Privacy Policy

1. Collection of personal information

Personal information: The type of information we collect may include:

• i. name;
• ii. contact details including email address, address and telephone number;
• iii. date of birth;
• iv. demographic information such as postcode;
• v. identification documentation such as your drivers licence number, international passport number, bank statement and utility bill;
• vi. credit card and recipient bank account information;
• vii. cashback credit balance, loyalty tier status, and rewards transaction history;
• viii. transfer volume and frequency data used for loyalty tier calculation;
• ix. device and technical identifiers and app telemetry (such as device identifiers, IP address, and usage and diagnostic data from our websites and apps); and
• any other information requested on our Sites or otherwise requested by us or provided by you.

Your use of our Site: As with most online businesses, we may log information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

Your opinion and feedback: We may contact you to voluntarily respond to questionnaires, surveys or market research to seek your opinion and feedback. Providing this information is optional to you.

If we receive your personal information from third parties, we will protect it as set out in this Privacy Policy.

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2. Sensitive and biometric information

To meet our identity-verification obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), our identity-verification process collects biometric information — namely, an image of your face and a short liveness/motion capture — which we, together with our identity-verification provider, use to confirm that you are a real person and match you to your identity document. This is "sensitive information" under the Privacy Act 1988 (Cth). We collect and use it only for identity verification and fraud prevention, and only with your consent, which we ask for separately at the point of capture. If you do not consent, we will not be able to verify your identity and you may not be able to use the Service. We do not use your biometric information for advertising or share it for any purpose other than identity verification and fraud prevention.

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3. Collection and use of personal information

We collect and use the information for purposes including:

• i. to contact and communicate with you;
• ii. for internal record keeping;
• iii. for identification purposes and for compliance purposes with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006;
• iv. for fraud prevention and sanctions/PEP screening;
• v. for market research and business development including website development;
• vi. for marketing including direct marketing;
• vii. to run competitions or offer additional benefits to you;
• viii. for data analytics purposes; and
• ix. to administer and manage the Rewards, Cashback & Loyalty Program, including calculating cashback, determining loyalty tier status, and preventing program abuse.

Payments into the Service are processed by trusted third-party payment providers: an Australian payments provider for bank transfers and PayID/NPP payments, and an international card acquirer for card payments (Visa and Mastercard). These providers handle your payment details under their own security controls. To provide the Service and to meet our record-keeping obligations under the AML/CTF Act, we collect and retain transaction records, and we collect the recipient bank account details you enter so we can deliver your transfer.

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4. Disclosure of personal information to third parties

We may disclose personal information to:

• i. our payout partners and financial institutions in the destination country, so we can deliver your transfer (see the overseas disclosure section below);
• ii. our service providers who help us run the Service, including our identity-verification provider, sanctions/PEP and fraud screening providers, payment providers, cloud hosting and communications providers;
• iii. advertising and analytics providers (including Google and Meta) where you have consented, to measure and improve our advertising;
• iv. courts, tribunals, regulatory authorities and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.

Where we disclose your personal information to third parties for these purposes, we will request that the third party follow this Privacy Policy regarding handling of your personal information.

If there is a change of control of our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible by law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser. We would seek to only disclose information in good faith.

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5. Overseas disclosure of personal information

Because we send money internationally, some of the recipients of your personal information are located, or store data, outside Australia. These include:

• Payout partners who deliver your transfer in the destination country — licensed international payout partners and their local agents, whose processing locations include the United Kingdom, Europe, the United States, and the regions we send money to across Africa, Asia, the Middle East and Latin America. Which partner is used depends on the corridor and payout method you choose.
• Identity, screening and fraud-prevention providers who help us verify your identity and screen transactions, and who may process data outside Australia.
• Advertising and analytics providers, including Google and Meta, which process data in the United States, where you have consented to analytics and marketing cookies (see our Cookie Policy).

Our primary document and data storage is hosted in Australia. Where we disclose your personal information overseas, we take reasonable steps to ensure it is handled consistently with this Privacy Policy and the Australian Privacy Principles.

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6. Your rights and controlling your personal information

• Choice and consent: Providing us with your personal information is optional to you. You can choose not to provide personal information. When you provide us with your personal information, you consent to the terms in this Privacy Policy, and to us disclosing or receiving your personal information for these purposes.
• Your provision of third party information: If you provide us with third party personal information then you warrant to us that you have the third party’s consent to provide this.
• Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us at the email address listed in this Privacy Policy.
• Access: You may request details of personal information that we hold about you, in certain circumstances set out in the Privacy Act 1988 (Cth). We do not charge you to make an access request; if a fee applies for giving access it will not be excessive. In certain circumstances set out in the Privacy Act we may refuse access, in which case we will give you written reasons and information about how to complain.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us by email. We rely in part upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.
• Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint about that breach, please contact our Privacy Officer by email at admin@topratetransfer.com.au setting out details of the breach. We will acknowledge your complaint and respond in writing, ordinarily within 30 days, setting out the outcome of our investigation and any steps we propose to take. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or on 1300 363 992.
• Unsubscribe: To unsubscribe from our e-mail database, or opt out of communications, please contact us using the details below or use the unsubscribe link in our messages.

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7. Retention of your information

We keep your personal information only for as long as we need it for the purposes described in this Privacy Policy, or for as long as the law requires. As a remittance service provider, the AML/CTF Act requires us to keep customer identification records and transaction records for at least seven years after our relationship with you ends or a transaction takes place. This means that, even if you ask us to delete your information or close your account, we cannot delete the records we are legally required to keep for that period; we will restrict their use to what the law requires. Once information is no longer needed and we are no longer required to keep it, we take reasonable steps to destroy or de-identify it.

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8. Storage and Security

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification and disclosure. These steps include encryption of data in transit, access controls, and physical, electronic and managerial safeguards. Connections to our Sites are secured using industry-standard encryption (TLS).

While we take these steps, no method of transmission over the Internet or method of electronic storage is completely secure. We continue to review and improve our security measures.

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9. Data breach notification

If a data breach occurs that is likely to result in serious harm to affected individuals, we will assess it and, where required, notify affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth).

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10. Cookies & Web Beacons

We may use cookies on this Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. However, once you choose to furnish the Site with personally identifiable information, this information may be linked to the data stored in the cookie.

We may use web beacons on this Site from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the visitors’ behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

For full detail of the cookies and similar technologies we use, and how to control them, see our Cookie Policy.

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11. Links to other websites

Our Site may contain links to other websites of interest. We do not have any control over those websites. We are not responsible for or liable for the protection and privacy of any information which you provide whilst visiting such websites, and such websites are not governed by this Privacy Policy.

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12. Amendments

This Privacy Policy may be amended, including with changes, additions and deletions, from time to time. We will notify you of material changes — for example, before we use your information for a new purpose, collect a new category of sensitive information, or disclose it to a new class of overseas recipient — and, where the law requires your consent, we will ask for it rather than rely on your continued use. You should check this Privacy Policy regularly to ensure you are aware of any changes.

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For any questions or notice, please contact our Privacy Officer at:

Registered Office: Top Rate Transfer Pty Ltd ACN 641 161 444,

Perth WA 6000

Email: admin@topratetransfer.com.au

Phone: 08 8992 7648

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