Effective 27 June 2016
1. These Privacy Principles describe how we collect, use and disclose your Personal Information.
2. We will collect your Personal Information such as your name, telephone number, mobile number, date of birth, address and bank account information only for the purpose of providing our services to you and any purpose that is directly incidental to the provision of those services. In the event that we wish to use your Personal Information for any other purpose, we will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law. If you choose to add a payment recipient on our website, we will ask you for your recipient’s name, email address, financial information (bank information) and physical address.
3. We are always willing to explain to you the purposes for which your information is being collected.
4. We may disclose information about you, including your personal information, to our affiliates, employees, officers and agents for the purposes set out in paragraph 2 above and to our contractors and suppliers to enable them to assist in the provision of the services to you. If we wish to provide your personal information to anyone else, we will identify them and obtain your consent before doing so, unless the provision of that information to that third party is permitted by law.
5. We will seek your consent to the use of your Personal Information either expressly or impliedly, depending on the circumstances and the type of information collected. For example, we will rely on your implied consent when you give us your name, address, telephone number and other details necessary for us to verify your identity in accordance with the provisions of the Customer Agreement.
6. Your consent may also be given by an authorised representative or a person having Power of Attorney.
7. You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.
8. We may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.
9. There may be circumstances in which we are obliged to collect, use, or disclose certain Personal Information without your consent. Such circumstances could include the following:
(i) a serious and imminent threat to someone's life, health or safety;
(ii) a serious threat to public health or public safety;
(iii) unlawful activity has been, is being or may be engaged in;
(iv) disclosure is required or authorised by law;
(v) the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law including the enforcement of laws relating to the confiscation of the proceeds of crime; or
(vi) the use or disclosure is necessary for the protection of the public revenue, the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
Limiting Collection and Retention of Information
10. The amount and type of information collected by us will be limited to that which is necessary to provide our services and the information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected.
11. You acknowledge that we are obliged under the relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.
12. Subject to any legislative requirements, we will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.
13. We will make reasonable efforts to inform you if we have collected personal information about you from someone else such as any credit information that may be obtained in the course of obtaining the identity particulars described above.
14. We will make reasonable efforts to ensure that your Personal Information is sufficiently accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.
15. We will not routinely update your Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Customer Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.
16. When registering or creating an account at our website, we collect your password and login name and other information we may request in order to identify you, maintain security of our website and verify and control access to your account or online profile. If you make inquiries through the e-mail links, forms or other contact methods provided on our websites, these inquiries are forwarded to the relevant office or department and are used to respond to your inquiry and maintain a record of correspondence.
17. We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
We use Internet technologies like cookies and web beacons to facilitate the services we provide on our websites and your use of our websites, including for the following reasons.
(i) To assist us in providing services to you.
(ii) To allow you to change web pages during your visit without having to re-enter your password.
(iii) To store your preferences and other information and to track activity on our website.
(iv) To better understand the effectiveness of our promotional campaigns.
(v) To determine whether you came to our site from a banner ad or an affiliate website.
(vi) To deliver information specific to your interests on additional web sites.
(vii) To determine whether you've acted on our promotional messages
NOTE: A "cookie" is a text file placed on your computer's hard drive by a web server, which allows for personalisation of certain aspects of your visit to that website. "Web beacons" are transparent electronic images placed in the web code that collect non-personal data while visiting a website. Cookies and web beacons can usually be disabled by changing your browser preferences. Your browser usually has documentation on how to disable cookies and web beacons. Note that disabling cookies may limit the performance of OFX's websites. If cookies are disabled, certain features of our websites may not function properly, and you may not be able to register or use your online account.
18. We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
19. As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service
provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
20. We use Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
Disclosure to Third Parties
21. We may disclose your Personal Information to any member of the OzForex Group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006 as amended or replaced from time to time).
22. We may disclose your personal information to third parties for the following purposes:
(i) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business assets;
(ii) if OFX, or substantially all of its assets, are acquired by a third party, in which case Personal Information held by us about our customers will be one of the transferred assets; and
(iii) in accordance with obligations imposed on us by our third party service providers so that they may process your transactions.
23. We may disclose or share your personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction such as any credit information that may be obtained in the course of obtaining the identity particulars described above.
25. Our website is not directed at children under the age of 18. We will not knowingly collect or maintain Personal Information on our website from those we actually know are under the age of 18.
26. Our website may be linked to or from third party websites. These links are provided as a convenience only. We are not responsible for the content or privacy principles of websites that are linked to or from our website. You are advised to review the privacy policies of any third party websites you visit.
27. We have in place a range of security safeguards to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held.
28. The methods of protection we employ may depend on the sensitivity of the information and the format in which it is contained. Security measures include: technological measures including Secure Socket Layer (SSL) encryption, which creates a secure connection with your browser when you register and login into our online services; physical measures such as locked filing cabinets and restricted access to offices and strategic measures such as security clearances and limiting access to a "need-to-know" basis.
29. We make every effort to ensure that our staff are aware of the importance of maintaining the confidentiality of personal information, however you acknowledge that authorised employees, agents, representatives and third parties may require access to your Personal Information in order to enable us to provide our service and we cannot accept responsibility for any unauthorised activities on their part.
30. You acknowledge that no data transmission over the internet or the telephone can be guaranteed to be perfectly secure. Any Personal Information you submit to us or access electronically or over the telephone is done at your own risk. We do not guarantee or warrant the security of information transmitted in these ways. You acknowledge that third parties could unlawfully intercept your transmissions or may wrongly instruct you to disclose Personal Information while posing as OFX representatives.
31. If your personal information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, ask to have it removed from a testimonial on our site or deactivate it by making the change on your Edit Profile page or by emailing us at email@example.com. We will respond to your request within a reasonable timeframe.We will upon request and within 10 days of any such request allow you access to your Personal Information. The requested information shall be provided or made available in a form that is generally understandable.
32. If you point out to us that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.
33. You acknowledge that there may be circumstances in which we may refuse access to some or all of your Personal Information, including where the provision of access would be too costly, the information may contain references to other individuals or for legal, investigative, security or commercial proprietary reasons.
34. We have procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Information. For more information, see our Complaints Policy.
35. We take all complaints seriously and will investigate all complaints.
Social Media Widgets
36. Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
37. We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Availability and changes to this Policy
38. This Policy is available on the OFX website. We may change this Policy from time to time. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.