GLIDER PRIVACY POLICY

Last updated May 2024

Glider is committed to your right to privacy. In the course of carrying out our activities, including providing our platforms and services Glider Pay Pty Ltd (ACN 654 579 325) and our affiliates, subsidiaries, and/or related bodies corporate (together, "Glider" "we," "us" or the "Company") will collect, store, use and disclose Personal Data.

1.  Application

1.1  This Privacy Policy ("Privacy Policy") is an integral part of our terms and conditions applicable to you, and governs the data collection, processing, use, transfer and disclosure made by us in connection with:

(a) visitors to our website: www.gliderpay.com (respectively, "Visitor" and "Website"); 
(b) the services provided by Glider, including a payments communication solution offered by Glider to its customers (respectively, "Glider Solution" "Customer"); 
(c) transactions made by Customer’s end users via the Glider Solution ("End Users"); and 
(d) other related services and applications, 
(collectively, "Services").  Each of the Visitors, Customers and End Users are referred to in this Privacy Policy as "you", "your" or "End User".

1.2  If you choose to use the Services, interact with the Website, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Policy. You may not use the Website and/or Services or submit any data through them if you do not agree to any of the terms of this Privacy Policy.

1.3  This Privacy Policy shall not be construed in any manner to derogate from any other agreement or understanding between Glider and you.

2.  What is Personal Data and how does Glider collect my Personal Data?  

2.1  "Personal Data" or "Personal Information" (will be referred together as "Personal Data"), means any information about an identifiable individual or that identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, online identifiers, IP address, billing information, information concerning households, devices etc.

2.2  "Non-Personal Data", means non-identifiable aggregated data, such as technical data transmitted by the user’s device and aggregated use of the website. This data is not used to identify individuals.

2.3  The ways we may collect your Personal Data include the following.

(a) Directly from the individual. We may collect Personal Data directly from the individual, including while providing our Services, from the Glider Solution, our Website and other online platforms, including using cookies (data files placed on your device or computer).
(b) From third parties. In some circumstances, we do not have a direct relationship with the person whose Personal Data we are receiving, accessing, handling, processing, and/or storing (as applicable). We may receive Personal Data about individuals from third parties with whom the relevant individual has a relationship with, including from Customers as follows. When you interact with our Services via our Customers, we may receive, access and process your Personal Data as follows.

(i) The Customer as your employer. Where our Customer is your employer and/or you’re otherwise engaged by the Customer (for example, as a contractor or other representative), the Customer may disclose your Personal Data to us while enabling your use of our Services.
(ii) The Customer as an entity with whom you interact. Where you interact with one of our Customers, including where you’re their End User, while using our Services, the Customer may make your Personal Data available to us to access and/or otherwise use or handle.

(c) Publicly available information. We may also collect Personal Data from publicly available sources of information, including via websites, directories, and social media channels.

2.4  While your disclosure of Personal Data to the third parties set out above remains governed by your relationship with that third party, including their privacy policy, our access and use of your Personal Data, once we receive access to it from such third parties, will be governed by this Privacy Policy.

3.  What data is collected by Glider and for what purposes is it processed and use?

3.1  We use Personal Data for the purposes specified below and in section 3.3 below.

3.2  We do not knowingly collect or process any  Sensitive Information as defined in the Privacy Act 1988 (Cth).

3.3  In addition to the purposes for processing set out against the specific types of Personal Data in the table above, we also collect, hold, use and disclose Personal Data for the following purposes.

(a) Conducting our business. This includes providing our Services, or the products and services of a third party, to our Customers and the End Users, including personalising a Customer and/or End User’s use of the Services, responding to enquiries, and providing technical support.
(b) Service improvement. To improve and optimise our Services and platforms.
(c) Legal. To comply with any legal obligations that we have in respect of Personal Data.
(d) Security. As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about the products, services, and communications.
(e) Communication. To provide you with information or advertising relating to our Services (including serving and targeting advertisements) or marketing communications we believe may be of interest you.
(f) Advertising. For our internal administrative, research, planning, marketing, and product development purposes.
(g) Administrative. For our internal administrative, research, planning, marketing, and product development purposes.

4.  Will Glider share my personal data with others?

4.1  We may also disclose Personal Data to the following third parties for their use for the same purposes as set out in section 3 of this Privacy Policy. 

(a) Our parent companies and other affiliates and related bodies corporate.
(b) Third-party service providers who assist us so we can make our Services available to our Customers and their End Users and/or assist with ancillary services made available through Services.
(c) Financial Institutions, third parties who provide and support payment infrastructure and networks, payment gateway service providers, and payment processors.
(d) Technology and marketing service providers and partners, such as Google Analytics. 
(e) The Customer as the entity who has employed or otherwise engaged you and/or with whom you, as an End User, have a relationship.
(f) To potential or actual buyers or other third parties involved in any sale, merger, acquisition, or any form of transfer of ownership of our business or consideration of the same.
(g) Other third parties with your consent or direction to do so.

4.2  While our disclosure of Personal Data to such third parties is governed by our privacy policy, such third party’s use of your Personal Data, including contacting them with any queries you have about the Personal Data they hold and how they are using it, will be governed by their privacy policy. It is your sole responsibility to review such privacy policies.

5.  Will Glider transfer my personal data internationally?

5.1  Our databases are currently located in Australia. Personal Data will only be stored or processed in Australia.

5.2  If you would like to receive more information about our practices and policies with respect to our use of service providers and the jurisdictions in which they are located, please get in touch with us using the contact information provided in section 11 below.

6.  How does Glider protect my data?

6.1  The Glider Solution incorporates measures to reduce the risks of loss of information and unauthorised access or use of information. We adopt appropriate and generally accepted data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your Personal Data.

6.2  In particular, your payment information is secured in accordance with the PCI-DSS standard. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure Personal Data, it is not guaranteed and you cannot reasonably expect that the Service and its related databases will be immune from any wrongdoings, malfunctions, unauthorised interceptions or access, or other kinds of abuse and misuse.

7.  Access and correction

7.1  We will take all reasonable steps to ensure any Personal Data we collect, use or disclose is up to date and accurate. If you believe Personal In Data formation that we hold about you is not up to date or accurate, you may ask us to correct it.

7.2  You may ask us to provide you with details of the Personal Information Data we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.

7.3  If we provide you with copies of the information you have requested, to the extent permitted by law, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.

7.4  Please direct all request for access and correction to the email address set out in section 11 below.

8.  Data Retention

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.

9.  Changes to this Privacy Policy

9.1  Glider may, at any time and from time to time, modify this Privacy Policy. Modifications to this Privacy Policy will be posted on the Website, and shall be effective as of the date in which they are posted on the Website. Therefore, you should review the terms of this policy periodically to make sure that you are aware of how we collect, hold, store and use Personal Data.
 
9.2  The date this Privacy Policy was last updated will be set out at the start of the policy.

10.  Complaints

10.1  If you consider a breach of the Privacy Act 1988 (Cth) has occurred, you may direct your query to us using the details set out in the contacting us section below and we will attempt to resolve your complaint as soon as we can, and in any case within 30 days.  

10.2  If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992.

11.  Questions or concerns regarding privacy

If you have any questions or concerns regarding privacy issues, please send us a detailed message to privacy@gliderpay.com and we will make every effort to resolve your concerns without delay.