MGU Privacy Policy

When you trust Me Global Union Pty Ltd (trading as SUPAY) with your personal information, you expect us to protect it and keep it safe. We are bound by the Australian Privacy Act 1988 (Cth) (‘Privacy Act’) and will protect your personal information in accordance with the Australian Privacy Principles. These principles govern how we can collect, use, hold and disclose your personal information, as well as ensuring its quality and security.

The Privacy Policy is published on our website to meet our obligation under Privacy Acts which requires us to set out our policies on the management of personal information in a clearly expressed document which is available to anyone. Your use of this website constitutes an acknowledgement that you have been made aware of our privacy practices as outlined in this policy.

If you would like more information about how we protect your privacy, please contact us.

1. About this policy

This privacy policy explains how we manage your personal information.

Me Global Union Pty Ltd (SUPAY) is a specialist foreign currency exchange and global funds transfer provider. We are committed to offering fast, secure, and efficient financial services while maintaining rigorous standards of data protection.

The Privacy Act requires entities bound by the APPs to have a privacy policy about its handling and management of personal information. SUPAY is an entity bound by the APPs. Therefore, this privacy policy outlines SUPAY’s practices for the handling and management of personal information.

This privacy policy aims to outline, in simple and plain English, how personal information (including, where relevant, any sensitive information) is collected by SUPAY, and how personal information that has been collected is stored, used and disclosed. The privacy policy also provides information on how you can access and correct your personal information, and how you can contact SUPAY to make a complaint if you believe your personal information has not been appropriately handled.

2. Overview

SUPAY administers the Anti-Money Laundering and Counter Terrorism-Financing program. SUPAY collects, holds, uses and discloses information as required or authorised under this program for the purposes of detecting, deterring and disrupting money-laundering and terrorism-financing risks and threats that affect Australia’s financial systems.

3. Collection of personal information

The collection of personal information by SUPAY can be either direct or indirect.  We collect most personal information directly from you whether in person, on the phone or electronically. Examples of how we may collect information from you include:

• When you enquire about our services;
• When you call our contact centre to speak with one of our staff, or when you write to us about a query you have;
• When you complete an application, for example when you apply to become enrolled with SUPAY;
• When you apply for a job with SUPAY.

We collect information that is reasonably necessary to be able to provide you with our services. In general, the main types of personal information we collect and hold includes (but is not limited to):

• Names
• Contact details
• Gender
• Dates of Birth
• Employment details and employment history
• Details of your financial circumstances, including bank account details, your assets and liabilities (both actual and potential), income and expenditure.

3.1. Collecting sensitive information

Sensitive information is a subset of personal information and is defined in section 6 of the Privacy Act as “information or an opinion about an individual’s racial or ethnic origin, political opinion, membership of a political association, health, criminal record, etc.”

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g. where required by law).

3.2. Anonymity

Except in situations otherwise required by legislation, SUPAY will allow you to interact with us anonymously or to use a pseudonym if you wish. For example, if you contact SUPAY’s contact centre to make a general inquiry and you do not wish to provide your name, we will not insist on asking for your name or other personal information if you indicate you do not wish to provide it.

However, for the most part SUPAY will usually need your name and contact details, as well as sufficient information about the particular matter to enable us to effectively and efficiently deal with your inquiry, request or complaint, so withholding your personal information may mean that we are not able to carry out our functions effectively and provide the services you require.

3.3. Collection through our website

When you visit SUPAY’s website, a record of your visit is logged and information is automatically recorded for statistical purposes to enable us to improve the site and our services. This information does not identify you individually and SUPAY does not otherwise track information about you and your visits.

Your web browser supplies information that includes:

• the IP address of your device;
• the type of web browser used;

4. Disclosure of information

Information, including personal information, which SUPAY has lawfully collected under the AML/CTF program, is SUPAY information. The use and disclosure of SUPAY information by us, including where personal information is involved, is carefully managed pursuant to the AML/CTF Act 2006 and other relevant legislation like the Privacy Act, and in consultation with the Office of the Australian Information Commissioner (OAIC), to ensure that the use and disclosure is consistent with both the restrictions in the AML/CTF Act and also the Australian Privacy Principles (APPs).

In providing our services we may need to disclose personal information to a third party. This will be done to the extent that it is permitted by law and set out in this Policy.

Examples of the types of third parties we may disclose personal information to include:

• Members of the SUPAY
• Companies or individuals contracted to assist us in providing services
• Courts, tribunals and regulatory authorities, as required or authorised by law
• Auditors or compliance officers, as required by Law, which means the disclosure is in connection with giving access to certain government agencies which, by law, are entitled or authorised to access SUPAY information.
• Anyone else to whom you consent, such as banks, accountants and other financial institutions.

5. Security of information

When SUPAY receives your personal information, whether directly from you or indirectly from other sources, the information is stored in a secure environment.  In addition to information classification and dissemination limitation markers, all information kept on our electronic databases is protected by security measures such as password protection or access restriction to only authorised personnel.  Your personal information will not be used or disclosed unless you have consented to that use or disclosure, or the AML/CTF Act or another law permits it.

SUPAY takes reasonable steps to ensure your personal information is protected from misuse, loss and unauthorized access, modification or disclosure.  We may hold your information in either electronic or hard copy form for 7 years.  Personal information that is no longer needed is destroyed after that.

Our employees are required to respect the confidentiality of personal information and the privacy of individuals, and privacy and data protection training is undertaken. As part of that training, all employees are required to read this policy and understand their obligations in regard to personal information.

If you have concerns in this regard, SUPAY has alternative methods of obtaining and providing information. Normal mail, telephone and fax facilities are available.

6. Accessing personal information and privacy complaints

6.1 Accessing and correcting personal information

You are entitled to request access to your own personal information, including for the purpose of correcting your personal information, unless the provisions of the Freedom of Information Act 1982 or another law of the Commonwealth that provides for access by persons to documents require or permit us to refuse to give access.

Requests for access to your own personal information are free.

Request for your own personal information may be made to SUPAY by:

Call   02 9267 8878

Email service@supay.com

Post SUPAY 62 Kingsway, Glen Waverley, VIC, 3150

We will respond to request to access (and where relevant, correct) your own personal information within 30 days of receiving the request.  If we are required or permitted to refuse access, we will give you a written notice setting out:

the reasons for refusing access (unless it would be inappropriate and unreasonable to do so having regard to the circumstances); and

the mechanisms available to you to complain about the refusal.

6.2 Making a complaint

If you wish to make a complaint about how SUPAY has handled your personal information, please do so in writing.  If you need help lodging a complaint, you can contact SUPAY on 02 9267 8878.

Complaints can be made to SUPAY by:

Email service@supay.com

Post SUPAY 62 Kingsway, Glen Waverley, VIC, 3150

If we receive a complaint from you, we will acknowledge your complaint within 3 business days of receiving the complaint.

We will consider your complaint and decide what action (if any) we need to take to resolve the complaint.  This may include, for example, referring your complaint to SUPAY’s Privacy Officer for investigation about the SUPAY staff member whose actions you are complaining about, or reviewing the security of our data bases, as the case requires.

We will respond to your complaint within 30 days (or another timeframe agreed with you) of receiving your complaint and explain the actions we have taken or propose to take to address the issues raised in your complaint.  If you are not satisfied with SUPAY’s response to your complaint, you may ask for a review by a Branch manager within SUPAY.

Changes to the Privacy Policy

We may change the way we handle personal information from time to time for any reason. If we do so, we will update this Privacy Policy. An up-to-date version is available on our official website.