Effective Date 03 Jul 2024
In this policy, HFCEX PTY LTD (T/A Currency Key) is referred to as “Currency Key”, “we”, “our”, or “us”.
“Personal information” in this Policy refers to any information or opinion about an identified individual or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not the information or opinion is recorded in a material form.
Currency Key recognises the importance of preserving and protecting the personal information of its clients/customers using Currency Key services as defined below. We respect and are committed to safeguarding the privacy and confidentiality of our customer’s Personal Information. We are bound by the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (the Act), both of which are available for viewing on www.oaic.gov.au and www.comlaw.gov.au, respectively.
The below privacy policy and its purpose is to explain the basis on which any of your Personal Information is collected, used, maintained and disclosed. Please read this Privacy Policy carefully. By proceeding to use any of Currency Key Services, you confirm that you have read, understood and agree to this Privacy Policy.
Currency Key will generally collect Personal Information directly from you when you deal with us and use our services either in person, online, by telephone, email, Currency Key mobile app or via our website. We may also collect your data and information to provide feedback for improvement and development. The following are Personal Information that Currency Key may collect:
Your full name, home and billing address, date of birth, Government-issued identification documents (i.e. passport, driving licence), gender, telephone number, employment information, and nationality;
Financial account details such as Debit/Credit Card number, Bank Account details (Bank Name, Branch and Bank Account Number, and any other information as required by us for significant transactions and to complete your transaction;
Reports and other customer Personal Information that Currency Key may receive from third-party agencies;
All mandatory data and information where Currency Key is required to comply with the Anti Money Laundering and Counter-Terrorism Financing Act 2006, AML/CTF Rules, laws and other regulatory requirements, including information needed for identification purposes and to prevent fraud, crime and illegal activities.
Currency Key may only be able to provide the requested product or service if you agree or consent to allow us to collect or obtain certain Personal Information about you.
Currency Key will assume that you have consented or agreed to the collection of all data and information you provided to us for use per this Privacy Policy unless you expressly inform us or tell us otherwise.
We collect your personal information for both our internal purposes and on behalf of the parties for whom we act as agents. Therefore, by consenting to this Privacy Policy, you also consent to your Personal Information being used by us or provided to and used equally by the parties whose products and services we sell.
If you have any questions about any person or entity for whom we act as agent, you may email us at info@currencykey.com.au.
Currency Key may use and disclose your Personal Information for the purposes for which it was collected or for a related purpose, including but not limited to the following purposes:
- Identifying, verifying, and determining the eligibility of you using our services and dealing with us;
– Collecting payment, processing and fulfilling your order and any tracking services as may be available;
– Contacting you with respect to your order for any updates or other issues − Reporting and complying with our legal and regulatory obligations (including fraud prevention, anti-money laundering screening and other criminal activities); − Our internal database, accounting, and administration;
– Seeking feedback from you as our customer.
We may disclose the Personal Information of current and former customers to the following persons or entities and/or for the following purposes:
– to trusted Currency Key business partners that perform services on Currency Key’s behalf under written agreements which will contain restrictions on the use of customers’ Personal Information for the limited purposes for which it is provided to them and to refrain from further use or disclosure unless permitted by law;
– to our affiliates who are permitted to disclose and use the Personal Information only to the extent that we may disclose and use the Personal Information under this Policy; − to
Currency Key’s professional advisors include lawyers, accountants, auditors and consultants;
– to our Information Technology systems affiliates, including our web, network, and data entry service providers;
– to prevent or protect against actual or potential fraud, suspicious transactions, unauthorised transactions, claims or other liabilities as permitted by law; − to various government/regulatory or law enforcement agencies/authorities to the extent permitted or required by law, or to comply our legal and regulatory obligations according to law;
– to comply with legal investigation properly undertaken by enforcement and regulatory bodies, the judicial process or other law enforcement authorities;
– in connection with any acquisition or divestment of assets by Currency Key.
Please note that your Personal Information may be transferred across national borders and overseas to process your transaction, consolidate data, store data, and manage data.
Currency Key will not use, disclose, sell, or lease customer Personal Information to any third-party agencies except as stated in this Policy.
The security of your personal and account information is our top priority. We implement numerous security measures to ensure that we offer you a service that is not only secure but also trustworthy.
Identity Protection:
We carefully collect accurate information to safeguard against identity theft and fraud. Passwords, multi-factor authentication (MFA), security questions, and automatic timeouts are utilized to enhance the security of your account.
Fraud Prevention:
We monitor registrations, logins, and transactions to identify suspicious activities. Our fraud prevention system utilizes a multi-layered approach to detect and prevent fraud, such as phishing, malware, and fraudulent applications that may compromise our products and customers.
Cyber Security:
Our commitment to identifying and mitigating security risks is unwavering. We adhere to the strictest international standards with our security framework, and we are dedicated to the constant enhancement of our security practices.
Currency Key will only retain your personal information on our internal database for as long as it is required to provide you with the products and services you ordered and comply with our legal obligations.
To comply with the Anti-Money Laundering and Counter-terrorism Financing Act 2006 and its associated rules and regulations, Currency Key must retain our customers' Personal Information for seven (7) years. We will destroy your Personal Information after this period.
We periodically ask customers who are dealing with us to ensure the accuracy of their Personal Information that is retained with us and will seek to update any changed Personal Information that you inform us about at the earliest opportunity during your dealing with us. If you do not have ongoing dealings with us, you can still change your Personal Information in accordance with this Privacy Statement.
If you require access to the personal information that we hold about you, you may contact us at any time by forwarding a request to our compliance officer through email.
compliance@currencykey.com.au
You may also request that a correction or update of your Personal Information be made with respect to your Personal Information currently held by Currency Key. We will take appropriate actions to process your request, amend the relevant information, and inform you about the
correction. If required by the Act, we will also inform any third party to whom the information has been disclosed about this updated, corrected or amended information.
Currency Key will respond to your request for access to your Personal Information within a reasonable period and no later than 30 days after the request is made. We shall give access to your Personal Information in the manner requested by you, if it is reasonable and practicable to do so, or otherwise, the requested Personal Information will be mailed or emailed to you.
Exceptions to Access and Correction of Information
Several circumstances may preclude Currency Key from granting you access to all of your Personal Information, including any request to correct your Personal Information. They include but may not be limited to the following:
Currency Key is prohibited by law to provide you with such access or, alternatively, denying you access is required (or authorised) by or under an Australian law or by way of a court/tribunal order that has been produced to Currency Key;
Currency Key reasonably believes that giving you access would pose a severe threat to the life, health or safety of any other individual or to public health or public safety; − the provision of information would have an unreasonable impact on the privacy of other individuals (s);
The request for access is frivolous or vexatious;
Currency Key has a reason or reasons to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions, activities, service and or website has been, is being or may be engaged in and giving access would likely prejudice the taking of appropriate action concerning the matter; and
Giving access would likely prejudice one or more enforcement-related activities conducted by, or on behalf of, an enforcement body/authority.
In any situation where your request has been refused, you will receive a written notification letter from us setting out our reasons and decisions, which will also outline the relevant process for you to follow to file a complaint about our refusal.
Cookies are small text files placed on your computer, phone or tablet by websites or sometimes by emails. We may use cookies to analyse and gather essential data and information for the purpose of improving our website and services.
Currency Key cannot use cookies to access your computer or any information about you. Most web browsers are automatically configured to accept cookies; however, you can modify your browser settings to decline cookies if you prefer.
Please note and remember that disabling cookies may limit or prevent your access to any part or the full range of services available on our website.
You should also note other websites that we may link or refer you to may also use cookies, over which we have no control. You should check the privacy policies of those other websites to find out how they manage cookies.
Our website may provide links to other websites for customer convenience and information. We do not endorse or make any representations about the information contained on their website. Please note that if you follow a link to any of these other websites, they will have their own privacy policy. We are not responsible for the privacy policy and practices or the content of such websites and cannot accept liability or responsibility for such policies and practices. It is advisable and your own responsibility to review these privacy policies before submitting your Personal Information to any of these other websites.
We reserve the right to amend, change or update our Privacy Policy at any time without prior notice. Updates or amendments to our Privacy Policy will be posted on our website immediately. It is your obligation to check your Privacy Policy from time to time to take notice of any changes we have made. By providing us with your Personal Information and continuing to use our Currency Key services, you will be deemed to have accepted these changes.
If you suspect that Currency Key may not have adhered to the Australian Privacy Principles, or if there's an aspect of GDPR you believe we've overlooked, we invite you to reach out with your concerns. Your detailed account of the situation will enable us to conduct an extensive internal investigation.
Currency Key is committed to upholding the highest standards of practice. Upon receiving your complaint, we will acknowledge it promptly, understand the circumstances, and strive for a resolution that aligns with both your expectations and our regulatory obligations.
Your complaint will be logged, and we will keep you informed of our progress. We aspire to resolve all matters within a span of 30 business days.
If you believe that you have grounds for a complaint, contact us immediately via email at admin@currencykey.com.au or call us at +613090886655. If you choose to call us, we will also require a written account of your complaint to ensure we can address it effectively.
After documenting your details, our Compliance Officer will lead an in-depth internal review. You will be updated on developments throughout the process, and the final outcome will be communicated within 30 business days.
If you're not satisfied with the outcome of our internal investigation, the Financial Ombudsman Service (FOS) is available. This independent entity addresses disputes related to the financial sector, considering matters such as privacy disputes connected to credit provision, debt collection and credit reporting.
The FOS can be contacted by dialling 1300 780 808, visiting www.fos.org.au, or by post at Financial Ombudsman Service Limited, GPO Box 3, Melbourne VIC, 3001.
Additionally, the Office of the Australian Information Commissioner (OAIC) is available for consultation regarding how we manage your personal data. You can reach the OAIC at 1300 363 992, online at www.oaic.gov.au, or by mailing your concerns to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.
This policy is crafted with a commitment to transparency and the importance we place on your privacy and will be revisited regularly to ensure it reflects the best practices and legal requirements.
HFCEX PTY LTD (T/A as CURRENCY KEY)
Level 8 90 Collins Street Melbourne VIC 3000 Australia
0390886655
Currency Key values its customers’ comments or opinions about this Privacy Policy. Should you have any queries or comments, please email us at admin@currencykey.com.au
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