Finch Privacy Policy

This Privacy Policy (“Privacy Policy”) sets out how Genriche Pty Ltd (Company, us, we, our) complies with its obligations under Australian privacy law when you use our services. When we refer to our “Services,” we mean all products and services owned and operated by Genriche Pty Ltd or any of its affiliated companies (collectively, “Genriche,” “we,” or “us”), including the content, features, tools, data, software and functions made available by Genriche through www.finch.me, our mobile application (“Finch” or “app”), and other websites or applications we operate, unless those websites or applications have posted separate or additional privacy policies. When you use our Services, you do so subject to our User Agreement and this Privacy Policy. This Privacy Policy may be amended from time to time and will be updated on our website.

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, or phone number.
(b) Non-Personal Information: This is information about you that doesn’t identify you personally, like your gender, income or occupation.

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 Information you give to us
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:

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;
(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. This Usage Information is a key part of how we improve your Finch experience and provide more personalized insights and recommendations. We may use various technologies to collect and store Usage Information in connection with our Services. We may provide this information to our business partners. Don’t worry, if we do then we will disclose this to you and ensure that they comply with our Privacy Policy too.

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. We will only use these locationenabled services on your device with your consent, though.

 

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) organisations involved in a transfer or sale of our assets or business;
(d) financial institutions involved in managing payments through Finch, such as banks;
(e) regulatory bodies, government agencies, law enforcement bodies and courts;
(f) 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 support@finchme.com and we will do our best to remove it.

 

4. 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. However, due to our recordkeeping and information retention requirements, we do not delete information about you upon deactivation. We will, however, disable your account and stop sending you further communications.

 

5. 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.

 

6.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 lodge a complaint with us by:

(a) writing – our Privacy Officer, Finch, 77/83 City Road, Southbank, VIC 3006
(b) emailing –toby@finchme.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 – enquiries@oaic.gov.au