Effortless Global B2B

Payments with TPS

1. INFORMATION YOU PROVIDE DIRECTLY TO US

• ● Account and Profile Information, Events participation, Newsletter or Content subscription: To use our Services or attend an event or receive content we publish, you must provide certain personal information to us, including contact details and other information required to establish an account profile, identity verification information, financial information and information regarding beneficiaries of payments. This information is necessary for us to perform the contracted services and also to allow us to comply with our legal obligations. If you are not able or willing to provide this information, we may not be able to provide you with all the requested Services.


• ● Survey, feedback, and promotions: Some information you provide to us is voluntarily provided by you and not mandatory. Examples of such information include your opting to respond to our surveys, provide feedback to us about our products and services, participate in promotions or contests or otherwise communicate with us. This information allows us to provide incentives or additional features to you, evaluate our performance and to create a better user experience for you when using our platform. This additional information will be processed based on our reasonable discretion or when applicable, your consent.

2. INFORMATION AUTOMATICALLY COLLECTED FROM YOUR USE OF SERVICES

We automatically collect certain data from you when you use the Services or visit any of our websites where we have a legitimate interest (such as to prevent fraud or misuse, or to understand your use of and improve our Services). This includes:
• ● transaction data, beneficiary information, card related information;
• ● usage data;
• ● information about the devices you use to access the Services;
• ● recordings;
• ● log data; and
• ● location information.
Please see information on Cookies below about how we use or may use cookies to automatically collect information relating to you and your use of our Services.

3. INFORMATION COLLECTED FROM THIRD PARTIES

We may also obtain information about you from other external sources, including information obtained from our ecosystem and financial partners, payment service providers, service providers, credit bureaus, credit reference agencies or other providers of credit information, financial institutions, debt collection agencies, companies and other official registers and databases, fraud prevention agencies and partners, community forums used to post ratings or reviews, certain business partners, or other sources of public records. We may combine information collected from third parties with information we collect from you directly. Regardless of the method of collection, the information we obtain from or about you is subject, at all times, to the privacy choices or rights exercised by you.

4. COOKIES

We use cookies and similar technologies (i.e. web beacons, pixels, ad tags and device identifiers) to recognize you and to customize your online experience.

What are cookies?
Why do we use cookies?
We use cookies to:

• ● recognise you whenever you visit our website;
• ● provide you with a great experience whenever you browse or use our website; and
• ● compile information to help us to improve our website.

What cookies do we or might we use?
We use the following types of cookies (which are a mix of first-party and third-party cookies):

• ● Performance cookies. These cookies measure how often you visit our website and how you use it. We use this information to get a better sense of how you engage with our website, therefore helping us to improve the way it works, for example, by ensuring that you find what you are looking for easily.
• ● Functionality cookies. These cookies are used to recognise you and remember your preferences or settings when you return to our website. This enables us to provide you with a more personalised experience. For example, if you are based in the United Kingdom, we will remember this and make sure that you receive a UK homepage when you visit our website, rather than a Australia or Hong Kong homepage.
• ● Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and content more relevant to your interests.

How to manage cookies
Your web browser may allow you to change your cookie preferences, including to delete and disable Airwallex and third-party cookies. Please consult the help section of your web browser to learn more about cookies. To find information relating to other browsers, visit the browser developer's website.
Please note: If you choose to disable some or all of the cookies, some features of our website or services may not operate as intended.

5. HOW WE USE YOUR PERSONAL INFORMATION

This section provides more detail on the types of personal information we collect from you, and why, and how we use or may use this information. Account and Profile Information (End User, and/or Representative only) This is needed by us to:

• - perform our contract with you to provide the Services and to send you communications related to your use of the Services.
• - ensure we have your consent to send you promotional or marketing communications.
• - serve our legitimate interests to prevent fraud misuse, or breaches of the Acceptable Use Policy.

What this is:

• Personal identifiers such as your name, residential address, email address, date of birth, social security number, driver’s license number, passport number, tax identification number or other similar identifiers

How this is or may be used:

• To provide the Services, e.g.
  • - to create a User Profile and associated permissions and authorisations to that User Profile;
  • - to process instructions from you payments and the use of our products;
  • - to provide customer support;
  • - to enable you to access and use the Airwallex products and platform;
  • - to evaluate your application to use the Services.
• To prevent fraud, misuse or breaches of the Acceptable Use Policy, e.g.
  • - to verify your identity or authenticate your right to access an account or other information;
  • - to manage risk, fraud and abuse of the Services and Sites;
  • - to conduct manual or system monitoring to protect against fraud and other harmful activity.
• To communicate with you, e.g.
  • - to respond to your inquiries and support requests;
  • - to send you service updates and notices, security alerts and other administrative messages;
  • - to provide information related to your transactions including confirmations, receipts and tracking notices;
  • - send you our newsletter or other content, or to send you marketing and promotional messages and offers.

Demographic Data (End User and/or Representative only) This is needed by us to improve our Services and Sites. What this is or may include:

• This may include demographic data about you including your employment history, education, income and other similar information.

How this is or may be used:

• To develop new products or enhance existing products and Services.
• To monitor and analyze trends, usage and other user activities on our Sites to optimize user experience.

Identity Verification Documents (End User and/or Representative only) This is necessary to satisfy our legal obligations under applicable law to provide our Services.
It is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy. What this is or may include:

• To comply with laws and regulations, we may collect copies of your government-issued identification document.
• Name, date of birth, identification document (including passport, driver’s licence or national ID card), address proof, tax residency information or other authentication information, all of which may include photographs of you.
• To the extent permitted by applicable law, we may obtain reports about you from public records. In order to obtain such reports, we may use information or personal information you provide to us.

How this is or may be used:

• To fulfil our legal obligations.
• To provide the Services, e.g.:
  • • to create your account for the Services in accordance with your request; and
  • • to verify your identity or authenticate your right to access an account or other information.
• To prevent fraud, or misuse or breaches of the Acceptable Use Policy, e.g.
  • • to verify your identity or authenticate your right to access an account or other information;
  • • to manage risk, fraud and abuse of our Services and Sites;
  • • to conduct manual or system monitoring to protect against fraud and other harmful activity.

Transaction Data (End User and/or Representative only) This is necessary to perform our contract with you to provide the Services.
Necessary to satisfy our legal and regulatory reporting obligations under applicable law. What this is or may include:

• We may collect financial information such as bank account details (account number, routing number), credit or debit card numbers, billing address, shipping address, payment method information, merchant, location, transaction amount, date of transaction or tax information.

How this is or may be used:

• • To provide the Services, including to process payments from and to the Business Customer’s account or the End User account, to process payment transactions from buyers or the users of any Airwallex card products.
• • To fulfil our legal and regulatory reporting obligations.

Beneficiary Information (End User and/or Representative only) This is necessary to perform our contract with you to provide the Services. It is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy. What this is or may include:

• We may collect information about the parties to the transaction, the designated recipient (including the recipient’s bank account information), the source of the funds, the reason for the transaction, the devices and payment methods used to complete transactions.

How this is or may be used:

• To provide the Services, e.g.
  • to process payments from and to the Business Customer or End User account.
• To prevent fraud, misuse or breaches of the Acceptable Use Policy, e.g.
  • • to verify your identity or authenticate your right to access an account or other information;
  • • to manage risk, fraud and abuse of the Services and Sites;
  • • to conduct manual or system monitoring to protect against fraud and other harmful activity.

Card Related Information (End User) This is necessary to perform our contract with you to provide the Services and to fulfil our legal obligations. What this is or may include:

• Card numbers and details

How this is or may be used:

• To provide the Services, e.g.
  • • to process payments made by the card;
  • • to issue cards and process their transactions as part of the Services;
  • • to validate the authenticity of the transaction; and
  • • to prevent fraud.

Business Entity Information (End User and/or Representative only) This is necessary:

• • to perform our contract with you to provide the Services.
• • to fulfil our legal and regulatory obligations.
• • It is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy.

What this is or may include:

• If you are using the Services on behalf of a business entity, we may collect information about the business including: the organizational structure of the company, the company address, the product and service offerings, website domain name used by the business, information about the beneficial owners of the business, tax classification of the business, tax identification number(s), company registration number(s), and its tax residence. We also may collect entity formation documents or other corporate records.

How this is or may be used:

• To provide the Services, e.g.
  • • to process payments to your suppliers and other recipients;
  • • to provide customer support;
  • • to enable you to access and use the Airwallex platform;
  • • to evaluate your application to use our Services;
  • • where applicable, to meet our legal obligations and conduct required and regulatory reporting, including to tax authorities.
• To prevent fraud, misuse or breaches of the Acceptable Use Policy, e.g.
  • • to verify your identity or authenticate your right to access an account or other information;
  • • to manage risk, fraud and abuse of our Services and Sites;
  • • to conduct manual or system monitoring to protect against fraud and other harmful activity.
• To communicate with you, e.g.
  • • to respond to your inquiries and support requests;
  • • to send you technical notices, updates, security alerts and other administrative messages;
  • • to provide information related to your transactions including confirmations, receipts and tracking notices.

Log Data (End User and/or Representative only) Necessary to perform our contract with you to provide the Services. It is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy and improve the Services. What this is or may include:

• When you access the Services, we collect server logs which may include information such as access times and dates, pages viewed and other system activity, including the third-party site you were using before accessing our Services.

How this is or may be used:

• • To provide the Services.
• • To prevent fraud, misuse or breaches of the Acceptable Use Policy and improve our Services.
• • To understand your use of and improve the Services.

Device Information (End User and/or Representative only) This is necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy and improve the Services. What this is or may include:

• We may obtain information about the devices you use to access the Services including: the device type, operating systems and versions, the device manufacturer and model, preferred languages, and plugins.

How this is or may be used:

• • To provide the Services.
• • To prevent fraud, or misuse or breaches of the Acceptable Use Policy and improve the Services.
• • To understand your use of and improve the Services.

Usage Information This is necessary to perform our contract with you to provide the Services. It is in our legitimate interests to protect the integrity of the Services and improve our operations. What this is or may include:

• We collect information about how you interact or engage with the Sites and how you use the Services including your user preferences and other settings selected by you. This information may be collected if you visit our Sites and regardless of whether or not you establish an account with us or conduct a transaction. In some cases, we do this by utilizing cookies, pixel tags and similar technologies. Please see further details about cookies and other tracking technologies in our Cookie Policy.

How this is or may be used:

• • To provide the Services.
• • To evaluate your satisfaction with our Services, platform and features.
• • To develop new products or enhance existing products and services.
• • To monitor and analyse trends, usage and other user activities on our Sites to optimize user experience and to improve the Services.

Location Information (End User and/or Representative only) This is necessary to perform our contract with you to provide the Services. It is in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy. What this is or may include:

• When you use certain features of the Services, we may collect information about your precise or approximate location as determined by data such as your IP address or mobile device GPS. Most mobile devices allow you to control or disable the use of geolocation services for applications by changing preferences on your mobile device.

How this is or may be used:

• • To provide the Services.
• • To enable you to access and use the Airwallex platform.
• • To manage risk, fraud and abuse of our Services and Sites or breaches of the Acceptable Use Policy.
• • To conduct manual or system monitoring to protect against fraud and other harmful activity.

Communications Data This is necessary to perform our contract with you to provide the Services. What this is or may include:

• Information related to your interactions and communications with us, which may include email messages, chat sessions, text messages, and phone calls that we exchange with you.

How this is or may be used:

• • To respond to your inquiries and customer support requests.
• • To send you technical notices, updates, security alerts and other administrative messages.
• • To provide information related to your transactions including confirmations, receipts and tracking notices.

Call Recordings This is necessary to perform our contract with you to provide the Services. What this is or may include:

• Voice recordings of you captured when you contact us or if we contact you, including interactions with our customer service or sales teams.

How this is or may be used:

• To respond to your inquiries and customer support requests.

Various other Information We collect this information with your consent. What this is or may include:

• Any information you may provide us when you respond to surveys.

How this is or may be used:

• To run the survey and analyse the results for our internal business purposes.

Any information you may provide us when you participate in contests. We collect this information with your consent. How this is or may be used:

• To facilitate promotional contests that you choose to participate in.

Any information you may provide us when you participate in promotions or request to receive promotional information. We collect this information with your consent. How this is or may be used:

• To deliver promotional offers, incentives, and targeted marketing in accordance with your preferences (as permitted by applicable law).
• To provide invitations and information about events or events held by our partners.

6. TRANSFERS AND STORAGE

To support our global operations and pursuant to our contract with you to provide the Services, we and our service providers may store or process your personal information in any country where we or one of our affiliates maintains a physical presence or where we engage third-party service providers. This could result in a transfer of your personal information to a region or country outside of your country of residence, the regions and countries to which your personal information may be transferred to include Australia, Germany, Hong Kong, India, Japan, Lithuania, Mainland China, Malaysia, the Netherlands, New Zealand, the Philippines, Singapore, the United Kingdom, and the United States. Our servers for the Services are located in Australia, Hong Kong, Japan, Mainland China, the Netherlands, Singapore, and the United States.

The laws and privacy regulations of such countries may differ from the country of your residence and potentially may not be as protective. There may be circumstances in which the law enforcement agencies or government authorities in such other countries may be entitled to access your personal information. Any transfer of your personal information outside your country of residence will at all times comply with the standards set forth in this Policy as well as the applicable data protection rules. For example, transfers of personal information outside the EEA or the UK will be made under the European Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses), or any equivalent contracts issued by the relevant authority of the UK, as relevant.

7. INFORMATION SHARING AND DISCLOSURE

Only where necessary will we share your personal information with third parties. Situations where this occurs are:

Third party service providers We engage a variety of service providers (who act as data processors) to enable us to provide our Services to Business Customers, and, indirectly, to you. For example, service providers may be used to: facilitate payment processing, support technology or infrastructure, cloud storage, conduct market research, marketing analytics, detect fraud, verify identity and perform audits or other functions. We will share your personal information with such service providers only to the extent necessary to allow the performance of their intended engagement. All service providers and business partners that receive your personal information are contractually bound to protect and use your information only in accordance with this Policy.

Our corporate affiliates To facilitate or support us in providing the Services to you, we may share your personal information within the Airwallex group of companies. All Airwallex group companies may only use your personal information in accordance with the relevant Intra-Group contracts governing such processing and for the purposes set out in this Policy.

Financial and Ecosystem Partners The Services may be offered to you (as an End User, Business Customer or Representative) in conjunction with or facilitated by other financial institutions, other payment institutions or other ecosystem partners (such as a provider of accounting or treasury management services or a marketplace payment service provider programmes). In respect of Financial or other payment institutions, such transfers and disclosures are necessary in order to provide the Airwallex services to you. In respect of Ecosystem Partners, such disclosures and transfers will be made in the manner you authorised or requested, or described to you (to enable use by you of such Ecosystem and Financial partners’ products and services) at the time you authorised or requested such disclosures. When you allow or authorise such 3rd party provider, plugins, widgets, and/or website to access your Airwallex Account or to receive your personal information, this will constitute a request and/ or authorisation.

In respect of Connected Account holders, the Platform (or any Platform partners) For the Airwallex for Platforms solution, personal information relating to the Connected Account will be transferred to the Platform (or the Platform partners) to allow the Connected Account to consume the Airwallex services via the Platforms’ (or Platforms’ partner’s) website or mobile app. The Platform (and/or Platform partner) is an independent data controller of the personal information it processes in relation to the Connected Account holder.

Commercial Partners We may also refer you to services provided by our Commercial Partners (as an End User, Business Customer or Representative). Such Commercial Partners provide services under their own licences or authorisations, will have direct contracts with you and may be independent data controllers of the data you provide to them or data generated from your use of their services. Airwallex has no responsibility for any Commercial Partner services. Any data that may need to be transferred to such Commercial Partners from us will be done with your consent or as requested by you.

Regulatory Authorities This includes regulators, judicial authorities and law enforcement agencies, tax authorities, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities (e.g. regulators, judicial authorities, courts, law enforcement agencies, tax authorities, and other public / government authorities both domestic and international), such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or to protect our users. These disclosures may be made with or without your consent, and with or without notice, subject to and in compliance with the terms of valid legal process, including but not limited to regulatory queries or requests, subpoenas, court orders, or search warrants. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may also disclose your information to:

• - enforce our Master Services Agreement entered into with the Business Customer or End User, or our online terms and conditions accepted by the Business Customer or End User or other applicable agreements or policies, including investigation of any potential violation thereof;
• - detect, prevent or otherwise address security, fraud or technical issues;
• - protect our rights, property, privacy, or security, or that of others, as permitted by law; or
• - comply with relevant law, legal process or governmental requests or orders.

Social Media Platforms Social media networks such as Facebook, Twitter, Pinterest, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our corporate website or mobile application. If you as a Visitor choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies — for more information about what information is shared or collected, and how it is used, see the applicable social media company's privacy policy.

Potential Acquirers of our Business If we are the subject of or are involved in any corporate merger, acquisition, consolidation, reorganization, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with bankruptcy or similar proceedings), we may share data with third parties during negotiations. In the event your personal information becomes subject to a different privacy policy, we will make reasonable efforts to notify you beforehand. We also may need to disclose information to a third party in connection with a commercial transaction where we or any of our affiliates are seeking financing, investment or funding.

Other Authorized Parties If you request (as part of the Services provided to you) or provide your consent, we may share your information including your personal information with a third party not defined in this Policy.

8. DATA RETENTION

We will retain your personal information only for the period of time required to comply with applicable law or fulfill any ongoing obligations to you. Please note that there are certain circumstances in which we will retain your personal information even after you close your account or request deletion of your personal information. Examples of such cases include:

• ● To process any transactions booked prior to closure or deactivation of an account.
• ● To comply with anti-money laundering regulations or other laws and rules that apply to us as a financial services provider.
• ● To detect or prevent fraud.
• ● To comply with legal process orders or law enforcement requests.
• ● To collect any fees or other outstanding amount owed and payable to us by you.
• ● To resolve any disputes or enforce our User Agreement or other applicable agreements or policies.
• ● To take any other action or exercise any other right in accordance with applicable law.

When a relevant retention period has passed, we will destroy personal information or, where applicable, sufficiently anonymize the personal information.

9. YOUR RIGHTS AND CHOICES

You have certain rights relating to your personal information. The ability and extent to which you may exercise these rights will vary depending on your location. For our customers who are resident in Singapore
Access You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us.

Correction You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us.

Our privacy team for the purposes of compliance with the Personal Information Protection Act 2012 can be contacted at the contact information provided in this policy.

A. ACCESS, CORRECTION, ERASURE You may review, correct or update information you provided to us at any time by logging into your account. Prior to changing or correcting your information, we may be required to verify your identity. There may be circumstances which preclude us from providing access to some or all of your information, for example where the information contains references to personal information about an individual other than you or the information is subject to legal or proprietary protections.

B. PORTABILITY You may have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., your name). You may have the right to receive this information in a structured, commonly used, and machine-readable format. You may also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

C. RESTRICTION OF PROCESSING You may have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

D. OBJECTION You may have the right to object to our processing of your personal information. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

10. DEVICE & MARKETING

Device Permissions Most mobile devices allow you to disable the use of location services, or revoke consent to applications to access your camera and photo library or send you push notifications. Please refer to your device settings to restrict the collection of certain information.

Notifications We may from time to time send you notifications when we consider it necessary to do so (for example, when we temporarily suspend access to the Services for maintenance, or for security, privacy, or administrative-related communications). You may not opt out of these service-related notifications, which are not promotional in nature.

Marketing Opt-Out You can opt out of receiving promotional communications from us by following the instructions included in those messages or by logging into your account and changing your preferences. Please note that if you opt out of marketing-related emails from us, we will continue to send you non-promotional messages that are required to provide our Services, such as transactional receipts and messages about your account or our relationship with you.

11. ADVERTISING AND ANALYTICS

We may partner with third parties to display advertisements to you on websites you visit. These third-party partners use cookies and other technologies to gather information about your activities on our Sites as well as other sites you visit in order to serve you advertising based upon your browsing history and interests.

12. SECURITY

We implement and update technical and physical security measures to safeguard your personal information against loss, misuse or unauthorized access on an ongoing basis. Safeguards used to protect your information include firewalls, data encryption, and access controls. Please keep in mind that the transmission of information over the Internet is never 100% secure and no data storage system can be guaranteed safe. Although we will do our best to protect your personal information, we cannot warrant the security of data transmitted to our Sites; any transmission is at your own risk. We encourage you to understand the integral role you play in keeping your own personal information secure and confidential. Please select passwords that are sufficiently complex and always keep our log-in details secure. If you suspect any unauthorized use or access to your account or information, please contact us immediately.

13. CHILDREN’S PRIVACY

Our Sites and Services are not intended for or directed at children. By children we mean users under the age of 16 or in the case of a country where the minimum age for processing personal information differs, such a different age.

We do not knowingly collect any information from children. If we obtain actual knowledge that we have collected personal information from a child, we will immediately delete it (unless we are legally obligated to retain such information). Please contact us if you believe that we inadvertently collected information from any child.

14. THIRD PARTY LINKS AND SERVICES

Our Sites may include links to third party websites or services, such as third-party integrations, co-branded services, or third-party branded services (“Third-Party Sites”) . Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not own or control these third-party websites and when you engage with these Third-Party Sites, you may be providing information directly to us, the Third-Party Site, Airwallex, or any or any combination of these. Third-Party Sites will have their own policies about the collection, use and disclosure of your information. Please review those policies for more information.

15. UPDATES TO THIS POLICY

We reserve the right to make changes to this Policy at any time by posting a revised version to our Site and updating the “Last Updated” date at the top of this Policy. To the extent permitted by applicable law, your continued use of our services after such notice or posting constitutes your consent to our revisions of this Policy. If you disagree with any of our changes, you may deactivate your account with us at any time.

16. CONTACT

If you have questions or concerns about this Policy or a specific request related to your personal information, please contact us at customer-service@tpssolutions.com
If you wish to make an inquiry regarding how we process your personal information, please contact us at the same address and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

17. LANGUAGE

Except as otherwise set out by law, in the event of any inconsistency between the English version and local language version of this Policy (where applicable), the English version shall prevail.