Privacy Policy

Hanpass | Collectioon Statement | August 2024

This Collection Statement was last updated on 09 August 2024.

To assist us in providing our products and services and otherwise conducting our business functions and activities, we need to collect personal information about you. By providing your personal information, you agree that it will be used and disclosed by Hanpass Global Pty Ltd ACN 666 565 340 and its related entities (collectively Hanpass, we, us or our) in accordance with this statement and our Privacy Policy, available at www.hanpass.com.au. If you do not agree, you must not provide your personal information, and we may not be able to communicate with you or provide certain products or services to you. We may disclose your personal information to other parties, including to third parties who provide products and services to us or through us in the ordinary operation, administration or promotion of our business and otherwise in accordance with our Privacy Policy. From time to time, these third parties may be located (and therefore your personal information may be disclosed) overseas, including Korea. We may use and disclose your personal information for direct marketing purposes, unless you use any choices presented at the time you provide your personal information to us to not opt in, or if you later opt out (which you can do at any time in accordance with our Privacy Policy). Our Privacy Policy contains information about how you may access and seek correction of your personal information, how you may complain about a breach of your privacy, and how we will deal with that complaint.

Hanpass | Privacy Policy | August 2024

This Privacy Policy was last updated on 09 August 2024.

1. About this Privacy Policy

1.1 Hanpass Global Pty Ltd ACN 666 565 340 (Hanpass, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 15.

1.2 Hanpass is related to other companies and entities, including our parent company Hanpass Korea Co,. Ltd (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Hanpass, we, us or our is also a reference to those related entities.

2. Personal Information

2.1 "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3. What Personal Information do we collect and hold?

3.1 The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

(a) name

(b) age and date of birth

(d) current address (including postal addresses)

(e) email address

(f) gender

(g) identification information such as driving licence details, including driving licence number, passport and other identity documents

(h) sensitive information, which may include the result of Document Verification Service (DVS) or other third-party document or identity verification service provider checks and background checks such as criminal history information for our onboarding and Know Your Client (KYC) processes

(i) payment details, such as your credit card or bank account details

(j) sender and recipient account and transaction details, including names, dates, account providers/institutions, account numbers, transaction amounts and descriptions, in order to provide, and keep records of, our remittance services

(k) geographical location

(l) photographs and/or images of you from camera footage

(m) information from social media accounts and profiles, and

(n) for job applicants, we may also collect:

(i) occupation and employment details including employment status and any previous work experience

(ii) information from or in connection with your resume or job application if you apply for a position with us, and

(iii) passport and visa details (where relevant).

3.2 We collect and record Personal Information about individuals such as:

(a) our customers, potential customers and their representatives

(b) the senders or recipients of transactions to and from our customers, including representatives of any sending or receiving business or other entity

(d) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us

(e) our directors and employees past and present, including applicants, and

(f) any other person who comes into contact with Hanpass.

3.3 Sender and recipient financial institutions will also collect Personal Information about their account holders who send or receive money through transactions that we remit, and may use that Personal Information for their own purposes separately from our collection and use for processing transactions. You must review and understand your financial institution's privacy policy and data collection notices to understand their Personal Information handling practices. We are not responsible for the use of Personal Information by sender or recipient financial institutions.

4. How and when do we collect Personal Information?

4.1 We collect your Personal Information to allow us to conduct our business functions, to process and remit transactions on behalf of our customers, and to otherwise provide, market and sell our products and services, and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

4.2 We may collect your Personal Information in the course of your use of our Website (see paragraph 5), mobile applications or other services, or when otherwise providing you with goods or services, or:

(a) when you provide us, or you offer or apply to supply us, with goods or services

(b) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)

(c) during the application or onboarding process for the use of our products or services, including during the identity/verification process

(d) when you are otherwise the recipient or sender of a transaction processed or remitted by us

(e) when you request information about us, our products or our services

(f) for fraud detection services

(g) when you provide feedback to us

(h) when you visit or fill in a form on our Website (see paragraph 5)

(i) when you register for or use an account on our Website or via our mobile applications

(j) when you use our mobile applications, whether or not you register for an account or for onboarding

(k) when you visit premises from which we operate

(l) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations

(m) when you submit a job application to us

(n) when you otherwise contact us by telephone, fax, email, social media, post or in person, or

(o) where we are otherwise required or authorised by law to do so.

4.3 Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

4.4 We may also collect your Personal Information to conduct a DVS check which is used for the purpose of authenticating Australian Government documents. One of our third party service providers may collect this Personal Information directly from you in order to undertake this and other KYC checks on our behalf. The DVS is a national secure online system, which enables authorised entities to electronically verify Evidence of Identity (EOI) documents issued by a range of Australian, State and Territory government agencies. Separate permission will be sought from you before this information is transmitted to DVS. More information regarding the DVS can be found here: https://www.idmatch.gov.au/.

4.5 We may also collect Personal Information about you from third parties and other sources such as:

(a) your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors)

(b) the other party (sender/recipient) to a transaction we process or remit

(d) related entities, companies and businesses of Hanpass

(e) document verification and background check service providers, document issuers or official record holders via third party systems for the purpose of confirming your identity and those provided, and undertaking background and KYC checks, or

(f) credit reporting bodies,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

4.6 If the Personal Information we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

4.7 Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

4.8 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you. If you do not provide the identity details and information we need to verify your identity and run KYC checks we will be unable to onboard you as a user.

5. Information collected via our Website and mobile applications

5.1 Personal Information may be collected by us and by our third party service providers who assist us in operating our website at www.hanpass.com.au, including its subdomains and any other website we operate from time to time (collectively the Website).

5.2 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website or using our mobile applications, including but not limited to the methods set out in this paragraph 5.

Google Analytics

5.3 We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

5.4 If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout

Click Stream Data

5.5 When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for purposes including statistical, reporting and website administration, maintenance and improvement purposes.

Cookies

5.6 Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.

5.7 Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

5.8 Cookies may also be used for other purposes on our Website.

5.9 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

5.10 If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Advertising networks

5.11 We use network advertisers to serve advertisements on unaffiliated websites or other media (e.g. social networking platforms). This enables us and network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors, and/or traffic measurement services may use pixels, cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These pixels, cookies and other technologies are governed by each entity’s specific privacy policy, not this Privacy Policy. We may provide these advertisers with information, including Personal Information, about you.

5.12 In accordance with applicable law, we may disclose certain information (such as your email address) to third party advertising networks such as Facebook Custom Audiences, so that we can better target ads and content to you and others with similar interests on other websites or media (Custom Audiences). For more information on Facebook Custom Audiences click here or to opt-out, go to the Facebook ad preferences page. We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.

5.13 You may be able to opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (DAA) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (NAI) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

5.14 Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e. contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt out may not be effective.

Facebook Pixel

5.15 With your permission, our Website utilises Facebook Pixel which belongs to the Facebook Business Tools. This tool allows us to follow the actions of users after they are directed to a provider’s website when clicking on a Facebook ad. The collected data is saved and processed by Facebook. Facebook may connect your data with your account and use it for their own advertising purposes. For more information please visit Facebook's Privacy Policy. You can revoke permission at any time through your Facebook account. For more information please see here.

Web Beacons

5.16 Web beacons are images that originate from a third party site to track visitor activities. We use web beacons to track the visiting patterns of individuals accessing our Website.

Third party content (eg social media links)

5.17 Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

6. How do we use your Personal Information?

6.1 We use the Personal Information we collect about you for our business functions and activities, to process and remit transactions as directed by our users, to operate our business efficiently, and to market our products and services for the benefit of our customers.

6.2 We may collect, hold and use your Personal Information:

(a) to identify and communicate with you

(b) to enable us to provide you with requested information, products or services

(d) to onboard our users, including to undertake identity verification and background checks which require us to use your identity documents and undertake KYC checks

(e) to collect and process payments (either on behalf of our users as part of our services, or payments made to us eg by our users in consideration for our products and services)

(f) to help us to manage and enhance products or services we provide to you

(g) to help us to manage and enhance goods and services we procure from our suppliers and subcontractors

(h) to personalise and customise your experiences on our Website and mobile applications

(i) to manage and administer any account you may hold with us

(j) to promote and market our products and services to you

(k) to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners

(l) to conduct research for the purposes of improving existing products or services or creating new products or services

(m) to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally

(n) to identify, investigate and protect you and us from fraud

(o) to provide for the safety and security of workers and onsite visitors

(p) to help us manage our business operations

(q) for business support purposes including maintenance, backup and audit

(r) to process any job application submitted by you

(s) to respond to any queries or complaints you may have

(t) to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information, or

(u) to comply with our statutory and legal obligations.

6.3 We may use your Personal Information to detect and prevent fraud against us and our users, including to detect unauthorised log-ins using your online activity. We may disclose your Personal Information to financial institutions, payment processors, card issuers and others involved in payment processing activities that have requested Personal Information about you so that they can assess the associated fraud risk with a transaction.

6.4 We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

6.5 We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or our mobile applications or to retain the content of any user session.

6.6 You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

6.7 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

(a) in accordance with this Privacy Policy or any agreement you enter into with us, or

(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

7. When do we disclose your Personal Information?

7.1 Hanpass may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

7.2 We may also disclose your Personal Information to:

(a) any of Hanpass's internal divisions, business units or departments

(b) your nominated representatives

(d) professional service providers and advisors who perform functions on our behalf, such as lawyers

(e) medical providers including medical and rehabilitation practitioners for assessing insurance claims

(f) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)

(g) debt collecting agencies

(h) banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers

(i) Government, regulatory authorities and other organisations as required or authorised by law (such as AUSTRAC)

(j) document verification service providers, document issuers or official record holders via third party systems (see paragraphs 4.4 and 4.5), and

(k) credit reporting bodies.

7.3 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website or mobile application experiences a technical problem or to ensure that it operates in an effective and secure manner.

7.4 As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

8. Overseas disclosures

8.1 Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

(a) our offices or related entities are overseas

(b) we outsource certain activities overseas

(d) our computer systems including IT servers are located overseas.

8.2 You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

8.3 In particular, your Personal Information may be disclosed to third parties in Korea, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries.

9. Other uses and disclosures

9.1 We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will generally seek to take reasonable steps to make it known to you at the time we collect or use your Personal Information, unless otherwise permitted by law.

10. Marketing

10.1 Unless you use any choices presented at the time you provide your Personal Information to us to not opt in, you consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

10.2 If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

(a) clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us

(b) logging into your account on the Website or in our mobile application and editing your communication preferences (if that functionality is available on the Website or mobile application), or

11. Storage and security of Personal Information held by us

11.1 We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or mobile applications or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.

11.2 If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it. Please note some laws applicable to us may require Hanpass to retain Personal Information for a minimum period of time, for example AUSTRAC requirements to retain information for a period of 7 years in relation to financial transactions. We may otherwise keep Personal Information for as long as permitted or required by applicable law.

12. You can access and update your Personal Information

12.1 You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, Hanpass may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

12.2 You can access and correct some of your Personal Information through the mobile application by logging into your account and updating or editing your profile at any time. Alternatively, a request for access can be made by contacting us in any of the ways specified in paragraph 15.

12.3 We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

12.4 Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.

12.5 It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

13. How do we deal with complaints about privacy?

13.1 If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint. Complaints from users will initially be directed to our Customer Support team. If Customer Support are unable to satisfactorily investigate or resolve the issue it may be escalated to an appropriate level of management depending on the issue.

13.2 If applicable, all relevant authorities or third parties (such as DVS) may also be advised of a request or complaint that involves information provided to or received from those authorities or parties where relevant.

13.3 It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

13.4 We will notify you of the outcome of our investigation.

14. Updates to this Privacy Policy

14.1 We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: www.hanpass.com.au where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

15. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

15.1 If you:

(a) have a query or concern about this Privacy Policy or our Personal Information handling processes

(b) wish to make a complaint in relation to a breach of your privacy

(c)           would like to access your Personal Information held by us

(d)           would like to update or correct your Personal Information held by us, or

(e)           would like to opt out of direct marketing,

please contact us using the details provided in our mobile application or in any of the following ways:

» Email Address: admin.au@hanpass.com

» Mailing Address: Level 25, 100 Mount Street, North Sydney, NSW, 2060 Australia, or

» Phone: +61 2 8912 2193.