e-Pocket Privacy Policy

Last updated: June 10, 2018
Version 1.0

Please read and understand this privacy policy. This Privacy Policy is subject to and governed by the e-Pocket Terms of Use ("TOU").

Welcome to e-Pocket!

Privacy and online safety are important to e-Pocket in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Privacy Act). We offer a peer to peer payment software system, platform and services for helping individuals and businesses pay, buy and sell goods & services with fiat or crypto currencies. We collect data about businesses and their customers (“Data”) when they use the platform, the services, and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.

In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to our website or the mobile App, a user of one or more of our Services (“User”), or a customer of a User (“Customer”). We’ll do our best to clarify who we are referring to at various points in the policy. This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully. If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer or mobile device after leaving our website or App, and (b) discontinue Your use of our Services.

Cookies

e-Pocket uses Google Analytics, Cloudflare and our own cookies to help deliver high quality, reliable and secure products to our customers.

These include:

  • Anonymous site performance cookies;
  • Anonymous analytics cookies;
  • Geotargetting cookies (Cloudflare);
  • Registration cookies.

For more information about how we use cookies, email us at info@e-pocket.com.au


1. Overview

The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when an e-Pocket account is created, test transactions are submitted through our website or mobile App, or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.

The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering, terrorism financing and other harmful activity.


2. Data We Collect

a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a business registers for an e-Pocket account, a Customer makes payments or conducts transactions through a User’s website or application, a person responds to e-Pocket emails or surveys, or when a Customer uses the “Remember Me” feature of e-Pocket Checkout.

We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:

  • Contact details, such as name, postal address, telephone number, email address;
  • Financial and transaction Data, such as credit or debit card number, and bank account information; and
  • Other Personal Data, such as date of birth, identification copy.

b. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include:

  • Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using;
  • Transaction data, such as purchases, purchase amount, date of purchase, and payment method;
  • Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and
  • Company data, such as a company’s legal structure, product and service offerings, jurisdiction, company records, and information submitted through e-Pocket service.

3. How We Use Data

a. Personal Data. We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users, Customers, and e-Pocket; and (iv) promote, analyse and improve our products, systems, and tools. Examples of how we may use Personal Data include:

  • To verify an identity for compliance purposes;
  • To evaluate an application to use our Services;
  • To conduct manual or systematic monitoring for fraud and other harmful activity;
  • To respond to inquiries, send service notices and provide customer support;
  • To process a payment with e-Pocket Checkout, communicate regarding a payment, and provide related customer service;
  • For audits, regulatory purposes, and compliance with industry standards such as AUSTRAC - Australian Transactions Reporting and Analysis Centre;
  • To develop new products;
  • To send marketing communications;
  • To improve or modify our Services; and
  • To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.

b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.


4. Google Analytics and Web Beacons

Google Analytics is a web analysis service provided by Google, in order to better understand your use of our website and how we can improve them. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to e-Pocket website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the e-Pocket website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the e-Pocket website to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the e-Pocket website, please review “How Google uses data when you use our partners' sites or apps,” (located here or any successor URL).

Some of the areas of the System may contain electronic images known as web beacons (sometimes known as clear gifs) that allow e-Pocket, and its third-party providers or affiliates, to count and track users who have visited certain portions of the System. Web beacons collect only limited information and do not collect any of your personal information. Specifically, e-Pocket plans to use a type of web beacon known as a “retargeting pixel,” which will allow users to receive targeted advertising from e-Pocket via certain social media websites, including Facebook.com.


5. How We Disclose Data

e-Pocket does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:

a. To e-Pocket Affiliates. We share Data with entities that we control, are controlled by us, or are under our common control, to provide our Services. e-Pocket Pty. Ltd. is the party responsible for overall management and use of the Data by these affiliated parties;

b. To e-Pocket Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, e-Pocket auditing;

c. To Our Users. We share Data with Users (such as merchants and application providers) as necessary to process payments or provide the Services. For example, we share Data with Users about purchases made by their Customers through the e-Pocket payment processing services;

d. To Authorized Third Parties. We share data with parties directly authorized by a User to receive Data, such as when a User authorizes a third-party application provider to access the User’s e-Pocket account using e-Pocket mobile App or web portal. The use of Data by an authorized third party is subject to the third party’s privacy policy;

e. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and

f. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.


6. Security and Storage

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. We also endeavour to restrict information access to our employees, agents and representatives only to those that have a legitimate need to access your information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), you agree to notify us immediately.

We use a variety of physical and electronic security measures and secure databases to keep personal information secure from misuse, interference, loss or unauthorised use or disclosure.

You agree to immediately notify us of any breach of platform's security, this Privacy Policy, or the Terms of Use of which you become aware


7. Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to You when You access our websites or mobile App, based on Data relating to Your access to and use of our websites or mobile App on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see.


8. Choice and Access

You have choices regarding our use and disclosure of Your Personal Data:

a. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.

b. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to Your e-Pocket account or by contacting us.

If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.

You have a right to access most personal information we hold about you and to seek its correction. Please contact us below to ask for access to your information, or if you have a complaint concerning your information privacy. We may deny your request in some circumstances. If we do this, we will tell you why. Any complaint will be investigated by the firm's Office of General Counsel and the outcome of that investigation communicated to you (please allow at least 30 days for us to do so). If you are not satisfied with the outcome, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au on 1300 363 992.


9. Retention Period

We will retain Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Please note that we have a variety of obligations to retain the Data that You provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering, counter terrorism and other laws and rules that apply to us and to our financial service providers. Accordingly, even if You close Your e-Pocket Account, we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.


10. Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we request that they do not provide Personal Data through the Services.


11. e-Pocket as a Data Processor

We may collect, use and disclose certain Personal Data about Customers when acting as the User’s service provider. Our Users are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.


12. Updates to this Privacy Policy and Notifications

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You through your e-Pocket Dashboard, email address and/or the physical address listed in Your e-Pocket account. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures.

Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.


13. Postings & Communications

a) Postings on the website (should such a facility become available) related to e-Pocket may be publicly available. You should always be cautious when deciding to disclose any of your personal information or opinions in any public posting.

b) When submitting information, corresponding, making requests for information, and otherwise interacting with e-Pocket and its representatives through or in connection with the App or the website, you choose what information to supply or submit, whether you wish to receive further information, and how you may be contacted. Please take care to share only such information as is needed or that you believe is appropriate. Should you object to providing us with some information, we may not be able to provide you with the service that you wished. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further promotional emails. You may also alter your communication preferences by logging into your account. You may disable your online account access at any time; however, this will not necessarily result in the deletion of any information.

c) We may send you emails with promotional offers only if you opt-in to receiving such emails. If you would no longer like to receive information, newsletters or other promotional messages from us, please click the link at the bottom of any such email you receive from us and follow the instructions. Your email address will be removed from our marketing list. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.


14. Contact Us

If You have any questions about this Privacy Policy, please contact us at privacy@e-Pocket.com.au or at:

e-Pocket Pty. Ltd.
30/35 Collins Street
Melbourne, VIC 3000
Australia

Attention: e-Pocket - Legal

The entity that provides the Services is e-Pocket Australia Pty. Ltd. If You are dissatisfied with our handling of any complaint You raise under this privacy policy, You may wish to contact the Office of the Australian Information Commissioner.