In this Policy:
(a) ‘Disclosing’ information means providing information to persons outside of us;
(b) ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
(c) ‘Privacy Officer’ means the contact person for questions or complaints regarding our handling of personal information;
(d) ‘Sensitive information’ is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
(e) ‘Use’ of information means our use of information
1. WHAT INFORMATION WE COLLECT
1.1 What type of information do we collect?
We may collect and hold a range of information about you to provide you with our Services. The types of information we may collect from you fit in two categories:
(a) Personal Information: information that identifies you personally, such as your name, address, email address, date of birth, bank account details, purchase history, or phone number or any other type of personal information that is relevant to the Services we provide.
(b) Non-Personal Information: This is information about you that doesn’t identify you personally, like your gender, income or occupation occupation and information not about individuals such as information about a company.
When we combine information that isn’t personal information (like Non-Personal Information or Usage Information, which we explain below) with personal information, we treat it like personal information.
We collect and hold personal information about customers, potential customers, and visitors to our website. This information will be used to provide you with our Services. Your information is an integral part of our business model and in providing you with the most personalized experience possible. We use it in a variety of ways in providing the Services and in operating our business.
To put it simply, there are three main ways we collect information about you: when you give it to us, when we automatically collect it, and when we ask others for it (with your consent). Allow us to continue…
1.2 Personal information you give to us
We may collect and hold a range of personal information about you to provide you with our services.
We may ask you to provide certain information to us through various forms, features or other means throughout our Services. If you do not provide us with this information, we may not be able to provide the Services to you.
Amongst other ways, we collect information from you when you establish a Finch account, use our Services, and when you send us comments, questions or other feedback.
We collect this information so that we can:
(a) provide you with our products and Services, including when those products or Services are provided to you as part of you dealing with another third party we’re affiliated with);
(b) review and better understand your personal ongoing needs;
(c) provide you with information we believe may be relevant or of interest to you;
(d) let you know about other products or services we offer, special offers or invite you to events (did someone say “PARTY”?!);
(e) consider any concerns or complaints you may have;
(f) comply with relevant laws, regulations and other legal obligations;
(g) help us improve the products and services offered to enhance your experience.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise or an exemption in the Privacy Act applies.
1.3 Information we automatically collect
In addition to information you provide to us, we automatically collect certain information about how you access and interact with our Services (“Usage Information”). This information may either be collected from your use of the Services, or from our service providers, who are involved in the delivery of the Services. It may also be collected from the use of a cookie (which is a small summary file containing a unique ID number) when you use the app, website or access other services online. If you do not wish to receive cookies, you can set your mobile or computer web browser to not accept them.
There are three types of Usage Information we may collect:
(a) “Device Information”. This is information about how you access our Services, such as the operating system, mobile phone model, application or browser type and version, and unique identifiers associated with your device. We may also integrate with built-in device features (e.g., when you turn on fingerprint access for your Finch account) for increased security and convenience.
(b) Log Information. There are certain pieces of information we automatically collect in system logs or similar files about how you interact with our Services, such as who you pay or request money from, which features you visit or like to use. This Log Information may also include things like your unique phone ID, browser or device configuration, date and time of access.
(c) Location Information. We may use certain information like your IP address or other Device Information or Log Information to estimate your location (e.g., your city or state). We may also request to use location-enabled services on your device (which typically provide GPS or Wi-Fi access point details) to enhance our Services.
Personal information may also be collected from a third party that provides services to you and that uses our Services to provide those services, such as a mobile app.
2. HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect from you and third parties to operate our Services, communicate with you, conduct research and development to improve or enhance our Services and our users’ experience, and promote our Services. These are a few examples:
2.1 Providing features
When you register for a Finch account, we use the Personal Information you provide in order to create and maintain your Member Profile.
2.2 Improving our recommendations and insights
The information we collect also helps us tailor our content and improve the way we match you to recommended offers or insights about your financial health. We’re constantly working on ways to better identify and present the information that’s most relevant to you.
2.3 Communicating with you
We may use information we collect to provide you with things like service-related announcements, spend monitoring alerts, and other updates or promotions. Most of the time we’ll communicate with you through the Finch app or push notifications, by email or text, but we may also contact you through email or text.
2.4 Legal reasons
We reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, any information (including Personal Information) as reasonably necessary to:
(a) Comply with any applicable law, regulation, subpoena or legal process, or respond to any governmental requests and cooperate with law enforcement, if we believe such action is required or permitted by law;
(b) Enforce our Terms of Service, including investigating any potential violations;
(c) Protect the safety, integrity, rights or security of our members, our Services or equipment, or any third party; or
(d) Detect, prevent or otherwise address fraud, security or technical issues related to our Services or our business partners.
3. WHEN WE SHARE THE INFORMATION WE COLLECT
3.1 Situations where we do not share information.
First, we want to be clear that we hate spam text/email and marketers as much as you do. We absolutely unequivocally promise (what we call the “F-Nos”) that we:
(a) Will not share your financial information with marketers or unaffiliated third parties
(b) Will not sell or rent Personal Information to marketers or unaffiliated third parties for their advertising or marketing lists.
Now that we’ve covered the F-Nos, let us explain how & why we might share information with third parties:
3.2 Situations where we do share information.
To provide you with our Services, we may share and disclose personal information to:
(a) a related entity of us;
(b) an agent, professional adviser or service provider we engage to carry out our functions and activities such as lawyers, accountants, IT contractors, and marketing companies;
(c) third parties we have commercial relationships with for business purposes, including arrangements where we act as a service provider;
(d) organisations involved in a transfer or sale of our assets or business;
(e) financial institutions and other third parties involved in managing payments through Finch and payment processing, such as banks;
(f) regulatory bodies, government agencies, law enforcement bodies and courts;
(g) anyone whom you authorise us to disclose it.
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.
We may sometimes share information about you with our business partners or other third parties we collaborate with in connection with providing or improving our Services. This can occur, for example, when we’re providing an integrated or co-branded feature with a business partner or doing a joint research project with another organization to help improve our Services. When we share information with third-party collaborators, our collaborators are obligated to follow the F-Nos above.
3.3 When you publicly post the information.
As part of our Services, we may provide opportunities for you to publicly post activity or photos (in Finch), reviews (app store), through our social media channels, or questions, comments, suggestions (community forums). Anything you share in a public forum is, obviously, public, so think carefully about what you decide to share. If you would like us to remove Personal Information included in your public activity, contact us at firstname.lastname@example.org and we will do our best to remove it.
4. HOW WE MANAGE YOUR INFORMATION
We take reasonable steps to protect personal information that we handle and hold from misuse, loss, unauthorized access, modification or disclosure. We may store some of the personal information we collect in electronic or hard copy form, but we don’t store all personal information that we handle. Depending on why we collected the personal information, we may instead pass it to a relevant third party in accordance with this Policy. Don’t worry, as we’ve said we will not be passing your information onto marketers or unaffiliated third parties. When we send your information to third parties, it is encrypted to keep it secure.
5. HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION
(a) Subject to exceptions in the Privacy Act, you can access the personal information that we hold about you by contacting the Privacy Officer. We will generally provide access within 30 days of your request. If we refuse to provide you with access to the information, we will provide reasons for the refusal.
(b) We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged.
(c) You are responsible for maintaining the accuracy of the information you provide to us, such as your Member Profile information. You can access and make changes to certain Personal Information at any time by logging in to your Finch account and updating your “Personal Info” in Settings.
(d) We hope this never happens, but if you decide you no longer want to use our Services, you can cancel and deactivate your account in your Settings. We will take reasonable steps to destroy or de-identify personal information we hold about you if it is no longer needed for one of the purposes described in this Policy. Regardless, we will however, disable your account and stop sending you further communications.
6. HOW TO ACCESS AND UPDATE YOUR PERSONAL INFORMATION
Your privacy is important to us. It is our responsibility to inform employees and other relevant third parties about this Policy. Our management are required to ensure that employees and other relevant third parties are advised of any changes to this Policy. All new employees are to be provided with timely and appropriate access to this Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.
7.MAKING A COMPLAINT
If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal information, you can make an enquiry or lodge a complaint with us by:
(a) writing – our Privacy Officer, Finch, 77/83 City Road, Southbank, VIC 3006
(b) emailing –email@example.com
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
(a) telephoning -1300 363 992 (b) writing -Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
(b) emailing – firstname.lastname@example.org