Privacy Policy.

Privacy Policy and Statement.

November 2019

Introduction

IN.C.C Payments Pty Ltd (ABN 94 623 555 699) (INCC) is committed to protecting your privacy. We maintain robust physical, electronic and procedural safeguards to protect personal information in our care. This Privacy Statement applies to the INCC website, INCC App, products and services and governs data collection and usage.

We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and will protect your personal information in accordance with the Australian Privacy Principles (as defined in the Privacy Act).

These principles govern how we collect, use, hold and disclose your personal information, as well as how we ensure the quality and security of your personal information.

What is personal information?

Personal information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. This may include your name, address, telephone number or email address.

How do we collect personal information?

INCC is a distributor of reloadable and non-reloadable prepaid solutions involving both products and services in Australia.

INCC’s main functions and activities it performs as a distributor of a payment solutions include:

• Application support and development;
• Program maintenance and reporting;
• Account management services;
• Cardholder and card program sponsor customer service; and
• Fraud and transaction monitoring.

INCC rarely has direct contact with the individual cardholder and we may need to collect personal information about you from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from other organisations, who jointly with us, provide products or services to you.

The circumstances in which INCC will collect personal information about you, as the holder of the prepaid solution, includes when:

• You contact us; or
• You register, activate or apply for a prepaid solution; or
• You use a prepaid solution for transactions and balance enquiries.

What personal information do we collect?

INCC collects and/or tracks the following types of personal information:

• The personal information you have provided us through our online card activation process includes:
  • • E-mail address;
    • Your name; and
    • Mobile telephone number.
• There is also information about your computer hardware and software that is automatically collected by INCC. This information can include:
  • • Your IP address;
    • Browser type;
    • Domain names; and
    • Access times.
• Information we receive from third parties including card program sponsors, credit bureaus and information services and aggregation businesses, regarding verification of identification details.

Throughout the life of your prepaid solution, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaint you make.

For what purposes do we collect, hold, use and disclose personal information?

The main reason we collect, use, hold and disclose personal information is to provide you with products and services.

This includes:

• Checking whether you are eligible for the product or service;
• Providing the product or service; and
• Assisting you with your inquiries or concerns.

We may also collect, use and exchange your information so that we can:

• Establish your identity;
• Manage our risks and help identify and investigate illegal activity, such as fraud;
• Contact you;
• Comply with our legal obligations and assist government and law enforcement agencies or regulators;
• Conduct research and training; or
• Provide general statistics regarding use of the INCC website.

INCC encourages you to review the privacy statements of websites you choose to link to and from INCC so that you can understand how those websites collect, use and share your information. INCC is not responsible for the privacy statements or other content on websites outside of the INCC website.

Is the information disclosed to third parties?

INCC may disclose your personal information to third parties:

• Who are service providers, contractors or prepaid solution sponsors of INCC;
• To facilitate the operation of the prepaid solution and the completion and settlement of transactions using the prepaid solutions;
• For anti-money laundering, counter-terrorism financing, detection of crime, legal compliance and fraud prevention purposes; and
• When required or allowed by law.

When your personal information is shared with service providers or contractors, it will only be to the extent reasonably necessary for the purpose of the services they are contracted to provide.

When your personal information is shared with program sponsors, it will only be to the extent reasonably necessary for the purpose of performing any necessary prepaid solution customer support, conducting statistical analysis, improving their product, services and practices.

INCC may also disclose personal information to other third parties in circumstances where:

• We must fulfil our legal obligations (for example, disclosure to Australian (and international) enforcement bodies such as the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre (AUSTRAC), Centrelink or the Courts);
• It is in the public interest (that is, to protect our interests or where we have a duty to the public to disclose, or where it is necessary in proceedings before a court or tribunal) and where a crime or fraud is committed or is suspected; or
• It can be reasonably inferred from the circumstances that the prepaid solution holder has consented to their personal information being disclosed to a third party.

INCC does not use or disclose the personal information for any other purpose unless one of the following applies:

• The individual has consented;
• The individual would reasonably expect INCC to use or disclose the personal information for a purpose that is related to the primary purpose; or
• Use or disclosure is required under Australian law.

As a matter of course, INCC does not disclose personal information to overseas recipients.

If this position changes, we will only send your personal information outside Australia where, for example:

• You have requested or consented that we send your personal information;
• We outsource a function or service to an overseas contractor with whom we have a contractual relationship; or
• It is necessary to investigate or facilitate a transaction on your behalf.

INCC will continue to keep your personal information as is reasonably necessary, for the purposes mentioned above, after the expiry of the prepaid solution.

Your consent is important

INCC may require your consent to use and/or disclose your information in particular ways.

We need your consent if we use your information for a purpose that is not related to the purpose for which we collected your information in the first place.

Depending on the circumstances, this consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example your agreement is implied by the fact that you have agreed to your product terms and conditions which contains information about the use of disclosure).

Do we collect personal information electronically?

Each time you visit our website or our app, we collect information about your use of the website or app, which may include the following:

• The date and time of visits;
• Which pages are viewed;
• How users navigate through the site/app and interact with pages;
• Location information about users;
• Information about the device used to visit our website/app; and
• IP addresses.

This information is obtained through the use of google analytics.

Security of your Personal Information

INCC protects your personal information from unauthorised access, misuse and disclosure.

Our security safeguards include:

Security Safeguard	Details
Physical Security	We maintain physical security, such as locks and security systems over our paper and electronic data stores and premises
Staff education	We train and remind our staff of their obligation with regard to your information
System security	When you transact with us we encrypt data sent from your computer to our systems. Where appropriate, we have firewalls, password protection, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses accessing our systems. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. We also limit access by requiring use of passwords.
Destroying data when no longer required	Where practical, we keep information only for as long as required (for example, to meet legal requirements or our internal needs).
Payment Card Industry (PCI) Data Security Standard (DSS)	The PCI Data Security Standard represents a common set of industry tools and measurements to help ensure the safe handling of sensitive information. The standard provides an actionable framework for developing a robust account data security process – including preventing, detecting and reacting to security incidents. We have achieved the highest level of PCI DSS accreditation ensuring our customers are afforded the upmost protection and reliability of our implemented processes, systems and environment.

Protecting your privacy

You can help us to protect your privacy by observing our security requirements and contacting us immediately if your contact details change.

We require you to keep your personal identification number (PIN), passwords and access codes confidential and secure at all times. This means that you should not disclose you PIN, passwords or access codes to any other person. You should contact INCC immediately, if you believe that your PIN, passwords or access codes may have been disclosed to another person or if you would like to change your PIN or password.

Access to your personal information

You are entitled to ask us to supply you with any personal information that we hold about you. You must submit your request in writing to the appropriate address as below:

Privacy Officer
INCC Payments
PO Box 94
Newtown NSW 2042

We maintain the quality of your personal information by taking reasonable steps to ensure that the information collected, used and disclosed is accurate, complete and up-to-date.

You may also update your personal information at any time by emailing INCC Payments at help@incccards.com.au

How to make a complaint

INCC welcomes your comments regarding this Privacy Statement. Should you wish to make a complaint about the way in which INCC has handled your personal information or if you believe INCC has breached the Australian Privacy Principles, please contact us on help@incccards.com.au

We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.

We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five business days but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.

If you’re not satisfied with our handling of your matter, you can refer your complaint to external dispute resolution.

Under the Privacy Act you may complain to the Office of the Australian Information Commissioner by calling them at 1300 363 992, online at www.oaic.com.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.

Changes to this Statement

From time to time it may be necessary for INCC to review and revise our privacy policy to reflect company and client feedback. INCC encourages you to periodically review this website to be informed of how INCC is protecting your information.