Unimoni Australia Privacy Policy

1. Introduction

Unimoni Pty Ltd is an international organisation providing diverse financial services. Working with some of the largest banks and non-banking financial companies, Unimoni has established one of the largest remittance networks in the industry.

Unimoni Pty Ltd. (“UNIMONI”) is an organisation subject to Australia’s Privacy Act 1988 (Privacy Act), the Australian Privacy Principles (APPs), Spam Act 2003 and other applicable regulations for processing Personal Information in Australia through its branches and digital channels. Our principal place of business is at Suite 1 Level 4, 1 Wentworth Street, Parramatta, NSW 2150.

2. Purpose of this Privacy Statement

UNIMONI respects your privacy and is committed to maintaining the confidentiality and security of the Personal Information of its existing, prospective and former customers and beneficiaries (“individuals” or “you”). This Privacy Statement informs you about how we process Personal Information, how we look after it and tells you about your rights with respect to your Personal Information. UNIMONI encourages you to review this Privacy Statement and become familiar with it.

You are entitled to object to UNIMONI’s processing of your Personal Information in certain circumstances, for example, if you no longer want to be contacted by us for marketing purposes. To exercise this right, or for more information, please contact us using the details below.

3. Personal Information processed by UNIMONI

3.1 What does Personal Information mean?

The Privacy Act defines Personal Information as "information or an opinion about an identified or reasonably identifiable individual" such as name, address, telephone number and e-mail address.

UNIMONI collects Personal Information from individuals mainly through its branches, UNIMONI’s websites and third parties or publicly available sources. For more information on these sources of Personal Information, please refer to the sections below.

Where UNIMONI needs to collect Personal Information by law or under the terms of a contract we have with you, and you fail to provide that Personal Information, UNIMONI may not be able to fulfil our contractual obligations (e.g. a money remittance) and we may have to cancel the services you requested.

3.2 Personal Information collected by UNIMONI

To provide the services requested by UNIMONI customers, UNIMONI collects the following Personal Information through its network of branches and Online Money Transfer platforms (OMT):

  • Full Name (sender and recipient of the transaction)
  • Address (sender and recipient of the transaction)
  • Nationality (sender and recipient of the transaction)
  • Telephone, including mobile (sender and recipient of the transaction)
  • Relationship between sender and recipient of the transaction
  • E-mail
  • Age
  • Gender
  • Birth Place
  • Labour details
  • Origin of the financial resources
  • Financial background
  • Identification document (e.g. National ID, Driving License, Passport)
  • Bank Statements
  • Transaction amounts
  • Bank account details
  • Credit / Debit card numbers
  • Marketing & other Contact Preferences

As a financial institution, UNIMONI has certain obligations with regards to identity verification, fraud prevention and other similar security purposes. To ensure compliance with those obligations, certain of the Personal Information described above may be collected from, or verified against, third party sources such as government agencies and consumer reporting agencies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.

3.3 Personal Information collected by UNIMONI websites

At its websites, UNIMONI collects aggregated user data (i.e. information that cannot be used to identify you), Personal Information that individuals voluntarily provide, and Personal Information collected using cookies (as explained in the next section).

3.3.1. Definition and usage of cookies

A "cookie" is a small piece of information that is stored on your device (such as your computer) and which records the way that you use a website so that, when you revisit that website, UNIMONI can provide tailored options based on the information that has been collected from your last visit. Cookies can also be used to analyse traffic and, in some cases, to provide you with tailored advertising and marketing.

Personal InformationFollowing are the broad categories of cookies used on UNIMONI websites:

  • Essential cookies: These cookies make UNIMONI website operation work and therefore they cannot be turned off or rejected. These cookies do not gather any information about you and do not have the ability to remember how you have used our website;
  • Performance cookies: UNIMONI use these cookies to help analyse how its website is used and to improve its performance. For example, UNIMONI use them to understand where visitors to the UNIMONI site are based, how many people visit the website and which sections of the website are the most used;
  • Functionality Cookies: These cookies allow UNIMONI website to remember if you have previously visited the UNIMONI site or the choices you made (e.g. language preferences) to provide a more personalised online experience.
  • Third-Party cookies: These cookies collect information from your device and perform tasks that analyse behaviour and collect other information, such as demographics. These cookies may be used to provide you with personalised advertising.
3.4.2 Third Party Marketing Cookies and Social Advertising

UNIMONI has relationships with online advertisers and social media networks. These partners use cookies and similar technologies for marketing purposes and may serve you with targeted advertising about UNIMONI services while you are on their website or mobile applications. You can choose to decline the Third-Party Cookies that enable this type of marketing at any time by setting your browser to ‘do-not-track’ by default. We encourage you to learn more about how companies use advertising on social media and how to adjust your marketing preferences by reading their privacy statement.

3.4.3 How to manage cookies

Our Performance, Functionality and Third-Party cookies will provide you with a better browsing experience. Most internet browsers are initially set up to automatically accept cookies, however you can decide at any time what type of cookies you want to accept. You can change the settings on your browser to block cookies or to alert you when cookies are being sent to your device.

3.4 Personal Data collected by UNIMONI through Social Media

UNIMONI may process anonymized data derived from individuals’ publicly available social media resources for statistical purposes. Although anonymized information may be derived from your Personal Information, it is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. We may also process Personal Information derived from publicly available social media resources that individuals make available when interacting with us including: Facebook, Twitter, YouTube, LinkedIn, Instagram, Google+, Pinterest, Weibo and WeChat. Such Personal Information may include but is not limited to:

  • Public Social Media Profile Name
  • E-mail
  • Mobile number
  • Region
  • UNIMONI related posts (e.g. Mentions & Hashtags)
  • Complaints/queries.

4.Legal grounds for processing Personal Data

Personal Information will be processed by UNIMONI only if and to the extent that at least one of the following applies:

Compliance with Legal Obligations

UNIMONI may process individuals’ Personal Information when necessary to comply with a legal obligation, e.g. Anti-Money Laundering screening and reporting requirements and where required to comply with court order or judicial proceedings.

Legitimate business interests

UNIMONI may process individual’s Personal Information in pursuance of its legitimate business interests where such processing is necessary, and our interests are not overridden by the privacy rights of the Individuals. E.g., our legitimate business interests may include communication with our customers in relation to requested transactions, pursuit of customer care initiatives, internal record keeping purposes and fraud prevention. For information about this balancing test, please contact us using the details below.

Consent

In certain scenarios, UNIMONI may rely on individuals’ consent to process their Personal Information for a specific purpose. For example, on basis of implied consent, UNIMONI sends direct e-marketing materials to individuals entering a service or business relationship with us and provides an opportunity to opt-out in every communication thereafter.

Contract

UNIMONI may process Personal Information as required to ensure we comply with our contractual obligations towards individuals.

5. Purpose of Data Processing:

UNIMONI generally uses Personal Information from individuals for providing a service. This may include the following:

  • Authorising and processing individuals’ transactions, including effecting and administering money transfers and ensuring proper payment to the designated recipient of funds.
  • Monitoring and improving our services including websites/mobile apps and its content.
  • Sending information to individuals about UNIMONI products and services.
  • Customer care initiatives to improve UNIMONI services.
  • Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
  • Maintaining business and transaction records for reasonable periods, and generally managing and administering UNIMONI business.
  • Meeting insurance, audit and processing requirements.
  • Otherwise as permitted or required by law.

6. Personal Information Sharing

To carry out the processing activities established in this Privacy Statement, UNIMONI may disclose Personal Information relating to individuals to:

  • Data Processors: UNIMONI may share Personal Information with third-party service providers (“Data Processors”), including affiliates of UNIMONI performing services on UNIMONI behalf, for example: information technology, data hosting, marketing, customer care, fraud prevention, etc. UNIMONI takes steps to ensure that Personal Information that is processed by Data Processors is protected and not used or disclosed for purposes other than as directed by UNIMONI.
  • Third Parties: UNIMONI may share Personal Data with third parties acting independently from UNIMONI as may be required in connection with the services provided to individuals, for example: any intermediary banks or other financial institutions involved in the transaction of UNIMONI services.
  • Successors: if UNIMONI is purchased by/sold to a third party, Personal Information held by UNIMONI will be transferred to the successor entity.
  • Relevant Authorities: UNIMONI may disclose individual’ Personal Information as necessary to meet legal and regulatory requirements. This may include disclosure of Personal Information to government authorities, for example, in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations.

7. Cross Border Personal Data Transfers

In connection with providing services to its customers, UNIMONI may transfer Personal Information outside Australia to overseas foreign recipient. When transferring Personal Information outside Australia, UNIMONI ensures that security measures and appropriate safeguards are put in place to protect the Personal Information and to ensure that all transfers comply with applicable data protection law. For example, for transfers of Personal Information between UNIMONI group companies, UNIMONI has in place an intra group data transfer agreement.

8. Individual’s Rights

Individuals have certain rights with respect to their Personal Information. In summary, these are:

  • To be informed: Individuals have the right to receive certain information about how their Personal Information is processed. Therefore we are providing you with this Privacy Statement.
  • Access: Individuals have the right to access and receive a copy of their Personal Information.
  • Correction: Individuals have the right to correct their Personal Information when inaccurate.
  • Right to object: In some circumstances, individuals have the right to object to UNIMONI’s data processing activities, for example, if the individual does not want to be contacted by UNIMONI for marketing purposes.
  • Consent: if UNIMONI relies on consent to process Personal Data, individuals have the right to withdraw their consent at any time by contacting us using the details below.

Individuals are also entitled to lodge a complaint with the Information Commissioner where they consider UNIMONI is processing their Personal Information unlawfully. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance. For more information on your rights, please contact us using the details below.

9. UNIMONI Contact

If you wish to exercise any of your rights, or if you have any queries or suggestions about this Privacy Statement, you can contact UNIMONI at: This email address is being protected from spambots. You need JavaScript enabled to view it.

10. Marketing Communications

UNIMONI employs a strict policy against sending communications if you opted-out from them. Please note that UNIMONI will continue to send administrative communications (i.e. Transaction Notifications) if you opt out from Marketing/Customer Care communications. UNIMONI may also contact individuals in response to their inquiries, to provide services at the Individuals’ request and to manage their requirements.

You may want to discontinue receiving marketing information from UNIMONI. While this may mean that you will not receive product or service information of interest to you, UNIMONI respects your wishes not to be informed directly of these promotions or product introductions.

You may inform UNIMONI at any time that you want to opt-out of these communications by following the opt-out links on any marketing message sent to you or by contacting us.

11. Third Party Websites

UNIMONI websites and emails may contain links to various other websites. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

12. Security Measures to protect Personal Information

UNIMONI takes all reasonable steps to ensure that all Personal Data collected through its branches and websites is treated securely and in accordance with this Privacy Statement and strict data protection standards including implementing measures to manage risks such as encryption, audit and monitoring of internal staff access to Personal Information, etc.

13. Retention of Personal Information

In general, the period for which UNIMONI retains individuals’ Personal Information is aligned with UNIMONI’s data retention obligations under anti-money laundering laws, i.e. seven years after the making of the record. In all cases, UNIMONI only retains Personal Information for as long as is necessary for the purposes described in this Privacy Statement. When determining the appropriate retention periods, UNIMONI will consider different factors, including: contractual obligations and rights; our legal obligations (for example, anti-money laundering laws); statute of limitations under applicable law; potential disputes; guidelines issued by relevant data protection authorities; and UNIMONI’s legitimate business interests. UNIMONI securely erases Personal Information once it is no longer needed.

14. Changes to this Privacy Statement

UNIMONI reviews and updates this Privacy Statement from time to time. We encourage individuals to periodically review this Privacy Statement to make sure they are aware of the latest version. If we make any material changes, we will bring this to your attention.