if we are allowed to. We do this to encourage you to use our services and send you offers or promotions that may interest you. You can ask us to stop sending you marketing information at any time. Details of how to unsubscribe will be included on each email that we send you.
We will not collect sensitive information about you without your consent unless an exception in the Act applies. For example, if the collection is required or authorised by law.
Who we are?
WorldRemit Pty Ltd ("WorldRemit", "we", "us", "our") having its registered office at Level 3, 60 Martin Place, Sydney NSW 2000 is a data controller for the purpose of Privacy Laws (as defined below). In this Policy, references to "You" and "Your" are references to a user of our website and/or of our Mobile App.
Definitions
To help clarify our meaning, we have used certain capitalised terms in this Policy. These terms and their meaning are:
“Customer” means any individual who has registered with us or used any of our Services or inquired about any of our Services.
“Privacy Laws'' means the Privacy Act 1988 and other applicable legislation relating to privacy or data protection, such as the Spam Act 2007.
“Marketing” means any action or advertisement or promotion or marketing material like surveys, vouchers, research and events. This list is not exhaustive.
“Services” means WorldRemit Money Transfer Service; WorldRemit Digital Money Account; Airtime Top Up; and such other services or products that we may introduce from time to time.
The personal information we collect about you
We may collect, record and use information about You in physical and electronic form and will hold, use and otherwise process this data in accordance with the Privacy Laws and as set out in this Policy.
The personal information we collect and use may include, amongst other things:
Your Full Legal name;
Your contact information such as Your email address, postal address and telephone number (or any telephone number used to call our customer services);
Your demographic information such as date of birth, age, education, gender, and interests;
evidence of Your identity (for example Primary Photo ID document such as passport information, passport copy);
any correspondence or complaint made to us;
unique identifiers such as Your username, account number and password;
Your profiles and postings on any other social media applications and services that we provide or that You make available to us;
Your payment details and other financial data (for example, Your bank or payment method provider’s name and Your account number and sort code); and
information about Your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We will not collect sensitive information about you without your consent unless an exception in the Act applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. For example, we might collect your biometric information when confirming your identity.
We also collect from You information in relation to other people (for example, details of the recipients of Your money transfers), where You provide us with such information. In providing this information you confirm to us that you have obtained all necessary permissions from them to the reasonable use of their information for the purposes and in the manner described in this Policy, or are otherwise permitted to give us this information on their behalf. Please also ensure that those other people are aware of this notice and that the provisions of this notice are clearly communicated to them.
How we collect your personal information
Information You give to us when You use our services.
If You use our services You will need to provide certain information including Your name, address and card number, as well as the name and other details of the recipients of the money transfers that you instruct us to carry out.
This information must be complete and accurate, and if not we may have to take additional steps to complete the transaction.
Other information You give to us.
This is information about You that You give us by filling in forms on our website (for example, the ‘contact us’ section) or when you communicate with us by phone, e-mail or otherwise. It includes, for example, information You provide when You register on the website for us to contact You, when You inquire about any of our Services, and when You report a problem with our website. The information You give us may include, among other data, Your name and email address.
Social Media
. Depending on Your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram, You might give us permission to access information from those accounts or services.
Other Sources.
We may receive information about You from other sources, including publicly available databases and combine this data with information we already have about You. This helps us to update, expand and analyse our records and provide services that may be of interest to You.
Information we collect about You.
Like most websites, we use "cookies" to help us make our site – and the way You use it – better. Cookies mean that a website will remember You. They are small text files that websites transfer to Your computer (or phone / tablet). They improve website use and speed – for example by automatically filling Your name and address in text fields. Please see our
Cookies Policy
for further information.
Log Files.
In addition, with regard to each of Your visits to our site, we will automatically collect certain information (for example, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data). We may combine this automatically- collected log information with other information we collect about You.
Social Media Widgets.
Our website includes Social Media Widgets or Features, such as the Facebook Like button and Twitter button which are interactive mini-programs that run on our site to provide specific services from another company (e.g. displaying the news, opinions, music, etc). Personal information, such as Your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it.
Personal information from third parties.
If we receive personal information about you that we do not request directly from you or from another party, we will decide whether we could have collected the information in accordance with this Policy and Privacy Laws. If so, we will keep the information and handle it in accordance with this Policy and applicable Privacy Laws. If we decide that we could not have collected the personal information in accordance with this Policy and applicable Privacy Laws, we will destroy or anonymise the information if it is reasonable and lawful to do so.
Mobile App.
When You download our Mobile App, in addition to the information mentioned above we:
automatically collect information on the type of device You use, operating system version, and system and performance information. We may send You push notifications from time-to-time in order to update You about events or promotions that we may be running. If You no longer wish to receive these types of communications, You may turn them off at the device level. To ensure You receive proper notifications, we will need to collect certain information about Your device such as operating system and user identification information;
may collect Your location-based information for the purpose of locating a place that You may be searching for in Your area. We will only share this information with our mapping provider for the sole purpose of providing You with this service. Your geo-location data may be shared with third parties for the purpose of serving You ads for places (such as restaurants) in Your area. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at
dataprivacy@worldremit.com
; and
may use mobile analytics software to allow us to better understand the functionality of our Mobile Software on Your device. This software may record information such as how often You use the Mobile App, the events that occur within it, aggregated usage, performance data, and where the Mobile App was downloaded from. We do not link the information we store within the analytics software to any personal information You submit within the Mobile App
Cookies and similar technologies
When you visit our site or use a Mobile App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may use your personal information through Cookies and similar technologies, in accordance with our Cookie Policy.
How we use your personal information
Our primary purpose in collecting user information is to provide You with a safe, smooth, efficient, and customised experience and to provide the services You have requested from us. We may also use the information that You have provided to ensure that the content on our site is presented in the most effective manner for You and Your computer or device.
We use Your information for the following specific purposes:
to carry out our obligations arising from any contracts entered into between You and us or from applicable law, and to provide You with the Services in accordance with our
terms and conditions
and with this Policy;
to register You with a WorldRemit account;
to fulfil Your Transaction / (Airtime Top Up) Request;
to send You confirmations;
to notify You about temporary or permanent changes to our services or other service-related messages;
to assist you where online applications are not completed;
to prevent fraud, money laundering, and any other illegal activity that may cause you, us or others harm including in relation to the Services;
comply with our legislative and regulatory requirements in any jurisdiction;
to ensure that content from our site is presented in the most effective manner for You and for Your computer;
to promote our business;
to send You Marketing communications, provided that You have given us Your contact details except you tell us not to do so.
to administer our site and for internal operations, including troubleshooting, data analysis, profiling and segmentation analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our site, Mobile App and our services safe and secure;
to measure or understand the effectiveness of advertising we serve to You and others, and to deliver relevant advertising to You;
to make suggestions and recommendations to You and other users of our site about services that may interest You or them;
to train, monitor and assess the effectiveness of the manner in which we provide the Services to You;
to consider and investigate any concerns or complaints you may have; and
to display personal testimonials of satisfied customers on our website in addition to other endorsements, where You have agreed with a third-party review site that we may do so. If You wish to update or delete Your testimonial, You can contact us using
this form.
What laws require or authorise us to collect personal data
We are required or authorised to collect certain identification information about you by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No 1).
Direct Marketing
We may use your personal information to contact you via email, telephone, direct mail or other communication formats to offer you products and services we believe may be of interest to you but we will not do so if you tell us not to. When we market products and services to you, we will comply with applicable Privacy Laws to obtain your consent if required.
You can ask us to stop sending you Marketing information by contacting us at any time. Details of how to unsubscribe will be included on each electronic mailing we send you. Alternatively, simply send an email to dataprivacy@worldremit.com with “URGENT - UNSUBSCRIBE REQUEST” in the subject line and the email address that you wish to be removed within the email.
Please note that it may take up to 72 hours to process your request and update our systems. Also note that if you request that we stop sending you Marketing messages, we will not stop sending you service and administrative communications (such as transfer updates and other important or transactional information).
We partner with third parties who may use technologies such as cookies to gather information about Your activities on this site and other sites in order to provide You advertising based upon Your browsing activities and interests (see Who we may share your personal information with). If You do not want to receive any information used for the purpose of serving You interest-based ads, You may opt-out by sending an email to dataprivacy@worldremit.com with “URGENT - UNSUBSCRIBE REQUEST”. You may continue to receive generic advertisements.
Who we might share your personal information with
Your personal information is very important to us. However there are circumstances where it is necessary for us to share your information in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your personal information to:
Our affiliates
- we share your information with our affiliates and other companies within the WorldRemit Group:
for our internal business, operational, management and service needs;
for compliance, regulatory and audit activity and in connection with legal, regulatory and tax claims and investigations;
to understand and support our Customers who use our services, apps and sites, as well as visitors to those apps and sites; and
to send Marketing communications.
Third party processors
which include
people with whom we do business or who provides services to us. If we engage a third party processor to process your information, the Processor will be subject to binding contractual obligations to: only use the personal information in accordance with our prior written instructions; and use measures to protect the confidentiality and security of the personal information, together with any additional requirements.
We may disclose data to provide our services, to respond to legal requirements, enforce our policies, liaise with judicial or regulatory authorities where required under applicable law, and protect our rights and property.
Processors may include:
Credit reference agencies or other service providers to verify Your identity or the identity of recipients of the money transferred through our services or for any other purpose related to providing our services;
Debt collectors;
Professional advisers, such as our auditors and lawyers;
Companies that capture or analyse information to help us understand how our services, sites and Mobile Apps are used and perform or to tailor our services and promotions, including for the purpose of allowing us to improve the services we provide;
Companies that provide us with marketing assistance, including: the management of email marketing operations, SMS and other services that deploy marketing on the internet or social media platforms (such as Facebook and Google); the running of surveys and other feedback activity; as analysis of the effectiveness of any marketing or customer engagement we do;
Banks, payment card processors and other service providers that process bank transfers, credit and debit card payments or otherwise provide financial infrastructure services to enable us to provide our services;
Our service providers, including those who provide data hosting services, fraud prevention services; technology services, and technology tools that allow us to monitor, test and improve our services, sites and Mobile Apps;
Companies that we have instructed to provide services to or for us for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
Other business entities should we plan to merge with, or be acquired by, or be invested in by that business entity, or if we undergo a corporate reorganisation; and
Any successor in business to us.
Fraud Prevention Agencies
- Where we have a good reason to suspect fraud, money laundering, counter terrorist financing or any other illegal activity, we can upon request or where legally obliged share your personal information with crime prevention agencies and other third parties for the purpose of detecting, preventing or reporting crime or for actual or suspected breach of any applicable law or regulation. These third parties may include business partners and companies that provide services to us, law enforcement bodies, regulatory and supervisory authorities, providers of fraud prevention and detection services. Please note, we may suspend activity on your account or any transaction, refuse access to your account or cancel any transaction you may want to make, if we think there is a risk of any illegal activity.
Public Agencies
- We release accounts or other personal information when we consider it appropriate to comply with the law, to enforce our Terms and Conditions and any other agreement to protect the rights, property, or safety of WorldRemit, our employees or Customers, our business partners or others. In these circumstances, we will only provide them with the information they require to perform their function.
Research companies -
We may share personal information in a secure way to allow research companies and feedback providers to contact you directly on our behalf to get your opinions on or refuse to take part in the research or surveys.
International transfer of your personal information
Due to the international nature of our business, we may need to transfer your personal information to other WorldRemit entities, to other third parties as stated in the “Who we might share your information with” section of this policy, and recipients, in connection with the purposes set out in this Policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.When we do disclose / or store personal information overseas, we protect that information using the security measures set out below and require overseas recipients to do the same.
Where recipients are outside Australia, we ensure that the information will be protected by: safeguards comparable to Australia’s Privacy Laws; or by methods including using contractual clauses; or by ensuring the recipient is subject to laws of another jurisdiction that provide comparable protection to the Privacy Laws.
We also ensure that our data protection and information security controls applying to your personal information in Australia continue to apply in the hands of our affiliates or contracted service providers located overseas.
How we keep your personal information secure
We have implemented appropriate technical and organisational security measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Unfortunately, the transmission of information via the internet (including by email) is not completely secure. Although we will do our best to protect Your personal information, we cannot guarantee the security of Your data transmitted to our site; and 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.
Access to and correction of personal information
You can request for access to the personal information we hold about you. You can also ask for corrections to be made. To do so please contact us.
There is no fee for requesting that your personal information is corrected or for us to make corrections. In some limited circumstances, there may be a reasonable charge for giving you access to your personal information. For example, if we have to search for, locate your personal information, and provide it to you.
Under Privacy Laws, your right to receive access to your personal information, or make corrections to it, is not absolute and exceptions exist. For example, we can refuse to provide information if fulfilling your request would reveal the personal information about another person and have an unreasonable impact on their privacy, or pose a serious threat to another person’s life, health and safety, or to public health, or where unlawful to do so.
If we refuse to give you access to or to correct your personal information, or to correct your personal information, we will give you a notice explaining our reasons except where it would be unreasonable to do so. If we refuse your request to correct your personal information, you have the right to request that a statement be associated with your personal information noting that you disagree with its inaccuracy. If we refuse your request to access or correct your personal information, we will also provide you with information on how to complain about the refusal.
You can contact us at dataprivacy@worldremit.com or at our address below if you want to enforce any of these rights. We will respond to your request without undue delay but no later than 30 days. We will require initial proof of your identity before we can respond to your request.
How long will we keep your personal information for
We take every reasonable step to ensure that your personal information is only retained for as long as it is required for the purposes set out in this Policy. Therefore, we will only keep the information we collect about You for as long as required for the purposes set out above, or as required to comply with any legal or regulatory obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
The period for which we will retain information about You will vary depending on the type of information and the purposes that we use it for. In general, unless applicable law requires a longer retention period, we will keep our records for up to seven years after you have terminated your relationship with us, in order to comply with our legal and regulatory obligations.
We have specific retention periods if you are a Customer. We will retain your information for as long as you remain a Customer and for a period of time after you cease to be one in the following manner:
Customers who have requested that we close their accounts - we keep your information for seven years after the date that your account was closed.
Call recordings - We delete call recordings after five years unless we need the information to investigate fraud, to respond to questions or complaints or for legal reasons.
Notifiable Data Breaches
From February 2018, the Privacy Act includes a new Notifiable Data Breaches (NDB) scheme which requires us to notify you and the Office of the Australian Information Commissioner of certain data breaches that are likely to result in serious harm to individuals; and recommend steps you can take to limit the impacts of a breach.
There are exceptions where notification is not required. For example, where we have already taken appropriate remedial action that removes the risk of serious harm to individuals.
We will notify of any data breach that we believe will result in a likely risk of serious harm and impacts your personal information.
How to make a privacy complaint?
WorldRemit takes all complaints seriously and will investigate your complaint accordingly.
If you believe that there has been a breach of the Act or elements of this Policy, or if you have any concerns about WorldRemit's handling of your personal information, please contact us using the Contact Us tab on our website or by emailing us at dataprivacy@worldremit.com. Your privacy complaint should be directed and addressed to the Privacy Officer.
Please note that we aim to respond to complaints within 30 days of receipt. If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
Writing to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Contact us
Questions, comments and requests regarding your personal information and our Policy are welcome and should be sent to dataprivacy@worldremit.com or you can send it by post addressed to the: Privacy Officer
Writing to: WorldRemit Pty Ltd, Suite 23.01, Level 3, 60 Martin Place, Sydney NSW 2000.
By phone: +61 (02) 6145 161
Email: dataprivacy@worldremit.com
You may also use these contact details if You wish to make a complaint to us relating to Your privacy.
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