Information we collect
We collect information and data:
(1) about your usage of this website and your interest in the eNett Products, through web tracking software (“Website User Information”); and/or when you report a problem with our site. This may include the full Uniform Resource Locators (URL) clickstream to, through and from our site; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page.
(2) comprising technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(3) that users provide when submitting a request for information when registering for eNett’s products (“Prospective Customer Information”) on our website or otherwise, including but not limited to:
Once you or your employer (or business which you represent or of which you are a beneficial owner) become a customer, such information (as amended, altered and/or updated from time to time) will be stored and processed in accordance with this policy as “Customer Data”;
(4) obtained from working closely with third parties (including, for example, business partners, suppliers and subcontractors in technical, payment and fulfillment services, advertising networks, analytics providers, search information providers, credit reference agencies and fraud prevention agencies or other similar organisations - who may check the information against any particulars on the Electoral Register and any other databases) who may provide us with information about you.
Prospective Customer Information and Customer Data may contain data which relates to a living individual who can be identified from that data (“Personal Data”). Together, Website User Information, Prospective Customer Information, Customer Data, and Personal Data are referred to in this policy as “Customer Information”.
Why we collect information
We process Customer Information (including Personal Data) for the lawful purposes set out below. These are either necessary:
In all other cases, we will only process your Personal Data with your specific consent given separately.
Customer Information is collected and processed to:
We may share and exchange Customer Information:
Please note that our group companies and the third parties referred to above may be located outside of the European Union in countries which have not been designated as ensuring an adequate level of protection for personal data. Where that is the case, see Storage and handling of information below.
In addition, we may share Customer Information, including Personal Data: (a) to the extent that ENI is required or requested to do so by law, by a court order, by another competent authority; (b) in connection with any ongoing or prospective legal proceedings; (c) in order to establish, exercise, defend or protect ENI’s legal or other rights; or those of our customers’ or others (d) in the event that we sell or buy any business or assets, in which case we may disclose your Customer Information to the (prospective) seller or purchaser of any such business or assets; and (e) if eNett is (fully or partially) acquired by a third party, in which case Customer Information held by it about its customers will be one of the transferred assets.
For the purposes of (a) to (c) this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Anonymised Transactional Data
eNett analyses, uses, discloses and processes statistical, aggregated and/or anonymised transactional data that eNett obtains or generates through your use of the eNett Payments Platform you access with your login details or eNett’s application programming interface (API). Typically, this includes information about your business, booking reference(s) transaction details, supplier/customer details, commission rates, payment amounts and currencies. Such data has been aggregated with other data or anonymised, such that the data cannot identify you and is not considered Customer Information and is not Personal Data.
Storage and handling of information
Customer Information that we collect, including Personal Data, may be stored in, processed in and transferred to and between any of the countries in which we and our group of companies operate (including, without limitation, the USA, Singapore and Australia) or have Issuing Organisations, suppliers, agents or subcontractors, in order to enable us to provide you with the eNett Products.
If you are located within the EU, please note that this means that we may transfer your Personal Data outside of the EU. It may also be processed by staff operating outside the EU who work for us, one of our affiliates or for one of our Issuing Organisations, suppliers, agents or subcontractors. Except where necessary to perform a contract with you or implement pre-contractual measures at your request or to perform or conclude a contract with a third party (including the business you represent) in your interest within Article 49.1 of the EU General Data Protection Regulation, whenever we transfer your Personal Data out of the EU, we either ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Where no such safeguard is implemented, we will obtain your specific consent to the transfer.
Your rights relating to Personal Data
You have the following rights in relation to Personal Data about you which we process:
Where your provision of Personal Data is required, such requirement is a contractual requirement and if not provided we may not be able to complete your application or that of the relevant business.
Data security and integrity
eNett implements and maintains technical and organisational security measures at a level appropriate to the risks to protect Customer Information from accidental or unlawful destruction, loss, alteration, misuse and unauthorised access, modification and disclosure. These measures include maintaining up-to-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of Customer Information.
We will store or otherwise process Customer Information, including Personal Data, no longer than is necessary to comply with our contractual and legal obligations and to fulfil our legitimate business and compliance purposes. This means that we may retain Customer Information for a reasonable period after you stop using eNett Products or stop using this website. After this period, we will take reasonable steps to destroy or permanently anonymise the Customer Information which consists of Personal Data.
Your provision of Personal Data of others
If, where required as described above, you have elected to receive marketing emails from eNett or its partners, all such emails sent to you will have an option to unsubscribe. Unsubscribe requests will be fulfilled immediately and ENI will do everything reasonably possible to ensure that no further such communications will be sent to you. However, we may still send you emails and other communications for other (non-marketing) purposes.
Information Exchanges and Transactions
Industry standard Secure Socket Layer (SSL) technology has been implemented throughout our 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 your session is completely private and secure from both external systems and other customers using eNett Products.
An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. ENI may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to this website and/or to certain users, and, (iv) better understand how this website and/or eNett Products are used.
Third Party Websites
Our website may contain links to other websites. ENI is not responsible for the privacy policies or practices of third parties’ websites. Personal Data access, correction and other requests – ENI Contact/Data Protection Officer.
If you wish to:
you may contact email@example.com or our Data Protection Officer at the address specified below:
Level 23, Optus Centre
367 Collins Street
Melbourne 3000 VIC
Attention: Data Protection Officer/Legal Department.
Once we receive your inquiry, our Data Protection Officer will investigate the matter and respond to you promptly. We will endeavour to do this within 30 days, or if not possible, we will endeavour to contact you with a revised timeframe.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We treat any complaint seriously. Once a complaint has been lodged, our Data Protection Officer will respond to you as soon as possible. If you are unhappy with our handling of your complaint, you may be able to make a complaint to an external dispute resolution provider or local data protection authority, depending on your jurisdiction.
Publication and effective date
This policy is published by eNett International (Singapore) Pte. Ltd. on behalf of the eNett group of companies. eNett International (Singapore) Pte. Ltd. is a Singaporean entity with its registered address located at 8 Marina Boulevard #05-02, Marina Bay Financial Centre, Singapore 018981.