Privacy Policy

1

Who We Are

Fintech Pacific is a Fiji-based financial technology company providing and developing digital payment and financial technology solutions.

Our products and services may include digital wallets, payment acceptance, QR payments, card-related services, merchant solutions, money transfers and remittances, travel payment solutions and other financial technology services.

Our products and brands may include DUA, DUAPAY, TravelMate and other products introduced by Fintech Pacific from time to time.

For the purposes of this Privacy Policy, references to “Fintech Pacific Services” include our websites, applications, products and services unless a separate privacy notice applies.

2

Scope of This Privacy Policy

This Privacy Policy applies to personal information collected by Fintech Pacific through:

• our websites, including www.fintechpacific.com
• Fintech Pacific mobile applications and digital platforms
• enquiries and contact forms
• applications for products and services
• customer and merchant onboarding
• payment and transaction services
• customer support and complaints
• promotions and marketing activities
• business and partnership relationships
• other interactions you have with Fintech Pacific

Certain products, including DUA, may have additional privacy notices explaining how information is processed for that particular service.

Where a product-specific privacy notice conflicts with this general Privacy Policy, the product-specific notice will apply to that product.

3

Information We May Collect

The information we collect depends on how you interact with Fintech Pacific and which products or services you use.

3.1 · Personal and Contact Information

We may collect information such as:

• full name
• date of birth
• residential and postal address
• email address
• mobile or telephone number
• nationality or country of residence
• other information necessary to identify or contact you

3.2 · Identity and Verification Information

For products requiring identity verification or regulatory compliance, we may collect:

• passport details
• driver’s licence or other government-issued identification
• photographs or copies of identification documents
• photographs, selfies or other identity verification information
• proof of residential address
• occupation and employment information
• tax or identification numbers where required
• source of funds or source of wealth information
• purpose of transactions or account activity
• other information required for Know Your Customer (“KYC”), Anti-Money Laundering and Counter-Terrorist Financing (“AML/CFT”) or other regulatory requirements

We may use specialist third-party identity verification and compliance providers to assist with these checks.

3.3 · Financial Information

Depending on the services you use, we may collect or process:

• bank account information
• payment account information
• wallet information
• card-related information
• transaction history
• payment amounts
• currencies
• beneficiary or recipient information
• merchant information
• payment references
• information relating to deposits, withdrawals, transfers, refunds or other transactions

Where payment card information is processed through third-party payment processors or card networks, Fintech Pacific may not directly store complete payment card credentials.

3.4 · Transaction Information

When you use a Fintech Pacific payment service, we may collect information about transactions, including:

• transaction date and time
• amount and currency
• sender and recipient information
• merchant details
• transaction location where applicable
• transaction status
• payment method
• device information associated with the transaction
• information required for fraud prevention, reconciliation, settlement and regulatory reporting

3.5 · Merchant and Business Information

If you represent a merchant, company or business partner, we may collect:

• business name
• company registration information
• registered and trading addresses
• directors, shareholders or beneficial owners
• authorised representatives
• bank and settlement details
• business activity information
• transaction information
• documents required for merchant onboarding, due diligence or regulatory compliance

3.6 · Device and Technical Information

When you access our websites, applications or digital services, we may automatically collect information such as:

• IP address
• browser type
• device type
• operating system
• device identifiers
• application version
• login information
• language settings
• access times
• pages or features accessed
• diagnostic information
• security and fraud-related information

3.7 · Location Information

Certain services may process general or precise location information where necessary to provide a feature, protect your account, prevent fraud or comply with legal requirements.

Where required, we will request permission through your device or application before accessing location information.

3.8 · Communications

When you communicate with us, we may retain information relating to that communication, including:

• emails
• customer support enquiries
• complaints
• feedback
• online messages
• telephone interaction records where permitted
• correspondence relating to your account or transactions

4

How We Collect Information

We may collect personal information:

Directly from you, when you register, submit an application, complete a form, contact us or use our services.

Automatically, when you use our websites, applications or payment services.

From merchants and business partners, where information is necessary to process a transaction or provide a service.

From financial institutions and payment providers, including banks, payment processors, card networks and other payment service providers.

From identity and compliance providers, including providers assisting with identity verification, sanctions screening, fraud detection and AML/CFT compliance.

From publicly available or legally accessible sources, where permitted or required for compliance, fraud prevention or verification purposes.

5

How We Use Your Information

We may use personal information to:

• provide and operate our products and services
• create and administer accounts
• verify your identity
• process payments and transactions
• facilitate transfers, remittances and settlements
• provide merchant services
• issue or support payment cards where applicable
• provide customer support
• respond to enquiries and complaints
• communicate important service information
• detect, investigate and prevent fraud
• protect customers, merchants and our systems
• perform AML/CFT, sanctions and other compliance checks
• monitor transactions where required by law
• comply with regulatory reporting requirements
• maintain financial and transaction records
• improve our products and services
• troubleshoot technical issues
• analyse service performance and usage
• develop new products and features
• manage our relationships with customers, merchants and partners
• send marketing communications where permitted
• enforce our agreements and policies
• establish, exercise or defend legal rights
• comply with applicable laws, court orders, regulatory requirements and lawful requests

We will not use personal information for purposes that are materially incompatible with the purposes for which it was collected unless permitted by law or we obtain appropriate consent.

6

KYC, AML/CFT and Regulatory Compliance

As a financial technology and payments business, Fintech Pacific may be required to collect, verify, retain and disclose certain information to comply with financial services laws and regulatory obligations.

This may include requirements relating to:

• Know Your Customer (KYC)
• customer due diligence
• AML/CFT
• sanctions screening
• politically exposed persons
• transaction monitoring
• suspicious transaction reporting
• fraud prevention
• payment system requirements
• card scheme requirements
• other regulatory reporting

Where required by law, we may process or disclose information without seeking additional consent from you.

We may also be prohibited by law from informing you about certain regulatory investigations, reports or disclosures.

7

Automated Fraud and Risk Controls

Fintech Pacific and our service providers may use automated systems to identify unusual, suspicious or potentially fraudulent activity.

These systems may consider information such as transaction behaviour, device information, account activity, location indicators, payment patterns and other risk signals.

Where appropriate, automated alerts may result in additional verification, a transaction being delayed or declined, or an account being temporarily restricted while we conduct further checks.

Such measures are intended to protect customers, Fintech Pacific and the integrity of the payment system.

8

When We May Share Information

We do not sell your personal information to advertisers.

We may disclose information where reasonably necessary to operate our business, provide services or comply with legal requirements.

Recipients may include:

Companies that provide services to us such as:

• cloud hosting
• technology infrastructure
• cybersecurity
• identity verification
• fraud detection
• customer communications
• analytics
• professional advisory services
• customer support technology

We may share information with banks and other financial institutions where necessary to process, settle, reconcile or investigate transactions.

Information may be shared with card networks, payment processors, acquiring institutions, issuing institutions and other participants involved in processing a transaction.

Where you make a payment to a merchant, certain information may be provided to the merchant as necessary to identify, process, reconcile or refund the transaction.

We may disclose information to the Reserve Bank of Fiji, Fiji Financial Intelligence Unit, law enforcement agencies, courts, government agencies or other competent authorities where required or permitted by law.

Information may be shared with lawyers, auditors, accountants, insurers and other professional advisers where reasonably necessary.

If Fintech Pacific undergoes a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, personal information may be disclosed to relevant parties subject to appropriate confidentiality and legal safeguards.

9

International Data Transfers

Fintech Pacific operates in the Pacific region and may use technology providers, payment partners, financial institutions or other service providers located outside Fiji.

As a result, personal information may be processed or stored in countries other than Fiji.

Where information is transferred internationally, we take reasonable steps to ensure that appropriate contractual, technical and organisational safeguards are used, having regard to applicable law and the nature of the information.

International payment transactions may necessarily require information to be transmitted to financial institutions, payment networks or service providers in other countries.

10

Data Security

We take reasonable administrative, technical and organisational measures designed to protect personal information from:

• unauthorised access
• loss
• misuse
• alteration
• disclosure
• destruction

Measures may include encryption, access controls, authentication, monitoring, secure infrastructure, cybersecurity controls and internal policies.

However, no electronic system or method of transmitting information over the internet can be guaranteed to be completely secure.

You are also responsible for protecting your passwords, PINs, devices and other account credentials.

You should notify us immediately if you believe your account, device or credentials have been compromised.

11

Data Retention

We retain personal information for as long as reasonably necessary to:

• provide our services
• maintain your account
• process and reconcile transactions
• respond to disputes and complaints
• meet financial, audit and accounting requirements
• comply with AML/CFT and other regulatory requirements
• prevent fraud
• resolve legal disputes
• comply with applicable law

Certain financial services and identity records may be required to be retained for a prescribed period after a transaction occurs or after the customer relationship ends.

When information is no longer reasonably required and there is no legal or regulatory requirement to retain it, we will take reasonable steps to delete, destroy or anonymise it.

12

Cookies and Similar Technologies

Our websites may use cookies and similar technologies to:

• operate the Website
• remember user preferences
• understand Website usage
• improve performance
• provide security
• analyse Website traffic
• support marketing where appropriate

Some cookies are necessary for the Website to function.

Where required, you may be provided with options to manage non-essential cookies.

You may also control certain cookies through your browser settings, although disabling cookies may affect some Website functionality.

13

Marketing Communications

Where permitted by law, we may use your contact information to send you information about Fintech Pacific products, promotions, features and services.

You may unsubscribe from marketing communications using the unsubscribe option provided in the communication or by contacting us.

Even if you opt out of marketing, we may continue sending important non-marketing communications relating to your account, security, transactions, regulatory matters or changes to our services.

14

Children

Fintech Pacific’s financial services are not intended for children unless a specific product expressly permits use by a minor with appropriate parental or guardian involvement.

We do not knowingly collect personal information from children through services for which they are not eligible.

If you believe that a child has provided personal information to us contrary to our requirements, please contact us.

15

Your Information and Choices

Subject to applicable law and regulatory requirements, you may contact us to:

• request access to personal information we hold about you
• request correction of inaccurate or incomplete information
• update your contact details
• withdraw consent where processing is based solely on consent
• object to certain marketing communications
• raise concerns about how your personal information is handled

Some requests may be restricted where we are legally required to retain information, where disclosure would affect another person’s rights, or where another lawful exception applies.

We may need to verify your identity before responding to a privacy request.

16

Account Closure and Personal Information

Closing a Fintech Pacific account does not necessarily result in immediate deletion of all information associated with the account.

We may retain information after account closure where necessary to comply with financial services, AML/CFT, accounting, fraud prevention, regulatory or legal requirements.

Information retained after account closure will remain subject to appropriate security and access controls.

17

Third-Party Websites

Our websites and applications may contain links to websites or services operated by third parties.

Fintech Pacific is not responsible for the privacy practices of independently operated third-party websites.

You should review the privacy policy of any third-party service before providing personal information.

18

Business Customers and Authorised Users

Where a company, merchant or other organisation provides us with personal information relating to its directors, shareholders, beneficial owners, employees or authorised users, that organisation is responsible for ensuring it has an appropriate basis to provide that information to Fintech Pacific.

We will process such information for purposes including onboarding, account administration, compliance, security and delivery of our services.

19

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• our products and services
• technology
• business operations
• regulatory requirements
• applicable law

The latest version will be published on our Website and will identify the date it was last updated.

Where required, we may provide additional notice of material changes through our Website, applications, email or other appropriate channels.

20

Complaints and Privacy Concerns

If you have a question, complaint or concern about how Fintech Pacific handles your personal information, please contact us.

We will review privacy complaints and aim to respond within a reasonable period.

Where applicable, you may also have the right to raise your concern with an appropriate regulatory, supervisory or dispute-resolution authority.

21

Contact Us

For privacy questions, requests or complaints, please contact:

When contacting us about your personal information, please provide sufficient information for us to identify you and understand your request. We may request additional information to verify your identity before releasing or changing personal information.