What personal information do We collect?
We may be able to provide some Services to You without requiring You to identify yourself. For example, You may be able to send and receive certain documents or information without having to reveal any of Your personal information. However, by their nature most of Our Services usually require You to disclose Your personal information before We can provide You with that Service.
We may collect the following types of personal information from You when You use any of Our Services:
- Mailing/street address
- email address
- telephone number(s)
- other contact details
- age/date of birth
- credit card information (via our payment platform)
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information
- details of the products and services We have provided to You or that You have enquired about, including any additional information necessary to deliver those products and services and respond to Your enquiries;
- any additional information relating to You that You provide to Us directly through Our Services or indirectly through Your use of Our Services or online presence or through other websites or accounts from which You permit Us to collect information;
- information You provide to Us through customer surveys; and/or
- any other personal information that may be required in order to facilitate your dealings with us.
In addition to disclosing Your personal information to enable Us to provide Our Services to You, Our Services enable You to send and receive documents, information and related meta data (collectively, “Data”) that may contain personal and sensitive information including:
- Financial records
- Health and medical information;
- Racial/ethnic origin
- Political opinions
- Membership of a political association, professional or trade association or trade union
- Religious beliefs or affiliations
- Philosophical beliefs
- Sexual orientation or practices
- Criminal records
- Biometric information that is to be used for certain purposes
- Biometric templates.
Our Services collect and store Data containing personal and sensitive information with Your consent, in limited situations which the law allows. We may collect and store these types of personal information either directly from You, or from external sources (see below).
External sources of information
In some cases We might collect Your personal information from external sources. Examples of the people or organisations that may provide Us with information include: employers, parents or guardians in respect of children, persons authorised by You (such as family members, lawyers, and financial representatives), hospitals, medical practitioners and health services providers, public sources of information and social media and other virtual communities and networks where people create, share or exchange information.
We will take reasonable steps to inform you that we have collected your personal information, unless:
- it is not reasonable to do so;
- it is apparent from the circumstances that you are aware of the collection; and/or
- you would expect us to have the information.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable You to access and use Our Services;
- to assist with Your application for finance, insurance or other product or service You wish to apply for;
- to enable the administration of financial, insurance or other products and services, which includes responding to Your enquiries, requests for information and managing claims or complaints;
- to comply with Our legal obligations, resolve any disputes that We may have with any of Our users, and enforce Our agreements with third parties;
- to operate, protect, improve and optimise Our Services, business and Our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send You Service, support and administrative messages, reminders, technical notices, updates, security alerts, and any other information requested by You;
- to send You marketing and promotional messages and other information that may be of interest to You, including information sent by, or on behalf of, Our business partners that We think You may find interesting;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by Us or Our business partners; and/or
- to consider your employment application.
We may also disclose Your personal information, but not Your Data, to a trusted third party who also holds other information about You. This third party may combine that information in order to enable it and Us to develop anonymised consumer insights so that We can better understand Your preferences and interests, personalise Your experience and enhance the products and services that You receive.
Do We use Your personal information for direct marketing?
We and/or Our carefully selected business partners may send You direct marketing communications as well as information about Our Services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from Us by contacting Us using the details set out below or by using the opt-out facilities provided (e.g. an Unsubscribe link). In the event You opt out of receiving direct marketing communications, We may still communicate with You regarding any Service of ours that You are using in order to provide the Service You have requested, update You as to features, pricing or other relevant issues.
To whom do We disclose Your personal information?
- any entity, including government agencies, regulatory bodies and law enforcement agencies, as required, authorised or permitted by law or a court order;
- any person, entity or platform provider authorised by You or acting on Your behalf including, without limitation, Your financial institution, legal, financial or other adviser, hospital, medical practitioner, health services provider, accountant, trustee, administrator, employer, guardian, attorney, agent, or other professional services provider;
- payment systems operators (e.g. when You pay any of Our fees by credit card)
- Our existing or potential agents, partners (which specifically includes financial service providers and insurers);
- Our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of Our Services and/or Our business or in connection with providing Our Services to You);
- professional advisers, dealers and agents;
- Our sponsors or promoters of any competition that We conduct via Our Services; and/or
- anyone to whom Our assets or businesses (or any part of them) are transferred.
Disclosure of personal information outside Australia
Unless otherwise made clear, all Your Data and personal information are stored and managed on servers located in Australia. We will not, without Your express consent, disclose Your personal information outside of Australia to third party suppliers, cloud storage and service providers located in other countries. In the event that You provide Your consent to the disclosure of Your information outside of Australia We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles, but You hereby acknowledge and agree that We may not be able to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law.
Using Our Services and cookies
We may hold Your personal information in either electronic or hard copy form. We take reasonable steps to protect Your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and We use a number of physical, administrative, personnel and technical measures to protect Your personal information. However, We cannot guarantee the security of Your personal information. We have processes in place to identify, manage and remediate privacy and data breaches in accordance with Our obligations under applicable law, including the notifiable data breach regulations. We educate Our staff about Our obligations to protect Your personal information and impose contractual obligations of confidentiality and strict controls over their access to any personal information. We will co-operate with Our customers, agents, and partners to promptly notify them of any privacy and data breaches in cases where there is a likelihood of a real risk of serious harm given the circumstances of the breach.
Accessing or correcting your personal information
You can access the personal information We hold about You by contacting Us using the Contact Us link or similar function on Our Services. Your access to Your personal information is subject to some exceptions permitted by applicable law, including any situation in which We reasonably believe that:
- providing access would pose a serious threat to the life, health or safety of You or any other person;
- access would have an unreasonable impact on the privacy of any other person;
- the information is protected from disclosure by applicable law;
- release of the information would be prejudicial to Us in relation to a legal or administrative dispute or complaint; or
- the information is protected by confidentiality obligations or is Our intellectual property and disclosure would be contrary to Our legal or commercial interests.
If We refuse to provide You with access to Your personal information We will, if reasonable to do so, provide You with a written explanation outlining the reasons for Our refusal. The explanation will also outline the steps available to You to complain about Our refusal. We may also need to verify Your identity when You request Your personal information. If You think that any personal information We hold about You is inaccurate, please contact Us and We will take reasonable steps to ensure that it is corrected.
Making a complaint
If You think We have breached the Privacy Act, or You wish to make a complaint about the way We have handled Your personal information, You can contact Us at email@example.com or via the Contact Us link or similar function on Our Services. Please include Your name, email address and/or telephone number and clearly outline Your complaint. We will acknowledge Your complaint and respond to You regarding Your complaint within a reasonable period of time. If You think that We have failed to resolve the complaint satisfactorily, We will provide You with information about the further steps You can take.
In the event that We are unable to resolve Your complaint to Your satisfaction, We will inform You as to how You can escalate the complaint to the appropriate external dispute resolution body. In cases of privacy related complaints, this is generally the Office of the Australian Information Commissioner (“OAIC”). There is specific information about the OAIC complaints and investigation process on the OAIC website at http://www.oaic.gov.au/ and contact details are:
Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW
Phone: 1300 363 992
EFFECTIVE: 27 September, 2019
Ezi Financial Services Pty Ltd
Level 2, 6 The Corso
Manly NSW 2095