Privacy Policy

LAST UPDATED: 20 January 2021

 

This privacy policy (‘the Privacy Policy’) applies to Circlepay (‘we’, ‘us’ or ‘our’), and details how we collect, manage and use Personal Information, including but not limited to Personal Information collected on our websites, mobile applications, via email, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (“Websites”).     By “Personal Information” we mean information that is associated with a specific person and can be used to reasonably identify that person.  Personal information does not include information that has been made anonymous and cannot reasonably identify a specific person.  It covers how we collect, use, and share that Personal Information as of the date that this Privacy Policy is posted.

Circlepay is committed to respecting the privacy of your Personal Information. We appreciate that individuals are concerned about the security of their Personal Information and we are committed to protecting any Personal Information in our custody or control. Circlepay is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Circlepay’s third party suppliers and commercial partners (together, ‘our Partners’) are independent of Circlepay and may have privacy policies which differ from ours. Our Partners are responsible for their own privacy policies and privacy practices. Please contact our Partners directly for further information on their privacy policies.

This Privacy Policy applies when you sign up for, access, or use our services, features, technologies, and functions on our Websites (collectively ‘Circlepay Services’) and in relation to Personal Information we may otherwise collect during the course of our business as set out in this Privacy Policy. 

 Circlepay may amend the Privacy Policy at any time. The updated version will be available by following the ‘Privacy’ link on the Websites. The revised version will be effective from the time we post it on the Websites. Circlepay may highlight any material changes to the Privacy Policy that may impact you by notifying you by email or otherwise.

 

Collecting Personal Information

Circlepay strives to be fair and open about the way we collect information about you and what we intend to do with the information. 

We receive and store certain types of information from you when you interact with our Websites to provide Circlepay Services, and help improve your overall user experience.  For example, like many other websites, we store “cookies” and other web-based files on user devices to get certain types of information when your web browser, mobile phone, or other device accesses our Website.  The information sent to us may include data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit our Websites or use Circlepay Services, we may also collect information about your transactions and your activities. Details on our collection of Personal Information through the use of cookies and analytical services is set out below.

In addition, if you open a Circlepay account with us or use Circlepay Services, we may collect the following types of information: 

• Contact information, such as your name, address (including your geolocation), phone number and email.
• Financial information, such as the full bank account numbers and/or credit or debit card numbers that you link to your Circlepay account or give us when you use Circlepay Services.
• Detailed Personal Information such as your date of birth, drivers license number, or other identification information or documents.

We may also obtain information about you from third parties including our Partners and related companies, as well as credit reporting bodies and identity verification services, and publicly or commercially available sources for the purposes of complying with relevant legislation (eg. anti-money laundering laws).

If you register for or log into our services using third party credentials (e.g. Facebook, Google, Apple), you choose to provide us with access to certain Personal Information of yours from such third party to help create your account with us. The information we may receive varies by third party and is controlled by that third party. By associating an account managed by a third party with your Circlepay account and authorising Circlepay to have access to this information, you agree that Circlepay may collect, store and use this information in accordance with this Privacy Policy.

We may also collect your Personal Information if you enter a competition or promotion we run (either directly or through our marketing agents or our Partners).

In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with our Websites or Circlepay Services. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

We may also collect additional information from or about you in other ways, such as through contact with our customer support team, suppliers or service providers (whether via mail, email or through telephone enquiries), your responses to a market survey, and from interactions with Circlepay’s Partners or as otherwise notified to you at the time.

 

Using Personal Information

Circlepay only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by law, court, or tribunal order.

We may use Personal Information we collect about you for a number of purposes including: 

• provide (or assess whether to provide) Circlepay Services;
• customer support;
• process transactions and send notices about your transactions;
• resolve disputes, collect fees, and troubleshoot problems;
• investigate and prevent potentially prohibited or illegal activities;
• enforce our User Agreement with you;
• learn more about your level of satisfaction, your expectations of us and our Partners, and how we can meet them (for example, in relation to Circlepay Services);
• customise, measure, and improve Circlepay Services and the content, layout, and operation of our Websites;
• deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
• contact you via telephone, text (SMS) or email messaging, including as authorised by our User Agreement;
• compare information for accuracy and verify it with third parties;
• confirm your identity for the purposes of anti-money laundering and counter-terrorism laws and assess applications and your suitability for Circlepay Services;
• for the purpose of performing data analytics including to improve our and our Partners’ services;
• for other purposes to which you have consented; and
• as required or permitted by relevant laws and regulations.

You agree that we may use your Personal Information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.   

If all or some of your Personal Information is not collected or cannot be verified, we may be unable to provide you with Circlepay Services or a customised experience, engage with you, or do business with you.

 

How we share Personal Information with other parties

We may share your Personal Information with:

• Our employees and related bodies corporate;
• Our affiliates and related companies;
• Our Partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
• Financial institutions that we may partner with to jointly create and offer a product;
• Credit reporting bodies and collection agencies, including to report account information, as permitted by law. When we share your Personal Information with credit reporting bodies we authorise them to use that information for the purposes of providing their credit reporting services. To request a credit report, we will provide information to the credit reporting body that identifies you;
• Companies that we plan to merge with or be acquired by or who may invest in us;
• Law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Circlepay; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of our User Agreement; and
• Other third parties with your consent or direction to do so. 

We will only share your Personal Information with third parties as described in this Privacy Policy or as otherwise notified to you at the time of collection or with your consent.

 

Disclosure of Personal Information outside Australia

We may disclose your Personal Information to our Partners with locations outside of Australia. 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.

 

Consent

We may require your consent to use and/or disclose your Personal Information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to Circlepay collecting, using and/or disclosing your Personal Information for such other purposes, this may affect Circlepay’s ability to deliver and improve our products and services, or to engage or do business with you.

 

Marketing and privacy

Circlepay may send marketing materials from time to time to those who have provided Circlepay with Personal Information about products and services offered by Circlepay and our Partners.

If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message.  You can also log-in to your account to opt-out and update your marketing preferences at any time. 

Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences.  Unless otherwise required to process your requests earlier by law, it may take up to 5 days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests. 

Even after you’ve opt-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes.  These include, for example, customer service issues, returns or product-related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.

You may also contact us on via email on [email protected].

 

Cookies

We use cookies and track IP addresses via our Websites so we can improve our services provided by our Websites and enhance your user experience.

When you access our Websites or use Circlepay Services, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively ‘Cookies’). We use Cookies to ascertain which web pages are visited and how often, to make our Websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in.

For example, Cookies allow us to save your password so you do not have to re-enter it every time you visit our site.

Most web browsers automatically accept Cookies. You can find information specific to your browser under the “help” menu. You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our Websites and Circlepay Services.

 

Third party analytical services

Our Websites also use Google Analytics, a web analysis service of Google Inc. ('Google'). Google Analytics uses Cookies to monitor traffic to, and use of, the Websites. Information about the use of the Websites generated by these Cookies is generally transferred to a Google server in the USA and stored there. Google uses this information on our behalf to evaluate your Website usage, to compile reports on the Websites activities, and to provide additional services connected with the Websites. We will not identify you to Google, and will not merge personal and non-personal information collected through this service. You can prevent the use of Google Analytics Cookies by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of the Websites if you do so.

In addition to Google Analytics, we may also use other third-party analytics tools including but not limited to Facebook Analytics (an analytics service provided by Facebook, Inc.) to monitor, analyse and collect information about your use of the Websites.

Users may prevent Google’s collection of data generated by your use of the Websites (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

 

Controlling Our Tracking Tools

Your browser may give you the ability to control cookies.  How you do so, however, depends on your browser and the type of cookie.  Certain browsers can be set to reject all browser cookies.  If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Websites.  If you block or delete cookies, not all of the tracking that we have described in this policy will stop.  If you continue without changing your settings, we will assume that you are happy to receive all cookies on this Site.  You can change your cookie settings at any time.  Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked.  These browser features are still not uniform, so we are not currently set up to respond to those signals.

 

Protecting Personal Information

Circlepay will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.    

We also review our security procedures periodically to consider appropriate new technology and updated methods.  Only properly authorised people who have a need to access Personal Information to perform their job will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

  

Accessing and requesting correction of Personal Information

We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under privacy law, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your Personal Information or do not agree to correct your Personal Information we will tell you why.

If you wish to obtain access to and/or correct your Personal Information held by Circlepay, please contact Circlepay via email on [email protected]

Unless we do not agree to your request for access to Personal Information, in most cases Circlepay will provide you with access as soon as reasonably possible following receipt of your request. If you request corrections to your Personal Information and Circlepay agrees with your request, these changes will be made as soon as practicable. If Circlepay does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you are dissatisfied with our refusal to provide you with access to, or correct, your Personal Information you may also complain to the applicable regulator in your jurisdiction.

Subject to the terms set out in the Circlepay User Agreement, you can also close your Circlepay account through our Websites. If you close your Circlepay account, we may retain information from your account for a period of time to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or risk, enforce our User Agreement, or take other actions as required or permitted by law.

 

Resolving your concerns