1. Introduction
SGCPAY (AUS) LIMITED (ABN 61 662 299 434) ("SGCPAY", "we", "us" or "our") is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose, store, and protect personal information, and how you can exercise your rights in relation to it.
This Policy should be read together with the other documents in our legal library, including our Terms and Conditions, Cookie Policy, and AML/CTF Statement. By using our services, you acknowledge that your personal information will be handled as described in this Policy.
2. Information we collect
We collect personal information that is reasonably necessary for our functions and activities. This includes identity information (such as your name, date of birth, nationality, and government-issued identification), contact information (such as your email address and telephone number), and, for business customers, information about the entity and its beneficial owners and officers.
We also collect transactional and account information, verification and due-diligence records, device and usage data generated when you interact with our website and applications, and any information you provide when you contact us or submit an application. Some of this information is sensitive or is required to meet our legal obligations, and we will tell you where the provision of certain information is mandatory.
3. How we collect information
We collect personal information directly from you when you apply for an account, complete a form, or communicate with us. We also collect information automatically through your use of our website and applications, as described in our Cookie Policy.
In some cases we collect information from third parties, such as identity-verification providers, sanctions and politically-exposed-person screening services, banking and payment partners, and publicly available sources, where it is reasonable and lawful to do so and consistent with our regulatory obligations.
4. Why we use your information
We use personal information to provide and administer our services, to verify your identity, to open and maintain your account, to process transactions, to communicate with you, and to improve and secure our platform. We also use it to comply with our legal and regulatory obligations, including anti-money-laundering, counter-terrorism-financing, sanctions, and record-keeping requirements described in our AML/CTF Statement.
Where we rely on your consent for a particular use, such as certain marketing communications, you may withdraw that consent at any time. We will not use your personal information for a purpose that is unrelated to the purpose for which it was collected unless you would reasonably expect us to, or the law permits or requires it.
5. Disclosure of information
We may disclose personal information to service providers who help us operate our business, including identity-verification, hosting, analytics, communications, banking, card-issuing, and payment providers, in each case subject to appropriate confidentiality and data-protection arrangements.
We may also disclose information to regulators, law-enforcement agencies, and other authorities where we are required or authorised to do so by law, including reporting to AUSTRAC. We do not sell your personal information.
6. Cross-border disclosure
Some of our service providers may be located, or may store data, outside Australia. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure that the recipient handles the information consistently with the Australian Privacy Principles, or we rely on another basis permitted under the Privacy Act.
By using our services, you acknowledge that your information may be processed outside Australia for the purposes described in this Policy.
7. Data security and retention
We take reasonable technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include access controls, encryption in transit, and internal governance procedures. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
We retain personal information for as long as necessary to provide our services and to meet our legal, regulatory, and record-keeping obligations, which for certain records include minimum retention periods under Australian anti-money-laundering law. When information is no longer required, we take reasonable steps to destroy or de-identify it.
8. Your rights
Subject to applicable law, you may request access to the personal information we hold about you and ask us to correct information that is inaccurate, out of date, incomplete, or misleading. We will respond to such requests within a reasonable period and in accordance with the Australian Privacy Principles.
In some circumstances we may be unable to provide access or make a correction, for example where doing so would be unlawful or would prejudice an investigation. Where that is the case, we will explain our reasons to the extent we are permitted to do so.
9. Cookies and website analytics
Our website uses a limited set of cookies and similar technologies. Details of how we use cookies, including the specific cookies we set, are described in our Cookie Policy. You can control cookies through your browser settings.
10. Making a privacy complaint
If you believe we have breached the Australian Privacy Principles or mishandled your personal information, you can contact us via the contact form on our website, and we will investigate in accordance with our Complaints Policy. If you are not satisfied with our response, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC).
We take privacy concerns seriously and will work with you in good faith to resolve them.
11. Changes to this policy
We may update this Privacy Policy from time to time. The current version is the version published on our website, and the "Last updated" date indicates when it last changed. Material changes will be communicated by reasonable means. If you have any questions about this Policy or how we handle your information, you can contact us via the contact form on our website.