In this Privacy Policy, "us" "we" or "our" means Payment Logic Pty Ltd (ACN: 158 935 810) ("Payment Logic") and its related entities and/or bodies corporate.

We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, postcode and contact details. It may also include financial information, including your credit card details.

In this document we will explain:

• Why we collect personal information;
• Type of information we collect;
• To whom do we disclose your personal information;
• Using our website and cookies;
• Links;
• Security;
• How to access your personal information;
• Quality of personal information;
• Getting in touch;
• Changes.

Why we collect personal information

Information is collected from you when it is reasonably needed for our business purposes.

This means we collect this information in order that we can provide you with the functionality you need from our system and so that we can provide you with the best possible customer experience.

We may collect, hold, use and disclose your personal information for the following purposes:

• to enable us to provide you with products and services;
• to ensure we offer you the best service where appropriate and applicable to you;
• to provide you products offered by other entities in the Payment Logic group;
• to enable you to access and use our website;
• to operate, protect, improve and optimise our website and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
• to consider your employment application.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

Type of information we collect

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• age or date of birth;
• credit and/or debit card information;
• bank account details;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
• information you provide to us through customer surveys; or
• any other personal information that may be required in order to facilitate your dealings with us.

We collect – straight from you

We collect most of your personal information directly from you, when you apply online to use our system.

You can choose not to provide your personal information or to deal with us anonymously, however if this occurs, we will most likely not be able to provide you with the functionality that you need, or the service that you would expect.

What we collect from others

As part of our onboarding process we may purchase information from credit reporting agencies in order to process payments in accordance with American Express and/or other card schemes' (Visa, MasterCard, etc.) payment rules.

What we collect whilst you are with us

We collect information about payments processed through our platform. This includes things like the amount of the payment, whom you are paying and some details around these payees such as their Australian Business Number (ABN), their banking details and contact information.

Sensitive personal information

When we refer to Sensitive personal information we mean details such as your race, ethnicity, political, religious or philosophical beliefs, sexual preferences, health, genetics or criminal record activities.

Sensitive personal information is not required by our business and therefore we will not ask for it or store it even if you happen to inadvertently disclose any of this information to us.

To whom do we disclose your personal information

We may disclose personal information for the purposes described in this privacy policy to:

• our employees and related bodies corporate;
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
• professional advisers, dealers and agents;
• payment systems operators (e.g. card schemes, acquirers receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Payment Logic has a commercial relationship with American Express and in order to provide our service we need to forward some payment details to them.

We are also a registered Bill Payment Service Provider, registered under the Visa card scheme via our acquirer (Fiserv ) and are required to forward some payment details to them.

Outsourcing

Our IT development and testing teams are predominantly based in the Philippines.

We have arrangements in place with these partners to ensure that your personal information use and disclosure is strictly limited. These teams are trained with the Australian Privacy Principles as a condition of working with Payment Logic.

Access to personal information from overseas

Whilst our IT development and testing teams are predominantly based in the Philippines, we only provide these staff with access to personal information so that they can do their job, which is essentially developing new features and services or fixing errors that occur from time to time.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

Legal Obligations and other privacy exceptions

We are also required to collect your personal information to comply with our obligations under Australian law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).

Payment Logic may be compelled to provide your personal information to legal authorities where we are obliged to by Australian Law. We may also disclose personal information collected as a result of unlawful activity, serious misconduct, or where a threat to life and safety is involved.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use "cookies" or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Opting Out

If you wish to opt out of receiving our notices, just let us know. Please refer to the section "Getting In Touch" below.

Security

Payment Logic has implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. Only authorised personnel and third-party vendors are provided access to personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, Payment Logic, however, cannot guarantee that unauthorised persons will not obtain access to your personal information.

Some of the security measures that we use include:

• PCI DSS Compliance
• Card tokenisation
• Multi factor authentication
• Use of randomly generated SMS authorisation codes with time limits on their validity
• Unique usernames and passwords to log into your account
• Secure work environments and workflow systems that prevent unauthorised access to your data and our systems
• Firewalls
• Virus scanning tools
• Ongoing training and security reviews
• Secured server and closed network environments
• Personal access privileges

Whilst together all these measures are quite robust, we understand that security risks are always evolving and changing, as a result we will remain vigilant in our continued efforts to help keep your information secure and protected.

How to access your personal information

When requested, we usually give you access to the personal information that we hold about you. We will always confirm your identity before giving access to your personal information.

You can request this by getting in touch with us. See the section called “Getting in Touch” below.

There will be some circumstances where we may not give you access to the personal information that we hold about you. This is dictated by Australian privacy laws, as an example if providing your information would:

• compromise someone else's privacy
• pose a threat to someone’s life, overall health, or safety
• breach an Australian Court, police or tribunal order.

Quality of personal information

Our aim is to keep your personal information up to date, accurate and complete.

Should you believe that our records need appending or correction please let us know on 1300 756 442 (1300 PLOGIC).

This of course also assists us in keeping in contact with you so that we can offer you a better payment service and user experience.

Getting in touch

We understand that your personal information is important to you, so let us know if you have further questions about this policy or our practices.

You can get in touch with us by:

• Phone on 1300 756 442 (1300 PLOGIC)
• Email at support@paymentlogic.com.au

If you wish to make a complaint about privacy, please use the contact methods listed above. We will acknowledge receipt of your complaint and try to investigate and respond within 14 days.

Changes

We’ll ensure that we update this policy where required if our business practice and processes change. Details of any new iterations or versions will be listed below.

Thank you for reading this document.

Versions

This version was updated on 01/09/2022.