FR Online Services Privacy Policy
ABN: 59 677 356 526
Website: www.topupmagic.com
Responsibility
- FR Online Services is responsible for all personal information you provide to it and will deal with that information in accordance with the following Privacy Principles.
- FR Online Services has implemented procedures to implement its Privacy Principles and to deal with complaints and enquiries. Our Compliance Manager has overall responsibility for ensuring that FR Online Services and its employees, agents and subsidiaries comply with our Privacy Principles. Our Compliance Manager may be contacted in relation to any enquiry or complaint at: admin@topupmagic.com
Privacy Principles
Purpose
- FR Online Services will collect personal information only for the purpose of providing its services to you or for any purpose that is directly incidental to the provision of those services. In the event that FR Online Services wishes to use your personal information for any other purpose, it will identify such purpose and obtain your consent before doing so, unless the new purpose is required by law.
- FR Online Services is always willing to explain to you the purposes for which your information is being collected.
What kind of personal information we collect and hold?
- Full Name
- Address
- Mobile number
- Email address
- Occupation
- Beneficiary full name
- Beneficiary address
- Beneficiary bank account details
- Proof of ID e.g. Australian Driver’s Licence, State issued Photo ID, Australian Passport or International Passport
- Source of income
- Source of wealth
How do we collect personal information?
We collect personal information from our customer at the time of he/she registers in our website or mobile app. Often we would collect these and additional information by direct communication with the customer e.g phone call, email, WhatsApp, and face to face meetings. We may also collect customers’ personal information from a third party e.g. electronic verification services, referrers, affiliates and marketing agencies. In doing so, we always make sure that the customer is aware of our Privacy and Information Retention Policy. We use the Document Verification Service (DVS) provided by the Australian Government to verify a customer’s identity by confirming the identity information provided by the customer with the government’s records. This service also confirms that customer’s ID information are valid and not expired.
Why do we collect personal information?
FR Online Services Pty Ltd is a money transfer company and its business is considered as designated services and regulated by Australian government agency AUSTRAC. In order for us to satisfy our regulatory obligations under relevant AML/CFT Laws (Anti-Money Laundering and Counter-Terrorism Financing Act 2006.), for example the obligation that FR Online Services takes reasonable steps to verify the identity of its customers. Also as this business is a Reporting Entity, it has obligation to report all the inward and outward money transfer transactions to AUSTRAC with correct and up to date information. Hence it has to collect and verify personal information of its customers and their money transfer activities.
Consent
- FR Online Services will seek your consent to the use of your personal information expressly. For example, FR Online Services will rely on your expressed consent when you register in our website and give us your name, address, telephone number and other details necessary for us to verify your identity.
- You may withdraw your consent at any time, subject to any legal restrictions and subject to any contractual restrictions you have already entered into with us, and provided that you give us reasonable notice in writing. We will explain to you the implications of such withdrawal.
- We may from time to time send you information that is relevant to the provision of our services. If, at any time, you do not wish to receive that information, you may by sending us an email opt-out and request that you are not included in any future mail-outs.
- There may be circumstances in which FR Online Services is obliged to collect, use, or disclose certain personal information without your consent. Such circumstances include:
- a serious and imminent threat to someone's life, health or safety;
- a serious threat to public health or public safety;
- unlawful activity has been, is being or may be engaged in;
- disclosure is required or authorised by law;
- FR Online Services reasonably believes that the use or disclosure is necessary for the prevention, detection, investigation, prosecution or punishment of:
- criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
- the enforcement of laws relating to the confiscation of the proceeds of crime;
- the protection of the public revenue;
- the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
- the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
- If FR Online Services is obliged to use or disclose your personal information under paragraph 4, it will create a written report of the use or disclosure.
Limiting Collection and Retention of Information
- FR Online Services may request the Credit Reporting Agency to provide an assessment of whether personal information given to us, matches (in whole or part) personal information contained in a credit information file in the possession or control of the Credit Reporting Agency.
- The Credit Reporting Agency may use your personal information such as the name, residential address and date of birth contained in credit information files of other individuals, for the purpose of preparing such an assessment.
- The Credit Reporting Agency will then provide FR Online Services with such an assessment. We will notify you in writing if we are unable to verify your identity using a Credit Reporting Agency. We will give you alternative means of verifying your identity, for example, by going to one of our branches with your Photo ID.
- In some circumstances, we may also disclose your personal information to intermediary banks in order to process certain transactions on your behalf, for example, by disclosing your name and address.
- FR Online Services will disclose your personal information and details about your transaction to AUSTRAC.
- The amount and type of information collected by FR Online Services will be limited to that which is necessary to provide our services.
- Personal information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected. However, you should be aware that FR Online Services is obliged under relevant anti-money laundering and counter-terrorism legislation to retain information relating to personal identity for 7 years.
- Subject to any legislative requirements, FR Online Services will destroy, erase, or make anonymous your personal information when it is no longer required to fulfil the purpose for which it has been collected.
- If you refuse or fail to provide any requested information, FR Online Services may not be able to process any transaction/s for you.
Accuracy
- FR Online Services will make reasonable efforts to ensure that your personal information is sufficiently accurate, complete, and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you.
- FR Online Services will not routinely update your personal information, unless such a process is necessary to fulfil the purposes for which the information was collected. In accordance with the Client Agreement, you must notify us as soon as possible if any of the information you have provided to us has changed.
Safeguards
- FR Online Services has in place a range of security safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which it is held.
- The methods of protection may depend on the sensitivity of the information and the format in which it is contained. Security measures employed by FR Online Services include:
- technological measures including SSL 128 bit encryption for all data transfers over the Internet;
- physical measures such as locked filing cabinets and restricted access to offices;
- FR Online Services ensures that its staff are aware of the importance of maintaining the confidentiality of personal information.
Access
- FR Online Services will upon request [and within 10 days of any such request] allow you access to your personal information. The requested information shall be provided or made available in a form that is generally understandable.
- In circumstances where you point out to FR Online Services that any information held by us is inaccurate or incomplete, we will take appropriate action to amend the information as required and, if necessary, notify any third party of the correction.
- There may be circumstances which preclude FR Online Services from providing access to some or all of your personal information. Those circumstances could be:
- the information may contain references to other individuals;
- legal, investigative, security, or commercial proprietary reasons; or
- the information is subject to solicitor-client or litigation privilege.
- FR Online Services may be prohibited by law from providing you with access to your personal information. For example, when the disclosure could:
- threaten the safety or physical or mental health of an individual other than you;
- reasonably be expected to cause immediate or grave harm to your safety;
- reveal personal information about another individual; or
- contravene another law that prohibits the disclosure.
Complaints
- FR Online Services has procedures in place, to receive and respond to, complaints or inquiries about our policies and practices relating to the handling of personal information. For more information, please email to admin@topupmagic.com.
- FR Online Services takes all complaints seriously and will investigate all complaints.
