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Register Login
Home Legal Privacy Policy


OFX PRIVACY POLICY

This policy applies from 15 June 2022 

Download OFX Privacy Policy

1. Overview of Policy

Scope

At OFX, your privacy is important to us, and so is being transparent about our
privacy practices.

This Privacy Policy (“Policy”) describes the information we collect from you and
how that information is used and shared by us. It also includes details about
the choices we offer you in relation to that information. If you are a customer
of OFX, this Policy should be read with the customer agreement you enter into
with us (“Customer Agreement”). 

OFX acquired Firma Foreign Exchange Corporation (“Firma”) on 1 May 2022. 
Firma’s privacy policies will continue to apply to Firma’s Canadian, New Zealand
and Australian businesses until those businesses are integrated into the OFX
business.

Definitions

“OFX”, “we,” “us” and “our” refers to the following companies: OzForex Limited,
CanadianForex Limited, NZForex Limited, OzForex (HK) Limited, OFX Japan G. K,
OFX Payments Ireland Limited, OFX Singapore Pte. Limited, UKForex Limited and
USForex Inc.

“Personal Information” refers to any information or opinion relating to or about
an individual or an individual who is reasonably identifiable.

“Online Channels” means:

 * Websites operated by us (“Websites”);
 * Software applications made available by us for use on or through computers
   and mobile devices (“Apps”);
 * Our social media pages and apps that we control (collectively, our “Social
   Media Pages”); and
 * HTML-formatted email messages that we send to you that link to this Policy or
   other communications with you.
 * Device notifications and other channels we use that are not Websites, Apps or
   Social Media Pages.

2. Information We Collect

Identification Information

We may collect some or all of the following information: your name, date of
birth, title, gender, mailing address, phone number, email address, nationality,
occupation and social security number or other tax identification number.

To comply with applicable laws and regulations (including anti-money laundering
and counter terrorism financing laws (“AML/ CTF Laws”), we may collect identity
verification information such as copies of your government-issued identification
(including passport, driver’s license, social security card, government health
benefits card or national ID card) or other authentication information, all of
which may include photographs of you.

We also may provide you with the option of using identification verification
technologies that analyse your facial imagery or other biometric information
provided.

Financial Information

In order to comply with AML/ CTF Laws, assess creditworthiness, and process
payments and transactions we may collect financial information such as bank
account details (account number, routing number), credit or debit card numbers,
credit information or reports or tax information, such as withholding allowances
and filing status.

Transaction Information

When you book transactions with us, we may collect information about the parties
to the transaction, the source of the funds, the reason for the transaction, and
the devices and payment methods used to complete transactions. If you choose to
pay someone else, we will ask you for the designated recipient’s name, mailing
address, email address and bank account information. This is necessary for us to
make a payment to them and you confirm that you know they agree or that you are
otherwise allowed to give us this information and will inform them of the
contents of this Privacy Policy.

Business Information

If you are using our services on behalf of a business entity, we may collect
information about the business including the organisational structure of the
company and individuals involved in the business. We also may collect entity
formation documents or other corporate records. OFX is required under AML/ CTF
Laws to collect Personal Information of individuals who ultimately own or
control corporate clients, directly or indirectly (“Beneficial Owners”). Such
information may include the Beneficial Owner’s name, date of birth, title,
gender, mailing address, phone number, email address, nationality, occupation
and social security number or other tax identification number. You confirm that
you know the Beneficial Owners agree or that you are otherwise allowed to give
us this information and will inform the Beneficial Owners of the contents of
this Privacy Policy

Background Information

To the extent permitted by applicable law, we may obtain, in the course of
providing you with the services you request, background check reports from
public records of criminal convictions and arrest records. Some jurisdictions
require us to obtain your consent. Where you refuse to provide consent, we may
be unable to provide services to you.

Log Data

When you access our Online Channels, we collect server logs, which may include
information such as IP address, access times and dates, pages viewed and other
system activity, including the third-party site you were using before and after
accessing our services.

Device Information

We may obtain information about the devices you use to access our Online
Channels including: the device type, operating systems and versions, the device
manufacturer and model, preferred languages, and plugins.

Usage and Preference Information

We collect information about how you interact with the Online Channels and how
you use our Online Channels, including your user preferences and other settings
selected by you. In some cases we do this by using cookies and other tracking
technologies. Please see further details in our Cookies & Tracking Notice.

Geolocation Information

When you use certain features of our Online Channels, we may collect information
about your precise or approximate location as determined by data such as your IP
address or mobile device GPS. Most mobile devices allow you to control or
disable the use of geolocation services for applications by changing preferences
on your mobile device.

Aggregated/Anonymised Data

We may also collect or create aggregated and/or anonymised data about our users
with anonymised or deidentified data. This data is used for industry and market
analysis, demographic profiling, marketing and advertising, and other business
purposes.

Other Information

We may collect any other Personal Information you may provide to us when you
update your account information, respond to surveys, post to community forums,
participate in contests or promotions, or use any other feature of our Online
Channels or services.

3. How We Collect Information

We collect information about you in a variety of different ways, including the
following:

Information You Provide

We collect Personal Information and other information from you when you complete
an application or form, register for an OFX user account, submit to our
verification procedures, apply for additional account features or services,
conduct transactions, respond to our emails, messages or surveys, communicate
with us including by telephone, email and online, provide feedback, participate
in promotions or contests, provide referrals, or upload content. We make and
store recordings of our telephone communications with you.

OFX will collect your Personal Information from you unless it is unreasonable or
impracticable to do so, or is authorised by applicable laws.

Information from Your Use of services

When you use our services, we collect Personal Information and other information
about you and the devices you use to access the Online Channels. If you connect
your social media account to your OFX account, you will share certain Personal
Information from your social media account with us, for example, your name,
email address, photo, list of social media contacts, and any other information
that may be or you make accessible to us when you connect your social media
account to your OFX account.

Information from Third Parties

We also collect Personal Information about you from third parties and other
sources, including government agencies, identity verification and fraud
detection service providers and databases, credit bureaus, credit reporting
bodies, credit reference agencies, community forums used to post ratings or
reviews, social media platforms, advertising, advertising technology and market
research companies, contact list, demographic & profile data brokers including
companies that publish OFX marketing and advertising materials that you interact
with, OFX business partners and associates through which you access our
services, or other sources of public records.

For corporate clients, we may collect Personal Information about the Beneficial
Owners of the business from any person that has represented to us that they have
authority to act on behalf of the business entity and provide that information. 

4. How We Use Your Information

We use Personal Information we collect from or about you (including credit
information) for several purposes, including:

To provide or improve our services

 * To process payments or money transfers.
 * To provide customer support.
 * To evaluate your application to use our services.
 * To develop new products or enhance existing products and services.
 * To monitor and analyse trends, usage, preferences and other user activities
   on our Online Channels to optimise user experience and to enhance the
   effectiveness of our promotional campaigns.
 * For quality control and staff training.

To ensure safety and security

 * To verify your identity or authenticate your right to access an account or
   other information.
 * To conduct manual or automated monitoring to protect against fraud, money
   laundering and other crimes and harmful activities.

To comply with legal obligations

 * To comply with laws, regulations, codes of conduct, stock exchange rules,
   binding determinations or to respond to legal process or government
   authorities.
 * To address disputes or resolve claims related to use of our services.
 * To enforce our terms and conditions and collect fees

To communicate with you

 * To respond to your inquiries and support requests.
 * To send you technical notices, updates, security alerts and other
   administrative messages.
 * To provide information related to your transactions, including confirmations,
   receipts, and tracking notices.

To market and advertise our services

 * To deliver promotional offers, incentives, and targeted or personalised
   marketing in a variety of ways including via email, SMS, push messages,
   telephone, social media or online.
 * To provide invitations and information about events held by us or our
   partners.
 * To facilitate promotional contests or sweepstakes.
 * For analytics and insights with any Personal Information that we collect or
   obtain about you, including combining your Personal Information with other
   personal information and data to use in advertising and marketing that may
   influence your behaviour or decisions or provide insights and measurement to
   us in relation to any advertising initiatives that we may run.

You can opt-out of receiving marketing at any time through the unsubscribe
function available in each marketing communication we send. Alternatively you
can update your preferences by logging in to your OFX account on the Website or
contact us at customer.service@ofx.com or using the “Contact Us” information
below.

Other purposes

Any other purpose disclosed at the time of collection.

5. Information Sharing and Disclosure

We will never sell your Personal Information to marketers or other third
parties. We may disclose or otherwise provide anonymised/aggregated data to
third parties. However, we may share information about you, including Personal
Information, with the following third parties if you ask us to, it’s required to
provide our services to you, if we have a duty to disclose it or an applicable
law allows us to do so for legitimate interests or business reasons:

Our Corporate Affiliates

To facilitate or support us in providing our services to you, we may share your
Personal Information with other companies in the OFX group.

Our Service Providers

We engage a variety of service providers to enable us to provide our services to
you. For example, service providers may be used to support technology or
infrastructure, analytics and insights generation, collect debts, determine who
we should market and advertise to, distribute marketing materials, conduct
market research, perform audits, provide professional advice or other functions.

Payment Processors

To payment processing service providers, intermediary banks and financial
institutions to process your transactions.

Credit Reference and Identity Verification Agencies

To credit bureaus, credit reporting bodies, credit reference agencies, identity
verification agencies and other companies and organisations (“Verification
Agencies”) to check your details, verify your identity and protect against
fraud, money laundering and other crimes and harmful activities.

In some cases Verification Agencies may need to access third party databases
(including without limitation databases of government issuers of identification
documents). You provide your authority for Verification Agencies to act as your
agent in accessing these databases. Verification Agencies may disclose to third
parties any information provided to them for identity verification purposes.

Our Partners, Business Associates or Contractors

To any of our partners, business associates, or contractors or your agents that
you have authorised to have access to your OFX account or your Personal
Information in connection with the provision of our services. A partner’s,
business associate’s or contractor’s access to and use of any transactional data
provided by OFX will be treated in accordance with that third party’s terms of
use. Xero’s access to and use of any transactional data provided to Xero by OFX
will be treated in accordance with Xero’s Terms of Use.

If you are an online seller receiving funds from a marketplace, we may be
required to share your Personal Information and OFX account information with the
marketplace to assist with minimising fraudulent and illegal activity or as
required by applicable laws.

Other Authorised Third Parties 

If you provide your consent, we may share your information including your
Personal Information with other authorised third parties. Such disclosure will
only be carried out in the manner described to you at the time you agreed to the
sharing. Authorising a third-party application or website to access your OFX
account or participating in certain promotional activities constitutes such
consent to share your information.

Government Authorities

If we believe it is necessary or appropriate, we may share your Personal
Information with law enforcement officials, government authorities, regulatory
bodies or other third parties, including for purposes of: (i) enforcing our
Customer Agreement or other applicable agreements or policies; (ii) protecting
our rights, property, privacy, or security, or that of others; or (iii)
complying with applicable law, legal process, or government orders.

Third-Party Acquirers

If we are the subject of or are involved in any corporate merger, acquisition,
consolidation, reorganisation, sale, joint venture, assignment, transfer or
other disposition of all or any portion of our business or assets (including in
connection with bankruptcy or similar proceedings), we may disclose or transfer
data, including Personal Information, with third parties in connection with such
events.

6. International Transfers

We collect information globally and may transfer, process and store your
information outside of your country of residence, to wherever we, our third
party service providers or any recipients referred to in section 5. Countries to
which we are likely to transfer your information are the United States of
America, Canada, United Kingdom, countries in the European Economic Area,
Australia, New Zealand, Hong Kong and Singapore. Whenever we transfer your
information, we take steps to protect it.

7. How long we keep Information

We need to keep your Personal Information so that we can provide our services to
you. Under relevant AML/ CTF Laws we need to keep your Personal Information and
information about your transactions for up to 7 years from the end of your
relationship with us. We also need to keep it for longer for legitimate business
purposes (such as transactional information for our accounting purposes) and for
other legal and regulatory reasons. Subject to this, we will destroy, erase, or
anonymise your Personal Information when it is no longer needed.

8. Choices and Transparency

You have choices regarding how to manage your Personal Information and how we
use and disclose your Personal Information.

How Your Information may be Accessed, Updated or Corrected

To ensure the information we hold is accurate, you should tell us as soon as
possible if any of the information you have provided us has changed. You may
request that we correct or update the Personal Information you provided to us at
any time by logging into your OFX account or by contacting us using the “Contact
Us” information below. If you want to access a copy of the Personal Information
we hold about you, you can contact us at privacy@ofx.com or using the “Contact
Us” information below.

We will respond to any such request consistent with applicable law. Prior to
changing or correcting your information or providing your information to you, we
may be required to verify your identity.

There may be situations where we cannot action your request including where the
information may impact the privacy of other individuals, the information is
subject to legal privilege, the disclosure could threaten the safety, physical
or mental health or life of an individual or OFX is prohibited by applicable law
from providing you with access. If this is the case, we will set out in writing
to you any reasons for our refusal to provide access to such information.

We will take reasonable steps in the circumstances to ensure that your Personal
Information is accurate, complete and up-to-date to minimise the possibility
that inappropriate information may be used to make a decision about you. We will
not routinely update your Personal Information unless such a process is
necessary to fulfil the purposes for which the information was collected.

If you are a Californian resident, please refer to the “Additional Information
for Californian Residents” section at the end of this Policy for more
information about the requests you may make under the California Consumer
Privacy Act.

If you are resident in the UK or European Union, please refer to the “Additional
Information for UK/EU Residents” section at the end of this Policy for more
information about the requests you may make under privacy legislation.

Restrict Sharing

If you are resident in the UK or European Union, you may request further limits
on our disclosure of certain of your Personal Information where such information
is not required for delivery of our services by contacting us
at privacy@ofx.com or using the “Contact Us” information below.

If you are a U.S. resident using our Services to conduct transactions for
personal, family or other household purposes, you may request further limits on
our disclosure of certain of your Personal Information to certain affiliated
third parties. Please refer to our Consumer Privacy Notice to learn more about
your opt-out rights and how to exercise them.

Device Permissions

Most mobile devices allow you to disable the use of location services, or revoke
consent to applications to access your camera and photo library or send you push
notifications. Some devices allow you to activate a ‘do not track’ function,
reset your device specific advertising identifier. Please refer to your device
settings to restrict collection of certain information.

Marketing Opt-Out

You can opt out of receiving our marketing at any time through the unsubscribe
function in each marketing communication or by updating your preferences under
the “Your Profile” section or “Profile & Settings – Notifications” section when
you log into the Website. Please note that if you opt out of marketing-related
emails from us, we will continue to send you non-promotional messages that are
required to provide our services, such as transactional receipts and messages
about your account or our relationship with you. 

Testimonials

We display personal testimonials of satisfied customers on our website in
addition to other endorsements. With your consent, we may post your testimonial
along with your name. If you wish to update or delete your testimonial, you can
contact us at privacy@ofx.com or using the “Contact Us” information below.

9. Security

We take appropriate technical, physical, and administrative measures designed to
safeguard your Personal Information against loss, misuse, or unauthorised
access.

The way we do this depends on the sensitivity of the information and the format
in which it is contained. Security measures include technological measures such
as encryption, physical measures like restricted access to offices and strategic
measures such as security clearances and limiting access to a “need-to-know”
basis.

Unfortunately, the transmission of information over the Internet or the
telephone is never 100% secure and no data storage system can be guaranteed
safe. We cannot warrant the security of data transmitted to us and any
transmission is at your own risk.

We encourage you to understand the integral role you play in keeping your own
Personal Information secure and confidential, always keep your log-in details
secure. You should also take care not to give any security credentials we
provide you or you choose (such as a password) to someone who is not an OFX
representative. We will never ask you for your full security credentials. If you
are unsure, please end the session. If you suspect any unauthorised use or
access to your account or information, please contact us immediately, using the
“Contact Us” information below.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to recognise you and to
customise your online experience. To learn more about cookies and the other
tracking technologies we may utilise, please refer to our Cookies & Tracking
Notice, which includes a comprehensive overview of cookies and provides further
details about how we use cookies and how to control our use of cookies. We do
not currently respond to browser do-not-track signals.

11. Advertising, Profiling, non-advertising issues and analytics

We may partner with third parties to display and personalise OFX advertisements
to you and to track and report on the performance of those advertisements. These
third-party partners use cookies and other technologies to gather information
about your activities on our Online Channels, as well as information from third
parties and your activities on other sites or online services on any of your
devices, in order to serve you advertising based upon your online behaviours
including browsing history and interests. They also use these technologies,
along with information they collect about your online use, to recognise you
across the devices you use.

To learn more about behavioural advertising and online tracking, including how
to opt out of interest-based online advertising delivered by member companies,
please visit Your Online Choices, Network Advertising Initiative and DAA’s
WebChoices Tool. You may download the AppChoices app here to opt out in mobile
apps. For more information about some of our online advertising supplier privacy
policies or the cookies that may be served through use of our Online Channels,
please refer to our Cookies & Tracking Notice. 

12. Social Media Features

Our Websites may include social media features, such as the Facebook Like
button, and widgets, such as the Share This button or interactive mini-programs
that run on our Website. These features may collect information about you and
your online activities and may set a cookie to enable the feature to function
properly. Social media features and widgets are either hosted by a third party
or hosted directly on our website. Your interactions with these features are
governed by the privacy statement of the company providing it.

13. Third Party websites and services

This Policy does not apply to third party websites, applications, products or
services, even if they are linked to our services or Online Channels, and we are
not responsible for the privacy, information, or other practices of third
parties. The inclusion of a link on the Online Channels does not imply
endorsement. You should review the privacy policies of any third party websites
you visit.

14. Children

Our services are not intended for or directed at individuals under the age of
18. We do not knowingly collect Personal Information from individuals under the
age of 18.

15. Complaints

OFX will investigate all complaints. For more information on how we manage
complaints see our Complaints Policy in the Legal section of our Website or
contact Customer Service at customer.service@ofx.com.

16. Updates to This Policy

We may change this Policy from time to time. If we make any material changes we
will notify you by means of a notice on our Websites. Any changes will become
effective on the date specified in the revised Policy posted on our Websites.

17. Contact Us

If you have questions or concerns about this Policy, need it in an alternative
format, have a specific request related to your Personal Information or any
complaints about our privacy practices, please contact us at privacy@ofx.com or
at:

For Australian Residents

OzForex Limited (trading as OFX)
Level 19, 60 Margaret Street,
Sydney NSW 2000 Australia
Attn: Privacy Officer
Tel: +612 8667 8090

For Canadian Residents

CanadianForex Limited trading as OFX
145 King Street, Suite 1002
Toronto, ON M5H 1J8
Attn: Privacy Officer

For EU Residents

OFX Payments Ireland Limited trading as OFX
Fitzwilliam Court, 2 Leeson Close, Dublin 2, D02 YW24, Ireland
Attn: Privacy Officer

For Hong Kong Residents

OzForex (HK) Limited trading as OFX
44th Edinburgh Tower, The Landmark
15 Queen’s Road
Central Hong Kong
Attn: Privacy Officer

For New Zealand Residents

NZForex Limited
C/- Bell Gully, Level 22, Vero Centre
48 Shortland Street
Auckland 1010 New Zealand
Attn: Privacy Officer

For Singapore Residents

OFX Singapore PTE. Limited
Capital Tower, 168 Robinson Road, #12-01 to #12-04, Singapore, 068912
Attn: Data Protection Officer

For UK Residents

UKForex Limited (trading as “OFX”)
4th Floor, The White Chapel Building, 10 Whitechapel High Street,
London, E1 8QS
Attn: Privacy Officer

For U.S. Residents

USForex Inc., dba OFX
49 Stevenson St, 13th Floor
San Francisco, CA 94105
Attn: Privacy Officer

Additional Information for Residents of Australia

Office of the Australian Information Commissioner (OAIC)

OAIC is a government agency which oversees the Privacy Act 1988 (Cth) and
related legislation, and investigates complaints about handling of Personal
Information under the Privacy Act. OAIC will in many cases only investigate once
OFX has been given the opportunity to resolve your complaint internally. You may
lodge your complaint with OAIC by sending the necessary documents and
information to:

Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Website: http://www.oaic.gov.au
Telephone: 1300 363 992
Facsimile: (02) 9284 9666
Email: enquiries@oaic.gov.au

Statement of Notifiable Matters – Credit Reporting

Credit reporting bodies are permitted to handle Personal Information relating to
credit. Credit reporting bodies may include your Personal Information disclosed
by OFX in reports provided to other credit providers to assist them to assess
your creditworthiness.

Details on the kinds of credit information OFX collects, uses, holds and the
purposes for which OFX discloses credit information is contained within the main
body of this Privacy Policy and as such, OFX’s credit reporting policy is set
out within this Privacy Policy.

OFX may collect information about you that it has obtained from businesses that
provide information about the credit worthiness of individuals, including
consumer credit reports from a credit reporting body. Applicable laws and
regulations outline what OFX can do with the information we obtain from a credit
reporting body. If you fail to meet your payment obligations in relation to the
payment services OFX provides to you, if you commit fraud or try to do so, or if
you otherwise commit a serious credit infringement, OFX may disclose your
Personal Information to those credit reporting bodies.

You have a right to access the credit related information that OFX holds about
you, to correct that credit related information and to make a complaint about
OFX’s handling of your credit related information, as set out in section 8
(Choices and Transparency) of this Policy.

The credit reporting bodies that OFX may deal with are:

CreditorWatch – https://creditorwatch.com.au/

illion – https://www.illion.com.au/

Contact details as well as information on how the credit reporting bodies manage
credit related Personal Information is available via the above links. You may
obtain a copy of the credit reporting bodies’ credit reporting policy by
contacting them directly.

You also have a right to request that credit reporting bodies do not use credit
related information held by them for the purposes of pre-screening of any direct
marketing by credit providers. If you would like to make such a request, please
contact the credit reporting bodies directly.

If you believe that you have been a victim of fraud, you have a right to contact
the credit reporting bodies and ask them not to use or disclose your credit
related information. Please contact the credit reporting bodies directly.

Additional Information for Residents of Canada

If you are not satisfied with the resolution of any complaint you make with us
concerning your privacy, you may submit a complaint to the Privacy Commissioner
in your province of residence or to the Office of the Privacy Commissioner of
Canada at:

Office of the Privacy Commissioner of Canada
30 Victoria Street, 1st Floor
Gatineau, QC K1A 1H3
1-800-282-1376
https://www.priv.gc.ca

Additional Information for EEA and UK Residents

Lawful processing

If you are an individual in the UK or European Economic Area (EEA), we collect
and process information about you only where we have legal bases for doing so
under the General Data Protection Regulation (GDPR) in the EEA and the Data
Protection Act, 2018 in the UK. The legal bases depend on the OFX services you
use and how you use them. This means we collect and use your information only
where:

 * We need it to provide you our services, including to operate our services,
   provide customer support and personalised features and to protect the safety
   and security of our services;
 * It satisfies a legitimate interest (which is not overridden by your data
   protection interests), such as to market and promote our services and to
   protect our legal rights and interests;
 * You give us consent to do so for a specific purpose; or
 * We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific
purpose, you have the right to change your mind at any time, but this will not
affect any processing that has already taken place. Where we are using your
information because we or a third party have a legitimate interest to do so, you
have the right to object to that use though, in some cases, this may mean no
longer using our services.

Your rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal
information.

Your right to rectification – You have the right to ask us to rectify personal
information you think is inaccurate or is incomplete.

Your right to erasure – You have the right to ask us to erase your personal
information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to
restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the
processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the
personal information you gave us to another organisation, or to you, in certain
circumstances.

Please contact us at privacy@ofx.com if you wish to make a request. If you make
a request, we have one month to respond to you.

Transfers to third countries

The Personal Information that we collect from you may be transferred to and
stored outside of your country of residence, including outside of the UK (for UK
residents) and outside of the EEA (for EEA residents). To facilitate our global
operations, we transfer information to and allow access by staff in countries in
which OFX owned companies have operations for the provision of our services.
Such staff are likely to be involved in, among other things, processing your
transaction or payment details and providing support services. We also share
information with third parties as described in this Policy. For example, this
may involve information being transferred to a banking partner in a country
where you have instructed us to send a payment.

Where we share information with an organisation outside of the UK or the EEA, we
will take all reasonable steps to ensure that they apply equivalent levels of
protection as we are required to provide, including the use of standard
contractual data protection clauses which have been approved by the European
Commission. If this is not possible, for example, we are required by law to
disclose your information, we will make sure that sharing the information is
lawful.

Additional Information for Residents of New Zealand

If we transfer your Personal Information outside New Zealand, we will ensure the
intended recipient is subject to privacy laws that provide comparable safeguards
to the Privacy Act 1993, is covered by a binding scheme or is subject to the
privacy laws of a country prescribed by the New Zealand Government or has agreed
to adequately protect the information. Alternatively, we will obtain your
explicit consent for the transfer.

Additional Information for U.S. Residents

If you are a U.S. resident using our services to conduct transactions for
personal, family or other household purposes, please also review our Consumer
Privacy Notice, which provides additional information about our privacy
practices and a description of your rights as a consumer to control how your
Personal Information is handled.

Additional Information for California Residents

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), we are providing
the following additional details regarding the categories of Personal
Information that we collect, use, and disclose about California residents. This
section does not apply to our job applicants, employees, contractors, owners,
directors, or officers where the Personal Information we collect about those
individuals relates to their current, former, or potential role with us. Under
the CCPA, “Personal Information” is information that identifies, relates to, or
could reasonably be linked with a particular California resident or household.

The following chart details which categories of Personal Information about
California residents we plan to collect, as well as which categories of Personal
Information we have collected and disclosed for our operational business
purposes in the preceding 12 months. We collect this Personal Information from
you and from other categories of sources, as described above, under “How We
Collect Information.” We do not sell and have not sold Personal Information in
the preceding 12 months, as “sale” is defined in the CCPA, and we do not sell
the Personal Information of minors under the age of 16.

Category of Personal InformationDisclosed to Which Categories of Third
PartiesIdentifiers, such as name, contact information, IP address and other
online identifiers.Corporate affiliates; service providers; authorised third
parties when you provide consent; government authoritiesPersonal Information, as
defined in the California customer records law, such as name, contact
information, and payment information.Corporate affiliates; service providers;
authorised third parties when you provide consent; government
authoritiesCharacteristics of protected classifications under California or
federal law, such as age, gender, marital status, national origin,
citizenship.Corporate affiliates; service providersCommercial information, such
as transaction information and purchase history.Corporate affiliates; service
providers; authorised third parties when you provide consent; third-party
acquirersBiometric information, such as face imagery, for fraud prevention
purposes.service providersInternet or network activity information, such as
browsing history and interactions with our website.Corporate affiliates; service
providersGeolocation data, such as device location and approximate location
derived from IP addressCorporate affiliates; Service providersAudio, electronic,
visual, and similar information, such as call and video recordings.Corporate
affiliates; Service providersProfessional or employment-related information,
such as work history and employer.Corporate affiliates; Service
providersInferences drawn from any of the Personal Information listed above to
create a profile about, for example, an individual’s preferences and
characteristics.Corporate affiliates; Service providers

We use this Personal Information to operate, manage, and maintain our business,
to provide our products and services, and to accomplish our business purposes
and objectives, including as described above, under “How We Use Your
Information.”

If you are a California resident, you may request that we:

(1) Disclose to you the following information covering the 12 months preceding
your request:

 * The categories of Personal Information we collected about you and the
   categories of sources from which we collected such Personal Information;
 * The specific pieces of Personal Information we collected about you;
 * The business or commercial purpose for collecting Personal Information about
   you; and
 * The categories of Personal Information about you that we otherwise shared or
   disclosed, and the categories of third parties with whom we shared or to whom
   we disclosed such Personal Information (if applicable).

(2) Delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please
contact us at privacy@ofx.com or 1-888-288-7354. We will verify and respond to
your request, taking into account the type and sensitivity of the Personal
Information subject to the request. We may need to request additional Personal
Information from you, such as email address, residential address, mailing
address, date of birth and or mobile phone number in order to verify your
identity and protect against fraudulent requests.

If you maintain a password-protected account with us, we may verify your
identity through our existing authentication practices for your account and
require you to re-authenticate yourself before disclosing or deleting your
Personal Information. If you make a deletion request, we may ask you to verify
your request before we delete your Personal Information. Please note that
certain Personal Information is not subject to CCPA requests, such as Personal
Information we collect that it is subject to the Gramm-Leach-Bliley Act.

You have the right to be free from unlawful discrimination for exercising your
rights under the CCPA.

If you want to make a request as an authorised agent on behalf of a California
resident, you may use the submission methods noted above. As part of our
verification process, we may request that you provide, as applicable:

 * Proof of your registration with the California Secretary of State to conduct
   business in California;
 * A power of attorney from the California resident pursuant to Probate Code
   sections 4121-4130;

If you are making a request on behalf of a California resident and have not
provided us with a power of attorney from the resident pursuant to Probate Code
sections 4121-4130, we may also require the resident to:

 * Provide you with a written permission signed by the resident to make the
   request on the resident’s behalf;
 * Verify the resident’s own identity directly with us;
 * Directly confirm with us that the resident provided you permission to submit
   the request.

Under California law, California residents have the right to request the contact
information of third parties with whom we have shared certain categories of your
Personal Information for those third parties’ direct marketing purposes, as well
as the categories of Personal Information shared for such purposes. Please note
that these categories of Personal Information do not include the Personal
Information covered under our Consumer Privacy Notice. If you are a California
resident and would like to request this information, please contact us
at privacy@ofx.com.

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©2022 OFX Payments Ireland Limited. OFX Payments Ireland Limited trading as OFX
is regulated by the Central Bank of Ireland (Firm Ref. No. C190174). Our
registered office address is Fitzwilliam Court, 2 Leeson Close, Dublin 2, D02
YW24, Ireland.
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