GoESCROW

1.    Our Privacy Obligations

GoEscrow Pty Ltd (ACN 650 709 354) (GoEscrow) cares about personal information and takes privacy matters seriously.  GoEscrow Pty Ltd are AFS Representative No. 001309800 of Australian Financial Services Licence (AFSL) No. 526194.  GoEscrow retains important personal and financial information and as such chooses to follow Australian Privacy Principles (APPs) as our Privacy Act 1988 compliant framework.   The principals regulate how we handle personal information.

The Australian Privacy Principals can be read here:  https://www.oaic.gov.au/privacy/australian-privacy-principles/read-the-australian-privacy-principles

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable.  ‘Financial Information’ means information generated from a service transaction or gathered from a banking transaction.

This privacy policy applies to personal information and financial information collected and/or held by GoEscrow and may be updated from time to time.

2.    Personal Information Types

We collect personal information about our customers and their transactions in order to provide our products, services, and support and to comply with government regulatory requirements.

Not all information requested, collected, and processed by us is “Personal Information” as it does not identify individuals specifically.  This will include majority of “User Generated Content” that you provide us with the intention of sharing with other users inside a transaction or within the wider payment protection platform.  Such “Non-Personal Information” is not covered by this privacy policy.  However, as non-personal information may be used in aggregate or be linked with existing personal information it will be treated as personal information.  As such, this privacy policy refers to both personal information and non-personal information.

Our products, services, and customer support are provided through many platforms including but not limited to websites, mobile applications, email, and telephone.  The specific platform and product, service, or support you interact with may affect the personal data we collect.

In some situations, users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information.  Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and control and thus the information provided will not be governed by this privacy policy.

In some situations, users may provide us with personal information over platforms that are outside our control; for example, through social media or forums.  Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.

3.    How We Collect

3.1    Personal information you provide

While you interact with us or use our products and services you may be asked to provide personal information.  This might happen through our website, mobile applications, online chat systems, telephone, paper forms, or in meetings.  The information we may request, collect, or process will be all or some of the following types with samples listed:

  • Account Details – name, password.
  • Contact Details – email address, phone number(s).
  • Location Details – physical address, billing address, country, time zone.
  • Personal Identity – 100+ points of identification comprising Passport, Drivers License and Medicare Card
  • Address Confirmation – rental lease documents, utility bills or government ID documents listing physical address details, property title documents.
  • Financial Information – tax file numbers, bank account details, PayID’s and PayTo facilities.
  • User Generated Content – transaction notes shared and unshared, transaction descriptions, transaction attachments, user to user messages.

3.2    Personal Information provided by others

Customers may initiate a transaction with non-users by providing contact details such as name, email addresses or phone numbers.  In these situations, the information will be collected and stored by us to contact the non-user, to store from whom a new customer was introduced and to prevent abuse of our systems.  Similarly our partners may provide non-user introductions in accordance with their privacy policies by providing contact details such as name, email addresses or phone numbers.  In these situations, the information will be collected and stored by us to contact the non-user, to store from whom a new customer was introduced and to prevent abuse of our systems.  Whilst our partners will be governed by their own privacy policy, any personal information that is transferred to our platform will be treated and protected as though it was submitted by a user.

Banking providers may transmit financial information about payments that include names and transaction references that we may collect or process.

Third party KYC/AML (Know Your Customer / Anti Money Laundering) service providers may provide lists of names of politically exposed persons, sanctions lists, watch lists and adverse media list members that we may collect or process.

3.3    Personal information generated by our staff and services

We create user IDs with unique email address and mobile phone pairs.  We create and store transaction and logging information and may create and store staff generated notes.

We generate transaction data that includes transaction IDs, parties involved with user IDs, amounts involved dates and times.

We generate invoices and credit notes, escrow account receipts and escrow account payment advisories.

We record device metadata, often referred to as device fingerprinting, for the purposes of fraud detection.  Our device fingerprinting may record your browser type, IP address, operating system type, hardware profile, screen size and resolution, software user-agent, system language and country, device orientation, installed fonts and web plugins and system time zone.  This information is combined to create a ‘device hash’ which is a unique mathematical representation of the above attributes.  We store this information as the device fingerprint used for an interaction with our service.

3.4    Personal information provided to others

We may link to other third-party web sites.  These links may be from us of from user generated content.  The third-party sites linked to are not GoEscrow properties and are not under our control and we are not responsible for them or for personal information you may provide to them.  We recommend you consult any third party web site or service providers privacy policies and terms and conditions before choosing to provide personal information to them.

We will not disclose your personal information or transaction data to any third party unless required by government regulatory requirements or to law enforcement or other statutory bodies as required by legislation or court order.  If information is requested and provided to government or law enforcement or other statutory bodies we may or may not inform you.

4.    How We Use

Personal information is used to provide the GoEscrow services.  Financial information is used to provide audit, compliance, and balance tracking.  Both information types are used for fraud detection and for compliance with Anti-Money Laundering and Counter-Terrorism Financing Act 2006.  Specifically we may use the information to:

  • To provide the service or product you have requested.
  • To confirm your identity and create your user ID
  • To facilitate the creation of GoEscrow transactions.
  • To provide technical or other support to you.
  • To answer enquiries about our services or to respond to a complaint.
  • To aid any dispute resolution processes.
  • To promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications).
  • To allow for debugging, testing or to otherwise operate our platforms.
  • To conduct data analysis, research and to otherwise build and improve our platforms.
  • To comply with legal and regulatory obligations.
  • To confirm you are permitted or not permitted to use the service by law.
  • For other purposes with your consent, unless you withdraw your consent for these purposes.

The ‘lawful processing’ grounds on which we will use personal information about our users are (but are not limited to):

  • When a user has given consent;
  • when necessary for the performance of a contract to which the user is party;
  • processing is necessary for compliance with our legal obligations;
  • processing is necessary in order to protect the vital interests of our users or of another natural person;
  • processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

5.    When We Disclose

We may disclose personal information to a parent, subsidiary or affiliate company of GoEscrow Pty Ltd at any time providing the parent, subsidiary or affiliate comply with this policy.

5.1    To other transaction parties

We may disclose your personal information to:

  • Counter parties in a transaction.
  • Affiliates or partners involved in the establishment of a transaction.
  • Third parties involved in settlement of a transaction who are not counter parties where you have made a request to disclose.

5.2    To third party service providers

Third party services providers may reside inside or outside of Australia with technical infrastructure ‘In The Cloud” will hold and process personal information on our behalf as bound by contract to GoEscrow acting under our instruction.  Our third party providers assist us with the following services:

  • SMS transmission facilities
  • Cloud hosting, storage, networking and related information technology services
  • Inbound payment banking services
  • Outbound payment banking services
  • Telephony providers
  • Helpdesk and customer relationship management services
  • Accounting and taxation compliance services
  • Email and other unified communication services

5.3    To other unrelated parties

Information may be disclosed to other third parties for the following reasons:

  • To provide a service or product you have requested.
  • To a dispute management organisation you have requested disclosure to
  • In response to a court instruction, judgement, order or subpoena.
  • If otherwise permitted or required by law
  • For other purposes as requested by you.

6.    Accessing and Correcting Information

You may request access to the information we hold about you and we will make it available to you within a reasonable time if not accessible from our web site or mobile applications.  Requests for a full account audit report will be processed within fourteen days for transactions with records available up to 364 weeks in the past and will be provided electronically.  Full audit requests made more than twice per year may incur a fee for service.

You may request the correction of any personal information we hold about you with all personal data editable via our web and mobile applications.  For assistance, please email [email protected]

6.1    Erasure and suspension

You have the right to close an account, but this does not entail account record erasure and deletion of personal and financial information as we are required to retain such records for regulatory reasons.

In the case of account closure, the email and mobile phone numbers will be available for reuse for a new account but audit trail data, device fingerprinting and personal records are retained.  This information is no longer available to the account holder via web or mobile applications and any request full account audit reports of closed accounts will incur a fee.

To close an account please use this form:  https://goescrow.com.au/account-bin

You have the right to suspend an account and have all functionality paused.  To suspend an account email [email protected]

You have the right to opt out of GoEscrow marketing communications and profiling.

7.    Escalation

If you have any enquiry, complaint, or escalation requirement about the way our platforms or helpdesk team handle your personal and financial information or seek in any way to exercise your privacy rights in relation to the information we hold about you, you may contact our Compliance Officer as follows:

By Email:          compliance @goescrow.com.au

By mail:            Compliance Officer
                         P.O. Box 141,
                         Kenmore, QLD.  4069  Australia