Privacy Policy
The Data Controller
The PayZe® Website (“website”) and PayZe® Mobile App Wallet (“Wallet”) are managed by Tranxactor New Zealand Limited (“Tranxactor”). In this Privacy Policy the use of “we” “us”, or “our” means Tranxactor.
Tranxactor is a company incorporated in New Zealand with its registered office address at A4/1 Beresford Square, Auckland 1010, New Zealand. Tranxactor is the controller of your personal data whilst using the website or the Wallet. A ‘controller’ is a person or organisation which decides how it will use information that has been provided by an individual and which identifies that individual in some way. The controller is also responsible for ensuring compliance with data protection obligations.
3rd Party Links
The website and the Wallet may include links to PayZe® content on various social media sites and applications like Facebook and Instagram. Facebook and Instagram share some personal data with us about you (see the section “How is your personal data collected”). You can find out more information on how Facebook and Instagram use your personal data in their privacy policies available on their websites and apps. See also our Cookie Policy in respect of cookies and links to third-party websites and apps.
The website and the Wallet may also include links to other third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave website or the Wallet, we encourage you to read the privacy notice of every website you visit.
Personal data means any information about an individual from which that person can be identified. It does not include data or information which has been anonymised so that the identity of the individual is not ascertainable. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name and last name
- Contact Data includes email address and telephone numbers
Transaction Data includes details about loading of value and other details of payments made using your physical plastic PayZe® Card (“Physical Card”) or if applicable, the digital code in the PayZe® Wallet (“Virtual Card”). Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website and the Wallet.
Profile Data includes your username or similar identifier, password, value loads, and payments made by you using any of the PayZe® products. Usage Data includes information about how you use the website and the Wallet. We may also collect, use and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
For example, we may aggregate your usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We do not collect any information about criminal convictions and offences.
If you fail to provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform our obligations under the contract we have or are trying to enter into with you (for example, to provide you with services or products). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How your Personal Data is collected
We use different methods to collect personal data from and about you including through: Direct interactions. You may give us your Identity Data, and Contact Data by filling in forms on the website or Wallet or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase or use a PayZe® product or service;
- create an account on the Wallet;
- subscribe to our services or publications;
- request marketing information to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Collection of data through tracking technologies
We collect data on visits and the visitors to the website and the Wallet: as you interact with the website and the Wallet, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our Cookie Policy or further details.
We collect Transaction Data when you use your Physical Card or Virtual Card to operate the PayZe® payment scheme.
Third parties or publicly available sources. we may receive data about you from various third parties and publicly available sources including as set out below:
- Google Analytics: we use features of Google Analytics for Firebase, Google’s mobile and web application development platform, to provide us with information on how the website and Wallet are used and to help with understanding application crashes of the website and Wallet. Google Analytics is a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies and tracking technologies, as detailed in our Cookie Policy, to allow an analysis of your use of the website or Wallet. Google Analytics provides us with detailed visitor demographic data, how behaviours can be tracked against “typical” journeys, the routes you take through the website and the Wallet, and how traffic trends compare across different time periods; and
- Social media platforms (for example, Facebook, Instagram and Twitter): we receive aggregated demographic information (such as age and interests) from social media platforms for the purposes of personalising our advertising campaigns.
How we use your personal data
We will only use your personal data when the law requires us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Purposes for which we will use your Personal Data
Third-Party Marketing
We will not share your personal data with third parties for marketing purposes except with your express opt-in consent. You can unsubscribe from such marketing at any time.
Sharing your Personal Data
We may share your personal data with the parties set out below:
- Companies that are part of the Tranxactor Group.
- UnionPay International
- External third-party service providers such as Google LLC and its group companies for the provision of Google Analytics for Firebase, a web analytics service (see our Cookie Policy for more details).
- Our auditors and professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
- We have appropriate data protection terms in place with our third-party service providers depending on our relationship with them. Where we use third party service providers to process personal data on our behalf, we do not allow such service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in strict accordance with our instructions. Any personal data you provide to our third-party service providers directly will be processed in accordance with the third-party service provider’s privacy policy.
- In addition to the specific disclosures of personal data set out in this Privacy Policy, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
- We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We do not sell your personal data to third parties.
- If you would like more information about who we share data with and why, please contact us.
We have set out below a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your personal data.
- To register you as a new customer
- Performance of a contract with you
- To provide our services and the associated benefits, including the transactions that you make
- To manage our relationship with you which will include:
- Notifying you about changes to our Terms & Conditions or Privacy Policy
- Asking you to leave a review or take a survey
- Responding to a query you may have
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
- Necessary to comply with a legal obligation to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
- Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
- To make suggestions and recommendations to you about goods or services that may be of interest to you, including direct marketing
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Marketing and Communications
We may use your Identity, Contact, Technical, usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. For example, if we see that you haven’t had any activity for a while, we might send you a special offer to encourage you use PayZe®. You will receive marketing communications from us if you have requested information from us or have used a PayZe® product you have not opted out of receiving that marketing.
Your Rights
Data protection law strengthens your rights over how companies use your personal data. A summary of these rights is as follows:
- The right to insist that companies who hold your personal data are fair and transparent about how and the manner in which they process and use your personal data. This is why we provide you with this privacy notice.
- The right to access your personal data. You have the right to request a copy of the personal data we hold about you.
- The right to insist that companies correct any mistakes in the personal data they hold about you. If you discover that any of the personal data we hold about you is incorrect or incomplete then you can ask us to correct it. However, we will need to check that the new personal data you are giving us is accurate.
- The right to erase or delete your personal data in certain situations. You can ask us to delete or remove personal data where there is no good reason for us to continue to process it. If you have successfully exercised your right to object to us processing your personal data or if we have processed your personal data unlawfully or we are required to stop processing your personal data as a matter of local law, then you can ask us to delete your personal data.
- The right to object to continued processing of your personal data, in certain circumstances. If we are relying on the basis of a legitimate interest to process your personal data and you feel it impacts on your fundamental rights and freedoms, you can ask us to stop processing your personal data. You can also ask us to stop processing your data for direct marketing purposes. However, we might have a compelling legitimate ground which will override your rights and freedoms.
- The right to restrict the way that companies process your personal data, in certain circumstances. You can ask us to suspend processing of your personal data if (i) you want to make sure the personal data is accurate; (ii) where our use of the personal data is unlawful but you don’t want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- The right to data portability. You can ask us to transfer your personal data to a third party but this right only applies to automated information you initially allowed us to process
- The right to withdraw consent. If we process your personal data on the basis of your consent, then you can withdraw your consent and we must cease processing it.
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘What to do if you have a concern or complaint about our use of your personal data’ below). To exercise any of these rights, please fill out this form.
No Fee usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
When exercising any of your rights listed above, we may need to request specific information from you to help us confirm your identity. 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.
Time Limit to Respond
We try to respond to all legitimate requests within one month from the date we received your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Your Choices
Your account includes your personal data and transaction history. You can update the details of your account at any time through the Wallet. You also have the choice to request closure of your account at any time.
Storage, Data Security and Accuracy of Personal Data
Where we Store your Personal Data
If you are located in the EEA or the UK, the personal data that we process about you may be transferred to, and stored at, a destination outside the UK or the EEA (as applicable). It may also be processed by staff operating outside the UK or the EEA (as applicable) who work for us or for one of our third party service providers (see ‘Disclosing your personal data’ section).
This would include staff who, for example, are engaged in the provision of support services, prior to any transfer of personal data to us or from us to any third party. We will take all reasonable steps to ensure that such parties have adequate security protections in place for the protection and secure transmission and storage of any personal data.
We will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Privacy Policy and as permitted by data protection legislation.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Accuracy of Personal Data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. we take all reasonable steps to ensure that your personal data is accurate, up-to-date, complete, relevant and not misleading.
Retention and Deletion of Personal Data
We will retain your personal data for as long as necessary to fulfil the purpose(s) for which it was collected including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may also retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you have a concern or complaint
We strive to act in accordance with relevant data protection legislation at all times. If you have a concern or complaint about our collection or processing of your personal data, then please contact us via [email protected] so that we can put it right.
You have the right to make a complaint at any time to the data protection regulator in your country. We would, however, appreciate the chance to address your concerns before you approach any regulators so please contact us in the first instance.
Access to information (Subject Access Request)
You have the right to access all personal data we hold about you, and we will usually provide you with an initial copy free of charge. Contact [email protected] if you wish to request a copy of your personal data.
However, we may charge a nominal fee as an administration charge in the event of access requests that are excessive or repetitive. Alternatively, we are entitled to refuse to comply with your request in these circumstances.
Changes to Privacy Policy
We keep our Privacy Policy under regular review and may change it from time to time. If we do, we will post the revised version on our website and the Wallet. You can check our website or the Wallet for the most up-to-date version.
