Privacy Policy

INTRODUCTION

China Payments is a business unit of Novatti Group Limited (Novatti). Novatti is listed on the Australian Stock Exchange with code (ASX:NOV).

This Privacy Policy describes the personal information that may be collected by China Payments (‘China Payments’, ‘we’ or ‘us’), the choices you can make about your personal information and how we protect your information.

If you would like a printed version of this policy, you can print this page using your browser, or contact us for a copy. Our contact details are listed at the end of this Policy

To meet your expectations about privacy and confidentiality, China Payments has established operational processes and procedures to comply with:

  • Australian Privacy Principles (APPs) contained in the Privacy Act 1988
  • Australian Direct Marketing Association (ADMA) Code of Practice in relation to how we market to our customers;
  • Spam Act 2003 in relation to electronic marketing;
  • Do Not Call Register Act 2006 where we might engage in telemarketing activities in the future.

If you have any questions not addressed in this policy, please feel free to contact us using the methods at the end of this policy under the heading “How to contact Us”.

ACKNOWLEDGEMENT

By using this website, you acknowledge that you’ve read and understood this privacy policy. Please note that this policy does not extend your rights or China Payments’ obligations beyond those defined in the legislation listed above.

Should there be any inconsistency between this policy, the Privacy Act and other Acts mentioned above, this policy shall be interpreted to give effect to and comply with the legislation.

Our websites may contain links to non-China Payments websites. We are not responsible for the privacy policies of those other websites. We recommend you review the privacy policies of each site you visit.

COLLECTION OF PERSONAL INFORMATION

‘Personal information’ means information we hold about you where your identity is either clear or can be reasonably determined. When you give us your personal information, it imposes a serious responsibility on us. Protecting your privacy when handling your personal information is very important to us and is fundamental to the way we serve you.

We will collect personal information directly from you, and only to the extent necessary to provide the product or service you requested or to carry out our internal administrative operations or meet relevant regulatory requirements. We may also collect personal information for the purpose of enhancing our ability to improve service delivery to you and other customers in the future.

We may collect personal information from you when:

  • you fill in the contact request form;
  • deal with us over the telephone;
  • purchase a product or service;
  • e-mail us;
  • participate in an online promotion;
  • provide us with feedback;
  • complete online surveys;
  • contact, register with, post to, like or follow any of our social media websites, pages, forums or blogs; and/or
  • ask us to contact you after visiting our website.

We will collect personal information from you by lawful and fair means.

If you choose to not provide your personal information when requested, we may not be able to deliver the product or service that you have requested. We will endeavour to make this as clear as possible for each case.

In some cases, where it makes sense and is lawful, you can interact with us anonymously or by using a pseudonym (an alias). We will endeavour to make this option clear when it is available to you.

Information collected

As noted above, we will only collect personal information from you that’s necessary to provide the product or service or to carry out internal administrative functions, or any other personal information you submit to us. We collect different personal information depending on the product or service that you have requested.

There may be occasions when we collect information about you from a third party where it is reasonably necessary or normal business practice to do so, for example from payment gateways relating to payments made through third party providers.

When you elect to purchase a product online, we collect basic contact details (name, address, phone, email) to simplify the checkout process for you and to allow you to sign-up to receiving related promotional offers.

Unsolicited information

“Unsolicited” personal information is personal information about an individual that an organisation has unintentionally received. This is an uncommon occurrence for China Payments, but when it does happen, we will protect your personal information with the same rigour as we treat personal information that we intended to collect. If we could not have collected this information through our normal processes, we will de-identify that information as soon as we can.

USES AND SHARING

We use the personal information you provide only for purposes consistent with the reason you provided it, or for a directly related purpose. We may also use your personal information where required or permitted by law. We may also use your information where you have provided us with your express or implied consent.

We may also use your personal information, or aggregate your personal information with the personal information of other customers (so that the aggregated information is no longer personal) for the purposes of:

  • analysis to help us better understand the needs of our customers so that we can better develop products and services for you;
  • providing information that is tailored to what we believe are your areas of interest; and;
  • analysing your product and services to improve your experience and to enable us to develop new or enhanced functionality for you.

We do not share your personal information with other organisations unless:

  • you give us consent, or
  • where sharing is otherwise required or permitted by law.

We may contact you periodically to advise you of new or enhanced functionality which is available in connection with our products and services. You will not be obliged to adopt any such functionality.

We have a strict duty to maintain the privacy of all personal information we hold about you. However, certain exceptions do apply. For example, where disclosure of your personal information is:

  • authorised or required by law (e.g. disclosure to various government departments and agencies, or disclosure to courts under subpoena);
  • in the public interest (e.g. where a crime, fraud or misdemeanour is committed or suspected and disclosure against the customer’s rights to confidentiality is justified);
  • with your consent – your consent may be implied or express and it may also be verbal or written.

Treatment of personal information with subsidiaries

China Payments can disclose personal information (excluding sensitive information) with subsidiaries and controlled entities as long as the purpose for sharing is related to the reason the personal information was originally collected.

Direct Marketing

From time to time we may use the personal information we collect from you to identify particular China Payments products and services which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. We will generally only do this with your prior consent (where practical) and we will always give you a choice to opt out of receiving such information in future.

Direct Marketing from China Payments generally takes the form of Electronic Marketing (email). In rare cases, we may use Telemarketing. Each of these channels is handled as follows:

  • Electronic marketing– Where we use your personal information to send you marketing information by e-mail, SMS, MMS or other electronic means we may do so with your express or implied consent. Consent may be implied from our existing business relationship or where you have a reasonable expectation of receiving an electronic marketing communication.
  • Telemarketing – China Payments does not usually engage in telemarketing activities to our consumer customers. Generally, such marketing is only used in relation to our business customers. Should any consumer telemarketing be undertaken or authorised by China Payments, we will, to the extent that it applies, comply with the relevant legislation (see above).

Every directly addressed marketing contact sent or made by China Payments will include a means by which customers may unsubscribe (or opt out) of receiving further marketing information.

Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to the Customer Support Team via the channels provided under Contact us’.

ACCESSING YOUR PERSONAL INFORMATION

You have the right to request access to the personal information we hold about you. This right is subject to certain exceptions allowed by law.

China Payments will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type (or types) of information requested. China Payments will deal with your request in a reasonable time – usually within 30 days.

Exceptions

Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information.

Freedom of information laws

In addition to privacy laws, you may have rights to access your personal information contained in certain China Payments documents. Details on how to apply for access to these documents are contained in the Freedom of Information Act 1982 (FOI Act).

More information is available at the Office of the Australian Information Commissioner’s freedom of information pages.

UPDATING YOUR INFORMATION

It is inevitable that some personal information which we hold will become out of date. We will take reasonable steps to ensure that the personal information which we hold remains accurate and, if you advise us of a change of details, we will amend our records accordingly.

Where we are unable to update your information, we will provide an explanation in writing as to why the information cannot be corrected.

INFORMATION SECURITY

China Payments is committed to protecting and securing your personal information.

We employ appropriate technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration.

We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law.

China Payments protects your personal information by complying with Information Security Standards and Statutory obligations. We regularly conduct targeted internal and external audits on our security systems to validate the currency of our security practices.

WEBSITE SECURITY AND PRIVACY

We understand that you may be concerned about the security of the personal information we collect from you online. Accordingly, we have systems in place to ensure our online dealings with you are secure.

In those instances, where we secure your personal information in transit to us and upon receipt, we use the industry standard encryption software, Secured Socket Layer (SSL) 128 bit encryption. The URL in your browser will change to “HTTPS” instead of “HTTP” when this security feature is invoked. Your browser may also display a lock symbol on its bottom task bar line to indicate this secure transmission is in place.

We employ security programs and services to monitor network traffic in order to identify attempts to breach our security.

Information collected on our website

We may collect non-personal information from you such as browser type, operating system, and web pages visited to help us manage our web site.

We use cookies (see below) and other internet technologies to manage our website and certain online products and services. We do not use these technologies to collect or store personal information unless you have opted in to such a feature. Where you’ve logged into our website we may reflect the products and services you use with your on-line behaviour to provide content that is of more interest to you.

Our internet server logs the following information which is provided by your browser for statistical and content optimisation and personalisation purposes:

  • the type of browser and operating system you are using;
  • your Internet Service Provider and top level domain name (for example – .com, .gov, .au, .uk);
  • the address of any referring website (for example – the previous web site you visited); and
  • your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).

All of this information is used by China Payments for aggregated statistical analyses or systems administration purposes only. No attempt will be made to identify users or their browsing activities, except where required by law.

Cookies

A “cookie” is a packet of information stored on your computer that allows the China Payments server to identify and interact more effectively with your computer.

Our websites use two different kinds of cookies:

  • Session cookies– temporary cookies that only last until you close your browser;
  • Persistent cookies – cookies that are stored for a longer term on your computer.

Session cookies

When you access our web site, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s internet browser type. When you close your browser, the cookie is deleted and no longer exists on your computer.

You are free to disable cookies in your browser (see details below). If you have disabled cookies, you may not be able to take full advantage of all of our website features.

We use session cookies in the following manner:

  • Transactions and site usability – We use session cookies to improve how you navigate through our website and conduct transactions. As examples, session cookies are used to maintain your online session as you browse over several pages; to store and pre-populate information so that you do not have to re-enter the same information twice. Session cookies may also be used to collect referral statistics when you click on a link or ad banner to or from China Payments.com.

Persistent cookies

China Payments may also use “persistent cookies”. A persistent cookie is a small piece of text stored on your computer’s hard drive for a defined period of time, after which the cookie is erased. China Payments will not collect or link to personal information through persistent cookies without your express consent.

We use persistent cookies as follows:

  • Site usage measurement– Our site measurement tool uses a persistent cookie to assist us in measuring how and when our web site and its various components are used. It functions as a “visit cookie,” so we can determine if you are a repeat visitor to our site. This allows us to know if we are attracting new visitors and what aspects of the site seem most useful. The cookie will expire 30 days after your last visit.
  • Click stream data – “Click stream data” is information which is derived from an analysis of your website activity based on the sequence of links which you click on while browsing our Website. When you visit the Website or use our products and services, we will collect this information for analysis, maintenance or reporting purposes and to improve the performance of our Website. This can include information such as your IP address, the duration of your visit and the date and time of your visit.

Cookie Management

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Most browsers accept cookies by default. To learn more about cookies, including how to refuse cookies on your computer, click these links:

Links to other sites

The China Payments site may contain links to other sites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read and understand the privacy policies on those websites prior to providing any information to them.

LOSS OF PERSONAL INFORMATION

Despite our every effort to protect your personal information, there remains the possibility that a breach of our security could occur. In the event of loss of personal information China Payments will:

  • Seek to rapidly identify and secure the breach to prevent any further breaches;
  • Engage the appropriate authorities where criminal activity is suspected;
  • Assess the nature and severity of the breach including the type of personal information involved and the risk of harm to affected individuals;
  • Notify the affected individuals directly if appropriate and where possible;
  • If appropriate, put a notice on our website advising our customers of the breach;
  • Notify the Privacy Commissioner, if the breach is significant.

HOW TO CONTACT US

China Payments is committed to working with its customers to obtain a fair resolution of any complaint or concern about privacy.

To contact us with a compliment or complaint or a privacy question, you can:

  • write to us at:
    China Payments Pty Ltd
    Legal & Operational Compliance Officer
    Level 1, 293 Swanston Street
    Melbourne Vic 3000
  • call us at our Customer Contact Centre on (03) 9011 8490 between 9.00am and 5.00pm EST Monday to Friday.

CHANGES TO THIS PRIVACY POLICY

We will post changes to the Privacy Policy and publish the effective date when this policy is updated.

Last updated: July 2017

Further information on privacy

You can obtain further general information about your privacy rights and Commonwealth privacy law from the Office of the Australian Information Commissioner by:

  • writing to:
    The Australian Information Commissioner
    GPO Box 5218
    Sydney NSW 1042