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This Privacy Policy (“Policy”) explains how Aspire Payment Pty Ltd (“Zinga Wallet,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you use the Zinga Wallet mobile application and related online services (collectively, the “Service”).
By downloading, registering, or using the Zinga Wallet app, you agree to the terms of this Policy. If you do not agree, please discontinue use of the Service.
1. Information We Collect
We collect and process personal information necessary to provide secure financial and payment services.
• Personal Information: Your full name, email address, phone number, date of birth, and identification details required for verification (such as driver’s licence, passport, or other government-issued ID).
• Financial & Transaction Data: Your bank account details, card information, transaction history, payment references, and wallet balance information.
• Device & Technical Data: Information such as IP address, device identifiers, operating system, app version, mobile network, and diagnostic or crash logs.
• Usage Data: Details about your activity within the app, including preferences, transaction frequency, and analytics data used to improve the Service.
• Location Data: Approximate or precise location information (collected only if you grant permission through your device settings).
• Support & Communication: Messages, feedback, or documentation submitted via in-app chat, customer support, or email.
• Sensitive Information: If required by law or for enhanced verification (e.g. biometric or facial verification), we may collect limited sensitive information with your explicit consent.
2. How We Collect Information
We collect personal information:
• Directly from you through registration, identity verification, forms, or communications.
• Automatically through cookies, device logs, and analytics tools.
• From third parties such as Aspire, payment processors, identity verification providers, or referral partners, in accordance with applicable law.
3. How We Use Your Information
We use your information to:
• Operate, maintain, and improve the Zinga Wallet Service.
• Process and authenticate transactions, including KYC and AML compliance.
• Facilitate payments, transfers, and account management.
• Detect, investigate, and prevent fraud, unauthorised access, or unlawful activities.
• Communicate with you about your account, updates, and support.
• Conduct data analytics to improve functionality and user experience.
• Comply with legal and regulatory obligations under Australian law.
• Provide referral and partner services (e.g. Aspire and other third-party integrations).
4. Legal Basis for Processing
Our collection and use of personal information are governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where applicable, we also comply with the General Data Protection Regulation (GDPR) and other international standards.
We process your data on the following bases:
• Contractual necessity: to deliver the services you request.
• Legal obligation: to meet compliance and regulatory requirements.
• Legitimate interest: to maintain, enhance, and secure our services.
• Consent: for optional features such as marketing, location access, or biometric verification.
5. Disclosure and Sharing of Information
We share personal information only when necessary to deliver our services, including with:
• Payment processors, banks, and financial institutions involved in transactions.
• Identity verification and compliance partners assisting with KYC/AML checks.
• Aspire and other trusted partners supporting payment facilitation or referral services.
• Technology and cloud providers offering hosting, storage, or analytics.
• Regulatory or law enforcement bodies as required by law.
• Business successors in the event of a merger, acquisition, or restructuring.
• Other third parties with your express consent.
Once you access or provide information to a third party through our Service, their own privacy policies and practices will apply. We are not responsible for the privacy, security, or data handling practices of third parties, except where required by law.
6. Data Storage and Security
We use robust technical and organisational measures to safeguard your data, including:
• Encryption of data at rest and in transit.
• Secure data hosting in Australia and/or reputable international cloud providers (subject to legal safeguards).
• Access restricted to authorised staff bound by confidentiality.
• Regular monitoring, system audits, and security testing.
• Breach Notification: If a data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required by law.
7. Data Retention
We retain personal information only as long as necessary for service provision or legal compliance. Financial and transactional data may be retained for up to seven (7) years under Australian tax and recordkeeping laws. When data is no longer required, it will be securely deleted, anonymised, or de-identified.
8. Cookies, Analytics, and Tracking Technologies
Our website and app may use cookies, analytics SDKs, and similar technologies to:
• Enhance user experience and performance;
• Remember preferences;
• Analyse usage trends and prevent fraud.
You can disable or manage cookies via your device or browser settings. Some app features may not function correctly if cookies are disabled.
9. Your Rights and Choices
You have the right to:
• Access your personal data;
• Request corrections to inaccurate or outdated information;
• Request deletion of personal data (subject to legal obligations);
• Withdraw consent for optional processing;
• Opt out of marketing communications.
To exercise these rights, contact our Privacy Officer (details in Section 15). We may request proof of identity before acting on your request.
10. Cross-Border Data Transfers
If personal data is transferred or processed outside Australia, we ensure appropriate protections are in place — such as contractual clauses or secure transfer mechanisms. By using the Service, you consent to such international transfers as required for service delivery.
11. Automated Decision Making
We may use automated tools for fraud detection, risk assessment, and compliance checks. These processes do not make decisions with significant legal effects without human review.
12. Children’s Privacy
Zinga Wallet is not intended for individuals under 16 years of age.
We do not knowingly collect data from children. If such information is discovered, it will be deleted promptly.
13. Complaints and Dispute Resolution
If you have concerns or wish to make a complaint about our data handling, please contact our Privacy Officer. We will respond promptly and aim to resolve all issues within a reasonable timeframe.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
14. Updates to This Policy
We may update this Policy from time to time to reflect legal, operational, or technical changes. All updates will be published on our website and in-app, with a revised “Effective Date.” We may also notify users by email or in-app alert where changes are significant.
15. Contact Us
If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you would like to exercise your privacy rights and choices, please contact us using the details below. We will respond within a reasonable timeframe and in accordance with applicable privacy laws.
Privacy Officer – Zinga Wallet
Email: [email protected]
Address: 70 Stirling Terrace, Albany, Western Australia, Australia