Information we collect
We collect information and data:
(1) about your usage of the ePP and your interest in the eNett Products, through web tracking software (“ePP User Information”); and/or when you report a problem with the ePP. 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”) or otherwise, including but not limited to:
- Business information (name, registration details, address),
- Contact details of the business’ representatives or beneficial owners’ details (such as name and email and postal address, mobile numbers, date of birth and formal identity document numbers),
- Banking details,
- Industry classification,
- Purpose of the business,
- Marketing and communications data (may include preferences you’ve indicated for receiving marketing and other communications from us and our third parties) and
- Annual revenue or other financial information.
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, ePP 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:
- to perform contracts with you
- to take steps requested by you in order to enter into contracts with you
- to comply with various legal obligations to which we are subject; or
- for our legitimate interests (which are not overridden by rights or freedoms of affected individuals), such as direct marketing, fraud prevention, internal administration, security as described further below.
In all other cases, we will only process your Personal Data with your specific consent given separately.
Customer Information is collected and processed to:
- Complete the registration of prospective customers (and for this we need to ensure the Customer Information is accurate and current for its intended use);
- Enable us to provide the eNett Products to you and carry out our obligations arising from any contracts entered into between you and us, manage customer accounts, assist with customer queries, notify you of any changes to the eNett Products or our service;
- Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant information to you;
- Enhance the user experience by displaying more relevant information and options to our customers;
- Analyse transaction data for product development;
- Comply with the laws and regulations and our suppliers’ obligations (including our Issuing Organisations), applicable to eNett and eNett Products, for example anti-money laundering and counter-terrorism financing legislation.
- Administer the ePP and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- Assist with keeping our site safe and secure;
- Improve and enhance the eNett products and services to you;
- Enhance the user experience by displaying more relevant information and options to our customers;
- Provide you with information about other goods and services we offer (unless you opt-out of receiving such information) which we feel may interest you except that if you are an individual customer, we will only provide such information by e-mail or other electronic means in relation to our goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you unless you have specifically consented to receive information about our other goods and services.
- If you are an individual customer, we may, if you have specifically consented provide your Personal Data to selected third parties so they can provide you with goods or services we feel may interest you,
- Whatever type of customer you are, if you do not want us to use Personal Data for marketing purposes in any of the above ways (whether or not you have previously consented), please elect the relevant opt-out option at any time, for example when you first register with us or when you log in to your account on the eNett Payments Platform or use the unsubscribe option when you receive an email.
We may share and exchange Customer Information:
- Within the eNett group of companies to enable us to provide the eNett Products to you
- With third parties such as Issuing Organisations (as defined in our terms and conditions), business partners, agents, suppliers and subcontractors appointed by us to perform services for us or on our behalf, such as financial institutions, card schemes and technology service providers and to enable us to provide the eNett Products and our services to you and comply with our (or the Issuing Organisations’) regulatory requirements
- With advertisers and advertising networks that require the data to select and serve relevant adverts to you and others and
- To credit reference agencies for the purpose of assessing your credit score where this is a condition of us providing our Products to you.
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 eNett 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 eNett’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:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- We will use specific contracts between us and the recipient of the Personal Data in a form approved by the European Commission. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them but we will use specific contracts between us and the recipient of the Personal Data in a form approved by the European Commission. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
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:
- The right to request from us access to and rectification or erasure of Personal Data or to restrict or object to processing;
- You have the right to have us transmit your Personal Data to another data controller where technically feasible;
- Wherever we have indicated that your consent is the lawful basis of our processing, you can withdraw such consent at any time with respect to future processing;
- The right to lodge a complaint with a data protection authority.
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 the ePP. 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 eNett 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.
Please refer to the WEX cookies notice for information about how we handle your Personal Information in relation to your activity on WEX Inc’s website(s) and platform(s).
You block cookies by activating the setting on your browser that allows you to refuse all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the ePP.
The list below informs you of the individual cookies we use on the ePP and the purposes for which we use them.
This STS Auth cookie is required to maintain state within the ePP as well as maintaining the user context:
These single sign-on cookies are used to determine and maintain authentication status to enable single sign-on:
This ASP.net cookie is required to determine and identify a user and a user’s session:
- More information can be found on Microsoft’s website here and here
Google Analytics generates statistical and other information about use of the ePP and compiles demographic, profile and usage data relating to the ePP and eNett Products. The information is used to create reports about the use of the ePP and eNett Products:
- More information on the Google site is here.
Several cookies are used by Eloqua. This cookie has one single value “Yes”. It is a session cookie and will be dropped and set to Yes when the webpage calls elqTrackPageViewDisplayOptInBannerByCountry or elqTrackPageViewDisplayOptInBannerForAll, so the strict-mode banner is only shown once during a session:
The purpose of this Eloqua cookie is to store a user’s response to the opt-in prompt:
This Eloqua cookie has a value of all the countries that are subject to strict-mode tracking in the install:
- More information on the Oracle site is here.
This Eloqua cookie gets dropped ONLY if a user consents to being tracked:
- More information on the Oracle website is here.
This Eloqua cookie enables us to track user behavior which assists us in making improvements in our communications and services:
This cookie remembers the language detected / picked by the user:
This cookie remembers if the user has filled in the gated form
This cookie remembers if the cookie notice was displayed for one for the countries under Europe Country List:
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 the ePP and/or to certain users, and, (iv) better understand how the ePP and/or eNett Products are used.
Third Party Websites
The WEX Inc website or the ePP may contain links to other websites. eNett is not responsible for the privacy policies or practices of third parties’ websites.
Personal Data access, correction and other requests – eNett Contact/Data Protection Officer.
If you wish to:
- Exercise any right of access, rectification, portability, deletion to your Personal Data that you may have under applicable law;
- Notify us of a data breach;
- Complain about our breach of an applicable law;
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.