SCOPE AND APPLICABILITY
"Personal Information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
We collect personal information about you only from you unless:
- if you are an agency:
- the individual consents to the collection of the information from someone other than the individual; or
- we are required or authorized by or under an Australian law, or a court/tribunal order, to collect the information from someone other than the individual; or
- it is unreasonable or impracticable to do so.
This personal information may include, but not be limited to,
- identities and contact information such as name, address, telephone numbers, email address, etc. of senders and recipients of money transfers
- credit card details, banking or other billing information, birth dates and other personal identifiers such as passports or governmental identification number used to verify your identity for security and fraud prevention purposes as part of our AML/CFT programs, and
- amounts paid, transferred or otherwise processed and
- such other information that we may collect with your consent.
We will not collect, use or disclose sensitive information about you unless it is necessary to provide you with a product or service and we have your express consent or, unless we are legally required to collect, use or disclose such information.
Sensitive information shall include (but not limited to) any information about a person’s religious beliefs or affiliations, sexual preferences or practices, racial or ethnic origin, political opinion, membership of a professional or trade association, membership of a trade union, criminal record or health information. We will always strive to explain the purpose for collecting sensitive information.
Consent to the collection, use and disclosure of Personal Information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of Personal Information) or implied (for example, when necessary information is provided for a requested service). You may provide your consent in some circumstances where notice has been provided about intentions to collect Personal Information and have not withdrawn your consent for it, such as by using an “opt out” option provided, if any. Consent may be given by an authorized representative (such as a legal guardian or a person having a power of attorney) also.
Consent may be withdrawn to the collection, use and disclosure of Personal Information at any time, subject to contractual and legal restrictions and reasonable written notice. Upon the withdrawal of consent to certain uses of Personal Information, we may no longer be able to provide certain of our products or services.
We may be required or permitted under Australian or foreign statute or regulation to collect, use or disclose Personal Information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
COLLECTION OF PERSONAL INFORMATION
We collect Personal Information only by lawful and fair means. In order to provide you with our services and products we may collect Personal Information (like name, mailing address, telephone number, email address, tax file number, date of birth, place of work, your transaction history, source of income and other financial details) that may be required for providing you with the requisite services offered through UAE Exchange. If you do not wish to provide us or are unable to provide us with such information, we may not be able to provide you with the products or services you have requested. We do not deal with individuals who do not identify themselves or use pseudonyms.
We collect Personal Information in a number of ways, including:
- Directly from you while you avail our products and services by way of filling an application form, telephone, email, visiting our websites, visiting us in person or when you submit your personal details to participate in our competitions and promotions;
- Information you voluntarily provide to us, for example, your name and contact information, when you sign up to receive information about our products and services by email, or use a ‘contact us’ feature or similar service available;
- Information about your transactions with us, including transaction history, such as frequency of use, amounts paid, transferred or otherwise processed;
In connection with identity verification including our AML/CFT programs, fraud prevention and similar security purposes, we collect and/or confirm certain identity-related information, financial background and similar information through third parties sources such as, but not limiting to, government agencies, consumer reporting agencies, credit reporting agencies, our business partners/service providers, your authorized representatives or our group/affiliate of companies;
- In limited circumstances, we may also collect your personal information through e-mail correspondences which are subject to the provisions of this policy and for the limited purpose of providing you with the products or services requested by you;
- Publicly available sources of information such as telephone directories, websites etc;
- We may collect Personal Information otherwise with your consent or as permitted or required by law.
USING YOUR PERSONAL INFORMATION
We may use your Personal Information for any one or more of the following purposes
- To verify your identity or authorizing and processing your transactions. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
- To assist in providing information about a product or service that may be of interest to you, unless advised by you that you would prefer not to receive any promotional or other material from us.
- To consider your request for a product or service.
- Collect amounts owed to us.
- Monitoring and improving our website and its content, or for research and development of our products and services.
- To administer and manage our products and services.
- To respond to queries, complaints or to provide you with our general customer service.
- To perform other operational tasks (including risk management, systems development and testing, staff training, market or customer satisfaction research).
- To prevent or investigate any fraud or crime (or a suspected fraud or crime).
- As may be required by relevant laws, regulations, Codes and external payment systems.
We may use your Personal Information for any additional purposes related to the purposes listed above. However we will not use your Personal Information other than for purpose you would reasonably expect or authorized by you or as required by law.
STORING OF PERSONAL INFORMATION
The system for processing transactions and providing other services and products of UAE Exchange is provided by a foreign correspondent located outside Australia and therefore the transaction processing data and other relevant information will be stored in such location of the foreign correspondent located outside Australia. UAE Exchange has real time access to this data, can retrieve this data at any time and also has control on how it can be used. UAE Exchange shall ensure that the foreign correspondent also adheres to privacy standards set out in this Policy.
DISCLOSURE OF PERSONAL INFORMATION
- To Provide Services
In order to process and complete requested money transfers and other transactions, we may disclose personal information to the recipient of a Money Transfer, to our agents or affiliates, and, if applicable, to any intermediary banks or other financial institutions or financial services companies or third parties involved in the transaction or our services.
- Service Providers
- Business Transactions
Your personal information may be used and disclosed to parties connected with the contemplated or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of our business or assets (including, for example, your account with us), for purposes related to the evaluation and performance of these transactions, including:
- Permitting such parties to evaluate and determine whether to proceed or continue with the transaction, and
- Fulfilling reporting, inspection or audit requirements or obligations to such parties
- Legal & Regulatory Disclosures
We may disclose your personal information as necessary to meet legal, regulatory, self-regulatory, insurance, audit, and security requirements, and otherwise with your consent or as permitted or required by law (including as required by applicable Australian and foreign laws). This may include lawful requirements to disclose personal information to government authorities in Australia (including AUSTRAC) and in foreign countries, for example disclosures in compliance with transactions and suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations in Australia and in foreign countries.
- General Disclosures
We may disclose your Personal Information to third parties when we contract out some of our functions and activities or when we have outsourced certain duties and tasks associated with the product or service and as required or permitted by law. We may also send Personal Information overseas if we outsource any functions and activities to overseas agents, contractors or associate companies to complete a particular transaction. If necessary, for transactional purposes, your Personal Information may be accessed by such overseas agents, contractors or associate companies in other countries.
We take the obligation to protect personal information very seriously and we make every effort to deal only with parties who have similar approach. In the event of the above situations:
- We prohibit third parties from using your Personal Information other than for the specified purpose.
- Ensure third parties do not disclose any Personal Information other than our own.
- Ensure confidentiality and non-disclosure arrangements are in place.
QUALITY OF PERSONAL INFORMATION
Accurate information about you enables us to provide you with the best possible service. We take reasonable steps to ensure your Personal Information is accurate, complete and up-to-date at the time of collecting, using or disclosing the information.
Each time you conduct a transaction or use any product or service, as part of our AML/CFT program, data already held by us is validated and updated, if necessary. Also, as a part of AML/CFT procedures, we undertake KYC checks to ensure that personal information collected during transactions is accurate and up-to-date by asking for ID proof, other relevant documents etc.
We request you to regularly review and advise us of changes to your Personal Information so we could update our records promptly.
ACCESS AND CORRECTION TO YOUR PERSONAL INFORMATION
You may request access to Personal Information that we hold about you or request correction to existing Personal Information by writing to us at “UAE Exchange Australia Pty Ltd, Level 5, 122 Castlereagh Street, Sydney 2000.” The right to access or correct your personal information is subject to applicable legal restrictions. Subject to such restrictions we will process such requests in reasonable time. To help protect your privacy and security, we may require additional information when trying to verify your identity.
Should we refuse access or correct your Personal Information we will provide you with a written explanation for such refusal and mechanism to complain about the refusal and any other matter prescribed by the regulations etc. We may refuse access or to correct your information on the following grounds:
- If the access would pose a serious threat to the life , health or safety of an individual , or to public health or public safety; or
- giving access would have an unreasonable impact on the privacy of other individuals
- the request for access is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings between the company and the individual;
- giving access would reveal the intentions of the Company in relation to negotiations with the individual in such a way as to prejudice those negotiations;
- giving access would be unlawful;
- denying access is required or authorized by or under an Australian law or a court/tribunal order; or
- we has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to the company’s functions or activities
- giving access would be likely to prejudice the taking of appropriate action in relation to the matter
- giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of an enforcement body.
- giving access would reveal evaluative information generated within the entity in connection with a commercially sensitive decision-making process.
SECURITY OF PERSONAL INFORMATION
We store Personal Information as a combination of electronic storage, paper based files and other records. We use current techniques and processes to ensure safety of such records. Such information is accessible only by authorized personnel on a need to know basis and storage has limited access.
We endeavor to take steps to protect your personal information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in its custody or control, which may include safeguards to protect against loss or theft, unauthorized access, disclosure, copying, use or modification. Information which is stored will be securely destroyed or de-identified in circumstances where there no longer exists a business or legal requirement for UAE Exchange to retain the information for a period of time.
WEBSITE SECURITY AND PRIVACY
- We do not ask you to register or provide personal information in order to view our website or have access to its content. However, we may collect personal information if it is voluntarily provided by you to us through the website or in response to e-mails in relation to features provided on the website. In the event you intend to conduct a money transfer transaction or use any of the products and services using our website, you may be required to be registered and provide personal information in order to further use the website to conduct the transaction.
- We automatically collect aggregate information relating to the use of its website, including how many consumers visit the website, which pages they access, what information they download, the type of web browser and operating system they use, the name of their internet service provider. When you visit the website, information is collected automatically and it is combined with similar information collected about all other visitors. By collecting this information, we learn how to best tailor our website to our visitors.
- We track the internet address of the domains from which people visit and analyse this data for trends and statistics, but the individual user remains anonymous.
- For better management of the website and for security and monitoring purposes, we may collect and use (i) user’s browsing history of our website; and (ii) aggregate user data, and browser type.
- UAE Exchange websites may contain links to other websites whose operator/s may or may not adhere to a Privacy Statement or be governed by the APPs. You should review and become satisfied with the privacy statement of these organizations before using such websites.
In order to serve you better we may use the Personal Information collected to identify and inform you about a product or service that may be of interest and benefit to you. We may contact you via phone, email or mail about our new or existing products, services, promotions or for customer survey purposes, unless you advise us that you would prefer not to receive promotional or other material from us.
If you do not wish to be contacted for such marketing information, you could contact us and we will update our systems accordingly.
We are bound by the Privacy Act 1988 (Cth), Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Australian Privacy Principles contained in Schedule 1 of the Act as amended by the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth).
If you would like further information about the way UAE Exchange handles your Personal Information or compliance with the Australian Privacy Principle, please contact us at the following address:
UAE Exchange Australia Pty Ltd., Level 5, 122 Castlereagh Street, Sydney, NSW 2000 Tel: 02 9269 8100 Fax: 02 92698101 or email us at firstname.lastname@example.org.
We will respond to your query on priority with details of the case officer and a response to your query.
In the unlikely event that you are not satisfied with our service, please contact us at UAE Exchange Australia Pty Ltd., Level 5, 122 Castlereagh Street, Sydney, NSW 2000 Tel: 02 9269 8100 Fax: 02 92698101 or email us at email@example.com.
If you are located in Australia and dissatisfied with our service, you may refer your compliant to the Office of the Australian Information Commissioner (“OAIC”):
Address: GPO Box 5218, Sydney, NSW 2001
Telephone: 1300 363 992
REVIEW OF THE DOCUMENT
The document shall be reviewed on a yearly basis or whenever a change is warranted by the applicable regulations
RESPONSIBILITY FOR IMPLEMENTATION AND COMPLIANCE MONITORING OF THIS POLICY
Operations department of UAE Exchange Australia Pty Ltd. will be responsible for implementation, compliance and monitoring of this policy along with review and approvals from key stakeholders within the organization’s global structure.