Privacy Policy

We, at AnkorPay Pty Ltd (“AnkorPay”, “we”, “us”, “our”), operate and provide AnkorPay, a payments and spend-management platform for superyachts, including APA and vessel wallets, multi-currency accounts, crew cards and expense reconciliation (the “Platform”), through the AnkorPay web and mobile apps and our website www.ankorpay.io (the “Website”) (the Platform and Website together referred to as the “Digital Media”).

We believe it is important to protect the privacy of personal information and for you to know what type of information we collect and how we treat information we may receive from you.

In this Privacy Notice, we detail what we do with your personal data in our role as data controller. We also set out how we collect personal information about you when you use our services or communicate with us, including when you download or interact with information in our Digital Media, or by third party users of the Digital Media.

Where we process your data as a data processor on behalf of third-party agents, information about the handling of your personal data will be set out in their privacy notices.

This Privacy Policy should be read in conjunction with the Platform’s Terms of Use.

How we collect your personal information

We may collect and store the following types of personal information about you in the following ways:

  • When you use our Digital Media;
  • When you communicate with us (for example, by email or telephone);
  • When you use our social media functions;
  • Through automatic collection through cookies, server logs and other similar technologies; or
  • Where third parties provide your data to us (for example, by agents acting on your behalf).

The types of information we collect

We may process the following personal data about you:

“Contact Information”
your first and last name, address, telephone number and email address.
“Profile Information”
your username, password and other registration information used on our Digital Media.
“Identity Information”
information such as your age, date of birth, country of residence, medical conditions, allergies, passport details, details of yachts you have chartered or worked on, or financial information.
“Communication Information”
information you send us (e.g., reporting problems or queries), which may include voice recordings of telephone calls.
“Data and Usage Information”
data about how you use our Digital Media, including functions/services used, visits, traffic data, location data and weblogs.
“Technical Information”
information such as browser type, operating system, device IMEI number, MAC address, mobile network information and time zone settings.
“Cookie and Tracker Information”
information collected through cookies and tracking technologies, which may include Data and Usage Information and Technical Information.

Our legal basis for processing your personal information

We only process your personal data where we have a legal basis to do so. These include:

Contractual obligation

Processing is necessary for performance of contracts to which you are a party, or to take steps at your request prior to entering into a contract.

Legitimate interests

Processing is necessary for legitimate interests pursued by us. These include:

  • providing our services to you and other customers;
  • ensuring the Digital Media is safe, efficient and customised;
  • providing updated information about AnkorPay’s activities;
  • ensuring Digital Media content is displayed effectively for you and your device;
  • allowing participation in features of the Digital Media;
  • our own marketing and research activities.

Legal obligation

Processing is necessary for us to comply with the law or court orders.

Consent

You have provided explicit consent to our processing, specifically related to data collected via cookies and similar tracking technologies. (See our Cookie Notice for more information.)

Our purposes for processing your personal information

  • To provide the Digital Media services to our customers;
  • To provide access to our Digital Media and ensure a safe, smooth, efficient experience;
  • To train our employees;
  • To prevent, detect and investigate prohibited or illegal activities and enforce our Terms of Use;
  • To manage, customise and improve our services and content;
  • To ensure you receive updated information about our services;
  • To provide targeted marketing and promotional offers;
  • To ensure digital content is presented effectively for your device;
  • To allow you to participate in Digital Media features when you choose;
  • For research to understand industry trends and our Digital Media’s role.

Sharing your personal information

Except as set out in this Privacy Policy or our Terms of Use, we do not share, sell, or lease your personal information to third-parties. We never share your personal information with third parties for direct marketing.

We may disclose your personal information to:

  • Provide our services, meet legal requirements, enforce policies, and protect rights/property;
  • Affiliated companies as needed to provide services;
  • Companies we instruct to provide services (e.g., payment processors)—only as needed and only for permitted purposes;
  • Law enforcement, governmental agencies or third parties where required by law, court order or regulatory authority;
  • Prevent fraud, cyber-crime, or protect our Digital Media or safety of individuals;
  • Other business entities in the event of a merger, acquisition or reorganisation.

Information for Data Subjects in the EEA or UK

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we may transfer your personal information outside the EEA or UK, including to jurisdictions without equivalent data protection laws. Your information will be transferred to and stored in Australia and may be accessed by staff in Australia working for us or our service providers.

When transferring data outside the EEA or UK, we will ensure adequate protections through contractual obligations, international data transfer frameworks, or transfers only to jurisdictions deemed to have adequate protection.

Information for Californian Customers

In accordance with the California Consumer Privacy Act (CCPA), we do not “sell” personal information. We may transfer limited personal data to partners, affiliates or issuers (such as Airwallex Ltd and its affiliates) to perform AnkorPay transaction or transfer services on our behalf. As these disclosures are for business purposes and subject to contractual restrictions, they do not constitute a sale. Californian residents retain full CCPA rights, including access, deletion, and correction rights.

Your rights

You have the following rights at any time:

  • To be informed about the processing of your personal data (purpose, type, recipients, storage periods, sources, automated decision-making details, etc.);
  • To request access to or a copy of your personal data;
  • To request correction if your personal data is inaccurate;
  • To request erasure of your personal data;
  • To object to processing for particular purposes;
  • To request not to be subject to automated decision-making or profiling without appropriate safeguards;
  • To request transfer of your data to another provider where feasible;
  • To opt out of marketing communications (see Opt-Out below).

Security and storage of your information

Although we maintain physical, electronic and administrative safeguards, transmission of information over the internet is not completely secure. Personal information may be stored on secure servers operated by third-party providers. Payment transactions will be encrypted using appropriate technology.

We may store personal data on your device through app caches or browser storage. Personal information is retained only as long as reasonably necessary or as required by law.

How long we keep your information

We retain personal information only as long as necessary for the purposes collected or as required by law. Telephone call recordings may be retained for up to 6 years to resolve disputes or improve our service quality.

Opt-Out

If you provide personal information, you may “opt out” of certain uses (such as newsletters or updates) by selecting or unselecting the relevant options at the time of submission.

You can also unsubscribe from any marketing communications at any time by emailing support@ankor.io with “remove” in the subject line and including the email address you wish to remove. It may take up to 28 days to process your request.

Contacting Us

If you have any questions about this Privacy Policy or wish to raise a complaint, contact us at: info@ankor.io.

We aim to respond within 30 days. If you are not satisfied with our response, you may contact:

  • The Information Commissioner’s Office (UK) at 0303 123 1113; or
  • The Office of the Australian Information Commissioner (OAIC) via their secure form, email enquiries@oaic.gov.au, or by post at GPO Box 5218, Sydney NSW 2001.

Changes to this Policy

We may amend this Privacy Policy at any time by posting updated terms on the Digital Media. All changes take effect immediately. Please check periodically for updates. If you do not accept the changes, you should stop using the Digital Media immediately.