Limepay Group Privacy Policy

Limepay is committed to protecting and respecting any Personal Information in our custody or control. We are subject to and informed by the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This privacy policy (Privacy Policy):

• applies to all entities in the Limepay Group, being Limepay Pty Ltd ACN 169 399 393, Limepay Credit Pty Ltd ACN 631 002 714, Limepay Limited (Company number 8022376) and their affiliates and related companies (Limepay, us, we or our);

• and details (as at the date this Privacy Policy is posted), how we collect, manage, use and share Personal Information in our business.

In New Zealand, Limepay Limited (Company number 8022376) (Limepay NZ) is the entity within the Limepay Group collecting and holding Personal Information. Limepay NZ may share that information with other parties as set out in this Privacy Policy. Limepay NZ's address is c/- Maberly & Co, Diana Collie, Level 15, 51 Shortland Street, Auckland 1010, New Zealand.

Personal Information is information or opinion about an individual whose identity is apparent or can be reasonably ascertained from the information or opinion as further defined under applicable privacy laws, but does not include information that has been made anonymous, and cannot reasonably identify a specific person.

This Privacy Policy applies when we collect Personal Information during the course of our business. This can happen in a number of different ways and times in the operation of our business, including when we sign up Merchants to our services, the Merchant uses our services, features, technologies and functions (which are offered as a white labelled, native payment solution by the Merchant), and when the Merchant’s customer selects the pay now or pay later option with the Merchant to facilitate the purchase of goods or services offered by the Merchant (Platform).

What information do we collect? When you interact with us, whether it is by engaging our services, using the Platform or another way, we may collect the following types of information from you:

• contact information, such as your name, address (including your geolocation), phone number and email;

• detailed Personal Information such as your date of birth, drivers license number, passport number or other identification information or documents;

• financial information, such as the full bank account numbers and/or credit or debit card numbers;

• your computer IP address, your location, mobile network information, data on the pages you access, device identifies, the type of operating system you are using, standard Web Log Data (including the browser type you are using and traffic to/from the Platform);

• information about your transactions and activities.

How do we collect your information? We may collect your Personal Information:

• when you select the “pay now” or “pay later” option with Merchants, we may receive and store related information from and on you;

• through contact (whether that is via email, mail or telephone) with our customer support team, Merchants, suppliers or service providers and your responses to surveys or other interactions with you;

• through “cookies” and other web-based files stored on user devices to get certain types of information when your web browser, mobile phone, or other device accesses the Merchant Website;

• if you apply for employment with us either directly or through an employment or recruitment agency;

• if you enter a competition or promotion we run (including through marketing agents or third parties) or otherwise engage with us or sign up to receive communications from us, such as joining our blog distribution list; or

• from credit reporting bodies and identity verification services, third parties and related companies, and publicly or commercially available sources;

• name, position, contact details and training records of staff or board members of Merchants or other third parties, including service providers (either directly from you or from that party in the course of our business activities).

In your dealings with us, you may also choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g. LinkedIn, Instagram, Facebook and Twitter). Such information is controlled by that site and varies by site. Only where it is reasonably necessary to deliver our products and services and we have your consent, or where it is required by law, will we collect and handle sensitive personal information about you, such as your health information. We may collect information about your use and interaction with the Platform or other products and services we offer to help protect against fraud and misuse of your Personal Information. This may include evaluating your computer, mobile phone or other access device to identify any malicious activity or software. Cookies Like many websites, we utilise “cookies” to maintain a record of your use of our services. A cookie is a small text file that is transferred by a web server and stored on the hard drive of your computer or mobile device. It can only be read by the server that sent it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided us with personal information. Cookies help us to improve our Platform and services, and to deliver more personalised service; to store information about your preferences; to speed up your searches and to recognise you when you return to our Platform or use our services. Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of the site, our Platform or our services.

Limepay only collects, holds and handles information about you that is necessary for our business activities, including for the set up and use of a Platform or our other products or services. We may also collect, hold and handle information about you as required by law, court or tribunal order. You agree that we may use your Personal Information for the purposes for which we collect it and for related purposes which would be reasonable to expect. The Personal Information about you that we collect, may be used by us for a number of purposes including:

• providing or assessing whether to provide our services;

• processing transactions and sending communications about transactions;

• customer support;

• resolution of disputes, collection of fees and troubleshooting problems;

• enforcing our rights;

• investigating and preventing potentially prohibited or illegal activities;

• learning more about Merchant and end user experience of a Platform or us, including learning more about your level of satisfaction, your expectations of us, Merchants and other third parties, and how we can do better and exceed your expectations in the goods and services we offer and provide;

• customizations and improvements to the content, layout, operation and general usability of a Platform;

• delivering targeted marketing, service update notices, and promotional offers to you in line with any communication preferences you have nominated;

• contacting you including via telephone, text (SMS) or email messaging and in line with our agreement(s) with you or relevant customer terms;

• comparing information for accuracy and verification purposes including with third parties;

• confirming your identity for the purposes of anti-money laundering and counter-terrorism or other applicable legal requirements and assessment of your suitability for the services we offer and provide;

• considering you for a position with us for which you have applied;

• to acquire goods or services from you or from your employer;

• for the purpose of performing data analytics including to improve our and other third party services;

• for other consented purposes; and

• as required or permitted by relevant laws and regulations.

If we cannot collect or verify your Personal Information, we may not be able to provide you with our services, engage with you or do business with you such as contemplated in this Privacy Policy.

We will only share your Personal Information with third parties:

• as described in this Privacy Policy;

• as otherwise notified to you at the time of collection;

• with your consent; or

• as otherwise required by law or regulation.

We may share your Personal Information with the following parties for the following reasons:

Party we share with	Reasons for sharing your information
Limepay group	To provide our services or otherwise in the operation of our business. As part of a corporate requirement, such as to another company that we plan to merge with or be acquired by or who may invest in us.
Credit reporting bodies and collection agencies	For credit reports, we will provide information that identifies you.
Suppliers and service providers who help with our business operations (such as identity verification services)	To assist with business operational matters such as fraud prevention, identity verification, marketing, customer service, payment collection, and technology services.
Merchants	To help them understand their customer base. Merchants may use this information to assist them in providing personalized offers and targeted marketing to customers.
Financial institutions that we may partner with	As may be required by relevant rules or contractual requirements.
Law enforcement, government agencies or officials, or other third parties	Pursuant to a subpoena, court order, or other legal process or requirement. To comply with law or credit card rules. When we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of our Merchant Terms or relevant customer terms.
Reference checks (if you are applying for a position with us)	So that we may check your nominated references.
Other third parties	With your consent or direction to do so.

It is important to note that some third parties we share your Personal Information with may be in other countries where the laws are different and the processing of your Personal Information may be less stringent. These recipients may be in countries such as Australia, New Zealand, the UK or USA. We will take all reasonable care, when we disclose your Personal Information overseas to ensure that your Personal Information is held, managed and accessed in accordance with appropriate standards. In relevant circumstances, you should also be aware that:

• merchants and third party suppliers that you buy goods or services from or contract with have their own privacy policies; and

• Limepay is not responsible for the actions of other these parties, including their respective information protection practices.

You are encouraged to review the privacy policies of the relevant retailer or third party before providing them with Personal Information.

If we need to use or disclose your Personal Information for a purpose that is not related to the purpose for which it was collected, we may require your consent. In this case, if you do not consent to us collecting, using and or disclosing your Personal Information for such other purposes, our ability to do business with you or interact or provide our services to you as applicable may be affected. When you provide us with your Personal Information, you consent to us disclosing that information in accordance with this Privacy Policy. For example, as a customer of a Merchant using our Platform, when you elect your payment method and insert your personal details such as your name, date of birth and residential address, we may provide this information to credit reporting bodies and request an assessment of whether the information you have provided matches personal information held by the body. This assists in verifying your identity. The credit reporting body may provide us with that assessment and use your personal information, and the names, residential addresses and dates of birth of other individuals, to prepare that assessment. If we are unable to verify your identity as described above or otherwise dissatisfied, we may seek to request further information from you such as full bank account numbers and/or credit or debit card numbers or photographic documentation. We use various other service providers to assist and provide us with verification assessment. If you do not want us to use your information as set out in this Privacy Policy, including to verify your identity, you should contact us as provided below prior to providing your Personal Information.

We may send marketing materials to those who have provided us with Personal information from time to time. We may use your Personal Information to make inferences and inform future communications with you. You can opt-out any time to any communications you have signed up to receive from us, at any time by clicking the unsubscribe link at the bottom of the message. In this case, we will do our best to process your request as soon as practicable, however if not required earlier by law, it may take up to 5 days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests. We may still contact you after you’ve elected to opt-out of receiving communications from us, where we need to contact you for transactional or informational purposes. For example, including where we need to contact you for customer service issues or outstanding payment inquiries. If you would like to contact us, you can on:         Email: support@limepay.com.au         Phone (Aus): 1300 815 324         Mail: Level 3, 283 Clarence Street Sydney

Limepay takes reasonable steps to protect your Personal Information from misuse, loss, and unauthorised access, use, modification, and disclosure. We do this by using physical, technical, and administrative security measures intended to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Periodically, we review our security procedures and consider appropriate new technology and updated methods. Only people who are properly authorized and who have a need to access Personal Information to perform their job will be able to see or use that information. We may retain Personal Information for a period of time to collect any fees owed, troubleshoot problems, assist with any investigations, resolve disputes, prevent fraud or risk, enforce our rights, or take other actions as required or permitted by law.

We work hard to ensure that the information we collect and use about you is correct. Subject to privacy law exceptions, we will let you see the information we hold about you and let you correct it if it is inaccurate, incomplete or out-of-date. If we are unable to grant you access to your Personal Information, or do not agree to your request to correct your Personal Information, we will inform you of our reasons for this. Requests to obtain or correct your Personal Information should be made to:         Email: support@limepay.com.au         Phone (Aus): 1300 815 324         Postal address: Level 3, 283 Clarence Street Sydney If we can approve your request to access your Personal Information, we will provide you with access as soon as reasonably possible following receipt of your request. Agreeable changes to your Personal Information will be made as soon as practicable. There is no charge for requesting access to your Personal Information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material). If we cannot approve your request, we will let you know (including why) and will keep a record of this. If you are not happy with our decisions to refuse you access to your Personal Information or to correct it, you may complain to the applicable regulator in the country you are located.

If you have a complaint in relation to our dealings with your Personal Information, please provide a written complaint to support@limepay.com.au. Upon receiving your complaint we will:

• Within 7 days, provide you with confirmation of receipt of your complaint; and

• Within 30 days, investigate your complaint and let you know our plan of action to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is. If your complaint is not resolved, you may refer your complaint to the Office of the Australian Information Commissioner who can be contacted by phone at 1300 363 992, by email at enquirie@oaic.gov.au, or by post at GPO Box, Sydney NSW 2001.

We may amend this Privacy Policy from time to time at our discretion. Updated versions will be effective from the time of posting and will be available by following the ‘Privacy’ link on the Websites. If any material changes are made to this Privacy Policy that may impact you, we may notify you by email or other means as we consider appropriate. If you have objections to the Privacy Policy, you should not access or use our site, or services.