Lotus Foreign Exchange Privacy Policy

1. Introduction (a) This policy sets out how Lotus Foreign Exchange Pty Ltd (ACN 108 877 050) (we, us, our) will collect, use, disclose and protect your personal information. (b) This policy applies if you use any of our products or services or contact us (including online, social media, our mobile apps, over the phone, over email, in-store, or by any other means) or visit our website or social media pages. (c) This policy does not limit or exclude any of your rights under the Privacy Act 1988 (the Act).
2. Changes to this policy (a) We may change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy.
3. Who do we collect your personal information from (a) We collect personal information about you from: (i) you, when you provide that personal information to us, whether in person, over the phone, on our app and including via our website and any related service, through any registration or subscription process, through any contact with us (e.g. telephone call or email), or when you buy or use our services and products; and (ii) third parties where you have authorised this, you are a recipient of a money transfer, or the information is publicly available.
   (b) If possible, we will collect personal information from you directly.
4. Types of information collected (a) We may need to collect the following information from you in order to process your transaction:
   (i) Your name, date of birth, address and contact details; (ii) Your identification documents and proof of address; (iii) Your credit or debit card information; (iv) Your bank account details; (v) If you are sending money, the recipient’s name, address and contact details; (vi) Your transaction records and interactions with us; (vii) Details regarding your transaction; (viii) The information set out in our customer registration form; (ix) Your location; (x) Your computer or network information; (xi) Relevant security information if you set up an online account; (xii) Any other information we may determine to be relevant; and (xiii) Other information required by law.
5. How we use your personal information (a) We will use your personal information:
   (i) to verify your identity; (ii) to provide services and products to you; (iii) to ensure the security of your transaction; (iv) to comply with our legal requirements; (v) to market our services and products to you, including contacting you electronically (e.g. by text or email for this purpose); (vi) to improve the services and products that we provide to you; (vii) to undertake credit checks of you (if necessary); (viii) to bill you and to collect money that you owe us, including authorising and processing credit card transactions; (ix) to respond to communications from you, including a complaint; (x) to conduct research and statistical analysis (on an anonymised basis); (xi) to protect and/or enforce our legal rights and interests, including defending any claim; (xii) for any other reasonable purpose we determine in relation to our business; and (xiii) for any other purpose authorised by you or the Act.
6. Disclosing your personal information (a) We may disclose your personal information to: (i) another company within our group; (ii) any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the website or other services and products; (iii) identity verification entities in order to verify your identity for transaction security purposes and to comply with our obligations at law; (iv) fraud prevention agencies; (v) a credit reference agency for the purpose of credit checking you; (vi) any of our partners who require your information in order to process your transaction; (vii) other third parties (for anonymised statistical information); (viii) a person who can require us to supply your personal information; (ix) when we have contracted an external auditor or organisation to provide us with AML/CTF compliance services, regulatory review, monitoring and screening. (x) to comply with our legal and reporting obligations; (xi) where we suspect that unlawful activity has been or may be identified pertaining your details; (xii) to Australian Transaction Reports and Analysis Centre (AUSTRAC) and other government agencies; (xiii) any other person authorised by the Act or another law; and (xiv) any other person authorised by you. (b) Due to the nature of our business which involves sending money overseas, and receiving money from overseas, businesses that assist us in providing our services and products may be located outside Australia. This may mean your personal information is held and processed outside Australia. (c) We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
7. Protecting your personal information (a) We will take reasonable steps to keep your personal information safe from loss, unauthorised activity, or other misuse. (b) We implement strict security measures to protect your information from unauthorised access, use, or disclosure. Advanced encryption technologies are employed to ensure the protection of your information during transmission and storage.
8. Refusal to provide information (a) You have the right to choose whether to provide personal information. However, please note that if you refuse to provide necessary information, we may be unable to complete your transaction request.
9. Internet use (a) While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. (b) If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal information. We suggest you review that site’s privacy policy before you provide personal information.
10. CCTV (a) For safety and security reasons, and to resolve customer complaints, we collect and store CCTV footage at all of our physical stores.
11. Cookies (a) We use cookies (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) to monitor your use of the website. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.
12. Lotus FX Online (a) When you download and use our mobile app or online portal, we may collect your mobile device information and location. (b) You are responsible for selecting your password for Lotus FX Online. Ensure this is something that cannot be easily guessed and keep it safe and secure.
13. Retention (a) We will retain your information as long as we need it in order to continue to provide our products and services to you. We are also bound by legal obligations in relation to our record keeping which requires us to hold transaction records for a minimum period of time.
14. Contacting us (a) If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us by email to aucustomercare@lotusfx.com, by phone on + 02 9806 0955, or in writing to PO Box 8084, Blacktown, NSW 2148.