Privacy Policy

Effective Date: 10 March 2025

To assist us in providing our products and services and in conducting business functions and activities, we need to collect personal information about you.  By providing this information, you agree to its collection, use, and disclosure by our group of companies as detailed below:

• Oligo Digital Pty Ltd ACN 679 588 277
• Oligo Payments Pty Ltd ACN 680 598 029, trading as Oligo

and any of our related entities (collectively referred to as “Oligo”, “we”, “us” or “our” in accordance with this statement and our Privacy Policy).  Our Privacy Policy outlines how we comply with the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).  If you do not agree, you must not provide your personal information, as this may impact our ability to communicate with you or provide our products and services. 

We may disclose your personal information to third parties, including those who provide services to us or assist in delivering our services (such as information technology suppliers, communication service providers, and our business partners), or as required by law, and otherwise in accordance with our Privacy Policy. These third parties may be located overseas, and such disclosures may involve disclosing your personal information to countries including New Zealand, the US, Ireland, Singapore, India, Ukraine, and other parts of Asia and Europe.  

In addition, we may use and disclose your personal information for direct marketing purposes, unless you choose to opt out.  You can opt out at any time as described in our Privacy Policy. 

We may update our Privacy Policy by posting revised versions on our website. Please check our website regularly to stay informed of any changes. Continued use of our products and services after any changes are posted constitutes your acceptance of those changes. Our Privacy Policy provides information on how to access and correct your personal information, file a complaint about a privacy breach, and how we address such complaints.

1. Purpose of this Privacy Policy

1. Oligo Australia Pty Ltd ACN 671 840 994, trading as Oligo, and any of our related entities (collectively “Oligo”, “we”, “us” or “our”) have established this Privacy Policy to inform you about the types of Personal Information we may collect or hold and how we collect, hold, use and disclose that Personal Information. This Privacy Policy details how we handle that Personal Information and your rights regarding its use, including your ability to access and correct that Personal Information. For inquiries about this Privacy Policy, please contact our Privacy Officer using the contact methods provided in Section 15. 
2. Oligo may be affiliated with other companies and entities (“related entities”).  This Privacy Policy applies to the use of your Personal Information by us and our related entities.  These related entities may have their own privacy policies with additional or differing practices.  In cases where their policies conflict with this Privacy Policy, those policies will take precedence concerning the actions of the related entities.  References to “Oligo”, “we”, “us” or “our” in this Privacy Policy also encompass our related entities.

2. Definition of Personal Information

1. Personal Information means any information or opinion about an individual who is identified or can be reasonably identified from that information or opinion.  This includes information, whether it is true or not, and regardless of how it is recorded.  Personal Information includes details that help us identify you, understand your financial position and any other information necessary for us to administer our products and services to you.

3. Types of Personal Information we collect and hold

1. The types of Personal Information we collect depend on the nature of our interaction with you. This information may include, but is not limited to:
   • Customers and potential merchants:
     • Identification details such as full name, date of birth, contact information (e.g., phone number and email) including current and previous addresses.
     • Document identification numbers (e.g., passports, driver’s licences, Medicare numbers, identity cards).
     • Additional identity verification information from third parties, including the Australian Government’s Document Verification Service (DVS), foreign identity verification sources, credit files, and other data reference points.
     • Financial account details including bank account numbers, credit card/debit card numbers, bank statements, and utility account statements
     • Invoices or proof of card transactions (both acquired and spent).
     • Business or company details including ABN, ACN and geographical location.
     • Transaction data including card transactions, QR codes, Buy Now Pay Later transactions and spent card transaction data.
     • Additional information as detailed in paragraph 3.1(e).
   • Customers of merchant:
     • Contact details (e.g., phone number and email) for sending electronic receipts.
     • Transaction data from payments made to merchants using our technologies, including card, QR code, Buy Now Pay Later, and spent card transaction data.
     • Additional information as detailed in paragraph 3.1(e).
   • Suppliers, potential suppliers, and their representatives:
     • Information to assess your business, including details about key personnel.
     • Business contact information (names, roles, contact details) for communication and administration.
   • Employees (current and former), including job applicants:
     • Employment details including status and previous work experience.
     • Information related to employment (potentially including health information).
     • Information from resumes or job applications (including referees, qualifications, work, and academic history)
   • Individuals engaging with us and our technologies:
     • Interaction data including device performance metrics (e.g., location, battery status, connectivity, thermal data) from our devices. 
     • Data and metadata from interactions with our devices, websites, and technologies.
     • Information from social media accounts and other publicly available sources.
   • Information collected via our website and other digital channels:
     • We may also collect information when you: visit our website, submit an online contact or application form, and if and when you correspond with us.
2. We are also required by law to collect certain Personal Information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), the AML/CTF Rules, and other relevant regulations. 

4. How and when do we collect your Personal Information?

1. We collect your Personal Information to conduct our business, provide, market, and sell our products and services, and for the purposes specified in Section 6. In some cases, collecting Personal Information is required by law.
2. We may collect your Personal Information in the following ways:
   • Applying for our products: when you apply for our products or request information about them, we collect Personal Information to perform an identity verification check.
   • Using our products: We gather data on how you use our products, including data from remote readings of device performance (such as hardware sensors).
   • Interacting with our services: We collect information from interactions with our devices and technologies, as well as from visits to our website (see Section 5).
   • Providing goods and services to us: We collect information to manage our relationship with your business and communicate with you.
   • Managing your relationship with us: This includes collecting information when you provide feedback, submit job applications, or contact us.
3. Other situations: when otherwise required or permitted by law.

3. We generally collect Personal Information directly from individuals where it is reasonable and practical.  However, we may also obtain Personal Information from other sources, such as:
   • Identity verification providers: These entities may access various databases and official records to verify your identity. 
   • Nominated representatives: Such as your spouse, accountant, or business brokers.
   • Publicly available information: Information that is accessible to the public. 
   • Related entities: Including related companies or businesses. 
   • Credit reporting agencies: Agencies that provide credit-related information. 

4. We will collect Personal Information from these sources if it is impractical to collect it directly from you or if permitted by law. 
5. If we need to collect sensitive information, such as health data, we will seek your consent unless the law allows us to collect it without your consent. 
6. If we interact with you multiple times regarding the same issue, we may not provide separate privacy notices for each interaction. 
7. If you decide not to provide your Personal Information or if we are unable to collect it, we may not be able to deliver certain information, products, or services, or manage our relationship with you effectively.

5. Information collected via our website and technology

1. Collection by us and Third Parties: We collect Personal Information through our website https://oligo.com.au/ and other related websites, and our third-party service providers may also do so.
2. Google Analytics: We use Google Analytics to analyse website usage. Google Analytics collects data via cookies, which are stored on your device, and generates reports on website use. You can opt out of Google Analytics by installing the browser add-on available at Google Analytics Opt-Out.
3. Click stream data: We collect data such as visit date, time, duration, accessed pages, IP address, and downloaded content for statistical, reporting, and improvement purposes.
4. Cookies: Cookies are small files transferred to your device to store information about your browsing patterns. We use cookies to monitor traffic, improve content and services, and enhance your experience. You can manage cookies through your browser settings. Note that disabling cookies may limit your access to certain website features.
5. Tracking pixels: We employ tracking pixels from third parties to track visitor activities on our website.
6. Interaction data: We collect data and metadata from interactions with our technology to analyse, enhance service quality, and improve product features. This information supports our business functions and potential future developments.
7. Third-party content: Our website may include third-party applications, such as social media buttons. These applications may collect information through your interactions. We are not responsible for the privacy practices of these third parties. Please refer to their privacy policies for details.

6. How do we use your Personal Information? 

This section outlines the general purposes for which we collect and use your Personal Information.

1. We collect and use your Personal Information for various business functions and activities, including to operating efficiently and marketing our products and services.
2. We may collect, hold, and use your Personal Information for the following purposes:
   • Communication: To interact with you, whether you contact us or we need to contact you.
   • Identity Verification and Compliance: To verify your identity and fulfil contractual and legal obligations. This includes performing identity checks through third parties, allowing audits by our vendors and service providers, enabling third-party payment aggregators to offer their services, and complying with statutory and legal requirements.
   • Service Provision and Support: To manage and support your Oligo products and services. This includes account management, providing payment systems, customer support, setting up direct debits, device management, diagnostics, remote administration, and debt recovery.
   • Service Improvement and Product Development: To enhance our services and develop new products. This involves improving our offerings, conducting research to understand customer needs, and creating new products and services.
   • Fraud Prevention and Risk Management: To protect against fraud, theft, and unauthorised use. This includes fraud monitoring, risk assessment, and fraud management.
   • Marketing: To promote and market our products and services. This includes direct marketing and providing information about Oligo, our clients, and business partners.
   • Business Activities: For various business-related activities such as research, recruitment, and safety. This includes personalising your website experience, conducting data analytics, managing business operations, processing job applications, and responding to queries or complaints.
3. We may aggregate and de-identify Personal Information for reporting, statistical analysis, and improving our business operations, products, and services.
4. We reserve the right to monitor, review, retain, and disclose information as required by law, though we are not obligated to monitor website use or retain specific user session content.
5. By providing your Personal Information, you consent to its use as described above and in this Privacy Policy.
6. We may also collect, use, or disclose your Personal Information as necessary for compliance with this Privacy Policy or any agreements you enter into with us, or as required or authorised by law, including under the Australian Privacy Principles in the Privacy Act 1988 (Cth).

7. Disclosure of your Personal Information

This section outlines the circumstances in which we may disclose your Personal Information to others. It includes a non-exhaustive list of the types of third parties to whom we may disclose your Personal Information.

1. Oligo may disclose or provide access to your Personal Information to third parties in connection with the purposes outlined in Section 6.  Depending on the nature of your engagement with us, we may disclose your Personal Information to:
   • Related entities: Our associated companies and internal teams.
   • Nominated representatives: Individuals or organisations you have authorised to act on your behalf.
   • Service providers: Third parties involved in providing services to you, such as:
     • Payment scheme operators (e.g., Visa, MasterCard, EFTPOS, American Express, Alipay, WeChat Pay, UnionPay).
     • Acquiring banks and payment processing service providers.
     • Prepaid issuing programme partners and direct entry processing service providers.
     • Identification service providers who may need to verify your identity with document issuers or official record holders and check other databases.
   • Mobile device manufacturers: Such as Apple, for setting up your mobile device for Mobile Device Acquiring Services. Mobile device manufacturers may also collect and handle personal information about you when you use certain features of your device.  The collection and handling of your personal information by these manufacturers will be governed by their own privacy policies.
   • Supply chain partners and vendors: Entities that supply goods and services to us or assist us in providing products and services.  This includes data storage and processing providers (e.g., cloud service providers), printing and mailing services, marketing agencies, banks, lenders, valuers, insurers, brokers, IT service providers, and employment agencies.
   • Professional advisers: Our legal, auditing, and consulting professionals.
   • Law enforcement and regulatory bodies: Agencies such as AUSTRAC, the ATO, ASIC, DHHS, and the police, as required or authorised by law.
2. As part of our business development activities, we may engage in transactions such as buying, investing in, merging with, or partnering with other companies or organisations.  These transactions may involve the acquisition of customer Personal Information.  In such cases, Personal Information may be included among the transferred assets.  Similarly, if we sell or transfer a portion or the entirety of our business or assets to a third party, or if we seek new investments, we may disclose certain information, including your Personal Information, to potential buyers, purchasers, or investors.  This includes situations involving the sale, potential sale, or investment in our business or assets, as well as in the event of insolvency.

8. Domestic and international disclosure

1. We operate nationally within Australia and may collect, use, and disclose Personal Information throughout Australia, including across states and territories.
2. Your Personal Information may be disclosed, transferred, stored, processed, or used overseas by us or by third-party service providers. This may occur if:
   • Our offices or related entities are situated outside of Australia.
   • We outsource certain activities to overseas providers.
   • Transactions, information, services, or products involve international components.
   • Our computer systems or those of our third-party IT service providers, including servers, are located outside Australia.
3. By providing your Personal Information, you consent to its collection, use, storage, and processing outside of Australia as outlined in this Privacy Policy.
4. Specifically, your Personal Information may be disclosed to third parties in countries such as New Zealand, the US, Ireland, Singapore, India, Ukraine, and other parts of Asia and Europe, where those parties or their computer systems may be located. Such information may be used for the purposes described in this Privacy Policy.  In these situations, you consent to the collection, use, storage, and processing of your Personal Information in those countries, with the understanding that we are not responsible under the Privacy Act 1988 (Cth) for such use or any breaches that occur.  Although you may have rights under local data protection laws to enforce compliance with applicable data protection laws, recourse under the Australian Privacy Act regarding how these overseas parties handle your Personal Information may be limited.

9. Additional uses and disclosures 

1. We may use and disclose your Personal Information for purposes not listed in this Privacy Policy. If we do, we will take reasonable steps to make this known to you at the time we collect or use your Personal Information.

10. Storage and security of Personal Information held by us

1. Storage and protection: Oligo stores information in both paper-based files and electronic records, using secure databases maintained by trusted third-party providers in Australia or overseas.  Paper documents may be converted to electronic format for storage, within the originals either securely archived or destroyed.  We take reasonable steps to safeguard your personal information from misuse, loss, unauthorised access, modification, or disclosure. 
2. Security measures: We implement physical security measures, including locks and security systems at our premises, to protect both paper and electronic data. Our digital security includes firewalls and other protective technologies such as user identifiers and passwords, to manage access to our computer systems. 
3. Internet transmission: Our websites may not always use encryption or other technologies for secure information transmission over the internet. We advise users to exercise caution when sending Personal Information online. 
4. Retention and disposal: We retain and dispose of Personal Information according to our retention policies. Transaction data is kept for at least seven years. When your Personal Information is no longer required, we will either de-identify it or securely delete it from our systems.

11. Privacy in marketing communications

1. You consent to receiving marketing information from us, including promotional material about our products, services, and those of our related entities and third parties, both now and in the future. This may be sent via direct email, SMS or MMS. 
2. To opt out of receiving marketing communications, you can: 
   • Click the ‘Unsubscribe’ or subscription preferences link in any direct marketing email from us, or 
   • Contact us using the contact details provided in Section 15. 
3. If you opt out of receiving marketing material from us, we may still contact you regarding our ongoing relationship with you. 

12. Accessing and updating your Personal Information

1. Right to access: You are generally entitled to access Personal Information held by us.  If you request access, we will provide it unless there are legal or administrative reasons to deny it. If we refuse your request, we will provide reasons where required by law.
2. Self-service access: You can access and update some of your personal and merchant information through Oligo’s Merchant Portal at any time.
3. Requesting access or correction: To request access to or correction of your Personal Information, contact our customer support team by telephone or our Privacy Officer by email as detailed in Section 15. 
4. Accuracy: We strive to keep your Personal Information accurate, complete, and up to date. Please provide accurate information and update it as necessary. Notify us if you believe your information is incorrect, and we will make reasonable efforts to correct it.
5. Submission of requests: For clarity and promptness, we prefer written requests that include detailed information about the changes or access you require.

13. Privacy Policy updates and revisions

1. Policy updates: We may periodically update this Privacy Policy to reflect changes in laws, regulations, practices or technology. 
2. How to notify you: The most current version of our Privacy Policy will be available on our website at Oligo.com.au/privacy. Updates to this policy will be posted on our website. We will endeavour to provide advance notice of significant changes, though this may not always be possible. 
3. Keeping updated: We encourage you to review this page regularly to stay informed about any updates.

14. Privacy complaint handling 

1. Making a complaint: If you believe we have not adhered to this Privacy Policy or have mishandled your Personal Information, please contact our Privacy Officer using the contact details provided in Section 15.
2. Investigation process: We will investigate your complaint and respond within a reasonable timeframe, considering the complexity of the issue.
3. Submission details: For a quicker response, please submit your complaint in writing with detailed information about the issue.
4. Outcome notification: We will inform you of the outcome of our investigation into your complaint.

15. Contact information for privacy concerns

1. If you have any questions or concerns about this Privacy Policy, our handling of your Personal Information, or if you wish to:
   • Make a complaint about a privacy breach;
   • Access or update your Personal Information;
   • Correct inaccurate or outdated Personal Information; or
   • Opt out of direct marketing.

Please reach out to our Privacy Officer using the following contact details:

Phone: +61 3 9981 6888
Email: privacy@Oligo.com.au