Privacy Policy

Introduction

You have come through to this page from a website or app which is published by Paylab Pty Ltd (ACN 650 927 325) of Suite 601, 153 Walker Street, North Sydney, NSW 2060 (Paylab) or one of its subsidiaries or related bodies corporate.

In this Privacy Policy, Paylab, us, we or our means Paylab Pty Ltd (ACN 650 927 325) and/or its subsidiaries and/or related bodies corporate.  Paylab is the operator of the Paylab Platform (which includes our websites and apps) and the data processor and data controller for the Personal Information collected and processed via the Paylab Platform.

This Policy explains how we collect, use, hold and disclose your Personal Information. We obtain this from you through our website, app, any social media page we maintain, and when you reach out to us directly such as by email.  We also obtain certain of your Personal Information from your employer’s payroll records directly (as authorised by you in our terms and conditions of use). We have also supplied additional information about our company. 

By accessing our websites, apps or using our services, you consent to the terms of this Privacy Policy, including consent to us collecting, holding, using and disclosing your Personal Information for the purposes set out in this Policy, and you agree to be bound by it. Whether you are new to Paylab or the Paylab Platform or a long-time user, please take the time to get to know our privacy practices.

About us and how to contact us
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) (subject to exemptions that apply to us under that Act) and any other applicable data protection laws.  This Privacy Policy does not limit or exclude any rights that you have or may have under the Privacy Act.

You can contact our Privacy Officer at:

Privacy Officer
Paylab Pty Ltd
Suite 501, Level 5, 153 Walker Street
North Sydney NSW 2060
Email: privacy@paylab.com.au

Our Privacy Collection Statement
Under the Privacy Act, we are required to make you aware of certain matters. This Policy incorporates our Privacy Collection Statement, as it addresses all these matters:

• our identity and contact details;
• the facts and circumstances, and the purposes, of collection of Personal Information;
• the consequences for you if Personal Information is not collected;
• other entities, bodies or persons to which Personal Information is usually disclosed;
• information about access and correction of, and how you may complain about the way we handle, your Personal Information; and
• likely cross-border disclosures of Personal Information.

What is Personal Information
When used in this Privacy Policy, the term “Personal Information” has the meaning given to it in the Privacy Act or any other applicable data protection law. In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your income, credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.

What Personal Information do we collect and hold
We may collect and hold a range of Personal Information from or about you, where the information is reasonably necessary for our business purpose, including to validate and authenticate you, connect to your company’s payroll system to retrieve the payroll information needed to operate the Paylab app payment system, and generally to provide the Paylab Platform to you, such information to include:

• first and last name;
• business and/or residential address including address, state, postcode, city or suburb, country;
• email address;
• telephone number;
• age;
• employment and salary details;
• bank account details into which your salary is paid;
• updates about when you have earned your salary;
• details of your withdrawals on the Paylab app;
• information about your device location and identity;
• other information that you provide us in relation to your profile;
• information received from surveys you complete;
• information about your interactions with us;
• information about the services which you have enquired about, together with any additional information necessary to deliver those services or to respond to your enquiries;
• information relating to you that you provide to us directly through the Paylab Platform or social media page that we maintain, or indirectly through use of the Paylab Platform or online presence through our representatives or otherwise; and/or
• other Personal Information we may require from time to time to manage your business relationship with us.

Cookies and Usage Data
When you visit our website or use our app, we may also collect information about your use of those websites or apps (Usage Data) through the use of a technology known as “cookies” and other tracking software. 

This Usage Data may include information such as your computer’s Internet Protocol Address (I.P Address), mobile device unique identifiers, other unique device identifiers, browser software version and type, the pages and/or functions within the Paylab Platform that you visit and/or access, the date and time of your visit and/or access, the time you spend on those pages and/or functions and other diagnostic data to support your usage and our operation of the Paylab Platform.

This Usage Data enables us to provide you with an improved and more effective and personalised service, keep track of the services you use, analyse trends, measure transaction and search patterns, administer our platform and websites, diagnose problems, test and improve the quality of our services, gather broad demographic information and enable us to conduct targeted online advertising and aggregate data to produce analytics and insights that support our users and customers use of the Paylab Platform.  

You can manage the use of cookies on your computer or mobile device. If you do not wish to receive cookies you can set your browser so that your computer or device does not accept them.  You can also clear stored cookies from that browser or device at any time. Please note however that blocking cookies may affect your browsing experience and result in our services not operating as efficiently or effectively as they could.

The usage data we collect and use in cookies is generally not of itself personally identifiable information but if it is linked to Personal Information about an individual, it may become personally identifiable usage data.  In those circumstances we will treat that usage data as Personal Information and only use it in accordance with our Privacy Policy, the Privacy Act and any other applicable data protection legislation.

Location Data
We may capture, store and use information about your location if you give us permission to do so (“Location Data”). We use Location Data to support and provide features on the Paylab Platform to ensure a contextually relevant experience for users.

You can enable or disable location services when you use the Paylab Platform at any time by way of your device settings.

Analytics Data
We may use third party services to monitor and analyse the use of the Paylab Platform.  In using the Paylab Platform you understand that these third-party services are collecting information about your usage of the Paylab Platform. 

How we collect Personal Information
Generally we collect your Personal Information directly from you unless it is unreasonable or impractical to do so. We do this in ways including:

• when you engage with us to use our services;
• create or register as a user;
• when you log in to use our App or website via your social networking site account;
• when you contact or request information from us including via our websites, apps, online forms, surveys and emails;
• posting or contributing material or content on the Paylab Platform ;
• through your conversations with our staff and our representatives;  
• when you make an enquiry, request to book a visit or tour or make an application; and/or
• when you write to us including via hard copy forms.

We will also collect your Personal Information through direct integration with your employer’s payroll system through which it may confirm your employment, confirm your authority to use the Paylab app in connection with your employer, and receive updates about your salary and salary deductions.  

We may also collect Personal Information from third parties including:

• our service providers;
• third party companies or agencies, other referral partners (such as those who refer your business to us) or government entities;
• from the organisations and entities identified under the “How we disclose your Personal Information” section below, including our related entities;
• from publicly available sources of information;
• advertisers;
• contractors and business partners;
• through someone else who has provided us with your information; and/or
• when legally required to do so.

Why do we collect, hold, use and disclose Personal Information
We collect, hold, use and disclose your Personal Information for the purpose for which it has been provided, for reasonably related secondary purposes, for other purposes for which you have consented, and for other purposes permitted under the Privacy Act.  This may include using your Personal Information for the following purposes:

• to enable you to access and use the Paylab App or our other services;
• for identity verification purposes, which may involve the use of third party systems, and matching information against government or official identification sources;
• to service your Paylab app product, give you notices, and give you service information;
• to provide services to you and deliver the best possible quality of customer experience on the Paylab Platform (such as by gaining an understanding of your needs);
• to provide you with a more targeted experience and match your requirements and provide your details to relevant service providers to meet your needs;
• to provide you with news, information or advice about our existing and new services, including for marketing (see the “Marketing” section below);
• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to communicate with you, including but not limited to, by email, mail, SMS or telephone;
• to manage and enhance our services (such as for research and development);
• to personalise and customise your experience;
• to provide as part of statistics, insights or business data to third parties or to use internally in our business;
• to conduct business processing functions for operation of our website, our app or our business;
• to manage our business relationship with you;
• for our administrative, promotional, planning, service development, quality control and research purposes, or those of our contractors, external service providers or business partners;
• to provide your updated Personal Information to us, our contractors, external service providers or business partners;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
• for any other purpose you have consented to or as otherwise required or permitted by any law (including the Privacy Act).

You authorise us to disclose Personal Information to any of our Related Bodies Corporate for the purposes set out above. 

Marketing
We may collect, hold, use and disclose your Personal Information to send you marketing communications that you may find of interest about our services as well as informative articles, promotions, offers, information about changes to our business as well as information on products or services being offered by third parties including Business Partners and Advertisers. 

By providing us with your Personal Information, you consent to us using your information to contact you on an ongoing basis for these purposes. We may do this through mail, phone, SMS, social media, email, app notifications and advertising through our app, website or third party websites.

You can contact us at any time to opt-out from receiving direct marketing communications from us by contacting us directly (see “how to contact us”), by following the unsubscribe instructions in the relevant communication or by updating your personal details on your account profile. We do not provide your Personal Information to other organisations for the purpose of direct marketing unless expressly authorised by you.

Please note that unsubscribing does not stop in-app notifications about applications that are essential to fulfilling any requests which were made via the Paylab Platform.

If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.

Your Personal Information will not be shared or disclosed other than as described in this Privacy Policy.

What happens if we can’t collect your Personal Information
The provision of your Personal Information may be necessary to receive our services as requested by you. If you choose not to provide us with the certain Personal Information described in this Privacy Policy, some or all of the following may happen:

• we may not be able to provide you with the services you requested, either to the same standard, or at all;
• we may not be able to continue our business relationship with you;
• we may not be able to provide you with information about services that you may want; or
• we may be unable to tailor the content of the Paylab Platform to your preferences and your experience of the Paylab Platform may not be as enjoyable or useful.

How we disclose your Personal Information
We may disclose your Personal Information to a number of third parties in the course of operating our business and for one or more of the above purposes or related purposes. These parties include:

• our employees or related bodies corporate to the extent that is reasonably necessary to provide access to and operation of the Paylab Platform to fulfill the services we provide to you;
• our external service providers including without limitation web hosting providers, advertisers, stationary printing houses, storage facilities, IT systems administrators, email distribution services, data entry service providers, electronic network administrators and professional advisers such as accountants, solicitors, auditors, business advisors and consultants and any other service providers we deem necessary who need to have access to your Personal Information to provide their services to us;
• our existing or potential Business Partners and Advertisers that provide products or services used or marketed by us from time to time;
• specific third parties authorised by you to receive information held by us;
• the police, any relevant government authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary;
• as otherwise required or permitted by law (including the Privacy Act).

Accessing and correcting your Personal Information
You may request access to any Personal Information we hold about you by contacting us (see “how to contact us”). We will respond to your request within a reasonable period. We will give access in the manner you have requested if it is reasonable to do so. We will not charge for simply making a request and will not charge for making any corrections to your Personal Information.  However, depending on the nature and scope of the Personal Information you have requested, we may charge you a reasonable fee to provide access to this information.

If you make an access request, we will ask you to verify your identity. There may be instances where, for legal reasons, we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal and information on how you can complain about the refusal.

We take reasonable precautions to ensure that the Personal Information we collect, hold, use and disclose is correct, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you or others provided to us. If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the Personal Information stating that you disagree with it. We will also give you written reasons for any refusal and information on how you can complain about the refusal.

Users of our website or app will generally be able to access and update their details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.

Disclosure of Personal Information outside Australia
We may disclose your Personal Information to entities located overseas for some or all of the purposes listed above. This may include disclosure to the following entities:

• our related bodies corporate;
• our service providers, IT systems administrators, email distribution services, data entry service providers or electronic network administrators; and
• other external service providers.

Personal Information that we collect is either held by us or on our behalf. Some or all of the Personal Information we hold may be stored or hosted in “the cloud” on databases, servers and data centres on our behalf which may be located in Australia and overseas in North America, Europe or Asia.

We transfer data outside of Australia to our service providers, including outsourced data processors with data centres in Australia and overseas, in order to obtain secure storage, back-up and data retrieval services to support the operation of the Paylab platform and the services accessible to you on the Paylab Platform.

We take reasonable steps to ensure that the overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information.  These overseas recipients may be required to disclose information we disclose to them under a foreign law.  In those instances, we will not be responsible for that disclosure.

Metadata
You may use our website or app without providing any Personal Information about you. In this case, we will collect metadata that results from your usage of our website including: browser type and version, operating system and interface, website from which you are visiting us (referrer URL), webpage(s) you are visiting on our website, date and time of accessing our website, and internet protocol address. The metadata will be primarily used to improve the quality and services of our website and services by analysing the usage behaviour of our users in anonymised form and to prevent fraud, misuse of our IT systems, as well as to ensure physical, IT and network security. We may also use metadata for other purposes, including online advertising.

Retention
Your Personal Information will only be retained for as long as it is reasonably necessary to fulfil the purposes for which it was collected or as required for a legal, accounting or reporting purpose.

Storage and Security
We will take all reasonable steps to protect the Personal Information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure, including by means of firewalls, password access, secure servers and encryption of credit card transactions.

If you suspect any misuse, interference or loss of, or unauthorised access, modification or disclosure of your Personal Information, please let us know immediately. 

Links
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Changes to our Privacy Policy
We may, from time to time, review and amend this Privacy Policy, including taking account of new or amended laws, new technology and/or changes to the Paylab Platform, our business and operations. All Personal Information held by us will be governed by the most recent updated Privacy Policy. Any updated versions of this Privacy Policy will be posted on our website. 

This Privacy Policy was last updated on 2 September 2021.

Complaints and further information
If you believe your privacy has been breached by us or have any feedback, questions or concerns about our Privacy Policy or privacy practices, please contact us using the contact information below and provide details of the incident so that we can investigate it.

Please contact our Privacy Officer at:

Privacy Officer
Paylab Pty Ltd
Suite 501, Level 5, 153 Walker Street
North Sydney NSW 2060
Email: privacy@paylab.com.au

We have a process for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint, the Privacy Officer will commence an investigation with the relevant business unit from which the alleged breach stemmed. The investigator will endeavour to determine the nature of the breach and how it occurred. We may contact you during the process to seek further clarification if necessary. If a breach is found, the Privacy Officer will work with senior management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.

We will treat your requests or complaints confidentially. Our representatives may contact you after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

If you are not satisfied with the outcome of your complaint or if you feel your privacy has been breached, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted at either www.oaic.gov.au or by calling 1300 363 992.