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Privacy Policy

1. Touch2Pay Pty Ltd commitment to privacy 
(a) Touch2Pay Pty Ltd (ACN: 645778481), its subsidiaries and affiliates in Australia (collectively 
referred to as "we" and "us") are committed to managing personal information in accordance 
with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with 
other applicable privacy laws. 
(b) This document sets out our policies for managing your personal information and is referred to 
as our Privacy Policy. 
(c) In this Privacy Policy, “we” and “us” refers to Touch2Pay Pty Ltd and “you” refers to any 
individual about whom we collect personal information. 

2. About Touch2Pay Pty Ltd
(a) Touch2Pay Pty Ltd is a payments solutions company. 
(b) Touch2Pay Pty Ltd offers a complete range of services, including Including application 
software, card payment terminals, & other payment related software applications.. 
(c) Please contact us for a full list of the companies which comprise Touch2Pay Pty Ltd and 
which are subject to this Privacy Policy. 

3. What information does Touch2Pay Pty Ltd collect about you? 
3. 1. Clients and prospective clients 

(i) When you enquire about our services or when you become a client of 
Touch2Pay Pty Ltd, a record is made which includes your personal information. 
(ii) The type of personal information that we collect will vary depending on the 
circumstances of collection and the kind of service that you request from us, but will 
typically include: 
(A) your name, e-mail, postal address and other contact details; 
(B) information about your employer or an organisation who you 
(C) your professional details; and 
(D) any additional personal information you provide to us, or authorise us to 
collect, as part of your interaction with Touch2Pay Pty Ltd. 

3. 2. Prospective employees or applicants 
(i) We collect personal information when recruiting personnel, such as your name, 
contact details, qualifications and work history. Generally, we will collect this 
information directly from you. 
(ii) We may also collect personal information from third parties in ways which you would 
expect (for example, from recruitment agencies or referees you have nominated). 
Before offering you a position, we may collect additional details such as your tax file 
number and superannuation information and other information necessary to 
conduct background checks to determine your suitability for certain positions (for 
example, positions which involve working with children). 

3. 3. Other individuals 
(i) Touch2Pay Pty Ltd may collect personal information about other individuals who are 
not clients of Touch2Pay Pty Ltd. This includes customers and members of the public 
who participate in events we are involved with, individual service providers and 
contractors to Touch2Pay Pty Ltd, and other individuals who interact with Touch2Pay 
Pty Ltd on a commercial basis. The kinds of personal information we collect will 
depend on the capacity in which you are dealing with Touch2Pay Pty Ltd. 
(ii) If you are participating in an event we are managing or delivering, we may take 
images or audio-visual recordings which identify you. 
(iii) In limited circumstances, Touch2Pay Pty Ltd may collect information which is 
considered sensitive information. For example, if you are injured at an event promoted or 
delivered by Touch2Pay Pty Ltd we may collect health information about you in an 
emergency or otherwise with your consent. 
(iv) We may collect personal information about children (for example, when children 
participate in events we are involved with). Where children do not have sufficient 
maturity and understanding to make decisions about their personal information, we 
will require their parents or guardians to make decisions on their behalf. 
(v) You can always decline to give Touch2Pay Pty Ltd any personal information we 
request, but that may mean we cannot provide you with some or all of the services you 
have requested. If you have any concerns about personal information we have 
requested, please let us know. 

3.4. Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed 

4. How and why does Touch2Pay Pty Ltd collect and use your personal information? 
(a) Touch2Pay Pty Ltd collects personal information reasonably necessary to carry out our 
business, to assess and manage our clients' needs, and provide services including Including 
application software, card payment terminals, & other payment related software 
applications.. We may also collect information to fulfil administrative functions associated 
with these services, for example billing, entering into contracts with you or third parties and 
managing client relationships. 
(b) The purposes for which Touch2Pay Pty Ltd usually collects and uses personal information 
depends on the nature of your interaction with us, but may include: 
(i) responding to requests for information and other general inquiries; 
(ii) managing, planning, advertising and administering programs, events, 
competitions and performances; 
(iii) researching, developing and expanding our facilities and services; 
(iv) informing you of our activities, events, facilities and services; 
(v) recruitment processes (including for volunteers, internships and work 
(vi) responding to enquires and complaints; and 
(vii) fulfilling our KYC & AML legal requirements . 
(c) Touch2Pay Pty Ltd generally collects personal information directly from you. We may collect 
and update your personal information over the phone, by email, over the internet or social 
media, or in person. We may also collect personal information about you from other 
sources, for example: 
(i) our affiliated and related companies; and 
(ii) third party suppliers and contractors who assist us to operate our business. 
(d) Touch2Pay Pty Ltd also collects and uses personal information for market research 
purposes and to innovate our delivery of products and services. 

5. How does Touch2Pay Pty Ltd interact with you via the internet? 
(a) You may visit our website ( without identifying yourself. If you 
identify yourself (for example, by providing your contact details in an enquiry), any personal 
information you provide to Touch2Pay Pty Ltd will be managed in accordance with this 
Privacy Policy. 
(b) Touch2Pay Pty Ltd's website uses cookies. A “cookie” is a small file stored on your computer's 
browser, which assists in managing customised settings of the website 
and delivering content. We collect certain information such as your device type, browser type, 
IP address, pages you have accessed on our websites and on third-party websites. You are not 
identifiable from such information.
(c) You can use the settings in your browser to control how your browser deals with cookies. 
However, in doing so, you may be unable to access certain pages or content on our 
(d) Touch2Pay Pty Ltd's website may contain links to third-party websites. Touch2Pay Pty Ltd is 
not responsible for the content or privacy practices of websites that are linked to our 

6. Can you deal with Touch2Pay Pty Ltd anonymously? 
Touch2Pay Pty Ltd will provide individuals with the opportunity to remain anonymous or use a 
pseudonym in their dealings with us where it is lawful and practicable (for example, when making a 
general enquiry). Generally, it is not practicable for Touch2Pay Pty Ltd to deal with individuals 
anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about 
you, you may be unable to utilise our services or participate in our events, programs or activities we 
manage or deliver.

7. How does Touch2Pay Pty Ltd hold information? 
(a) Touch2Pay Pty Ltd stores information in paper-based files or other electronic record keeping 
methods in secure databases (including trusted third party storage providers based in Australia or 
overseas). Personal information may be collected in paper-based documents and converted to 
electronic form for use or storage (with the original paper-based documents either archived or 
securely destroyed). We take reasonable steps to protect your personal information from misuse, 
interference and loss and from unauthorised access, modification or disclosure. 
(b) Touch2Pay Pty Ltd maintains physical security over paper and electronic data stores, such as 
through locks and security systems at our premises. We also maintain computer and network 
security, for example, we use firewalls (security measures for the internet) and other security 
systems such as user identifiers and passwords to control access to our computer systems. 
(c) Our websites do not necessarily use encryption or other technologies to ensure the secure 
transmission of information via the internet. Users of our websites are encouraged to exercise 
care in sending personal information via the internet. 
(d) We take steps to destroy or de-identify information that we no longer require. 

8. Does Touch2Pay Pty Ltd use or disclose your personal information for direct 

(a) Touch2Pay Pty Ltd may use or disclose your personal information for the purpose of 
informing you about our services, upcoming promotions and events, or other opportunities 
that may interest you. If you do not want to receive direct marketing communications, you 
can opt-out at any time by contacting us using the contact details below. 
(b) If you opt-out of receiving marketing material from us, Touch2Pay Pty Ltd may still contact 
you in relation to its ongoing relationship with you. 

9. How does Touch2Pay Pty Ltd use and disclose personal information? 9.1. 
For clients
The purposes for which we may use and disclose your personal information will depend on the 
services we are providing you. For example, if you have engaged us to deliver a service, we may 
disclose information about you to service providers where this is relevant to our services.

9.2. For customers and participants
If you are a customer or participant in an event, we may disclose your personal information to 
our clients and venues where this is reasonably necessary for, and relevant to, the delivery of 
the event. We may use images or audio-visual recordings which identify you for promotional 
purposes where you would reasonably expect this to occur.

9.3. Disclosure to contractors and other service providers
(i) Touch2Pay Pty Ltd may disclose information to third parties we engage in order to 
provide our services, including contractors and service providers used for data 
processing, data analysis, customer satisfaction surveys, information technology 
services and support, website maintenance/development, printing, archiving, mailouts, and market research. 
(ii) Personal information may also be shared between related and affiliated companies of 
Touch2Pay Pty Ltd, located in Australia or overseas. 
(iii) Third parties to whom we have disclosed your personal information may contact you 
directly to let you know they have collected your personal information and to give you 
information about their privacy policies. 

9.4. Use and disclosure for administration and management
Touch2Pay Pty Ltd will also use and disclose personal information for a range of
administrative, management and operational purposes. This includes:
(i) administering billing and payments and debt recovery; 
(ii) planning, managing, monitoring and evaluating our services; 
(iii) quality improvement activities; 
(iv) statistical analysis and reporting; 
(v) training staff, contractors and other workers; 
(vi) risk management and management of legal liabilities and claims (for example, 
liaising with insurers and legal representatives); 
(vii) responding to enquiries and complaints regarding our services; 
(viii) obtaining advice from consultants and other professional advisers; and 
(ix) responding to subpoenas and other legal orders and obligations. 

9.5. Other uses and disclosures
We may use and disclose your personal information for other purposes explained at the time of 
collection or otherwise as set out in this Privacy Policy.

10. How can you access or seek correction of your personal information? 
(a) You are entitled to access your personal information held by Touch2Pay Pty Ltd on request. To 
request access to your personal information please contact our privacy officer using the 
contact details set out below. 
(b) You will not be charged for making a request to access your personal information but you 
may be charged for the reasonable time and expense incurred in compiling information in 
response to your request. 
(c) We will take reasonable steps to ensure that the personal information we collect, use or 
disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if 
you notice errors or discrepancies in information we hold about you and letting us know if your 
personal details change. 
(d) However, if you consider any personal information we hold about you is inaccurate, out-ofdate, incomplete, irrelevant or misleading you are entitled to request correction of the 
information. After receiving a request from you, we will take reasonable steps to correct 
your information. 
(e) We may decline your request to access or correct your personal information in certain 
circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, 
we will provide you with a reason for our decision and, in the case of a request for correction, we 
will include a statement with your personal 
information about the requested correction.

11. What should you do if you have a complaint about the handling of your personal 

(a) You may contact Touch2Pay Pty Ltd at any time if you have any questions or concerns 
about this Privacy Policy or about the way in which your personal information has been 
(b) You may make a complaint about privacy to the privacy officer at the contact details 
set out below. 
(c) The privacy officer will first consider your complaint to determine whether there are simple or 
immediate steps which can be taken to resolve the complaint. We will generally respond to 
your complaint within a week. 
(d) If your complaint requires more detailed consideration or investigation, we will acknowledge 
receipt of your complaint within a week and endeavour to complete our investigation into 
your complaint promptly. We may ask you to provide further information about your 
complaint and the outcome you are seeking. We will then typically gather relevant facts, 
locate and review relevant documents and speak with individuals involved. 
(e) In most cases, we will investigate and respond to a complaint within 30 days of receipt of 
the complaint. If the matter is more complex or our investigation may take longer, we will 
let you know. 
(f) If you are not satisfied with our response to your complaint, or you consider that 
Touch2Pay Pty Ltd may have breached the Australian Privacy Principles or the Privacy Act, 
a complaint may be made to the Office of the Australian Information Commissioner. The 
Office of the Australian Information Commissioner can be contacted by telephone on 1300 
363 992 or by using the contact details on the website ( 

12. How changes are made to this Privacy Policy? 
Touch2Pay Pty Ltd may amend this Privacy Policy from time to time, with or without notice to you. We 
recommend that you visit our website ( regularly to keep up to date with any 

13. How can you contact Touch2Pay Pty Ltd? 
The contact details for Touch2Pay Pty Ltd are:
(a) Touch2Pay Pty Ltd privacy officer: 
(b) 32B Hope Street, South Brisbane, Queensland, 4101 
This Privacy Policy was last updated on 17th April 2023

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