Privacy Policy

This policy applies to information collected by Dada International Pty Ltd and its related entities (“DADA” “we”). It outlines how we collect and use personal information that we hold about you in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”).

Our Commitment to You

DADA International Pty Ltd respects each individual customer’s right to privacy. This Privacy Policy sets out the ways DADA is managing your information including upon your access to this website. 

Types of Personal Information 

DADA may collect the following types of personal information:

• Identity Information – your first and last name or title.  
• Contact Information – your email address, physical address, and telephone numbers.
• Financial Information – where you provide this over our Website to purchase one of our products/our services, including information about your investments and transactions and other information related to the services we provide.
• Location Information – your device location if you log into our systems remotely.
• Profile Information – email address, password, username, audit trail of systems used and documents accessed and downloaded.
• Marketing and Communication Information – includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical Information – internet protocol (IP) address, browser type and version, time zone setting and generic location, browser plug-in types and versions, operating system and platform on the devices you use to access our systems.
• Usage Information – information about how you use our systems.

Collection of personal information

DADA is required to collect your personal information to provide financial services and satisfy your needs in customer services from time to time. We only grant access permission to those staff who need to know to process your transactions and serve your accounts. We only collect personal information that is reasonably necessary for us to provide services. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested.

We collect personal information (which may include sensitive personal information) of our clients for our company registration requirements and identification documents listed in our application form) to provide services to you, and we use your personal information (which may include sensitive personal information) for verification including for KYC checking, and related services including marketing. DADA uses the ID3 GBG Global Identity Verification Solution to perform screen checking.

ID3 GBG Global is a third-party organization. You should check out their privacy policy found on their website.

Use and disclosure of your personal information

DADA may use your personal information for the primary purpose of providing remittance and currency exchange services to customers located in Australia (Services). 

Our customers are individual customers who use our services for the purposes of immigration, funding real estate transactions or international students who need financial support. We also have corporate customers who may use our services to facilitate cross-border payments from their clients or their suppliers. In addition, we may have a small number of trustee customers using our services to facilitate investments.

DADA’s legal justification for collecting and using your personal information include where we use your personal information for the following purposes:

• fulfil our contract with you;
• pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy);
• comply with a legal obligation that we have; or
• do something for which you have given your consent.

If we intend to use your personal Information for a new purpose, we will update our privacy notice.

Other related purposes of use of your personal Information include:

• to verify your identity or transactions which you may enter into with us;
• to administer and manage the provision of our products and services;
• to provide you with offers of other DADA products or services;
• to comply with laws and regulatory requirements including complying with any request made by a governmental authority or regulator, including in connection with legal proceedings or the prevention or detection of fraud and crime;
• to comply with DADA’s risk management policies and procedures;
• conducting due diligence as part of a pre-employment screening or acceptance of your account with DADA; or
• another purpose related to the primary purpose.

We may also collate, extract, copy, process or otherwise use the Information from the Services in order to aggregate such Information and anonymise it so as to remove any customer personal Information (“Anonymised Information”). The Anonymised Information may be used by DADA for delivering or improving the Services (including for commercial benefit) or for other business purposes, and it may be shared with members of DADA and/or made available to third parties as part of the Services (or otherwise), provided always that any use of the Anonymised Information by DADA, and any distribution of such Anonymised Information outside of DADA, is in accordance with applicable law.

Types of sensitive personal information

DADA may collect the following types of sensitive personal information:

• Biometric Information – photographs including but not limited to those on passports, Chinese ID card, Australian driver’s licence, Chinese driver’s licence, proof of age cards, centrelink or social security cards, photo ID cards and other forms of ID.
• Religious/Race/Ethnicity Information – photographs including but not limited to those on passports, Chinese ID card, Australian driver’s licence, Chinese driver’s licence, proof of age cards, centrelink or social security cards, photo ID cards and other forms of ID that may reveal your race, religion or ethnicity.
• Health Information – photographs including but not limited to those on passports, Chinese ID card, Australian driver’s licence, Chinese driver’s licence, proof of age cards, centrelink or social security cards, photo ID cards and other forms of ID that may reveal any health information, including but not limited to skin conditions.

The foregoing types of sensitive personal information are not actively collected, rather they may be inadvertently collected, processed, and stored by DADA in the ordinary course of providing services to you.  DADA does not actively collect or process the types of sensitive personal information described above. If DADA becomes aware of a piece or type of sensitive personal information in respect of a data subject, it will seek to delete it.  In this context, you freely give your consent to the collection, storage and processing by DADA of your sensitive personal information, confirm you have capacity to give this consent, confirm you have adequate information in respect of the consent granted, and the consent given is current.

If requested by DADA you will either (i) confirm your consent upon request; or (ii) provide the personal information required by DADA to provide the applicable services to you with any and all sensitive personal information removed.   

Access and correction and updating personal information

Generally, we will provide you with access to your personal information that we hold within a reasonable time of your request unless an exception applies under the Privacy Act. If we refuse access, we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint. In some cases, we may charge you a reasonable administrative fee (for example, $30) to provide you with access to this information.

If you believe the personal information that DADA holds is inaccurate, incomplete or out-of-date, we will take reasonable steps to correct your information within a reasonable period. If we have previously disclosed your personal information to another entity, you may ask that we notify the other entity of the correction. If we refuse correction, we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint.

You should keep us informed of any changes to your information by notifying us in writing (which may be through your financial adviser or stockbroker). We may also ask you to review, confirm and advise of us changes to your personal information.

Storage and Security of information

DADA stores personal information in a combination of computer storage facilities, paper-based files and other records. We take reasonable steps to protect personal information from interference and loss, misuse, unauthorised access, modification or disclosure.

We protect our systems and your account from unauthorised access. 

If after a reasonable period of time (generally, up to 7 years) we are no longer required to hold your personal information, we may delete or destroy it.

To decide how long to keep personal information (also known as its retention period), we consider the volume, nature, and sensitivity of the personal information, the potential risk of harm to you if an incident were to happen, whether we require the personal information to achieve the purposes we have identified or whether we can achieve those purposes through other means (e.g. by using aggregated Information instead), and any applicable legal requirements (e.g. minimum accounting records).

Confidentiality and Permitted Disclosure

Under DADA company policy, our employees are required to maintain and protect the confidentiality of your personal information, and must follow the established procedures to do so. 

We will not sell, share, or reveal any of your personal information, unless you have specifically requested that we do so. 

DADA will take reasonable steps to protect your information from unauthorized access or use by third parties. Depending on the business operation and product and services concerned, DADA may be required to disclose your information to Any agent or third-party service provider of DADA, Credit reporting or reference agencies and/or Courts, tribunals and any regulatory authorities or exchanges which relate to or govern any business of DADA, etc. 

For the purposes we have described, we may disclose your personal information:

• to our suppliers (including service and content providers), contract and service providers, professional advisers, dealers and agents;
• to government agencies or individuals responsible for the investigation and resolution of disputes or complaints covering your use of our services and facilities including for example ASIC, or the OAIC;
• other parties involved in the administration of your investments including stock exchanges, product issuers, investment registries or mailing houses;
• anyone to whom our assets or business (or any part of it) is transferred (or offered to be transferred, subject to confidentiality provisions);
• other entities in the wider DADA group; or
• where you have otherwise consented or as otherwise required or authorised by law.

Overseas disclosure of personal information

We may transfer personal information to related bodies corporate, unaffiliated service providers or other persons to whom we disclose personal information as described in this Privacy Policy in locations beyond Australia (including, but not limited to, the United States, People’s Republic of China, Hong Kong, Vietnam, and Singapore) in the course of storing that information and when using or disclosing it for one of the purposes referred to above.

Prior to transferring personal information to an overseas recipient, DADA will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguards, and that the recipient does not breach the APPs in relation to that information.

Please be aware that overseas recipients and third parties may be from countries whose laws provide various levels of protection for personal Information which are not always equivalent to the level of protection that may be provided under the Privacy Act and APPs.

This may mean for information sent overseas you do not have the protections of or any redress under the Privacy Act or in the foreign jurisdiction for any breach. The overseas recipient may not be subject to privacy obligations equivalent those under the Privacy Act and could be compelled by foreign law to make disclosure of the information.

Contacting us and Complaints

If you wish to contact us for any purpose regarding this policy including making a complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act) you may do so to our Compliance Officer in writing, to the address set out at the end of this policy.

When you contact us, include your email address, name, address and telephone number and clearly describe your complaint. Our Compliance Officer will investigate the complaint and respond to you promptly.

If you consider that we have failed to resolve the complaint satisfactorily, and you are an individual located in Australia, you can file a complaint with the Office of the Australian Information Commissioner (OAIC) by emailing enquiries@oaic.gov.au (or whichever the most current email address/contact details that can be found on the officia OAIC website is) or mailing the complaint to the relevant OAIC postal address.

Postal Address: GPO Box 5218 Sydney NSW 2001

Fax:+61 2 9284 9666

If you have a question or concern about your personal information or this privacy policy statement, please contact us by e-mail: compliance@dadafx.com.au

Changes to this policy

This policy is subject to change from time to time as DADA considers necessary. We will publish material changes by making them available to you on our website.