Thank you for visiting pinoyfirst.com.au, an online service managed by Pinoy First Pty Ltd located in Cairns, QLD. We respect and protect the privacy of our users. This privacy policy tells you how we collect and use information.

The term "Personal Information" in this privacy policy means any information from which your identity is apparent or can be reasonably ascertained. We do not collect Personal Information about you when you visit this online service.

You can use this service without telling us who you are or revealing other Personal Information. If you send us a contact or feedback form you do not need to identify yourself or use your real name.

The term Pinoy First Pty Ltd ABN 58 161 586 116 ('Pinoy First', 'we', 'us', 'our') refers to same.

RESPONSIBILITY

Pinoy First takes your privacy seriously. This privacy document applies to the site www.pinoyfirst.com.au and is effective as at 4th December 2016.

We respect your rights to privacy and is bound by the 1988 Privacy Act of Australia. Visit http://www.comlaw.gov.au/Series/C2004A03712 - for more information on the act.

We are committed to protecting our clients' privacy and security. Please review the following document to ensure you fully understand what information we collect about you and with whom we share it. You should read this document in its entirety. It should also be noted we may amend the content of this document at any time by posting a revised version on our website.

Pinoy First provides the following information to explain what personal information we collect about you, with whom we share it, and how you can direct us not to share certain information with certain parties. "Personal Information" refers to the meaning given to it under the relevant acts in your region. You should read this document in its entirety.

Pinoy First collects information by lawful and fair means only.

COLLECTION OF INFORMATION
We are required to collect various types of information. This includes:

1. Information that you provide us while using our service, such as your name, residential or business address, email address, and telephone number.
2. Details of the services which you require from us.
3. We may also collect certain sensitive information from you including your bank account number, credit card number, date of birth, passport number, drivers licence number and social security number. Information about your usage of our service, including your transaction history, and how and to whom you use our service to send or receive money;

To use our services, we also request certain third party information. This includes the recipients:

1. Full name, physical address, email address and phone number
2. We may also collect from you a recipient's sensitive financial information including their bank account and routing number.

If we are unable to collect the above information, then we may be unable to provide you with our service.

We collect this information in various ways, including but not limited to;

1. Conversations held over the phone by you and our team members
2. Through your use of our website, including support messages
3. When you submit a payment, or complete a contract
4. When you send information in emails or correspond with us
6. Information that we lawfully obtain from third parties such as verification services and credit reporting agencies
7. Information that we indirectly obtain from you, such as information about the hardware and software you use when accessing our service, your IP address, the pages you access on this website, and other websites that you visit prior to accessing Pinoy First.
8. We may also use "cookies" to track your use of this website. A cookie is a small data file that we may place on your computer to identify you when you return to the website. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of the Service. The information we store in the cookie is not Personal Information but a number that we generate and could not be used to lookup a user's Personal Information without the proprietary Pinoy First system. Should you wish to opt-out of digital advertising or remarketing, please follow the applicable links: Bing, Google and Facebook.

We are required to collect certain personal information under the AML/CTF Act 2006 in Australia.

We are required to collect personal information to:

1. To provide services and products to you and undertake associated business processes and functions
2. To verify your identity and comply with legal obligations under the relevant anti-money laundering acts dependent on your jurisdiction.
3. To collect payment for your use of the website and the services provided
4. To troubleshoot problems with the website and the services provided
5. To detect and prevent fraud and other illegal use of the website and the services provided
6. To send you marketing notices, service updates, and promotional offers
7. For administration, planning and account management
8. To develop, monitor and improve services
9. Any other purpose disclosed to you at the time of information collection

SHARING INFORMATION WITH OTHERS
We will not sell or lease the information we collect to third parties for their promotional purposes unless we receive

your permission to do so. Nevertheless, we may share personal information about you as follows:

1. To entities or service providers under contract with us for the purposes of conducting our business and providing our services to you. This includes; transaction processing, fraud prevention and professional advisors such as solicitors, business advisors and consultants. Entities we partner with to offer additional products and services, but only when you elect to receive information about those additional products and services.
2. In the event of the sale, acquisition or merger of some or all our assets, your personal information might be a part of the transferred assets. We shall notify you in the event of such an occurrence by placing a notice on our website.
3. Law enforcement and government officials, but only about a formal request, subpoena, court order, or similar legal procedure, as well as circumstances where we believe in good faith that disclosure is necessary to comply with the law, report suspected illegal activity, or investigate violations of our User Agreement. This is to satisfy our obligations under the relevant AML/CFT Laws.
4. As may be required under any other law

MODIFY AND ACCESS YOUR INFORMATION
We are required to hold client information for a period of 7 years. Should you wish to close your account we will remove access to your Pinoy First account. However, all information relating to your payments including but not limited to;

1. Your name, address, date of birth and other relevant personal information.
2. The amount you paid and the amount that was received by the beneficiary
3. The details of the recipient bank account.
4. The details of the recipient bank account.

Options to access, modify or update your personal information saved to our website can be found by logging into your account and changing your preferences or in the instances where personal information cannot be modified or amended by you by contacting Pinoy First to request changes you may deem necessary.

We will take reasonable steps to ensure that all information we hold on your file is up to date, complete and accurate, this is to minimise the possibility that you are contactable and appropriate information is used to decide about you. However, please note that Pinoy First is in no way responsible for information that is not updated on your account and as such advises all clients that they routinely check that the information provided on their account is correct.

MODIFY OR RESTRICT THE USE OF YOUR INFORMATION

A Pinoy First client may restrict the sharing of their personal information as follows: If, after giving us your permission to share your personal information with third parties, with whom we deem it necessary to provide our jointly offered services, you later decide that you no longer want us to share such information, you can email support@pinoyfirst.com.au or telephone 07 3063 4777. It should be noted that a request to restrict or modify the use of your information may result in you no longer being able to use our services.

ACCESS TO INFORMATION

You are entitled to request all personal information held by us at any given time. To do so you need to contact us directly via support request or email. Where you are entitled to that information we will ensure it is provided in the manner you requested it. If it is not practical or probable to do so, we will provide the information in another suitable form such as via email or post.

There may be circumstances which mean that information cannot be released to you. For example, these circumstances may include:

1. The information may impact the privacy of another individual
2. The information is commercially sensitive evaluative information
3. The information is subject to solicitor-client or litigation privilege
4. Pinoy First is prohibited by law from providing you with access
5. The disclosure could be expected to threaten the safety, physical or mental health or life of an individual.
6. If Pinoy First decides that it cannot provide you with certain information it will outline the reasons for its decision in writing and the mechanisms available to complain about the refusal

SECURITY – SECURE SOCKET LAYER WEBSITE CERTIFICATE

We take all reasonable steps to maintain the security of your personal information. We have a range of safeguards to protect this information. We use the highest level of online security available to protect the information you submit to us through our website. We have put in place an SSL encryption technology to protect your sensitive information transmitted from our website. We also require a username and password from each user who wishes to access the information held in their Pinoy First account and other areas on the our website. All forms of personal information are kept online on your account. However, in some instances where information is mailed to us, we upload the documents and then destroy them.

COMPLAINTS AND DISPUTES

Any dispute or complaint about our terms of use or the our privacy policy must be dealt with by you in Australia as detailed in the terms of use of our website and or online service.

THIRD PARTY WEBSITES

Our website contains links to other websites. Pinoy First maintains it is not responsible for the privacy practices or the content of other web sites. Please ensure you familiarise yourself with the privacy practices of these other sites prior to submitting your personal information to them.

AVAILABILITY AND CHANGES TO THIS POLICY

This policy is available on our website. We retain the right to change this privacy policy from time to time. All updated versions of this policy will be posted and kept up to date on the website.