WEBSITE PRIVACY POLICY

1. Important information and who we are

Purpose of this privacy notice 

This privacy notice aims to give you information on how The Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service. 

This website is not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller 

The Company is part of the ChangeGroup group of companies operating in various geographical regions, including where The Company operates, and includes The Change Group Denmark ApS, ChangeGroup Sweden AB, The Change Group Helsinki Oy, The Change Group International Plc, The Change Group Corporation Ltd, ChangeGroup ATMs, The Change Group London Ltd, Prosegur Change UK Limited, Alpha Centurion Services Limited, Prosegur Foreign Exchange Pty Limited or any of their subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (referred to herein as "ChangeGroup", "we", "us" or "our".)

Within the European Union

• For the purposes of compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and any applicable data protection laws, the Company, namely the local ChangeGroup entity in the country, to which the local website version you are visiting, relates, is the Data Controller and responsible for your personal data and adhering to data protection and privacy laws within  the European Union.

Outside the European Union 

• If you are based outside of the European Union and have questions or concerns about our use of your personal data, then you may contact your local ChangeGroup Company, or The Change Group International PLC, whose contact details are listed below.   

The Change Group International Plc operates several websites to which this Privacy Notice applies and will be published on them.  

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.  

Contact details for The Change Group International PLC 

Our full details are: The Change Group International Plc 

Full name of legal entity: The Change Group Corporation Ltd/ The Change Group London Ltd/ ChangeGroup ATMs Ltd 

Data Protection Officer: Prettys Solicitors LLP 

Email address: changegroupdpo@prettys.co.uk.   

Postal address: 6th Floor, St Vincent House, 1 Cutler Street, Ipswich, Suffolk, IP1 1UQ 

You have the right to make a complaint at any time to the appropriate data protection supervisory authority (in Australia this is the Office of the Australian Information Commissioner (OAIC) - https://www.oaic.gov.au/about-the-OAIC/contact-us). We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.

Changes to the privacy notice or to your personal data 

This version was last updated in April 2023. Previous versions can be obtained by contacting us. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: 

• Identity Data includes first name, last name, username or similar identifier, title and date of birth. 

• Contact Data includes billing address, delivery address, email address and telephone numbers. 

• Technical Data includes internet protocol (IP) addresses (your login data, browser type and version, time zone setting and location, browser plug-in types and version, operating system and platform) and other technology on the devices you use to access this website. 

• Profile Data includes your username and password, purchases or orders made by you, your interests, feedback and survey responses.   

• Usage Data includes information about how you use our website, products and services. 

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through: 

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our website, or by post, phone, email or otherwise. This includes personal data you provide when you: 

• apply for our products or services; 

• subscribe to our service or publications;  

• request marketing to be sent to you; 

• enter a competition, promotion or survey; or 

• give us feedback or contact us. 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy for further details. 

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:  

• Technical Data from analytics providers or search information providers. 

• Contact from providers of technical and delivery services. 

• Identity and Contact Data from data brokers or aggregators. 

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform the contract, we are about to enter into or have entered into with you. 

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 

• Where we need to comply with a legal or regulatory obligation. 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).  

You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for promotion and, in each case, it is in our Legitimate Interests to use your personal data in this way and we have obtained your consent to this where necessary.  

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company outside ChangeGroup for marketing purposes.  

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.  

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions. 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please refer to the Cookie Policy. 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is related to the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your personal data without your consent, in compliance with the above rules, where this is required or permitted by law. 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.  

• Internal third parties. These include other ChangeGroup companies and organisations who are based in Australia, Austria, Denmark, Estonia, France, Finland, Germany, Spain, Sweden, United Kingdom and USA.  

• External Third Parties.  These include: 

1. IMX Software (UK) Ltd, who provide us with Point of Sale and Reserve and Collect systems. 

2. Zen Managed Services, who maintain our IT managed services 

3. Pritesh Patel, who provides us with website development services. 

4. Professional advisers including lawyers, bankers, auditors and insurers who provide various professional services to us. 

5. Third parties to whom we may choose to sell, transfer or merge parts of our business or assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If that happens then the new owners may use your personal data in the same ways as set out in this privacy policy.   

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

International transfers 

We may share your personal data within ChangeGroup.  Due to the locations in which ChangeGroup companies are based, this may involve transferring your data to locations outside of Australia and may include the UK and the EU.  Data sharing agreements are also in place within ChangeGroup. 

Whilst we do not otherwise currently transfer your personal data to companies within ChangeGroup or to service providers outside of the EU (which has been identified by the Office of the Australian Information Commission as a jurisdiction which has data privacy standards no less onerous than those required by Australian law), it is possible that if we change our service providers or engage a new service provider then they may be based outside of the EU.  In this case we will ensure that the recipients of the data must provide a similar degree of protection to your personal data to that required under Australian law, by ensuring that at least one of the following safeguards is implemented:  

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.  

• Where we use certain service providers, we may use specific contracts terms approved by the European Commission which give personal data the essentially equivalent protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

Please contact our Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.