SurePayd cares about the rights of individuals and do not sell personal information. We believe that everyone should be able to protect their identity online, understand what information is being held about them and also how it is being used.
SurePayd takes measures to protect the data of individuals, processing data in secured computing environments.
SurePayd have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
In addition, where SurePayd provides services globally, SurePayd endeavours to comply with the requirements of regional privacy legislation and guidelines.
SurePayd does not guarantee website links or policy of authorised third parties.
1. What is personal information and why do SurePayd collect it
Personal Information is information or an opinion that identifies an individual.
SurePayd collects your Personal Information for the primary purpose of providing our services to you, providing services to our clients and marketing our services.
We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
The information that we collect about you may include:
Postal and street address
Place of work
Information relating to job applications
Information relating to complaints you have made to us
Various personal preferences including notification preferences
Device related information such as IP address and browser versions
We also use your payment information as allowed by law for processing invoices when you purchase a product or service from us.
Personal Information processed by our SurePayd Invoicing and Payments Solution is provided to SurePayd by our clients under contract and protected by non-disclosure agreements.
When we collect Personal Information directly, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
2. How we collect personal information
SurePayd receives information from three specific sources, from you directly, from automated sources and from third parties, such as our clients or lead generators.
Information you provide voluntarily
This is personal information that you choose to provide to us voluntarily, for example when interacting with our websites or using our products and Services. It includes details such as your name, email address, residential address, or other information permitting your identity to be directly or indirectly inferred. It will be apparent to you at the time you provide your information what information is requested, why, and whether the provision of the information is optional or mandatory.
Examples of when you provide information to us:
Registering for newsletters, a product trial or placing an order
Completing transactional services and/or payment services
In discussion when contacted by a sales person
Registering for products or services purchased
Using the SurePayd website
Participating in customer surveys, advising us of your marketing and communication preferences
Submitting a job application
Updating and/or altering your contact details
When requesting to opt-out of the service or submitting a data privacy request
2. Personal information we collect automatically
This is information that we collect automatically from the devices of visitors to our websites or users of our Services. This type of information is generally collected for analytics and reporting purposes, to improve advertising and marketing campaigns, and to maintain the security of our products, Services, and websites.
The following are examples of information we collect automatically:
Log files generated by our websites which contain
Your IP address
Your browser version
The operating system of your device
Tracking of links through the application
Creation and manipulation of cookies
3. Information we collect from third parties.
Sales leads from our joint initiative partners and lead generation services.
Publicly available sources such as social media websites.
Third parties that provide SurePayd with marketing leads.
Material shared with SurePayd to enable us to provide our services to you.
Data processed by SurePayd under contract.
4. Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law.
4. Information provided by third parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Whereby SurePayd provides data processing services on behalf of our clients, our clients providing this information will take reasonable steps to ensure that you consent to having your data processed by SurePayd, and SurePayd will abide by the terms of the confidentiality clauses the data is provided under.
Most cookies do not collect personal information and only contain coded information that cannot be used by third parties to access your confidential information.
Most web browsers allow you to adjust settings to erase cookies, disallow cookies, or receive a warning before a cookie is set.
Please note that some parts of SurePayd websites may not function fully if you disallow cookies.
6. Disclosure of personal information
SurePayd may disclose your personal information to the following categories of recipients:
Third party service providers and partners where the processing of your personal information is a function of providing the service
To any other third parties where you consent to the use or disclosure
In the event SurePayd participates in the process of any third-party acquisition or potential acquisition of an interest in us or our assets
To process a job application including reference and background checks
Where required or authorised by law.
7. European union / European economic area data subjects and GDPR
EU/EEA data subjects may exercise the rights provided them under the provisions of the GDPR by requesting in writing to the address provided.
Request erasure or suspension of processing by SurePayd
Request access to the personal information processed by SurePayd
Resolve inconsistencies in the personal information held by SurePayd
To opt out and/or withdraw consent relating to the processing of personal information
Under certain circumstances, your personal information can be provided to you in machine readable formats for transfer to another controller
SurePayd will review each request on a case by case basis and respond in accordance with the applicable data protection law.
8. Security of personal information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.
9. Data retention
SurePayd have legitimate business needs to retain certain data.
This information is retained to comply with our legal obligations, resolve disputes, protect rights and enforce our agreements
Customer names, addresses and order history are maintained for 3 years from the last purchase or order activity unless required as part of accounting records.
Accounting records including invoices, purchase orders and other historical financial records are stored for 7 years for legislated accounting purposes.
Our backup media is protected using security measures including encryption and is disposed of securely when retired.
10. Collection and use of data relating to minors
SurePayd does not knowingly collect personal information relating to children under the statutory age of majority.
If you believe SurePayd has recorded children’s personal information, please contact us and we will delete this information on request. We encourage you to talk with your children about communicating with strangers, use of social media and disclosing personal information online.
11. Access to your personal information
You may access the Personal Information we hold about you and to update and/or correct it, as required by law and subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Where SurePayd processes your information on behalf of another entity, request should be made to that entity in the first instance.
SurePayd will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information, we may require further identification from you before releasing the requested information.
If you do not want us to use your personal information for direct marketing of SurePayd services, you can let us know at any time through the contact details provided below.
12. International transfers
SurePayd uses facilities in locations globally including Australia, United Kingdom, USA and Singapore to process information in these regions.
If you are an individual from the European Union or European Economic Area (EEA), note that the information that we collect from you, including personal information relating to you or Customer Relationship Information that we process in providing a Service, may be transferred to, and processed by, SurePayd service providers outside the EEA for the purposes described in this Policy.
While these affiliates and service providers may be based in territories whose data protection laws are different from those of the country or region in which you are based, Surepayd will always protect your personal information in accordance with this Policy. In addition, we protect transfers to countries outside the EEA with appropriate safeguards, by as using standard contractual clauses adopted or approved by the European Commission.
Further details can be provided upon request to the address provided below.
13. Maintaining the quality of your personal information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
SurePayd has a range of security measures in place to protect the personal information that we hold.
For example, our web pages that request sensitive information employ encryption technologies such as Transport Layer Security (TLS 1.2+), and data is secured in encrypted databases.
You can confirm that a data-entry page uses encryption by checking that:
1. The page address in the web browser’s tool bar or status bar begins with https://; and
2. The padlock icon in the web browser’s tool bar or status bar is locked.
If you are considering sending us any personal information by email, please be aware that the information may be less secure in transit. As we are required by law to take steps to protect the security of personal information once it comes into our possession, please contact SurePayd stating the nature of the communication and we will provide a secure upload facility to use.
14. Policy updates
This Policy may change from time to time and is available on our website:
This policy was revised on the 9th July 2020
15. Enquiries, concerns and complaints
If you want to make a complaint or advise SurePayd about a breach of your privacy, you can contact us using the contact details at the bottom of this web page. All complaints will be investigated by an appropriately qualified representative. We will endeavour to resolve your complaint as quickly as possible, and in any event within 30 days. If your complaint takes longer to resolve, we will keep you informed of our progress with the investigation. We will let you know the outcome of the investigation, including how we propose to resolve your complaint and what, if any, corrective measures will be put in place.
If you are not satisfied with our handling or resolution of your complaint, you can lodge a complaint with the Office of the Australian Information Commissioner. For more information about making a complaint to the OAIC, visit http://www.oaic.gov.au/privacy/making-a-privacy-complaint.
CONTACT THE PRIVACY OFFICER
Privacy OfficerSurepayd Services Pty Ltd
Suite 3, Level 27,
Governor Macquarie Tower
1 Farrer Place,
Sydney NSW 2000