Privacy Policy
This Privacy Policy was last updated October 2023.
- About this Privacy Policy
- Volt Connect Pty Ltd (ABN 18 662 145 708) (Volt, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 15.
- It is important that you read this Privacy Policy together with any other notices or policies we may provide to you on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your Personal Information. This Privacy Policy supplements the other notices and policies, and is not intended to override them.
- From time to time, Volt may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to Volt, we, us or our is also a reference to those related entities.
- Personal Information
“Personal Information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
- What Personal Information do we collect and hold?
- The types of Personal Information we may collect about the individuals we interact with depend upon the nature of our interaction with them. These include (but is not limited to) the following:
- End-users: These include individuals who use Volt’s services to purchase goods or services, or otherwise use Volt’s products or services as a consumer. We receive Personal Information about End-users from Merchants and providers of technical, payment and delivery services, as well as from your bank when you make a payment using Volt’s services. We also receive Personal Information directly from you when you make a payment or if you contact us. We may collect the following types of information from End-Users:
- name;
- age and/or date of birth;
- contact details including telephone numbers (landline and/or mobile);
- residential address (including postal address);
- email address;
- gender;
- a unique transaction reference (which will link to all of the transaction details including the transaction date, beneficiary, method of payment, currency paid);
- payment details, such as your credit card or bank account details including bank name, sort code, account number, whether a business or personal account, balance and currency, transaction history and analysis;
- non-mandatory information you chose to include in your ‘user profile’ such as a user photo;
- payment status including any decisions from your bank to decline payment;
- International Bank Account Number (IBAN);
- information about whether your account is a business or personal account;
- transaction history and analysis;
- information collected via our application and website as specified in paragraph 5.
When you make a payment with Volt, we use data insights to measure performance and optimise conversion. These insights provide Volt with real-time data and analytics to enable us to smart route payments for speed and resilience including to predict settlement times and rates as well as the likelihood of a fraudulent payment. We may provide such information, in connection with the payments they relate to, to our Merchants and Partners.
- Merchants and Partners of Volt: Entities (including individuals who are directors, officers or employees of such entities) who enter into contractual agreements with Volt to facilitate payments for goods and/or services through Volt’s services. If you or your employer or the entity of which you are a director or officer applies for Volt’s products or services we may collect Personal Information about you and the entity on whose behalf you are applying. Such interactions may also include when you contact us, subscribe to Volt for marketing purposes or give us feedback. We may collect the following types of information from Merchants and Partners of Volt:
- your name and/or the name of the entity you are representing including Australian Business Number (ABN);
- contact details including telephone numbers (landline and/or mobile);
- email address;
- identification information such as driving licence details, including driving licence number;
- payment details, such as credit card or bank account details;
- information from social media accounts and profiles; and
- information collected via our application and website as specified in paragraph 5.
- Prospective Employees: Individuals who apply for employment with Volt. We may collect the following types of information from Prospective Employees:
- name;
- contact details including telephone numbers (landline and/or mobile);
- residential address (including postal address);
- email address;
- gender;
- identification information such as driving licence details, including driving licence number;
- occupation and employment details including employment status and any previous work experience; and
- information from or in connection with your resume or job application if you apply for a position with us.
- Any person who comes into contact with Volt and our services: information about your contact with us, including all data and metadata produced by collected data or interactions with Volt, including all user interactions with our services, devices, Websites, and other technologies; photographs and/or images from camera footage such as CCTV cameras in our premises; and information from social media accounts and profiles, and other publicly available sources.
- Volt investors and shareholders: identification information and information about your shareholding, to identify our investors and shareholders and to administer their investment in Volt.
- Volt suppliers, potential suppliers, and their representatives: generally information to assess your business (such as its key personnel); and business contact information (names, roles, contact details) to communicate with you, arrange and administer your provision of goods and services to us.
- End-users: These include individuals who use Volt’s services to purchase goods or services, or otherwise use Volt’s products or services as a consumer. We receive Personal Information about End-users from Merchants and providers of technical, payment and delivery services, as well as from your bank when you make a payment using Volt’s services. We also receive Personal Information directly from you when you make a payment or if you contact us. We may collect the following types of information from End-Users:
- The type of Personal Information that we collect in respect of the above individuals will depend on our interaction with them however we will collect as little Personal Information as required and necessary to engage with them and conduct our services and business functions.
- The types of Personal Information we may collect about the individuals we interact with depend upon the nature of our interaction with them. These include (but is not limited to) the following:
- How and when do we collect Personal Information?
- We collect your Personal Information to allow us to conduct our business functions, to provide market and sell our products and services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law.
- We may collect your Personal Information about you in the course of providing you with goods and/or services, or:
- when you use or buy our products or services;
- when you offer goods or services to Volt;
- when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
- when you request information about us, our products or our services;
- when you provide feedback to us;
- when you visit or fill in a form on our Website (see paragraph 5);
- when you register for or use an account on our Website;
- when you otherwise contact us by telephone, fax, email, social media, post or in person;
- where we otherwise communicate with you; or
- where we are otherwise required or authorised by law to do so.
- The other specific circumstances we may collect your Personal Information from you will depend upon our interaction with you and these are set out below:
- End Users:
- to facilitate payments including contacting your bank to do this; or
- when we confirm your identity for the purposes of security and fraud prevention.
- Merchants and Partners of Volt:
- when you provide your authentication details for our digital products;
- conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations; or
- when you visit premises from which we operate.
- Prospective Employees
- when you visit premises from which we operate;
- when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations; and
- when you submit a job application to us.
- End Users:
- Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.
- We may also collect Personal Information about you from third parties and other sources such as:
- the Merchant or Partner of Volt through which you are seeking to purchase goods and/or services;
- your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors);
- publicly available sources of information; or
- related entities, companies and businesses of Volt,
however we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
- If the Personal Information we collect includes sensitive information, including biometric information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.
- Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
- If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.
- Information collected via our Website and applications
- Personal Information may be collected by us and by our third party service providers who assist us in operating our website at www.volt.io/, including its subdomains and any other website we operate from time to time (collectively the Website).
- We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website or using our applications, including but not limited to the methods set out in this paragraph 5.
- Google Analytics
We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated is used to create reports about the use of our Website. Google will store this information. - If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout
- Cookies
Our Website may use ‘cookies’ from time to time. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. Find out more about the use of cookies on www.allaboutcookies.org. - Cookies may be used on our Website to:
- monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.
- enable core functionality. Without these cookies, services you have asked for, like providing secure payment, cannot be provided. If you disable these cookies, certain parts of the website will not function for you.
- collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer’s hard drive.
- You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You may also control your use of cookies through our Cookie Management Platform.
- If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites. For more information about the cookies we use, please see cookie policy.
- Browser fingerprinting
We also use other forms of technology which serve a similar purpose to cookies and which allow us to monitor, secure and improve our website and services, such as browser fingerprinting. - Browser fingerprinting collects information about your browser type and version, operating system, active plugins, time zone, language, screen resolution and various other active settings.
- If you wish to turn off browser fingerprinting you can do so through our Cookie Management Platform.
- Click Stream Data
When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. - Third party cookies
Your use of our website may result in some cookies being stored that are not controlled by us. This may occur when the part of the website you are visiting makes use of a third-party analytics or marketing automation/management tool or includes content displayed from a third party website. You should review the privacy and cookie policies of these services to find out how these third parties use cookies and whether your cookie data will be transferred to a third country. A list of the third parties who place cookies on the website can be found on our Cookie Management Platform. - Third party content (eg social media links)
Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.
- How do we use your Personal Information?
- We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our customers/clients.
- We may collect, hold and use Personal Information about you:
- to identify and communicate with you;
- to take payments which you have authorised;
- to enable us to provide you with requested information, products or services;
- to enable us to provide Merchants and Partners of Volt with information about the progress of your payment, to allow them to verify that payment has been made;
- to otherwise assist in providing information and support including customer service;
- to help us to manage and enhance products or services we provide to you;
- to help us to manage and enhance goods and services we procure from our suppliers and subcontractors;
- to personalise and customise your experiences on our Website;
- to manage and administer any account you may hold with us;
- to monitor use of our website and use your information to help us monitor, improve and protect our services;
- to use your information to help us assess and improve the Volt services (including to conduct research for the purposes of improving existing products or services or creating new products or services as well as asking you to complete surveys or leave reviews);
- to use information you provide as well as information which we have collected about you to investigate any complaints received from you, or from others, about our website, products or services;
- to use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary;
- to protect you and us from fraud: this includes via Volt’s fraud prevention function, Circuit Breaker, which identifies and blocks suspicious payments and builds a risk profile to manage potential fraud;
- to train machine learning models for various purposes (which includes but is not limited to the purposes of fraud prevention, error detection and improvement of our solution);
- to help us manage our business operations;
- for business support purposes including maintenance, backup and audit;
- to respond to any queries or complaints you may have, or otherwise respond to correspondence you send us;
- to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information; or
- to comply with our statutory and legal obligations.
- The other specific circumstances we may collect, hold and use your Personal Information from you will depend upon our interaction with you and these are set out below:
- End-users:
- to make enquiries with your bank to enable payment;
- to personalise our services for you, such as remembering your preferred bank;
- to provide information about the progress of your payment to our merchants customers to allow them to verify if payment has been made; or
- to use the personal data you have provided to assist our merchant customers in enforcing fraud rules they set to protect their business.
- Merchants and Partners of Volt:
- to collect, manage and process payments as well as manage any fees and charges;
- to collect and recover money owed to us;
- to promote and market our products and services to you;
- to tailor our services to the needs of the Merchant or Partner of Volt (which may be you or your employer), including by implementing contextual or role-based access to customer information in the Fuzebox platform;
- to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners;
- to discharge our obligations as a regulated financial service provider including ‘know your customer’ checks, anti-money-laundering checks, politically exposed persons checks, sanctions checks; and
- in response to requests by government or law enforcement authorities conducting an investigation.
- Prospective employees:
- to provide for the safety and security of workers and onsite visitors, or
- to process any job application submitted by you.
- End-users:
- We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers’ preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.
- We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.
- You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.
- We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
- in accordance with this Privacy Policy or any agreement you enter into with us, or
- required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).
- When do we disclose your Personal Information?
- We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 6. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
- We may also disclose your Personal Information to:
- any of Volt’s internal divisions, business units or departments
- your nominated representatives;
- other organisations or individuals who assist us in providing products and services to you;
- professional service providers and advisors who perform functions on our behalf, such as lawyers;
- representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as who provide IT and system administration and product support services and undertake leadership reporting);
- third party providers who provide us with ‘know your customer’ services, including anti-money-laundering checks;
- banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers; and
- Government, regulatory authorities and other organisations as required or authorised by law.
- We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
- As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.
- Overseas disclosures
- Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
- our offices or related entities are overseas;
- we outsource certain activities overseas;
- transactions, information, services or products have an overseas connection; or
- our computer systems including IT servers are located overseas.
- If you are an End-user, the banks we engage with on your behalf may also disclose your Personal Information overseas in order to facilitate a Volt payment. Please review your bank’s Privacy Policy to understand the specific countries this information may be disclosed or transferred to.
- Your Personal Information may be disclosed to third parties in the EEA or the UK, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, while we will take all reasonable steps and measures to ensure those third parties comply with the Privacy Act 1988 (Cth), where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.
- Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
- Other uses and disclosures
We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information. - Marketing
- If you have enquired about or use our Merchant services, set up an End User account, used our service (including leaving items in a website or app shopping cart but not checking them out or subscribed to a communication such as an email newsletter from us, you consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.
- If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:
- clicking on the ‘Unsubscribe’ or subscription preferences link in a direct marketing email that you have received from us; or
- contacting us using the contact details specified in paragraph 15.
- Storage and security of Personal Information held by us
- We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.
- Where we process information about you as an End-user in connection with our contract with you and the transactions carried out through our services, including processing for verification and fraud purposes, then depending on the nature of the Personal Information involved, we process this data for five years from the date of the relevant transaction or five years from the date our business relationship with the relevant merchant came to an end, for legal and regulatory purposes.
- If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.
- You can access and update your Personal Information
- You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
- You can access and correct some of your Personal Information through the Website by logging into your account and updating or editing your profile at any time. Alternatively, a request for access can be made by contacting us in any of the ways specified in paragraph 15.
- We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
- Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.
- It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
- How do we deal with complaints about privacy?
- If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 15 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.
- It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.
- We will notify you of the outcome of our investigation.
- Updates to this Privacy Policy
We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: au.volt.io/legal/user-privacy where the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes. - What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy
- If you:
- have a query or concern about this Privacy Policy or our Personal Information handling processes
- wish to make a complaint in relation to a breach of your privacy
- would like to access your Personal Information held by us
- would like to update or correct your Personal Information held by us, or
- would like to opt out of direct marketing,
- If you:
please contact us via email at: legal@volt.io.