1. About this Privacy Policy

1.1 PayGroup Limited ACN 620 435 038 (referred to as PayGroup, we, us or our) has implemented this Privacy Policy to provide information about what             kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our           use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy           Policy, you should contact our Privacy Officer in any of the ways specified in paragraph 15.

1.2 PayGroup is related to other companies and entities (related entities). This Privacy Policy applies to the collection and use of your Personal Information           in respect of our Australian business operations only, whether such collection or use is by us or by those related entities. Those related entities may also         have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are                   inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities in                     respect of our Australian business operations. A reference in this Privacy Policy to PayGroup, we, us or our is also a reference to those related entities.

2. Personal Information

2.1 “Personal Information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual           or an individual who is reasonably identifiable.

3. What Personal Information do we collect and hold?

3.1 The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information               that we collect may include (but is not limited to) the following: 

      (a) name
      (b) age and/or date of birth
      (c) contact details including telephone numbers (landline and/or mobile)
      (d) current and previous address (including postal address)
      (e) email address
      (f) gender
      (g) identification information such as driving licence details, including driving licence number
      (h) payment details, such as bank account details
      (i) information about our employees, and our client’s employees, including tax file numbers, social security numbers and similar information
      (j) payroll data including information about our clients’ employees such as taxation, salary, allowances, leave, deductions and general benefits                               (superannuation or the equivalent)
      (k) occupation and employment details including employment status and any previous work experience
      (l) information from or in connection with your resume or job application if you apply for a position with us, and
      (m) Australian Business Number (ABN).

3.2 We collect and record Personal Information about individuals such as:

      (a) our clients, potential clients and their representatives
      (b) our clients’ employees and staff
      (c) our investors and shareholders
      (d) our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders
      (e) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to               us
      (f) our employees past and present, including applicants, and
      (g) any other person who comes into contact with PayGroup.

3.3 We are authorised to collect tax file numbers (TFNs) by the Income Tax Assessment Act 1936 (Cth). It is not compulsory for you to provide your TFN for         our products and services, but if you do not, taxation law may require additional deductions to be made from amounts payable to you.

4. How and when do we collect Personal Information?

4.1 We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the               specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law, including but not                   limited to laws related to the accurate processing of payroll information.

4.2 We may collect your Personal Information in the course of providing you with goods or services, or:

      (a) when your employer gives us your information to process its payroll information or to conduct other functions on their behalf
      (b) when you use or buy our products or services
      (c) when you provide us, or you offer or apply to supply us, with goods or services
      (d) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a                business card)
      (e) when you request information about us, our products or our services
      (f) when you provide feedback to us
      (g) when you visit or fill in a form on our Website (see paragraph 5)
      (h) when you register for or use an account on our Website
      (i) when you visit premises from which we operate
      (j) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are                   carrying out activities in connection with our operations
      (k) when you submit a job application to us
      (l) when you otherwise contact us by telephone, fax, email, social media, post or in person, or
      (m) where we are otherwise required or authorised by law to do so.

4.3 Generally, except in relation to our payroll services or other services we provide on behalf of your employer, when providing our products and services,           dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect personal information directly         from the relevant individual where reasonable and practicable.

4.4 We may also collect Personal Information about you from third parties and other sources such as:

      (a) your employer
      (b) your nominated representatives (eg spouse accountant, power of attorney, brokers and other professional advisors)
      (c) our share registry service provider
      (d) publicly available sources of information, or
      (e) related entities, companies and businesses of PayGroup,
            but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if                  we are otherwise permitted to do so.

4.5 From time to time, the Personal Information we collect may include sensitive information, including health information. We will ask for your consent to             collect sensitive information unless the law allows us to collect it without your consent.

4.6 Where we engage with you multiple times over a short period in relation to the same matter, we might not provide you with a separate notice about               privacy each time we engage with you.

4.7 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the              Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our                    relationship with you.

5. Information collected via our Website

5.1 Personal information may be collected by us and by our third party service providers who assist us in operating our websites at:

      (a) http://www.PayGrouplimited.com
      (b) http://www.payasia.asia
            including their subdomains and any other website we operate from time to time (collectively the Website).

5.2 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not                     limited to the methods set out in this paragraph 5.

Click Stream Data

5.3 When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date,             time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded.

Cookies

5.4 Our Website(s) may use ‘cookies’ from time to time. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the           purpose of storing information about a user’s identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web             traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We may use this information to         enhance the content and services offered on our Website.

5.5 Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or           click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer’s hard drive.

5.6 Cookies may also be used for other purposes on our Website.

5.7 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help”         menu of your browser to learn how to change your cookie preferences.

5.8 If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to           gain access to all of the content and facilities in those websites.

Third party content (eg social media links)

5.9 Some of the content on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share           content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of                       information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are             not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant         third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal                 Information.

6. How do we use your Personal Information?

6.1 We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to                     market our products and services for the benefit of our clients.

6.2 We may collect, hold and use your personal information:

      (a) to identify and communicate with you
      (b) to enable us to provide you with requested information, products or services
      (c)  to undertake payroll processing and other services including outsourced business functions on behalf of our clients
      (d)  to otherwise assist clients by providing them with information and support
      (e)  to collect and process payments
      (f)   to help us to manage and enhance products or services we provide to you
      (g)  to help us to manage and enhance goods and services we procure from our suppliers and subcontractors
      (h)  to help us manage and respond to a general or specific shareholder enquiry
      (i)   to process share applications and service shareholders’ needs
      (j)   to provide facilities and services a shareholder may request
      (k)  to carry out appropriate administration in relation to our shareholders and our share registry
      (l)   to personalise and customise your experiences on our Website
      (m) to manage and administer any account you may hold with us
      (n)  to promote and market our products and services to you
      (o)  to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material,                   regarding us, our clients, and our business partners
      (p)  to conduct research for the purposes of improving existing products or services or creating new products or services
      (q)  to help us research the needs of our clients to enable us to market our products and services with a better understanding of your needs and the                       needs of clients generally
      (r)   to analyse our shareholder base and for product development and planning
      (s)  to provide for the safety and security of workers and onsite visitors
      (t)  to help us manage our business operations
      (u)  for business support purposes including maintenance, backup and audit
      (v)  to process any job application submitted by you
      (w) to respond to any queries or complaints you may have, or
      (x)  to comply with our statutory and legal obligations.

6.3 We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no             obligation to monitor the use of the Website or to retain the content of any user session.

6.4 You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.

6.5 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

      (a) in accordance with this Privacy Policy or any agreement you enter into with us, or
      (b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

7. When do we disclose your Personal Information?

7.1 PayGroup may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6.                    Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third          parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you            have submitted).

7.2 We may also disclose your Personal Information to:

      (a) your employer (and its related companies if required) on whose behalf we undertake any activities and provide our services
      (b) any of PayGroup’s internal divisions, business units or departments
      (c) your nominated representatives
      (d) other organisations or individuals who assist us in providing products and services to you
      (e) professional service providers and advisors who perform functions on our behalf, such as lawyers, accounting firms, auditors, management                                consultants, lodgement service providers and benefit processing providers
      (f) medical providers including medical and rehabilitation practitioners for assessing insurance claims
      (g) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or             administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development), and
      (h) Government, regulatory authorities and other organisations as required or authorised by law (such as Centrelink, the Australian Taxation Office, and                any other government authorities for the purposes of statutory submissions relating to an individual’s employment).

7.3 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example                 when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

7.4 We may also disclose your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of PayGroup, our                 business or any of our assets, including in insolvency, in circumstances which require the purchaser or potential purchaser to use such Personal                         Information consistently with this Privacy Policy.

8. Overseas disclosures

8.1 Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may         happen if:

      (a) our offices or related entities are overseas
      (b) we outsource certain activities overseas
      (c) transactions, information, services or products have an overseas connection, or
      (d) our computer systems including IT servers are located overseas.

8.2 You consent to the collection, use, storage, and processing of your Personal Information both interstate within, and outside of, Australia as set out in this         Privacy Policy.

8.3 In particular, your Personal Information may be disclosed to third parties in Singapore, India, Malaysia, Hong Kong and the Philippines, and such other             countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in         this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries,               without us being responsible under the Australian Privacy Act 1988 (Cth) for such use (or for any breach). Where such parties are located overseas, you         may have rights to enforce such parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under           the Australian Privacy Act in relation to how those parties treat your personal information.

9. Other uses and disclosures

9.1 We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you         at the time we collect or use your Personal Information.

10. Marketing

10.1 You consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services,             as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such                             information by means of social media, direct mail, telemarketing, email, SMS and MMS messages

10.2 If you do not want to receive marketing information from us or if you want to stop receiving telemarketing, you can unsubscribe in any of the following             ways:

      (a) clicking on the ‘Unsubscribe’ or subscription preferences link in a direct marketing email that you have received from us
      (b) logging into your account on the Website and editing your communication preferences, or
      (c) contacting us using the contact details specified in paragraph 15.

11. Storage and security of Personal Information held by us

11.1 We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems           is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.

11.2 If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and                   destroy all record of it.

12. You can access and update your Personal Information

12.1 You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary                       circumstances we will give you full access to your Personal Information. Depending on the nature of the request, PayGroup may charge for providing              access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If              we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give                   those reasons.

12.2 You can access and correct some of your Personal Information through the Website by logging into your account and updating or editing your profile               at any time. If you are an employee of a client, you may also contact your employer to request access to, or to correct, your Personal Information that               we hold about you and process on their behalf. Alternatively, a request for access can be made by contacting our Privacy Officer in any of the ways                  specified in paragraph 15.

12.3 We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you            need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to                keep it true, accurate, current and complete.

12.4 Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and            we will use all reasonable efforts to correct the information.

12.5 It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include            as much detail as possible.

13. How do we deal with complaints about privacy?

13.1 If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our                   Privacy Officer in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate your queries and privacy complaints           within a reasonable period of time depending on the complexity of the complaint.

13.2 It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

13.3 We will notify you of the outcome of our investigation.

14. Updates to this Privacy Policy

14.1 We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All               Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at:                                                                                 http://www.PayGrouplimited.com/privacy-policy. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We             encourage you to check this page from time to time for any changes.

15. What to do if you have a question, problem or want to contact us about our use of your Personal Information or this Privacy Policy

15.1 If you:

      (a) have a query or concern about this Privacy Policy or our Personal Information handling processes
      (b) wish to make a complaint in relation to a breach of your privacy
      (c) would like to access your Personal Information held by us
      (d) would like to update or correct your Personal Information held by us, or
      (e) would like to opt out of direct marketing,

      please contact our Privacy Officer in any of the following ways:

» Mailing Address: Level 1 325 Flinders Lane, Melbourne VIC 3000, Australia

This Privacy Policy was last updated on 6 October 2021.