Last updated: 7 October 2022

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Thank you for using Airwallex!

We understand that by entrusting us with your personal information, we have a responsibility to protect and maintain your privacy. We take this privacy commitment seriously. As part of our dedication to transparency, this Privacy Policy (the “Policy”) describes the information we collect from you and how that information is used and shared by us. It also includes details about the choices we offer you in relation to your information. Please review it carefully.

Here is a summary of the information contained in this Policy (although it is not a substitute for reading the full Policy). We have included hyperlinks to help you jump to the relevant sections with more detail).

What does this Policy apply to?This Policy applies to any user of products, services, technologies or functionalities offered by us anywhere in the world, and to any visitor to our website, mobile app, or other channel.Link
Who is the data controller?“We” in this Policy refers to Airwallex. The data controller of your personal information varies by your location:
Australia: Airwallex Pty Limited
Canada: Airwallex (Canada) International Payments Limited
EEA/Switzerland: Airwallex (Netherlands) B.V.
Malaysia: Airwallex (Malaysia) Sdn Bhd
New Zealand: Airwallex (New Zealand) Limited
Singapore: Airwallex (Singapore) Pte Ltd
UK: Airwallex (UK) Limited
United States: Airwallex US, LLC
Hong Kong and all other countries: Airwallex (Hong Kong) Limited or UniCard Solution Limited (depending on the Services provided)
Link
What types of information do we collect and why?When you set up an account to use our Services, we require information (such as your name, address, government-issued ID, tax identifier, business information) to set this up. We also process certain identity information when we undertake our KYC/AML process. We will process information in connection with transactions (including payment information and the beneficiary of payment). Our Service also processes network, device and usage information in order to maintain the integrity of our systems. You can read more about what personal information we process and why below.Link
How is your information shared?Our affiliates and select third parties support the operation of the Services and will necessarily transfer personal information in order to facilitate the Services and services provided by third parties at your request and/or with your consent. If a third party is engaged to support the Services, this is solely for the purpose of the Services and we require that the third party comply with appropriate safeguards to protect personal information. Services supported and/or provided by third parties may include support services, effecting transactions, account information services, payment initiation services, cloud services, analytics, market research, fraud detection, Enterprise Partners’ services and other functions in connection with the Services. We also have affiliates around the world who help us deliver the Services and we may be required by a court or legal obligation to disclose certain information in some circumstances. You can read more about how we share your personal information below.Link
Where do we store your information?Our servers are located in datacenters hosted by Google Cloud Platform and Alibaba Cloud in Australia, Hong Kong, Japan, Mainland China, the Netherlands, Singapore, and the United States. We may access these servers from other locations as necessary to support the operation of the Services. You can read more about where your personal information is stored below.Link
How long do we retain information for?We only retain personal information for so long as it is required to fulfil the purpose for which it was collected, unless we are subject to legal or regulatory obligations to retain such information. You can read more about how long we retain specific categories of personal information below.Link
What rights do I have to processing of my information?Depending on where you are, you may have certain rights with respect to your personal information, such as rights of access, to receive a copy of your information, or to delete your information or restrict or object to our processing of your information. You can read more about your rights below.Link
How can I contact Airwallex?If you have questions or concerns about this Policy or a specific request related to your personal information, please contact us at [email protected].Link
How will we notify you of changes 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.Link
Are there specific terms that apply to certain countries?Yes. You can read more about the specific processing activities for certain jurisdictions in the Jurisdiction-Specific Addenda below.Link

1. SCOPE OF POLICY

This Policy applies to any user of our Services anywhere in the world and any visitor to our website, mobile app, or other channel (collectively, “Sites”). This Policy does not apply to third- party websites, products or services even if they are linked or provided in conjunction with our Services or Sites. “Services” means any products, services, technologies or functionalities offered by Airwallex. The Services we offer may vary by region.

2. DATA CONTROLLER

As used in this Policy, “we,” “us” “our” and “Airwallex” refers to the Airwallex group company that acts as the data controller with respect to your information. The data controller responsible for your information under this Policy varies depending on your country of residence.

Our privacy team can be contacted at [email protected].

The data controller that is responsible for your personal information differs by the location in which you are ordinarily resident or which entered into an agreement to provide Services to you.

Country of ResidenceData ControllerAddress
AustraliaAirwallex Pty LimitedLevel 7, 15 William Street, Melbourne, VIC 3000, Australia
United StatesAirwallex US, LLC1390 Market Street, Suite 200, San Francisco, CA 94102
Hong Kong and all other countriesAirwallex (Hong Kong) Limited

or UniCard Solution Limited (depending on the Services provided)
Suites 6308-10, 63/F, One Island East, 18 Westlands Road, Quarry Bay, Hong Kong, China
6308, 63/F One Island East, 18 Westlands Road, Quarry Bay, Hong Kong
UKAirwallex (UK) Limited1 Long Lane, London, SE1 4PG, United Kingdom
EEA or SwitzerlandAirwallex (Netherlands) B.V.Vijzelstraat 68, 1017HL Amsterdam
MalaysiaAirwallex (Malaysia) Sdn BhdWeWork Mercu 2, Level 40, No.3 Jalan Bangsar, 59200, Kuala Lumpur, Federal Territory of Kuala Lumpur, Malaysia
New ZealandAirwallex (New Zealand) Limitedc/- CSNZ, Level 5, 79 Queen Street, Auckland 1010
SingaporeAirwallex (Singapore) Pte Ltd30, Cecil Street, #19-08, Prudential Tower, Singapore 049712
CanadaAirwallex (Canada) International Payments LimitedSuite 2600, Three Bentall Centre, 595 Burrard Street, Vancouver, BC, Canada V7X1L3

3. THE TYPES OF PERSONAL DATA WE USE

By “personal information” we mean information that identifies you, such as your name, address, telephone number, email address, date of birth, payment card information, bank account information and any other data that is associated with your identity. The specific categories of personal information which we process are listed in the section “How We Use Your Personal Information” below. This section describes the different types of personal information we collect from you and how we process it.

A. INFORMATION YOU PROVIDE DIRECTLY TO US

  • Account registration: To use our Services, you must provide certain personal information to us, including 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 the Airwallex platform. This additional information will be processed based on our reasonable discretion or when applicable, your consent.

B. 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 Sites 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:

  • usage data;

  • information about the devices you use to access the Services;

  • log data; and

  • geolocation information.

Our Cookie Policy provides additional information about the technologies we use to automatically collect your personal information mentioned above.

C. INFORMATION COLLECTED FROM THIRD PARTIES

We also obtain information about you from other external sources, including information obtained from our service providers, credit bureaus, community forums used to post ratings or reviews, Airwallex business partners through which you access our Services, or other sources of public records. We may combine information collected from third parties with information we collect from you directly through the Airwallex platform.

Regardless of how 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.

D. 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. To learn more about cookies and the other tracking technologies we may utilize, please refer to our Cookie Policy, which includes a comprehensive overview of cookies and provides further details about how we use cookies and how to control our use of cookies.

4. HOW WE USE YOUR PERSONAL INFORMATION

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area or Switzerland (each a “Relevant Jurisdiction”), it also identifies the legal basis under which we process your personal information.

Personal InformationDescriptionUseLegal Basis (only relevant if you are located in a Relevant Jurisdiction)
Account and Profile InformationPersonal 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.We use this information: 

To provide 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; and
- To evaluate your application to use our Services.

To prevent fraud or misuse, 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; and
- To provide information related to your transactions including confirmations, receipts and tracking notices.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Demographic DataWe may also collect demographic data about you including your employment history, education, marital status, income and other similar information.We use this information to:

-develop new products or enhance existing products and services; and
- monitor and analyze trends, usage and other user activities on our Sites to optimize user experience.
It is in our legitimate interests to use this information to improve our Services and Sites.
Identity Verification DocumentsTo comply with laws and regulations, we may collect copies of your government-issued identification (including passport, driver’s license or national ID card) or other authentication information, all of which may include photographs of you.We use this information to provide the Services, specifically:

- to create your account for the Services in accordance with your request;
- to verify your identity or authenticate your right to access an account or other information;
- to evaluate your application to use our Services;
- to manage risk, fraud and abuse of our Services and Sites; and
- to conduct manual or system monitoring to protect against fraud and other harmful activity.
Necessary to satisfy our legal obligations under applicable law to verify your identity, and it is in our legitimate interests to prevent fraud or misuse.
Payment InformationIn order to collect funds and process payments we may collect financial information such as bank account details (account number, routing number), credit or debit card numbers, credit reports or tax information, such as withholding allowances and filing status.We use this information to provide the Services, specifically to process payments to your suppliers and other recipients.Necessary to perform our contract with you to provide the Services, and necessary to satisfy our legal obligations under applicable law in relation to payment transactions.
Beneficiary InformationWhen you book payments, 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.We use this information: 

To provide Services, e.g,
- To process payments to your suppliers and other recipients;

To prevent fraud or misuse, 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.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Business Entity InformationIf you are using our services on behalf of a business entity, we may collect information about the business including: the organizational structure of the company, the product and service offerings, website domain name used by the business, and information about the beneficial owners of the business. We also may collect entity formation documents or other corporate records.We use this information: 

To provide 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; and
- To evaluate your application to use our Services.

To prevent fraud or misuse, 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; and
- To provide information related to your transactions including confirmations, receipts and tracking notices.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Background InformationTo the extent permitted by applicable law, we may obtain back reports about you from public records. In order to obtain such reports, we may use information or personal information you provide to us.We use this information to prevent fraud or misuse, 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.
It is in our legitimate interests to prevent fraud or misuse.
Log DataWhen you access our 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.We use this information to:
- provide the Services; and
- prevent fraud or misuse; and 
- understand your use of and improve our Services.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Device InformationWe may obtain information about the devices you use to access our Services including: the device type, operating systems and versions, the device manufacturer and model, preferred languages, and plugins.We use this information to:
- provide the Services;
- prevent fraud or misuse; and 
- understand your use of and improve our Services.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Usage InformationWe collect information about how you interact or engage with our Sites and how you use our 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.We use this information to:
- provide the Services;
- evaluate your satisfaction with our Services, platform and features;
- develop new products or enhance existing products and services; and
- monitor and analyse trends, usage and other user activities on our Sites to optimize user experience and to improve our Services.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to protect the integrity of the Services and improve our operations.
Location InformationWhen you use certain features of our 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.We use this information to:
- provide the Services;
- enable you to access and use the Airwallex platform;
- manage risk, fraud and abuse of our Services and Sites; and
- conduct manual or system monitoring to protect against fraud and other harmful activity.
Necessary to perform our contract with you to provide the Services, and it is in our legitimate interests to prevent fraud or misuse.
Communications DataInformation 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.We use this information:
- to respond to your inquiries and support requests;
- to send you technical notices, updates, security alerts and other administrative messages; and
- to provide information related to your transactions including confirmations, receipts and tracking notices.
Necessary to perform our contract with you to provide the Services.
Call RecordingsVoice recordings of you captured when you contact us including interactions with our customer service or sales teams.We use this information to respond to your inquiries and support requests.Necessary to perform our contract with you to provide the Services.
Various InformationAny information you may provide us when you respond to surveys.We use this information to allow you to participate in surveys in accordance with your request.We collect this information with your consent.
Any information you may provide us when you post on community forums.We use this information to allow you to post on community forums and use the Services and our Sites.Necessary to perform our contract with you to provide the Services.
Any information you may provide us when you participate in contests.We use this information to facilitate promotional contests.Necessary to perform our contract with you to provide the Services.
Any information you may provide us when you participate in promotions or request to receive promotional information.We use this information to <br< - to deliver promotional offers, incentives, and targeted marketing in accordance with your preferences (as permitted by applicable law); and
- to provide invitations and information about events or events held by our partners.
We collect this information with your consent.

5. 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.

INFORMATION SHARING AND DISCLOSURE

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

Third PartyPurpose
Third party service providersWe engage a variety of service providers to enable us to provide our Services 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 affiliatesTo facilitate or support us and our Enterprise Partners in providing products and services to you, we may share your personal information within our worldwide corporate family of companies among entities that are related by common control or ownership. All related group companies may only use your personal information in accordance with this Policy.
Enterprise PartnersOur Services may be offered to you in conjunction with or facilitated by other financial institutions or other enterprises (an “Enterprise Partner”) and their products and services. Such Enterprise Partners may include (without limitation) entities which operate online marketplaces or other e-commerce platforms through which you are able to sell your goods, services, content or other products.  Such Enterprise Partners may have access to your personal information but only to the extent required to enable use by you of our or their products and services.
Regulatory Authorities: regulators, judicial authorities and law enforcement agencies, 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, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
- enforce our User Agreement 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 applicable law, legal process or governmental orders.
Social Media PlatformsSocial media networks such as Facebook, Twitter, Pinterest, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our website or mobile application (e.g., to log into an account, or to share content with your friends and followers on social media). If you 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 businessIf we are the subject 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 PartiesIf 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. Such third parties may include third party financial service providers, including but not limited to account information service providers and payment initiation service providers. Such disclosure will only be carried out in the manner you requested or consented to, and/or the manner described to you (whether by us or the relevant third party) at the time you agreed to the sharing, and in accordance with applicable law. Authorizing a third-party service provider, application, or website to access your Airwallex account or participating in certain promotional activities constitutes such request and consent to share your information.

6. 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 Airwallex 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, Airwallex will destroy personal information or, where applicable, sufficiently anonymize the personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal InformationRetention Policy*
Account and Profile Information
Identity Verification Documents
Business Entity Information
Background Information
Log Data
Device Information
Usage Information
Communications Data
Call Recordings
Other Information
Payment Information
Beneficiary Information
Location Information
Stored for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request), plus no less than 5 years.
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