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, when such user is a business entity, to any individual who is the owner of, or who acts on behalf of, such user), and to any visitor to our website, mobile app, or other channel whose personal data we process. Personal data is any information that is related to an identified or identifiable natural person. The definition under applicable laws is broad, and can include information that could be used indirectly and/or with other information to identify an individual – such as device identifiers or IP address. Examples of personal data include your name, email address, ID document information, bank account number, credit card details, telephone number, transaction information or home address.

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Who is the data controller?

“We” or “us” in this Policy refers to Airwallex. The data controller of your personal information varies by your location:

Australia Airwallex Pty Ltd, Airwallex SVF Pty Ltd, and/or Airwallex Capital Pty Ltd (depending on the Services provided)

Brazil Airwallex (Brasil) Ltda.

Canada Airwallex (Canada) International Payments Limited 

EEA/Switzerland Airwallex (Netherlands) B.V., or Airwallex Capital (Netherlands) B.V., or Airwallex Digital (NL) B.V., or Airwallex Lithuania UAB (depending on the Services provided) 

Indonesia PT Skype Sab Indonesia

Israel Airwallex (Israel) Ltd

Malaysia Airwallex (Malaysia) Sdn Bhd 

Mexico MexPago Transacciones, S.A.P.I. de C.V., Institución de Fondos de Pago Electrónico

New Zealand Airwallex (New Zealand) Limited 

Singapore Airwallex (Singapore) Pte Ltd, Airwallex Capital (Singapore) Pte Ltd, or Airwallex Digital (SG) Pte. Ltd. (depending on the Services provided) 

United Arab Emirates Airwallex Middle East Innovation In Financial Solutions - L.L.C - O.P.C

UK Airwallex (UK) Limited; Airwallex Capital (UK) Limited (depending on the Services provided)

United States Airwallex US, LLC, Airwallex Digital (US) LLC; Airwallex Capital US, T0 Finance LLC (depending on the services provided)

Vietnam Payment Telecom Informatics Post A Member Of Company Limited.

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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 Services also process 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.

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How is your information shared?

Our affiliates and select third parties support the operation of the Services and will necessarily receive and/or transfer personal information in order to facilitate the Services and services provided by third parties at your request and/or with your consent where legally required. 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, Business Customers’ 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.

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Where do we store your information?

Where we store your information depends on your location and associated applicable laws. We primarily host personal information in Singapore, Belgium, the Netherlands, Japan, Australia, Malaysia, and the United States. As a global business, we may also transfer or process personal information in countries outside your country of incorporation, business operations, or residence, to where our affiliates, select third parties, Ecosystem and Financial Partners and service providers are located. Any cross-border data transfers or processing is done in compliance with applicable law, as described in Section 5 below.  

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How long do we retain information for?

We 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. 

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What rights do I have regarding the  processing of my information by Airwallex?

Depending on where you are located, 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.

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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].

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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.

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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.

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Country of Residence

Data Controller(s)

Address

Australia

Airwallex Pty Ltd (for payment and other financial services);

Airwallex SVF Pty Ltd (for stored value services); 

and 

Airwallex Capital Pty Ltd

(for investment management services)

Level 7, 15 William Street, Melbourne, VIC 3000, Australia

Brazil

Airwallex (Brasil) Ltda

Avenida Brigadeiro Luís Antônio, 300, 100 andar, conjunto 104, parte, Bela Vista, Brazil

United States

Airwallex US, LLC

Airwallex Digital (US) LLC

Airwallex Capital US (for investment services) 

T0 Finance LLC 

188 Spear Street, 9th Floor, San Francisco, CA 94105, USA

UK

Airwallex (UK) Limited

Airwallex Capital (UK) Limited (for investment services)

Wells and More, 45 Mortimer St, London, United Kingdom, W1W 8HJ

EEA or Switzerland

Airwallex (Netherlands) B.V.

Airwallex Capital (Netherlands) B.V. (for investment services)

Airwallex Lithuania UAB

Rivvia, Keizersgracht 127, 1015 CJ Amsterdam, Netherlands Konstitucijos ave. 21B, Vilnius, the Republic of Lithuania

Malaysia

Airwallex (Malaysia) Sdn Bhd

WeWork Mercu 2, Level 40, No.3 Jalan Bangsar, KL Eco City 59200, Kuala Lumpur, Malaysia

New Zealand

Airwallex (New Zealand) Limited

c/- CSNZ, Level 5, 79 Queen Street, Auckland 1010, New Zealand

Singapore

Airwallex (Singapore) Pte Ltd

Airwallex Capital (Singapore) Pte Ltd (discretionary portfolio management service)

#20-01, Guoco Tower, 1 Wallich Street, Singapore 078881

36 Robinson Road, #20-01, City House, Singapore 068877

Canada

Airwallex (Canada) International Payments Limited

Suite 2600, Three Bentall Centre, 595 Burrard Street, Vancouver, BC Canada, V7X 1L3.

Israel

Airwallex (Israel) Ltd

Derech Menachem Begin 132, Tel Aviv-Yafo, Israel 6701101

Indonesia

PT Skype Sab Indonesia

PT Skye Sab Indonesia, 73A Mampang Prapatan Raya Street, Tegal Parang, Mampang Prapatan, South Jakarta 12790

Mexico

MexPago Transacciones, S.A.P.I. de C.V., Institución de Fondos de Pago Electrónico

Bosque de Duraznos 65, 602B, Bosques de las Lomas, Miguel Hidalgo, Ciudad de Mexico, 117000

UAE

Airwallex Middle East Innovation In Financial Solutions - L.L.C - O.P.C

Silver Castle Building, Mussafah, M33, Plot 67, Office 5, Abu Dhabi, United Arab Emirates)

Vietnam

Payment Telecom Informatics Post A Member Of Company Limited

No. 04-117, Lim Tower 3, 29A Nguyen Dinh Chieu, Sai Gon Ward, Ho Chi Minh City, Vietnam

Personal Information

Use

Legal Basis (only relevant if you are located in a Relevant Jurisdiction or in other jurisdictions which require us to identify the legal basis for each processing)

Account and Profile Information (End User, and/or Representative only)

Personal identifiers such as your name, residential address, email address, phone number, date of birth, social security number, driver’s license number, passport number, tax identification number, username in combination with your password to access your online account, or other similar identifiers.

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; and

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; and

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 help you explore and learn about our features, capabilities and products;

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; and

send you our newsletter or other content, or to send you marketing and promotional messages and offers. 

Necessary to perform our contract with you to provide the Services and to send you communications related to your use of the Services.

Consent to send you promotional or marketing communications (depending on your jurisdiction and our existing relationship with you). 

It is our legal obligation and in our legitimate interests to prevent fraud misuse, or breaches of the Acceptable Use Policy.

Demographic Data (End User and/or Representative only)

We may also collect demographic data about you including your employment history, education, income and other similar information.

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.

It is in our legitimate interests to use this information to improve our Services and Sites.

Identity Verification Data (End User and/or Representative only)

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 validate your identity, we may also conduct a liveness check (for example by making a selfie). 

To the extent required or 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.

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; 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 provide our Services.

It is  our legal obligation and in our legitimate interests to prevent fraud,  misuse or breaches of the Acceptable Use Policy.

Transaction  Data  (End User and/or Representative only)

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.

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.

Necessary to perform our contract with you to provide the Services.

Necessary to satisfy our legal and regulatory reporting obligations under applicable law.

Beneficiary Information (End User and/or Representative only)

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.

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; and

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.

It is our legal obligation and in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy.

Card Related Information (End User only)

Card numbers and details

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.

Necessary to perform our contract with you to provide the Services and to fulfil our legal obligations.

Log Data (End User and/or Representative only)

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.

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.

Necessary to perform our contract with you to provide the Services.

It is our legal obligation and in our legitimate interests to prevent fraud, misuse or breaches of the Acceptable Use Policy and improve the Services.

Device Information (End User and/or Representative only)

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.

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.

Necessary to perform our contract with you to provide the Services, and it is our legal obligation and in our legitimate interests to prevent fraud,  misuse or breaches of the Acceptable Use Policy and improve the Services.

Usage Information 

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.

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.

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.

Location Information (End User and/or Representative only)

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.

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.

Necessary to perform our contract with you to provide the Services.

It is our legal obligation and in our legitimate interests to prevent fraud,  misuse or breaches of the Acceptable Use Policy.

Communications Data

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.

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.

Necessary to perform our contract with you to provide the Services.

Call Recordings

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

To respond to your inquiries and customer support requests.

Necessary to perform our contract with you to provide the Services.

Various other Information 

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

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

We collect this information with your consent.

Any information you may provide us when you participate in contests.

To facilitate promotional contests that you choose to participate in.

We collect this information with your consent.

Any information you may provide us when you participate in promotions or request to receive promotional information.

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.

We collect this information with your consent.

Third Party

Purpose

Third party service providers

We engage a variety of service providers (who in general act as data processors (where we are data controller) or sub-processors (where we are a processor) 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 third 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:

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.