We respect your rights to privacy under the Privacy Act and we comply with all its requirements in respect of the collection, management and use of your personal information, and the management of data breaches under the Notifiable Data Breach scheme set out in the Privacy Act. We also comply with other applicable law and regulatory guidance, including those relating to the Consumer Data Rights under the Competition and Consumer (Consumer Data Right) Rules 2020 (Cth) in our role as authorised data recipient.
We are also bound by Part IIIA of the Privacy Act, which regulates consumer credit reporting in Australia and is supported by the Privacy Regulation 2013 (Cth) and the Privacy (Credit Reporting) Code 2014.
2. What is your personal information?
What personal information do we collect and hold? We may collect a range of personal information, including:
- mailing or street address;
- e-mail address;
- telephone contact number;
- age or birth date;
- profession, occupation or job title;
- financial and credit-related information, such as the full bank account numbers and/or credit or debit card numbers that you link to your 1derful account or give us when you use our services;
- marital status;
- Government-related identifiers (such as tax file number*, driver’s licence number, Medicare number or passport number);
- the products and services you have purchased or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
- any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites, through our representatives or otherwise;
- and information you provide to us through our service centre, customer surveys or visits by our representatives from time to time; and in relation to AML transaction monitoring by our service providers, criminal convictions, offences and political opinions where returned from a relevant search by Comply Advantage.
* Please know that while we may collect or hold Government-related identifiers, we do not use them as a means of identifying you. In particular, use and disclosure of tax file numbers are strictly regulated by tax laws and the Privacy Act.
We may also collect some information that is not captured by the “personal information” definition because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
3. Apple, Google and Samsung Pay exchange
5. Online advertising and Google Analytics
We may work with online advertising partners to provide you with ads that are relevant and useful for you, including ads located on or through our website from third parties. We may use information collected by us or by third parties to provide you with these ads, which may be based on your activities on our website or on third party websites. If you access any third party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties. Where you access a third party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.
We may advertise on third party websites. When you access our website after viewing one of our advertisements on a third party website, the advertising company may collect information on how you utilise our website (for example, which pages you viewed) and whether you commenced or completed an online application or other online form. We may use Google Analytics website measurement software and systems to assist in tracking traffic patterns to and from our website, aggregating anonymous information about visits to our website, and randomly and anonymously surveying users of our website. The system is used to collect information on our network such as the number of page views, the number of unique visitors, how long these visitors spend on the website and any affiliated websites when they do visit, and common entry and exit points into and from our website and any affiliated websites. Random anonymous surveys are also used to collect further information about our users.
This non-personal information is aggregated using Google Analytics and then used by us in our analysis of our website and any affiliated websites. The Google Analytics data is also accessible by media organisations and research companies for the purpose of conducting industry comparisons with other websites. Our website is coded with a small piece of Google Analytics code that is transparent to you when you read that page. The software stores a cookie in your browser (if you have enabled cookies) which contains a unique identifier to allow us to track the number of unique visitors to our website and any affiliated websites. This information is collected and aggregated by Google Analytics and in no way can you be identified personally and no personal information is stored about you.
In addition to Google Analytics, we may also use other third party analytics tools including Amplitude (an analytics service provided by Amplitude Inc.) to monitor, analyse and collect information about your use of the website. Your browser may allow you to disable this feature, however you may not be able to fully use all of the functions of the website if you do so.
For more information about our online advertising partner and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info. You may also opt out of the Google Analytics feature by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
We may retain your personal information after you have closed your Account for a period of time, for the following purposes:
- to collect any fees you may still owe;
- to resolve disputes with you or troubleshoot issues which may arise;
- to assist with any investigations and prevent fraud or risk;
- to enforce any agreement that we have with you; and
- to take other actions as required or permitted by law.
6. Consent to use your personal information to verify your identity and other purposes
We will notify you if we are unable to verify your identity through this process. If you do not want to use this process to verify your identity, please contact us using our contact information below.
We may also require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected. If you do not consent to us collecting, using and/or disclosing your personal information for such other purposes, this may affect our ability to deliver and improve our products and services, or to engage or do business with you.
7. Access from third-party websites
Once you have established an Account, you may access your Account from our website or from third party websites or via a third party app which are not controlled by us. If you do so, then any information you provide may be shared with that third party. These third party websites or apps will be governed by their own privacy policies. Please review these privacy policies before sharing your personal information, as we are not, and will not be, responsible for the conduct or information practices of that third party.
8. How to access and correct your personal information
You may request access to any personal information we hold about you at any time by contacting us (details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you for providing the information in response to your request for access, provided that the charge does not apply to the making of the request and is no more than the cost of that response and excludes our costs of obtaining related legal advice or other advice.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if we are required or authorised to refuse access by law. If that happens, we will give you written notice of the reasons for the refusal within 30 days of receipt of your request, together with information about how you can complain about our refusal if you wish to do so.
If you believe that personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment, we will give you written notice of the reasons for the refusal within 30 days of receipt of your request, together with information about how you can complain about our refusal if you wish to do so.
9. Resolving your privacy concerns and complaints
Our representative will contact you within a reasonable time after hearing from you to answer your questions and discuss your concerns. If you have a complaint, we will acknowledge it within 7 Business Days of receiving it.
We will try to resolve your complaint within 30 days of receiving of your complaint or any longer period agreed by you in writing. If we cannot resolve your complaint within this timeframe, we will:
- inform you of the delay before the end of the period;
- provide you with reasons for the delay;
- provide you with an expected timeframe to resolve the complaint and seek your agreement to the extension;
- inform you that under the Privacy Act, you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information, and provide you with their contact details; and
- inform you that you may lodge your complaint to the Australian Financial Complaints Authority (relating to either the provision of credit or credit reporting information in general), and provide you with their contact details.
10. Direct marketing
We may use your personal information to directly offer you products and services we believe may be of interest and value to you, but we will not do so if you tell us not to. For example, if you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message.
Even after you opt-out, please allow us sufficient time to process your marketing preferences. Unless otherwise required to process your requests earlier by law, it may take up to 5 days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests.
Even after you’ve opted-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.
11. Protecting your personal information
We take reasonable steps using physical, technical, and administrative security measures to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in this policy.
We review our security procedures to protect your personal information periodically and will implement new technology and updated methods from time to time as we consider appropriate. Only authorised personnel will have access to your personal information on a need-to-know basis.
Please be aware that, as our website is linked to the internet, and the internet is inherently unsecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us is transmitted at your own risk.
13. Other Important Notes
A target market determination must be made publicly available before any person distributes a financial product that is subject to the design and distribution obligations. You will be able to review our TMDs on this website when distribution commences.