2. POLICY UPDATES
3. WHO WE COLLECT INFORMATION FROM
We collect personal information from users of our platform and their customers.
4. HOW WE COLLECT INFORMATION
4.1 We collect information regarding your customers when you input data into our platform or website. This is information sent to us by your computer, mobile phone or other access device and includes:
4.1.1 contact information, such as name, address, phone, email and other similar information;
4.1.2 financial information, such as full bank account numbers and/or credit card numbers;
4.1.3 detailed personal information such as dates of birth.
4.2 We assume that you have consent to provide the personal information of your customers to us.
4.3 In certain circumstances, we will collect personal information regarding your customers from third parties. For example, from:
4.3.1 a credit reporting agency;
4.3.2 an individual’s financial advisers;
4.3.3 an individual’s representatives (e.g. authorised representatives or legal advisers);
4.3.4 an individual’s employer;
4.3.5 publicly available sources of information; or
4.3.6 any other organisation identified below (see ‘Disclosing personal information’ below).
4.4 You may choose to provide us with access to certain personal information of your customers stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site.
4.5 We may collect information about your use and interaction with our platform.
5. HOW WE PROTECT AND STORE PERSONAL INFORMATION
5.1 We use the term “personal information” to describe information about an individual whose identity is apparent, or can be reasonably be ascertained, from the information. We do not consider personal information to include information that has been de-identified or made anonymous so that it does not identify a specific individual.
5.2 We store and process personal information securely on our platform.
5.3 We protect personal information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls.
6. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
6.1 Our key purpose in collecting personal information is to provide our services. We may use personal information to:
6.1.1 provide the services on our platform, website and customer support;
6.1.2 resolve disputes, collect fees, and troubleshoot problems;
6.1.3 prevent potentially prohibited or illegal activities, and enforce any relevant agreements;
6.1.4 customise, measure, and improve the content, layout, and operation of the platform and our website;
6.1.5 deliver targeted marketing, service update notices, and promotional offers based on your communication preferences in accordance with the Australian Privacy Principles;
6.1.6 compare information for accuracy and verify it with third parties
6.2 Where personal information is disclosed we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles and other applicable privacy laws and codes.
6.3 As we operate throughout Australia, some of these uses and disclosures may occur outside your State or Territory and/or outside Australia. In some circumstances we may need to obtain your consent or the consent of your customers before this occurs.
7. CONSEQUENCES OF NOT PROVIDING PERSONAL INFORMATION
Failing to provide us with certain personal information means that, potentially, we may not be able to provide the relevant service to you.
8. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
8.1 We may combine your information with information we collect from other companies and use it to improve and personalise our website content and advertising.
8.2 We assume that we have consent to use or disclose personal information for the purposes of informing you about the following matters in a business context unless we are told otherwise:
8.2.1 our products and services that may be of interest and suit your requirements; and
8.2.2 promotions or other opportunities in which you may be interested
8.3 We will provide you with the opportunity to opt out of receiving marketing communications if and when we first send marketing material to you.
8.4 We further assume we have consent to use service providers to assist us with marketing (e.g. mailing services or advertising agencies) unless you advise us otherwise.
8.5 We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
8.6 We may call or text message (SMS) you at a mobile phone number that you have provided to us.
9. HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES
9.1 We may disclose personal information to the following organisations:
9.1.1 outsourced service providers who manage the services we provide (e.g. mailing services, billing and debt recovery functions, marketing services, data analysis specialists, data processing organisations and loyalty program administrators);
9.1.2 our suppliers;
9.1.3 our business associates and others for purposes directly related to the purpose for which the personal information is collected;
9.1.4 credit reporting agencies;
9.1.5 our advisers (including our accountants, auditors and lawyers);
9.1.6 government and regulatory authorities and other organisations, as required or authorised by law;
9.1.7 organisations involved in marketing our products and services;
9.1.8 organisations jointly participating in, or assisting us to manage, a promotion, event, seminar or competition;
9.1.9 organisations involved in a transfer or sale or our assets or business;
9.1.10 organisations involved in managing our corporate risk; and
9.1.11 our related companies
9.2 Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in Australia. However, we will ensure that we take reasonable steps to ensure the third parties do not breach the Australian Privacy Principles in relation to the personal information.
9.4 Where possible, we try to ensure that our disclosure of information to other organisations (for example suppliers) is in a way which does not personally identify individuals.
10. UNSOLICITED PERSONAL INFORMATION
We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately unless it is necessary for one or more of our functions or if it would be unlawful for us to destroy it. Unsolicited information is information that we have not requested from you and could not have collected from you.
11. HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION
11.1 You have the right to access your personal information, subject to some exceptions allowed by law.
11.2 You can review and edit your personal information by:
11.2.1 requesting from us in writing the personal information that we have about you (see ‘Contact us’ below). We will provide you with the information within 28 days of receiving a written request. We may charge a fee for collating and providing access to personal information.
11.2.2 where you have an online account with us, you will be able to update your details from within your private account.
12. KEEPING YOUR PERSONAL INFORMATION ACCURATE AND UP-TO-DATE
We intend to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case so we can provide you with a better service. However, the accuracy of that information largely depends on the quality of the information provided to us. We ask that you let us know if there are any errors in your personal information and keep us up-to-date with changes to your personal information (see ‘Contact us’ below).
13. DEALING WITH US ANONYMOUSLY
We permit individuals to not identify themselves when dealing with us, where practicable.
14. SENSITIVE INFORMATION
14.1 Without your consent, we do not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record. Such information is classified as Sensitive Information.
14.2 We will only collect Sensitive Information in accordance with the Australian Privacy Principles.
15.2 If we do not satisfactorily answer an individual’s concerns, they have the right to make a complaint to the Privacy Commissioner.
16. CONTACT US
Individuals may ask any questions about privacy and the way we manage personal information or obtain a form requesting access to personal information by contacting us in person at or by writing to Level 1, 136 The Parade, Norwood, South Australia, or by telephoning 1300 765 685.
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