HospoPay is committed to respecting the privacy of your Personal Information and protecting all Personal Information in our possession or control. HospoPay is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Personal Information refers to information that is associated with a specific person and can be used to reasonably identify that person, but does not include information that has been made anonymous and cannot reasonably identify a specific person.
HospoPay operates provides a ‘buy-now-pay-later’ software and technology platform that allows participants in the hospitality industry to manage and pay invoices for purchases of goods and services on 30-day interest-free terms (subject to credit assessment and compliance checks).
The suppliers registered on HospoPay Platform (Suppliers) and HospoPay’s service providers (including designated credit providers) (Third Parties) are independent of HospoPay and may have privacy policies which differ from ours. These Parties are responsible for their own privacy policies and privacy practices, which are available upon request made directly to these Third Parties.
Collecting Personal Information
HospoPay strives to be fair and open about the way we collect information about you and what we intend to do with the information. We receive and store certain types of information from you when you interact with the HospoPay Platform, including to undertake credit and transaction integrity processes in order to assess the provision of an invoice loan to you. A part of your membership terms, you agree that we may direct access Personal Information for these purposes through our connection with your Venue’s accounting or banking systems.
In addition, if you open an HospoPay account with us or use our Products, we may collect the following types of information:
- Contact information, such as your name, address (including your geolocation), phone number and email.
- Financial information, such as the full bank account numbers and/or credit or debit card numbers that you link to your HospoPay account or give us when you use our Products.
- Detailed Personal Information such as your date of birth, drivers license number, or other identification information or documents.
We may also obtain information about you from Third Parties or our affiliates, as well as credit reporting bodies and identity verification services, and publicly or commercially available sources for the purposes of complying with relevant legislation (eg. anti-money laundering laws).
We may also collect your Personal Information if you enter a competition or promotion we run (either directly or through our marketing agents or our affiliates or Third Parties), or if you apply for employment with us either directly or through a recruitment or employment agency. We may collect Personal Information about our staff directly from those staff or from our affiliates or Third Parties. We may also collect the Personal Information of our Suppliers or Third Parties during the course of our business activities. The information we collect may include your name, position, contact details and training records.
In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with the HospoPay Platform or our Products. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.
We may also collect additional information from or about you in other ways, such as through contact with our customer support team, suppliers or service providers (whether via mail, email or through telephone enquiries), your responses to a market survey, and from interactions with HospoPay’s affiliates or Third Parties or as otherwise notified to you at the time.
Using Personal Information
HospoPay only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by law, court, or tribunal order.
We may use Personal Information we collect about you for a number of purposes including:
- provide (or assess whether to provide) our Products, including for credit assessment processes in connection with invoice loans provided through the HospoPay Platform;
- customer support;
- processes invoice loans, including payment of invoice loans and to send notices about your transactions;
- resolve disputes, collect fees, and troubleshoot problems;
- investigate and prevent potentially prohibited or illegal activities;
- enforce our Membership Terms with you;
- customise, measure, and improve the HospoPay Platform and our Products;
- deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
- contact you via telephone, text (SMS) or email messaging, including as authorised by the Membership Terms which apply to our relationship with you;
- compare information for accuracy and verify it with third parties;
- confirm your identity for the purposes of anti-money laundering and counter-terrorism laws and assess applications and your suitability for our Products;
- to consider you for a position at HospoPay or its affiliates for which you have applied;
- for the purpose of performing data analytics including to improve our services;
- for other purposes to which you have consented; and
- as required or permitted by relevant laws and regulations.
You agree that we may use your Personal Information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.
If all or some of your Personal Information is not collected or cannot be verified, we may be unable to provide you with our Products or a customised experience, engage with you, or do business with you.
How we share Personal Information with other parties
We may share your Personal Information with:
- our affiliates and related companies;
- our partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
- our third party suppliers, so that they can provide goods or services to you (or the recipient of third party goods or services) or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you. If you transact with a retailer in another country, we will disclose personal information to such locations.
- financial institutions that we may partner with to jointly create and offer a product;
- credit reporting bodies and collection agencies, including to report account information, as permitted by law. When we share your Personal Information with credit reporting bodies we authorise them to use that information for the purposes of providing their credit reporting services. To request a credit report, we will provide information to the credit reporting body that identifies you;
- banking partners as may be required by credit card association rules for inclusion on their list of terminated merchants;
- companies that we plan to merge with or be acquired by or who may invest in us;
- law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to HospoPay;
- when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of the Membership Terms;
- your nominated referees so that we may check your references if you are applying for a position with HospoPay; and
- other third parties with your consent or direction to do so.
Please note that these third parties may be in other countries where the laws on processing Personal Information may be less stringent than in your jurisdiction. When we disclose your Personal Information overseas, we will take all reasonable measures to ensure that your information is held, managed and accessed in accordance with appropriate standards for the handling of Personal Information.
In addition, you should note that Suppliers that you buy goods or services from or contract with (even if such goods or services are purchased using Invoice Loans provided by HospoPay) have their own privacy policies, and HospoPay is not responsible for their actions, including their information protection practices.
If you open an HospoPay account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on the HospoPay Platform) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with Personal Information. HospoPay is not responsible for the content or information practices of such third parties.
We may require your consent to use and/or disclose your Personal Information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to HospoPay collecting, using and/or disclosing your Personal Information for such other purposes, this may affect HospoPay’s ability to deliver and improve our products and services, or to engage or do business with you.
When you provide us with your name, date of birth and residential address in establishing your profile with us, you consent to us disclosing that information to credit reporting bodies and requesting an assessment of whether it matches personal information held by the body to assist in verifying your identity under anti-money laundering laws. The body may provide us with that assessment and use your personal information, and the names, residential addresses and dates of birth of other individuals, to prepare that assessment.
If there is a failure to verify your identity in the way described above, we will notify you within the secure HospoPay service or otherwise. In Australia, we use Illion (www.illion.com.au) to provide us with the assessment to assist in verifying your identity.
If you do not want to proceed in this way to verify your identity, you should contact us, as provided below.
Marketing and privacy
HospoPay may send marketing materials from time to time to those who have provided HospoPay with Personal Information about products and services offered by HospoPay and its affiliates.
If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message. You can also log-in to your account to opt-out and update your marketing preferences at any time.
Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences. Unless otherwise required to process your requests earlier by law, it may take up to 5 days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests.
Even after you opt-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.
You may also contact us on:
Phone (Australia): 1300 739 707
Mail: Level 1, 121 Trafalgar Street Annandale 2038 NSW
Protecting Personal Information
HospoPay will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.
We also review our security procedures periodically to consider appropriate new technology and updated methods. Only properly authorised people who have a need to access Personal Information to perform their job will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.
Accessing and requesting correction of Personal Information
We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under privacy law, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your Personal Information or do not agree to correct your Personal Information we will tell you why.
If you wish to obtain access to and/or correct your Personal Information held by HospoPay, please contact HospoPay on:
Phone (Australia): 1300 739 707
Mail: Level 1, 121 Trafalgar Street Annandale 2038 NSW
Unless we do not agree to your request for access to Personal Information, in most cases HospoPay will provide you with access as soon as reasonably possible following receipt of your request. If you request corrections to your Personal Information and HospoPay agrees with your request, these changes will be made as soon as practicable. If HospoPay does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you are dissatisfied with our refusal to provide you with access to, or correct, your Personal Information you may also complain to the applicable regulator in your jurisdiction.
Subject to the terms set out in the Membership Terms, you can also close your HospoPay account through the HospoPay Platform. If you close your HospoPay account, we may retain information from your account for a period of time to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or risk, enforce the Membership Terms, or take other actions as required or permitted by law.