WHAT PERSONAL INFORMATION DO WE COLLECT?
The type of personal information WAIV collects depends on the nature of your dealings with us. WAIV operates a platform that is used by member banks and merchants for the local and international remittance and transfer of funds. The platform can be accessed online or via the WAIV app. Access is limited to WAIV members.
To become a WAIV member and to allow us to undertake a Know Your Customer check (KYC), we need your:
date of birth;
name of employer;
photo ID; and
any other details as required by AML-CTF legislation.
To be able to use the WAIV platform to remit and transfer funds and make purchases, a WAIV account must be associated with an account with a member bank. The bank will provide us with customer account details. We will also store information about how you use your account.
If you are employed by one of our partner banks or merchants, we may collect your name, contact details and position in the organisation and other personal information that is relevant to managing our dealings with you.
If you are one of our suppliers or contractors, or one of their employees, we may collect your name, contact details and position in the organisation and other personal information that is relevant to managing our dealings with you.
If you apply for a job with us, you may provide us with certain information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.
We may also collect your personal information you provide as a result of completing a customer survey, or if you send us an enquiry.
HOW DO WE COLLECT PERSONAL INFORMATION?
How we collect personal information depends on the nature of your dealings with us.
We collect personal information directly from you whenever it is reasonable and practical to do so. We may also collect personal information from third parties depending on the circumstances.
Because of obligations under KYC and AML-CTF legislation, WAIV is unable to interact with customers (or potential customers) on an anonymous or pseudonymous basis.
We collect personal information:
from you directly, when you provide information over the phone, online or on documentation, complete a customer survey or apply for a job with us;
from you when you use your account;
from other customers who request us to provide goods or services to you, when they provide information over the phone, online or on documentation;
from banks and merchants we partner with; and
from your employer, if you are employed by one of our partner banks or merchants or one of our suppliers or contractors and they provide us with your personal information.
COLLECTING PERSONAL INFORMATION FROM OUR WEB SITE
WAIV collects some information from you when you use our web site. Your use of the facilities and services available through our web site will determine the amount and type of information which we collect about you. Some of this information will not be personal information because it will not reveal your identity.
The only personal information which WAIV collects about you when you use our web site is what you tell us about yourself, for example by completing an online form or information you provide to us when you send us an email. We will record your email address if you send us an email.
While we take great care to protect your personal information on our website, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we make our best effort to ensure its security in our possession.
Our website may contain links/plug-ins to other sites. We are not responsible for the content of, or the privacy practices or policies of, those sites.
Most web browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings on your web browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not.
We do not currently track WAIV customers and/or track WAIV customers across third party websites for targeted advertising purposes. WAIV does not respond to ‘do not track’ signals. In future, WAIV may work with third party sites to browse your activities when you receive WAIV content to enable us to tailor what we present to you.
HOW DO WE USE PERSONAL INFORMATION?
WAIV only collects personal information in connection with carrying out its business activities. We will only use your personal information for the purpose(s) you have provided the personal information, or for a purpose to which you have consented.
Generally, how WAIV uses personal information will be apparent from the way in which we collect it, or will be disclosed at the time of collection.
Personal information may be used to:
become a WAIV member and access the WAIV platform;
keep a record of how you use your account;
provide you with goods and services, or information regarding our goods and services;
administer our relationship with you efficiently; and
audit, inspect and / or investigate a WAIV customer or potential WAIV customer in line with the relevant laws of the territory/country.
WAIV may use your personal information for research and development of our goods or services or to send you information about other goods or services offered by us which may be of interest to you.
If you would prefer not to receive promotional or other material from us, simply select the “unsubscribe” option in any of the emails that you receive from us.
If you are employed by one of our partner banks or merchants, we use your personal information to manage our dealings with you.
If you are one of our suppliers or contractors, or one of their employees, we use your personal information to manage our dealings with you.
If you apply for a job with us, we will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is reasonably necessary. In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.
Except as required by law or a court/tribunal order to retain personal information or for WAIV records, the personal information retained by WAIV will be held only for the purpose(s) you have provided the personal information, or for a purpose to which you have consented. WAIV will take reasonable steps to destroy or de-identify the personal information it holds once the personal information is no longer needed for purpose(s) identified.
WHAT PERSONAL INFORMATION DO WE DISCLOSE?
In general, WAIV will not sell, rent or lease your personal information to others. However, in certain circumstances, WAIV may disclose your personal information to organisations offering goods and services which may be of interest to you for direct marketing purposes.
WAIV may disclose your information:
where WAIV is required by law to disclose information to third parties; or
to related companies that may be located in other countries. At present WAIV related companies are located in the USA, Mexico and Brazil; or
in certain circumstances to organisations offering goods and services which WAIV considers may be of interest to you for direct marketing purposes; or
member banks and merchants to provide account holders with information of their offerings.
DO WE DISCLOSE PERSONAL INFORMATION?
When an account is set up with WAIV it must be associated with an account with a member bank. To be able to access the WAIV platform, we will have to disclose your personal information with that bank, WAIV will disclose personal information via a secure ftp.
HOW DO WE KEEP PERSONAL INFORMATION SECURE?
WAIV is committed to ensuring the security of your personal information. We use encryption technology, privacy protection controls, comply with the PCI SSC data security standards and have restrictions on employee access in order to safeguard your personal information.
We require any third parties (including related bodies corporate of WAIV and partner organisations) with access to your personal information to have proper and adequate safeguards to maintain the confidentiality and security of your personal information.
Your personal information will be encrypted and stored in a PCI Compliant Data Centre in the USA. At present, the cloud where your personal information is stored is located in the USA. Provided WAIV is satisfied that your personal information will be secure, WAIV may move your personal information to a PCI Compliant Data Centre outside the USA.
HOW YOU CAN ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You can request access to your personal information by Contacting WAIV through one of the contact offices listed below. Before we are able to provide you with access to your personal information, we will require some proof of identity. For most requests, your information will be provided free of charge, however we may charge a reasonable fee if your request requires a substantial effort by us.
If any of the personal information you have provided to us changes (for example, if you move or change your phone number), please let us know so that we can update your personal information.
If you find any inaccuracies in your personal information, please contact us and let us know.
As an extra measure all customers have the option of having the information in relation to their account protected by a pin when accessing their account by the WAIV App or username and password when accessing their account by a PC.
HOW DO WE DEAL WITH PRIVACY COMPLAINTS?
Your privacy is important to WAIV and we will make every effort to resolve your concerns. To assist us in helping you, we ask you to follow a simple three-step process:
gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do;
email the address provided below, your email will be reviewed and if possible, resolved straight away; and
if you are not satisfied with our response, we may require you to submit a formal complaint by email at the email address provided below with your contact details. We will then investigate your complaint and endeavour to respond to you in writing within 7 days of receipt of your written complaint.
After this three-step process if the matter has not been resolved to your satisfaction, you may be able to pursue your complaint with the local privacy regulator. In Australia you can telephone the Australian Information Commissioner’s hotline on 1300 363 992 or, if calling from outside Australia, +61 2 9284 9749.
The personal information controller of WAIV is the Chief Compliance Officer:
Level 32, 2 Park St, Sydney, Australia, 2000
Date last revised: 10 March 2017
COUNTRY SPECIFIC PROVISIONS
For more information about your privacy rights please contact the Australian Government Office of the Australian Information Commissioner (OAIC) via their website here: https://www.oaic.gov.au/.
If you would like to withdraw your consent to disclosing your personal information, please contact firstname.lastname@example.org.
Where a data breach has occurred or WAIV has a reasonable belief that a data breach has occurred, the Personal Information Controller will contact you if you are affected by this data breach or potential data breach.
For more information about your privacy rights please contact National Privacy Commission at Telecommunications Office Building, A. Roces. Ave. cor. Sct. Reyes St., Quezon City, Metro Manila 1103 or by email email@example.com.
United States of America (USA)
The United States does not have a central privacy regulator. For more information about your privacy rights please contact Federal Trade Commission at https://www.ftc.gov. You may also contact your state attorney general or privacy officer.
California residents may request WAIV to provide a notice describing the categories of personal information WAIV shares with third parties or companies related to WAIV for their direct marketing purposes (Your California Privacy RightsNotice). The Notice will include the names and addresses of those third parties or companies.
In your request to WAIV, please specify that you would like “Your California Privacy Rights Notice” and allow for at least 30 days to receive a response.