Privacy Policy

1. Introduction

Jet Support Pty Ltd (ABN placeholder) trading as NewPay ("we", "us", "our", or "NewPay") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our payment processing platform, advertising services, and website (collectively, the "Services").

We comply with the Australian Privacy Principles ("APPs") contained in the Privacy Act 1988 (Cth) and any applicable state or territory privacy legislation. By using our Services, you consent to the collection and use of your information as described in this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.

2. Information We Collect

We collect different types of information depending on how you interact with NewPay. The categories below describe the information we collect from each type of user.

2.1 Merchants

When you register as a merchant on our platform, we collect the following information:

• Business information: legal business name, trading name, Australian Business Number (ABN), business address, business type, and merchant category
• Contact information: name, email address, phone number, and business address of the primary account holder and any authorised representatives
• Financial information: bank account details (BSB, account number, account name) for settlement purposes
• Transaction data: details of payment transactions processed through our terminals, including transaction amounts, dates, times, card type (but not full card numbers), and terminal identifiers
• Terminal information: terminal serial numbers, location data, software versions, and usage metrics
• Identity verification documents: as required for regulatory compliance (e.g., driver's licence, passport)

2.2 Advertisers

When you register as an advertiser on our platform, we collect:

• Company information: company name, ABN or ACN, registered address, and industry
• Contact information: name, email address, and phone number of the primary contact and any authorised representatives
• Billing information: payment method details for prepaid balance top-ups and invoicing
• Campaign data: advertising creative assets, targeting preferences, campaign budgets, and scheduling information
• Performance data: ad impression counts, display duration, and associated transaction values for reporting purposes

2.3 Website Visitors

When you visit our website, we may collect:

• Device information: IP address, browser type and version, operating system, device type, and screen resolution
• Usage data: pages visited, time spent on pages, referral source, click patterns, and navigation paths
• Cookies and similar technologies: as described in Section 8 below
• Form submissions: any information you voluntarily provide through contact forms, inquiry forms, or newsletter sign-ups, including your name, email address, and message content

2.4 Customers (Cardholders)

When you make a payment at a merchant using a NewPay terminal, please note:

• We do not store full card numbers. All card data is processed in compliance with PCI DSS (Payment Card Industry Data Security Standard) requirements.
• We collect truncated card information (last four digits), transaction amount, date and time, merchant location, and card type for transaction processing and reporting.
• Advertising displayed on the terminal does not collect personal information from cardholders. No cameras, microphones, or biometric sensors are used.

3. How We Use Information

We use the information we collect for the following purposes:

• Payment processing: To facilitate and settle card payment transactions between cardholders, merchants, and the acquiring bank
• Account management: To create, maintain, and manage your NewPay account, verify your identity, and communicate with you about your account
• Advertising delivery: To display relevant advertising content on payment terminals based on merchant category, location, and advertiser targeting preferences
• Reporting and analytics: To provide merchants with transaction reports and advertisers with campaign performance data
• Settlement: To process daily settlements and transfer funds to merchant bank accounts
• Platform improvement: To monitor, analyse, and improve our Services, including terminal software, website functionality, and user experience
• Compliance: To comply with legal obligations, including anti-money laundering (AML) and counter-terrorism financing (CTF) requirements, tax reporting, and card scheme rules
• Communication: To send you service-related communications (e.g., settlement confirmations, platform updates, security alerts) and, where you have consented, marketing communications
• Security and fraud prevention: To detect, investigate, and prevent fraudulent transactions, unauthorised access, and other illegal activities
• Dispute resolution: To manage chargebacks, disputes, and complaints

4. How We Share Information

We may share your personal information with the following categories of recipients:

• Payment processing partners: Acquiring banks, card schemes (Visa, Mastercard, eftpos), and payment gateway providers (e.g., Linkly) who are necessary to process transactions
• Terminal providers: Hardware manufacturers (e.g., Verifone) for terminal provisioning, maintenance, and software updates
• Advertisers: We provide advertisers with aggregated, anonymised campaign performance data. We do not share personally identifiable information about individual merchants or cardholders with advertisers without consent.
• Service providers: Third-party vendors who assist us in operating our platform, including cloud hosting providers, email service providers, analytics tools, and customer support platforms
• Legal and regulatory: Government agencies, law enforcement, regulators, or other parties when required by law, subpoena, or court order, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others
• Business transfers: In connection with a merger, acquisition, reorganisation, or sale of assets, your information may be transferred to the acquiring entity
• With your consent: We may share your information with other parties when you have given us explicit consent to do so

We do not sell your personal information to third parties.

5. Data Security

We take the security of your personal information seriously and implement appropriate technical and organisational measures to protect it, including:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
• PCI DSS compliance for all card payment data handling
• Role-based access controls limiting who can access personal information within our organisation
• Regular security audits and vulnerability assessments
• Secure development practices and code review processes
• Incident response procedures for data breaches, in compliance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act
• Staff training on data protection and privacy obligations

While we take reasonable steps to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

6. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our retention periods are as follows:

• Transaction records: 7 years from the date of the transaction, as required by Australian tax law and card scheme rules
• Merchant account data: For the duration of the merchant relationship plus 7 years after account closure
• Advertiser account data: For the duration of the advertiser relationship plus 7 years after account closure
• Contact form submissions: 2 years from the date of submission, unless the inquiry leads to an ongoing business relationship
• Website analytics data: 26 months from the date of collection
• Terminal logs: 12 months from the date of the log entry

When personal information is no longer required, we securely delete or de-identify it in accordance with our data disposal procedures.

7. Your Rights

Under Australian privacy law, you have the following rights in relation to your personal information:

• Access: You have the right to request access to the personal information we hold about you. We will respond to access requests within 30 days.
• Correction: You have the right to request correction of any personal information that is inaccurate, incomplete, out-of-date, or misleading.
• Complaints: If you believe we have breached the Australian Privacy Principles, you may lodge a complaint with us. We will investigate and respond to complaints within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
• Opt-out of marketing: You can opt out of receiving marketing communications at any time by clicking the unsubscribe link in our emails or contacting us directly.
• Anonymity: Where practicable, you have the option of interacting with us anonymously or using a pseudonym. However, if you choose not to provide certain information, we may not be able to provide you with our Services.

To exercise any of these rights, please contact us at privacy@newpay.jetsupport.com.au.

8. Cookies and Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and understand where our visitors are coming from. The types of cookies we use include:

• Essential cookies: Required for the website to function properly (e.g., session management, security tokens). These cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with our website by collecting anonymous usage data (e.g., Google Analytics).
• Functional cookies: Remember your preferences and settings to provide a more personalised experience.
• Marketing cookies: Used to deliver relevant advertising and track the effectiveness of our marketing campaigns.

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, disabling certain cookies may affect the functionality of our website.

Our payment terminals do not use cookies or web tracking technologies. Advertising displayed on terminals is delivered based on merchant category and location, not individual cardholder behaviour.

9. Third-Party Links

Our website and Services may contain links to third-party websites, applications, or services that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. This includes payment card schemes, terminal manufacturers, and any advertisers whose content may be displayed on our terminals.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at privacy@newpay.jetsupport.com.au so that we can take appropriate action.

11. International Transfers

NewPay primarily stores and processes personal information in Australia. However, some of our service providers (such as cloud hosting and analytics providers) may store or process data in other jurisdictions, including the United States, the European Union, and Singapore.

Where personal information is transferred overseas, we take reasonable steps to ensure that the overseas recipient handles the information in accordance with the Australian Privacy Principles. This may include entering into contractual arrangements that require the recipient to comply with privacy obligations substantially similar to those under Australian law.

By using our Services, you consent to the transfer of your information to these jurisdictions, where data protection laws may differ from those in Australia.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last updated" date at the top of this page
• Post the revised Privacy Policy on our website
• For material changes, notify you by email or through a prominent notice on our platform

We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes to this Privacy Policy constitutes your acceptance of those changes.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us:

We will respond to all privacy-related inquiries and complaints within 30 days. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC):