privacy policy

• This is your guide to how personal data is managed by Pearls eXchange. Please read it carefully. Data privacy is taken very seriously at Pearls eXchange. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfil our obligations under the Australian Privacy Act (1988). We comply with the Privacy Act 1988 (Cth) (Australia) and the Australian Privacy Principles (together “Data Protection Rules”). The aim of this policy is to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. We want you to be clear on:

Who we are

The information we collect about you

When and how we collect information about you

How we use your information

How we use automated processing or “analytics”

Who we share your information with

How long we hold your information

Implications of not providing information

The legal basis for using your information

How to exercise your information rights (including the right to object)

How to contact us

Changes to this notice

You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is not a legitimate business interest or the performance of a task is not in the public interest. If you have any questions about how your information is gathered, stored, shared or used, please contact us.

Who we are

Throughout this document, “we”, “us”, “our” and “ours” refers to Pearls eXchange. www.Pearls eXchange.com, (the “Website”) is owned and operated by Pearls eXchange PTY Ltd (“Pearls eXchange”).

The information we collect about you

There are a number of reasons for gathering information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to understand your financial circumstances combined with economic rationale for conducting transactions. We need this information so that we can offer you products and services and give you the best possible customer experience. The information we collect falls into various categories.

Identity & contact information

Name, date of birth, copies of ID, contact details, PPS number (or foreign equivalent), online user identities (such as your log on identity, internet protocol, addresses, cookie identifiers and radio frequency tags used in contactless cards), security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status, family details, tax residency and tax related information.

Financial details/circumstances

Bank account details, credit/debit card details, income details, personal guarantees provided, application processing and administration records, your employment status.

Information you provide us about others or others provide us about you

If you give us information about someone else (for example, information about a spouse, family member, beneficiary, or financial associate provided during the course of a an application or to explain the economic rationale for a specific transaction with that person, beneficiary), or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Data Privacy Notice.

Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this Data Privacy Notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Data Privacy Notice.

Information from online activities.

We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy, which is available on our website.

We collect information about your internet browser settings or otherwise Internet Protocol (IP) and other relevant information to help us identify your geographic location when providing you with our services.

Other personal information.

Telephone and image recordings.

Sometimes we may collect and use your information even though you are not a customer of ours. For example, you may be a beneficiary, guarantor, director, cardholder or representative of one of our customers, or you may be in the process of making an application for a Pearls eXchange product or service. In other cases, your own circumstances may have a material impact on the ability of our customer to perform their obligations to us, and we will need to consider these. If so, we will apply the principles outlined in this Data Privacy Notice when dealing with your information.

When and how we collect information about you

As you use our services, apply for products, make enquiries execute transactions and engage with us, information is gathered about you. We may also collect information about you from other people and other parties, for example, when you are named in an application, from identification verification companies, credit rating agencies and from sources where you have chosen to make your information publicly available, such as electoral registers, social media sites.

When we collect information about you:

When you use our website and online services provided by us (including mobile applications) and visit our offices.

When you or others give us information verbally or in writing. This information may be on application forms, online application forms, in records of your transactions with us or if you make a complaint.

When you use our products or services, including making transactions on your account, we gather details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.

Cookies

“Cookies” are small pieces of information that are stored by your browser on your device. Like most websites, we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish to disable these cookies, the “help” section of the toolbar on most browsers will tell you how. However, if you set your browser to disable cookies, you may not be able to access certain areas or features of our Website.

How we use your information

Whether we’re using it to confirm your identity, to help in the processing of an application for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Notice are always applied.

We use your information:

To provide our products and services to you, and to fulfil our contract with you.

To provide our products and services to you and perform our contract with you.

Process your applications for products and/or services.

Establish your eligibility for our products and services.

Establish your identity.

Manage and administer your accounts, policies, transactions, benefits or other products and services that we or our partners may provide you with.

Conduct our regulatory requirement of ongoing due diligence.

Carry out account reviews, including some semi-automated decision processes (which may have a legal or similarly significant effect on you), and to search for details of your identity at identification verification companies, credit bureaus/agencies. Where we make these searches, all these companies/agencies may keep a record of the search.

Process payments that are paid to you or by you. For example, if you are making international payments, we may need to share information with our banking partners in order for the payment to be completed.

Contact you by post, phone, text message, email, social media, fax, using our online website or other means, but not in a way contrary to your instructions to us or contrary to law.

Monitor and record our conversations when we speak on the telephone (for example, to check your instructions to us, to analyse, to assess and improve customer service and for training and quality purposes).

Manage and respond to a complaint or appeal.

To run our business on a day to day basis including to:

Carry out strategic planning and business portfolio management.

Compile and process your information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand trends in our customer behaviour and to understand our risks better, including for providing management information, operational and data risk management.

Protect our business, reputation, resources and equipment, manage network and information security (for example, developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity), including using CCTV at our premises.

Manage and administer our Group’s legal and compliance affairs, including complying with our obligations to banking partners, credit card providers, compliance with regulatory guidance and voluntary codes of practice to which we have committed.

Enable us to share or access your information for internal administrative purposes, audit, prudential, statistical or research purposes (including making your data anonymous) to help us understand trends in customer behaviour, for helping us to understand our risks better and for the purposes set out in this Data Privacy Notice (but not for the purposes of direct marketing where you have objected to this).

Facilitate a potential or actual transfer of any product or service provided to you to another company.

To manage our legitimate interests

To manage our business we may use your information to:

Engage agencies to trace you (for example, where the address you have provided is no longer accurate and the Bank needs to provide you with legal documentation)

Provide service information, to improve our service quality and for training purposes

We may gather information about your interactions with us – for example, where you consent, when you download one of our apps, we may gather location information from your mobile phone or other electronic device you may use to interact with us.

To comply with our legal and regulatory obligations, we need to use your information to comply with legal and regulatory obligations including:

Complying with your information rights.

Providing you with statutory and regulatory information and statements.

Establishing your identity, residence and tax status in order to comply with law and regulation concerning taxation and the prevention of money laundering, fraud and terrorist financing.

We are required by law to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result, we may need to disclose information to government and other statutory bodies.

Preparing returns to regulators and relevant authorities including preparing income tax, capital gains tax, capital acquisition tax and other revenue returns.

Reporting to and, where relevant, conducting searches on the Central Credit Register and other industry registers.

Complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies/prosecutors.

For other reasons where a statutory reason exists we do so, including use of your Personal Public Service (PPS) number (or foreign equivalent).

Complying with court orders arising in civil or criminal proceedings.

Performing a task carried out in the public interest.

Conduct marketing activities

Where you have given us permission (which you can withdraw at any time) we may:

Send electronic messages to you about product and service offers from our Group and/or our selected and trusted partners.

Share your data with third parties so that they may send you electronic messaging about their products and offers.

Use transaction history/account information from your Pearls eXchange account or Multi Currency card to identify your transactional patterns and habits in order to personalise offers that are exclusive and individual to you, based on your account transactions.

Use cookies in accordance with our Cookie Policy.

Use special categories of data, or sensitive data.

Use your location data to send you information regarding special offers from us or our partners close to your location.

Use information you have made public and combine with this with the activities outlined above.

When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with.

For example, running competitions, promotions and direct marketing (provided that you have not objected to us using your details in this way), and research, including customer surveys, analytics and related activities.

How we use automated processing or “analytics” & our legal basis

We use automated statistical analysis of the information we collect about you as part of our business:

Analysis of your information helps us to make automated decisions.

When you apply for a financial product or service, we may evaluate the application using statistical analysis to determine whether or not the product best meets your needs.

We may decide whether or not to give you a financial product or service.

We may calculate the specific charges that we need to charge on a specific product or transaction to reflect the risk involved.

To manage existing credit agreements you have with us, such as your Current Account overdraft. For example, when you or any authorised user seeks to perform a transaction, information may be sent to us to evaluate and determine whether to approve, decline or refer a transaction for further review. Where we make solely automated decisions that affect you in a legal or a significant way, you have the right to provide your point of view and have those decisions reviewed by a member of our team.

Automated analysis of our customer information (including your information) as a whole helps us to manage our business for our legitimate interests.

It enables us to:

Make more informed business decisions, including improving the quality of products and services we can offer (including for the purposes of direct marketing, unless you have objected to us using your details in this way).

Test and maintain the stability and performance of our systems.

Carry out long-term statistical modelling, provided that such modelling does not affect any decision we make about you.

Automated analysis of your information also enables us for service, administrative purposes and helps us to form a single view of your relationship with Pearls eXchange.

This is intended to help us to manage and build our relationship with you and is an important part of managing our business in our legitimate interests.

For example, it enables us to develop personalised information for you in real-time based on your financial and personal circumstances (for example, providing you with information when you log into your account on how to minimise exchange fees, bank charges, or to warn you that your account is running low so you can put it in funds in order to meet a future need).

Automated analysis of your information assists us to comply with our legal obligations.

For example, in connection with our money laundering, fraud and terrorist financing prevention obligations, we may use automated processing to screen for suspicious transactions, or to identify payments which may be subject to international sanctions.

There are certain automated analyses of your information that we will only carry out where you have given us your consent (which you can withdraw at any time).

We will only automatically process your information to enable us to undertake the following activities where we have your consent and each time we interact with you we will always provide you the opportunity to cease to receive further such messages.

Send electronic messages to you about new product and service offers enhancements from Pearls eXchange and/or our selected trusted partners.

Share your data with third parties so that they may send you electronic messaging about their products and offers.

Use your transaction history/account information from your Pearls eXchange account and Multicurrency card Bank of Ireland current to identify your transactional patterns and habits, in order to personalise offers that are exclusive and individual to you, based on your account transactions. We will provide you with more information on this when we seek your consent.

Use your location data to send you information regarding special offers from us or our partners close to your location.

Use sensitive categories of data, as set out in data protection legislation.

Use information you have made public and combine this with the activities outlined above.

Who we share your information with

We only share your information with a select number of individuals and companies, and only as necessary. Sharing can occur in the following circumstances and/or with the following persons:

Your authorised representative, accountant and/or your primary bank.

Your, attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data.

Third parties we need to share your information with in order to facilitate payments you have requested (for example, Banking Partners, SWIFT, credit card issuers and other banks) and those you ask us to share your information with.

How long we hold your information

The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product we have provided to you.

Those factors include:

The regulatory rules contained in laws and regulations or set by authorities like the Australian Prudential Regulatory Authority (APRA)

Whether you and us are in a legal or some other type of dispute with another person or each other.

The type of data we hold about you.

Whether you or a regulatory authority asks us to keep it for a valid reason.

Whether we use your data for long-term statistical modelling, provided that such modelling does not affect any decision we make about you.

Implications of not providing information

Sharing information with us is in both your interest and ours. We need your information in order to:

Provide our products and services to you and fulfil our contract with you.

Manage our business for our legitimate interests.

Comply with our legal obligations.

Of course, you can choose not to share information, but doing so may limit the services we are able to provide to you.

We may not be able to provide you with certain products and services that you request. We may not be able to continue to provide you with or renew existing products and services.

We may not be able to assess your suitability for a product or service, or, where relevant, give you a recommendation to provide you with a Pearls eXchange financial product or service.

When we request information, we will tell you if providing it is a contractual requirement or not, and whether or not we need it to comply with our legal obligations.

The legal basis for using your information

We will use your data and share that data where:

Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so you can enter into a contract with us.

Its use is in accordance with our legitimate interests outlined in this notice.

Its use is necessary because of a legal obligation that applies to us (except an obligation imposed by a contract). An example of this would be us sharing your information with the Central Credit Register.

You have consented or explicitly consented to the using of your data (including special categories of data) in a specific way.

Its use is necessary to protect your “vital interests”.

In exceptional circumstances we may use and/or disclose information (including special categories of data) we hold about you to identify, locate or protect you

Where you have made clearly sensitive categories of data about yourself public.

Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims.

Where authorised by law or regulation, we may undertake processing of special categories of data for a substantial public interest.

Processing your information outside Australia

Your information is stored on secure systems within Pearls eXchange premises and with providers of secure information storage.

We may transfer or allow the transfer of information about you and your products and services with us to our service providers and other organisations outside Australia. For example, we may process payments using third parties (including other financial institutions such as banks and the worldwide payments system operated by the SWIFT organisation) if, for example, you make a CHAPS payment or a foreign payment. Those external organisations may process and store your personal information abroad and may disclose it to foreign authorities to help them in their fight against crime and terrorism.

How to exercise your information rights (including the right to object)

Providing and holding personal information comes with significant rights on your part and significant obligations on ours. You have several rights in relation to how we use your information. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.

You have the right to:

Find out if we use your information, to access your information and to receive copies of the information we have about you.

Request that inaccurate information is corrected and incomplete information updated.

Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide.

Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes

Have your data deleted or its use restricted – you have a right to this under certain circumstances.For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for particular legitimate business interests.

Obtain a transferable copy of certain data to which can be transferred to another provider, known as “the right to data portability”.

This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.

Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why.

How to contact us:

If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at:

E-mail: compliance@Pearls eXchange.com

Changes to this notice

Any updates to this Data Privacy Policy will be made available to you at any time via the website and/or copies can be requested by email.H