Privacy Policy

eNett International (Jersey) Limited, eNett international (Netherlands) BV and each of their affiliates (jointly “ENI”) respects the privacy of its licensees, clients, users and their customers in respect of their use of ENI’s centralised accounts payable/receivable management system (“eNett”). This Privacy Policy outlines the specific information that is collected by ENI and how that information is used.

Incorporation into Service Agreement

This Privacy Policy forms part of and is incorporated into the eNett Client Licence Agreement (“ECLA”) or the General Terms and Conditions between eNett and its licensees or customers that sign up to either the ECLA or eNett’s General Terms and Conditions (each considered hereafter a “Customer”). Terms used in this Policy have the same definition and meaning as in the ECLA or General Terms and Conditions and vice versa. As such, ENI and its Customers agree to be legally bound by and honour this Privacy Policy.

What ENI Collects

ENI collects the following details about Customers: business name, legal entity registration details, contact details (address, telephone, facsimile and email), web address(es), banking details (account name(s), bank(s), BSB(s) and account number(s)), industry classification and/or membership details and regulatory details (if any). Additionally, ENI collects the following personal information about nominated representatives of Customers: title, name, position, contact details (telephone and email). ENI collects the following transactional information about the Customer’s business: customer details, invoice/booking reference/transaction details, supplier/customer details, commission rates, revenue splits, payment amounts and currencies. This information is contact, billing and service oriented and critical in enabling ENI to deal effectively with Customers and their representatives and to process transactions pursuant to the ECLA or the General Terms and Conditions. From time to time, ENI also collects and securely transmits credit/charge card details including cardholder name, account number, card type and expiry date. Collectively, all of the above is “Customer Information”.

From whom and how we receive information

ENI only receives and collects Customer Information directly from Customers, or prospective Customers. Information is received and collected as part of and in the context of ENI’s service offering.

ENI receives Customer Information directly from Customers by way of the:

• Registration Form, Direct Debit Requests and Account maintenance process, and
• Transmitting transactional information to eNett whilst using the eNett solutions.

ENI treats all such Customer Information with th utmost confidentiality.

Why ENI collects information

ENI collects Customer Information solely in the context of fulfilling is service obligations to its Customers. In this context, Customer Information is predominantly collected so as to:

• Create and maintain Customer Accounts;
• Commuicate with Customers;
• Provide Customer with ENI solutions; and
• Bill and receive payment from Customers.

Additionally, ENI collects and uses Customer Information so as to:

• Develop new products and services;
• Undertake planning, research and statistical analysis;
• Assist with Customer queries;
• Prevent fraud and crime in relation to Customers' Accounts; and
• Fulfil our legal requirements (for example, disclosure to law enforcement agencies or the courts).

ENI does not collect or use Customer Information for the purpose of resale, rent or transfer to anyone, including, “junk mail / spam” operators, direct marketing companies, telemarketers, etc. Credit card details, are collected and securely transmitted by ENI, and it’s banking partners, to process payments via the services offered by ENI to its Customers.

Sharing Client Information

For the purposes outlined in this policy, ENI shares Customer Information with its business partners and affiliates, including but not limited toits financial services partners WORLDWIDE.

Storage & Handling

ENI procures the storage of Customer Information predominantly on secure computer servers and filing systems. ENI takes reasonable steps and uses up-to-date techniques and processes to protect Customer Information from misuse, loss and unauthorised access, modification and disclosure. Only ENI employees and those who perform services on ENI’s behalf or in conjunction with ENI are authorised to handle or have access to Customer Information. All ENI employees are bound both by internal policies and procedures and confidentiality clauses in their employment agreements. Those who perform services on ENI’s behalf are also bound by privacy and confidentiality agreements. Paper documents containing Customer Information are protected from unauthorised access or use through the various security systems that we have within our physical premises. ENI also maintains up-to-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of Customer Information. To ensure the security of your Customer Information, we ask that you observe the security requirements that relate to the use of your Customer Information and Account, including user IDs and passwords.

Access & Correction

It is the Customer’s responsibility to ensure that Customer Information is accurate and current. Customers can access, change, correct or delete the following information online via their Account by:

• Themselves;
• Their Representatives;
• Their Passengers; and Opt-in marketing preferences

Ancillary Information

In the course of providing the ENI services to Customers, ENI compiles demographic, profile and usage data relating to the services.

ENI compiles such data for the following reasons:

• To better manage, administer and deliver the service; and
• To enhance the user experience by displaying more relevant information and options to the Customer.

Additionally, ENI compiles and aggregates anonymous demographic and usage information, available for public dissemination, for the purpose of promoting eNett and the services.

Information Use by Third Parties

ENI will not provide Customer Information to third parties without the Customer’s express permission or only in instances where such disclosure is necessary to process transactions or provide services to the Customer.

Despite the above, ENI will only divulge Customer Information if ENI:

• is compelled to do so by an appropriately empowered governmental authority; or
• makes the eNett technology or services available to Customers through or with the assistance of its business partners.

In either case, ENI will not share with them any more information than is necessary.

If services (in part or whole) are provided via an eNett partner, ENI may provide Customer Information to the partner.

Such partners have agreed to use the information only in regard to analysing the success of the partnership arrangement or to facilitate the provision (in part or full) of the eNett services. ENI only does business with partners who agree to respect our Privacy Policy.

Opt-in Marketing

Customers can elect to receive, or not receive, certain information from ENI or its partners. If so elected, such information will be sent to the email address of nominated Customer representatives. In this regard, ENI strictly adheres to this permission-based email marketing policy.

Except as mentioned above, ENI will not send Customers, nor their representatives, unsolicited emails, commercial offers or advertisements. ENI will not sell, rent, or loan Customer Information to any outside firms nor will ENI use Customer Information for its, or its partners, own marketing purposes, other than as requested

All emails sent to Customers at their request, will have an option to unsubscribe. Unsubscribe requests will be fulfilled within minutes and ENI will do everything reasonably possible to ensure that no further communications will be sent to Customers who have stated that they do not wish to receive the specified information.

All ENI partners who offer Customers information via email must adhere to this privacy policy and unsubscribe policy.

Information Exchanges and Transactions

Industry standard Secure Socket Layer (SSL) technology has been implemented throughout eNett application systems.

Information exchanges and transactions, including authentication, passwords, reporting and billing related data between Customers and eNett application systems are strictly protected using this SSL technology.

This ensures that a Customer's session is completely private and secure from both external systems and other Customers using eNett.

Credit Card Information

When credit/charge card payment is chosen, information is transferred to ENI’s payment processing partners using industry-leading, secure transmission technology, including SSL – the transmission standard used for transactions by major financial institutions.

Cookies

ENI uses cookies for the purposes of system efficiency and minimisation of transaction processing time. ENI does not use cookies to capture personal information about Customers.

Effective Date of Policy

This policy is current as at July 2010. From time to time, and for any reason, ENI may make changes to this policy, processes and systems relating to how we handle information. ENI will update this policy to reflect changes.

Conclusion

Maintaining the privacy of Customer Information is of paramount importance to ENI as it helps foster confidence, goodwill and stronger relationships.

Clients are encouraged to address questions or concerns about this privacy policy to privacy@enett.com