Privacy Policy

Effective Date: 27 June 2024

Introduction

Read about how Cryptospend Pty Ltd (ACN 630 245 813) trading as Wayex (Wayex, us, our) collects, protects, uses and discloses your personal information.

Our Commitment

Your privacy is important to us. We are committed to protecting your privacy and as part of that commitment, we want to ensure that you have a clear understanding about the data we collect about you, how we use it and who we share it with.

We provide products and services that require us to collect, store, share and use your personal information. This Privacy Policy applies when you use our products or services (described below).

Our Privacy Statement

This Privacy Policy sets out how we collect the data about you, how we use it and how we keep it secure.

Changes to Privacy Policy

We may change this Privacy Policy from time to time by publishing changes to it on our Website (www.wayex.com). Please check our website regularly to ensure that you are aware of any changes to this Privacy Policy. If we make substantial changes to this Privacy Policy, we will email you with an update.

Your Responsibilities

Please read this Privacy Policy and the Website Terms & Conditions.

If you provide us with any data relating to a third party, you confirm that you have the right to authorise us to process that data on your behalf in accordance with this Privacy Policy.

When and How We Collect Data

From the moment you visit our Website or access our products or services, we are collecting data from you, sometimes you might provide this data by completing application forms, setting up an account, otherwise we may collect the data automatically. We may also collect the data:

• when you interact with us (over the telephone or messaging apps), our website or mobile application;
• when you use our products or services; or
• when we provide you with assistance or support or request information regarding our products and services;
• you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products and services; and
• when you participate in any promotions.

Types of Data We Collect

What we collect depends entirely on how you use our products or services and the type of relationship we will have with you as our customer. Some of the more obvious things we collect are your name, address, email, date of birth, driver’s licence, bank account details or credit or debit card details. We may also collect more detailed information, including:

• Personal Information relating to your contact details as noted above in addition to biometric information as well as information about demographics, your employment history and connections with others whose personal information we also collect or hold;
• Technical Information; such as internet protocol address, location information, information about the type of device and operating system used by you as well as details of your interactions with us;
• Financial Information, this relates to such things as transaction details relating to your use of our products, services and rewards as well as information regarding your source of funds and wealth;
• Third Parties, we may collect information about you from third parties such as related entities, data providers, exchanges, credit providers and third party suppliers and service providers in connection with providing our products and services; public sources; your advisers; banks, financial institutions and other third-party providers;
• Telephone recordings, we may record telephone calls you have with us for training and quality assurance purposes;
• Any other relevant information that you give to us for the purpose of providing you with our products or services.

Why We Use Your Data and Disclosure

Under data laws, we are only allowed to use your data for specific reasons and where have a legal basis to do so. We will use your data for the purposes it was collected and related purposes including:

• to verify your identity;
• to run the Website and mobile application;
• to provide you with products, information and services;
• to refer you to receive products or services from Flexewallet Pty Ltd;
• for customer support;
• to detect and prevent fraud;
• to improve our Website and mobile application;
• for the purposes of meeting our legal and regulatory obligations;
• to make your experience on our website and mobile application more efficient and enjoyable;
• for market research e.g. we may contact you for feedback about our products and services;
• to provide you with information about events, other products or services or opportunities that may be of interest;
• for direct marketing purposes;
• to comply with our legal obligations, resolve any disputes that we may have with any of our clients, and enforce our agreements with third parties; and
• to monitor your compliance with our Terms & Conditions, Product Disclosure Statement and other documents issued by us.

We may disclose your data for the purposes it was collected and also:

• as required by law subject to our obligations;
• with your consent;
• within our business;
• send you marketing material (subject to complying with applicable laws);
• process your participation in any promotions and giveaways (including contacting you if you win, displaying your name online); and
• share with third party suppliers and service providers in connection with providing our products and services.

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• our related entities, employees, officers, agents, contractors and other companies that provide services to us;
• to merchants and recipients of funds to identify you as the sender of the funds and to a party whom sends you funds In connection with a transfer to you of funds;
• to third-parties in order to let you know about goods and services which may be of interest to you;
• to third-party identity verification providers;
• to our professional advisers such as consultants, bankers, insurers, brokers and auditors in connection with the operation of our business;
• third party suppliers and service providers in connection with providing our products and services;
• to software providers or intermediaries where you participate in online or 'app' based service offerings where your information is disclosed or otherwise stored;
• debt recovery agencies to recover funds owing to us;
• payment systems operators;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us;
• government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

What Are Your Choices?

Don’t provide us with personal data

You can choose not to provide us with any personal data. However, if you do this, we will not be able to provide you with any products or services. However, you can continue to use our Website and may have limited access to the mobile application.

Turning off cookies

Our Website uses cookies and similar technologies to provide certain functionality to our Website. You can turn off cookies by activating the setting in your browser that allows you to do this. You can also delete cookies through your browser settings. If you do decide to turn off cookies, you can continue to use the Website, however, certain services may not work as effectively.

Don’t want marketing?

We will always let you know before we collect any data from you what the intended use is and if we intend to use it for marketing and if third parties are involved we will obtain your consent (which you can withdraw at any time). You can change your mind about marketing material by opting out by (a) contacting us or by unsubscribing within the email if you have previously subscribed to our mailing list.

Do we disclose personal information outside Australia?

We may disclose personal information outside of Australia to third-party service providers, such as cloud-based storage providers and software providers. These providers are located in the United States of America, South Africa, Argentina, Philippines, Jamaica and Ireland.

We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

For more information, please contact the Privacy Officer using the contact information set out below.

Using our Website and cookies

We may collect personal information about you when you use and access our Website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our Website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your device.

We may also use 'cookies' or other similar tracking technologies on our Website that help us track your usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

How do we keep your information safe?

Security

We appreciate that our customers trust us to protect their data and whilst we cannot guarantee the security of any information you transmit to us, we take the task of protecting your information seriously we take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example we:

• train our staff about how to keep your information safe and secure;
• have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised access to our systems;
• place password protection and access control over our information technology systems and databases;
• have building security measures in place;
• take regular back-ups of our electronic systems;
• destroy and de-identify data when it is no longer required.

Minors

You must be over the age of 18 to use our products and services. We reserve the right to request proof of age so that we can verify that you are eligible to use our products and services.

Links

Our Website and mobile application may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

What are your rights?

You can exercise your rights at any time by contacting us via our Website, mobile application or using the contact details below.

You can access information we hold about you.

We will provide you with the information within 30 days of your request, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We will tell you if we can’t comply with your request and why.

Inaccurate information

You can contact us to ask us to correct any information we hold about you, that you believe is inaccurate.

Objections to using data for profiling or automated decisions

We may use your data to determine what products and services are relevant to you (e.g. tailoring our emails based on your behaviour). Otherwise, the only circumstances in which we will use this data is to provide our products and services to you.

You have the right to be forgotten

You have the right to request for your data to be erased. This means we have to delete all information that we hold about you, except to the extent of any information we are required to hold due to our legal obligations.

You have the right to make a complaint regarding the use of your data

If you have any complaints regarding how your data is handled, please contact us using the contact details set out below. We are committed to ensuring that your complaint is dealt with promptly.

To assist us in helping you, please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time, but no later than 10 days.

We will do our best to ensure we resolve your complaint within 30 days of receiving it. If we think that your complaint requires more time to investigate, then we will make sure to keep you informed and let you know the reason for any delay and provide you with a new timeframe. You will appreciate, that we may need to consult with a third party to investigate your complaint.

We like to think that we can resolve your complaint without needing to involve any third party, however, we understand that you may feel that we have failed to resolve the complaint satisfactorily, in such a situation, we will provide you with information about the further steps you can take by providing you with details of relevant regulator.

If you are not satisfied with how we have dealt with your complaint you can also contact the Office of the Australian Information Commissioner using any of the following details:

GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
www.oaic.gov.au

If you are an individual in the EU, you may lodge a complaint with your local data protection supervisory authority within the European Union if your complaint has not been adequately dealt with by us.

Accessing or correcting your information

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your information.

You can also request confirmation from us as to whether we are processing your personal information.

If you think that any information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Do we disclose information to credit reporting bodies?

We do not disclose any of your credit information to credit reporting bodies including for the purpose of requesting a credit check on you.

How long we hold onto your data

How long we hold onto your information will depend on the types of information we hold about you. Generally, your information will be retained for the period during which you have an ongoing relationship with us and for a period of at least 7 years after this relationship ceases, or such other period of time as required under any applicable laws.

Individuals located in EU

If you are an individual located in the EU, you have the following additional rights:

• Erasure of your personal information: You may request erasure of your personal information in certain circumstances. For example, if you believe your personal information is no longer necessary for the purpose which we collected it or if you have withdrawn your consent for us to process your personal information.
• Restriction or objection to processing personal information: You may request us to restrict or stop the processing of your personal data in certain circumstances. For example, if you believe the personal information, we hold is not accurate, if you believe that the data has been unlawfully processed or if we are using your personal information for direct marketing activities.
• Data portability: You may request us to provide you with a copy of your personal information in a format that you can easily move or provide to another service provider. Your right to data portability applies to some, but not all, of your personal information.

Requests should be made by in writing and addressed to the Privacy Officer, using the contact details below. We may refuse your request, for example if we still have a legitimate business interest in keeping and continuing to process that personal information, if processing of your personal information is necessary to comply with a legal obligation, or if the request is manifestly unfounded or excessive (as applicable). If we deny your request, we will provide our reasons in writing.

How to contact us

For further information about our Privacy Policy or practices, or to access or correct your information, or make a complaint, please contact us using the details set out below:

Privacy Officer
E: support@wayex.com
A: PO BOX 1182 Broadway NSW 2007