Privacy Policy

Privacy Policy – Money Circles

1. Introduction

We are bound by the Privacy Act and APPs.This Privacy Policy contains information about how:

we comply with our obligations under the Privacy Act and APPs;
we use and disclose personal information we hold about you;
you may access the personal information we hold about you;
you may seek the correction of your personal information;
how we seek to keep your personal information confidential and secure;
you may complain about a breach of the Privacy Act, including the APPs; and we will deal with a privacy complaint.

2. What kind of personal information do we collect and hold?

We may collect and hold a range of personal information about you to provide you with our services. This information includes your name, address, date of birth, phone number, email address, occupation, bank account details, driver’s licence details and financial information.

3. How do we collect personal information?

We generally collect personal information directly from you. For example, personal information will be collected through registration processes, forms and other interactions with you in the course of providing you with our products and services, including when you use our mobile app. We may also collect personal information about you from a third party, such as electronic verification services, credit reporting agencies, referrers and marketing agencies. If so, we will take reasonable steps to ensure that you are made aware of this Privacy Policy. We may also use third parties to analyse traffic at our website, which may involve the use of cookies. Information collected through such analysis is anonymous. We will not collect sensitive information about you without your consent, unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. If the personal information we request is not provided, we may not be able to provide our products and services. We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for us to deal with individuals who are not identified.

4. Unsolicited personal information

We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.

5. Who do we collect personal information about?

The personal information we may collect and hold includes (but is not limited to) personal information about customers, potential customers, service providers or suppliers, prospective employees, employees and contractors and other third parties with whom we come into contact.

6. Website collection

We collect personal information when we receive completed online generated forms from our website (www.moneycircles.com) and mobile app. We may use third parties to analyse traffic on our website, which may involve the use of cookies. Information collected through such analysis is anonymous. To use our website, you must consent to our use of cookies. You can withdraw or modify your consent to our use of cookies at any time. If you no longer wish to receive cookies, you can use your web browser settings to accept, refuse and delete cookies. To do this, follow the instructions provided by your browser. Please note that if you set your browser to refuse cookies, you may not be able to use all of the features of our website. Cookies do not contain personal information in themselves, but can be used to identify a person when combined with other information. Cookies are small text files which are transferred to your computer’s hard drive through your web browser that enables our website to recognise your browser and capture and remember certain information.

7. Why do we collect and hold personal information?

We may use and disclose the information we collect about you for the following purposes:

assess whether you are eligible to receive our products and services;
provide you with our products and services;
verify your identity in order to meet our Know Your Customer obligations;
review and meet your ongoing needs;
provide you with information we believe may be relevant or of interest to you;
let you know about other products or services we offer, send you information about special
offers or invite you to events;
consider any concerns or complaints you may have;
comply with relevant laws, regulations and other legal obligations; and
help us improve the products and services offered to our customers and enhance our overall
business.

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.

8. Who might we disclose personal information to?

We may disclose personal information to:

a related entity of Money Circles;
an agent, contractor or service provider we engage to carry out our functions and activities,
such as our bankers, lawyers, accountants, debt collectors or other advisers;
organisations involved in facilitating deposits and withdrawals from your account on our
behalf, including banks, payment providers and other financial institutions;
regulatory bodies, government agencies, law enforcement bodies and courts;
financial product issuers; and
anyone else to whom you authorise us to disclose it or is required by law.

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 we will make third parties aware of this Privacy Policy.

9. Sending information overseas

We do not disclose personal information overseas.

10. Management of personal information

Your personal information is only stored electronically on our computer database.
‍
We recognise the importance of securing the personal information of our customers. We take reasonable steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.
‍
However, data protection measures are never completely secure and despite the measures we have implemented, we cannot guarantee the security of your personal information. You should notify us as soon as possible if you become aware of any security breaches. Any submission of personal information is at your own risk.

11. Direct marketing

We may only use personal information we collect from you for the purposes of direct marketing without your consent if:

the personal information does not include sensitive information; and
you would reasonably expect us to use or disclose the information for the purpose of direct
marketing; and
we provide a simple way of opting out of direct marketing; and
you have not requested to opt out of receiving direct marketing from us.

If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.

You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.

12. How do we keep personal information accurate and up-to-date?

We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.

We encourage you to contact us to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.

13. Accessing your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.

We will require identity verification and specification of what information is required.

14. Updates to this Privacy Policy

This Privacy Policy may be updated from time to time to take account of new laws and technology, and changes to our operations and the business environment. The latest version of the Privacy Policy will be available from our website.

15. Complaints

You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
‍
If you have any questions about this Privacy Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:

writing – 94 Foundation Road Truganina VIC 3029
emailing – complaints@moneycircles.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:

telephoning – 1300 363 992
writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
online submission – https://forms.business.gov.au/smartforms/landing.htm?formCode=APC_PC

16. Definitions

APPs means the Australian Privacy Principles.
Money Circles, we, our, us means Money Circles Financial Services Limited ACN 672 145 498 and any related body corporate.
Personal information means information or an opinion relating to an individual, which can be used to identify that individual.
Privacy Act means the Privacy Act 1988 (Cth).
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.