Privacy Policy

Last Updated: November 2024

Introduction

snug-beaver ("we", "our", or "us") is committed to protecting the privacy of individuals who visit our website and use our services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our website and payment services.

By using our website or services, you consent to the data practices described in this policy. If you do not agree with the terms of this privacy policy, please do not access our website or use our services.

Information We Collect

We may collect information about you in various ways, including:

Personal Information

When you enquire about our services or become a merchant customer, we may collect:

• Name and contact details (email address, business address)
• Business information (company name, industry, estimated transaction volume)
• Banking details for settlement purposes
• Identification documents as required for merchant verification

Transaction Data

For merchants using our payment processing services, we collect and process:

• Transaction amounts and timestamps
• Card type and last four digits (we do not store full card numbers)
• Terminal identification numbers
• Settlement and reconciliation data

Website Usage Information

When you visit our website, we automatically collect:

• IP address and browser type
• Pages visited and time spent on site
• Referring website or search terms
• Device information and operating system

How We Use Your Information

We use the information we collect for the following purposes:

• To provide and maintain our payment processing services
• To process merchant applications and conduct due diligence
• To communicate with you about your account or enquiries
• To improve our website and services based on usage patterns
• To comply with legal obligations and regulatory requirements
• To detect and prevent fraud or unauthorised transactions
• To send service updates and important notices

Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract Performance: Processing necessary to provide our services to you
• Legal Obligation: Processing required to comply with Australian law and regulations
• Legitimate Interest: Processing for fraud prevention, security, and service improvement
• Consent: Where you have provided explicit consent for specific processing activities

Information Sharing

We may share your information with:

• Banking Partners: Financial institutions that process transactions and settlements
• Card Networks: Visa, Mastercard, and other networks as required for payment processing
• Service Providers: Third parties who assist with our operations (hosting, analytics, support)
• Regulatory Bodies: AUSTRAC, ASIC, and other authorities when legally required

We do not sell your personal information to third parties for marketing purposes.

Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• PCI DSS compliance for payment card data
• Access controls and authentication systems
• Regular security assessments and penetration testing
• Staff training on data protection practices

Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. Transaction records are retained for a minimum of seven years in accordance with Australian tax and anti-money laundering legislation.

Your Rights

Under the Australian Privacy Act 1988, you have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your information (subject to legal retention requirements)
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Office of the Australian Information Commissioner

International Data Transfers

Some of our service providers may be located outside Australia. When we transfer personal information overseas, we ensure appropriate safeguards are in place to protect your information in accordance with Australian privacy requirements.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last Updated" date. We encourage you to review this policy periodically.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Privacy Officer
snug-beaver
Suite 405, 221 Queen Street
Melbourne VIC 3000
Email: [email protected]