Privacy Policy

TransAction Solutions Limited ACN 084 571 040

The protection of Personal Information collected, used or stored by TransAction Solutions Limited (ACN 084 571 040) and its related companies from time to time (we, us or our) is fundamental to our business.

We are committed to safeguarding the Personal Information we hold and we are committed to do so in accordance with the requirements of the Australian Privacy Principles (APP) under the Privacy Act 1988 (Cth) (Privacy Act) and any other relevant laws, regulations and contractual arrangements we have in place with our clients.

This Privacy Policy sets out our policy relating to the management of Personal Information by us.

Personal Information is information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

How do we collect Personal Information?

We provide managed services to our clients such as credit unions and mutual banks.

The managed services we provide to our clients include:

infrastructure as a service delivering transaction processing between our clients and their respective customers;

desktop as a service; and

application service management; and

disaster recovery services; and

data storage and warehousing.

In providing the managed services to our clients we have access to and are provided with data provided by our clients which includes Personal Information of their customers.

We also may collect Personal Information from an individual if we provide a service to a client which involves us having direct access to one of its customers.

What kind of Personal Information do we collect and hold?

We collect and use Personal Information about customers of our clients in connection with the provision of managed services to our clients. The kind of Personal Information that we collect includes:

names;

addresses;

phone numbers;

email addresses;

financial information such as income information, transaction history and credit history; and

bank account details.

Where we receive Personal Information from our clients we have requested them to provide you with a copy of our Privacy collection statement. A copy of our Privacy collection statement is attached and also available at www.tas.business/

Alternatively you can request a copy of our Privacy collection statement by contacting:

Contact: Privacy Officer, TransAction Solutions Limited

Address: PO Box 6764 Silverwater NSW 2128 Australia

Phone: +61 2 9647 4600

How do we hold Personal Information?

We collect, hold, use and disclose Personal Information for the purposes of providing the managed services discussed above to our clients. We may use or disclose Personal Information for another purpose only if:

you consent to having access to the Personal Information;

require access to the Personal Information to perform their work for us or any of our clients;

we are required to give access to the Personal Information by or under an Australian law or a court/tribunal order;

you would reasonably expect us to give access to, and the access is related to our provision of services to our clients (for example where we engage third party contractors or services providers to assist under in the provision of services to our clients or to service, maintain or repair any equipment on which Personal Information is held; and

we reasonably believe it is necessary to provide access to for one or more enforcement related activities conducted by, or on behalf of an enforcement body.

All Personal Information is maintained subject to physical security procedures to manage and protect the use, storage and disclosure of the Personal Information in our premises in Australia. For example, all servers on which Personal Information data is held are only physically accessible by limited and specifically authorised personnel in accordance with our Information Security Management Policy and Procedures.

For what purposes do we collect, hold, use and disclose Personal Information?

We collect, hold, use and disclose Personal Information for the purposes of providing the managed services discussed above to our clients. We may use or disclose Personal Information for another purpose only if:

you consent to the particular use or disclosure of the information; or

the use is one that an individual would reasonably expect us to use or disclose the information for and the use or disclosure is related to the provision of managed services to our clients.

For example we may disclose or give access to Personal Information to service providers or subcontractors which are engaged in connection with:

the provision of the managed services; or

providing services to us.

Access or disclosure of Personal Information to service providers or subcontractors is only provided if and to the extent reasonably necessary for providing the above services.

The collection, holding, use and disclosure of Personal Information of our clients’ customers are governed by:

this Privacy Policy;

contractual arrangements we have with our clients; and

applicable laws such as the Privacy Act, Evidence Act 1995 (Cth) and any other applicable legislation or regulations which may require us to disclose any Personal Information to a third party include law enforcement agencies.

How may you complain about a breach of the AAP’s and how we deal with such a complaint?

If you believe that we have breached an APP you should advise us by contacting our Privacy Officer on the contact details stated below.

Upon receiving such a complaint our Privacy Officer will:

consider the details of your concerns;

request further information from you if necessary to better review your complaint; and/or

contact you to:

discuss the way in which we propose to resolve your concern;


advise you of the steps that we intend to take to resolve your complaint.

advise you of the findings of our review of your complaint; and/or

We will use our reasonable efforts to resolve your complaint as soon as reasonably practicable.

How do you get access to the Personal Information held by us and seek correction of it?

You have a right to request access to your Personal Information unless:

the access would have an unreasonable impact on the privacy of other individuals;

the request for access is frivolous or vexatious;

there are existing or anticipated legal proceedings between us and you and would not be accessible by the process of discovery in those proceedings;

giving access would be unlawful; or

such access can be denied under the APPs, any law or by a law enforcement agency.

You may request access the Personal Information that we may hold about you in the following manner:

(Direct Personal Information) if you wish to have access to, or correct, Personal Information about you that was collected directly by us, you should issue your request to our Privacy Officer at the address above; and

Our ability to grant you access to, and correct, Personal Information which we hold about you, which was collected and provided to us by our clients, may be limited by our contractual arrangements with our clients.

If we receive a request about any Indirect Personal Information held by us, we will refer that request to the client, for whom we may hold that information, and who may better attend to your request.

We will respond to a request for access to Personal Information within a reasonable period after the request is made, which is general within a 30 day period. We may also charge a fee for providing access to Personal Information to recover the reasonable costs that we incur in processing your request.

Are we likely to disclose Personal Information to overseas recipients

We are not likely to disclose any Personal Information to overseas recipients.

Changes to this privacy Policy.

As our business or the services we provide may change from time to time, we may also modify or change this Privacy Policy. If we do so we will only do so in a manner that is consistent with the APP’s.

We encourage you to periodically review our Privacy Policy for any changes.

Contacting us

You may obtain a copy of this Privacy Policy from our website at www.tas.business

Alternatively you can request a copy of this policy by contacting:

Contact: Privacy Officer, TransAction Solutions Limited

Address: PO Box 6764 Silverwater NSW 2128 Australia

Phone: +61 2 9647 4600

How Current is our Privacy Policy?

This Privacy Policy was last updated on 30 September 2014.

Further Information

For further information about privacy issues and the protection of privacy visit the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au

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