Privacy Policy

Last Update: February 2019

This Privacy Policy (“policy”) explains how Financial Mindfulness Pty Ltd (ACN 612 673 177) (referred to collectively as “us”, “we” or “our”) manages the collection, storage, use and disclosure of personal information in accordance with the Privacy Act 1988 (Cth) (the “Act”) and the Australian Privacy Principles (“APPs”) in Schedule 1 to the Act, and how to contact us if you have any further queries about our management of your personal information.

In this policy, a reference to our “services” shall be read as a reference to any of our products and services that we offer via our website (www.financialmindfulness.com.au (including any and all subdomains thereof (“website”)) and our proprietary software application (“app”).

By becoming a member, using our services or by providing us with your personal information, you confirm that you have read and accepted the terms of this policy and you consent to the collection, storage, use and disclosure of your personal information in accordance with the terms of this policy.

This policy is in addition to any other terms and conditions applicable to our services. We may amend this policy at our discretion, in which case we will make the amended version of the policy available via our website and/or our app. You acknowledge that that updated policy will apply to the collection, storage, use or disclosure of personal information from the date of release and it is your responsibility to regularly check our website and app for updates.

If you do not agree to the terms of this policy, you must not use our services.

  • Types of Personal Information We Collect
  • How We Collect and Hold Personal Information
  • How do we protect your personal information?
  • Usage information and cookies
  • The Purposes for Which We Collect, Hold, Use and Disclose Personal Information How You Can Access Your Personal Information That We Hold and Seek the Correction of Such Information
  • How You Can Complain About a Breach of the APPs and How We Will Deal With Such a Complaint
  • Which Overseas Recipients and Countries Are We Likely to Disclose Personal Information to

1. Types of Personal Information We Collect

The types of personal information that we collect and hold about you could include your name, email address or phone number, gender, professional public register information and professional activity details relating to our services, personal information that you submit or provide to us in communications or via the use of our services and other contact details such as social media accounts.

Sensitive information requires a higher level of protection under the the Act. If we need to collect sensitive information about you, we will seek your consent at or before the time we collect it. Sensitive information includes information about an individual’s race, political opinions, religious beliefs, membership of a professional or trade association, health information, sexual orientation and criminal record.

2. How We Collect and Hold Personal Information

We may collect personal information:

  • from people who use or access our services;
  • if you create an account with us, or subscribe to receive any publications or newsletters from us;
  • during conversations between you and our representatives;
  • when you communicate with us via email, chat, post or fax; and
  • from other people who are connected to our operations and activities – including employees, service providers and supplier

We will collect your personal information from you unless it is unreasonable or impracticable to do so. In some cases, we may be required to collect personal information about you from third parties. For example, we may collect personal information from companies with whom you work, other organisations with whom you have dealings, credit reporting bodies, information service providers or from public sources. Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the fact and circumstances of that collection unless the circumstances do not permit this or we are prohibited from doing this by law.

3. How do we protect your personal information?

We will do all that is reasonable in the circumstances to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Personal information we collect and store is stored on secure servers, and is only accessible by those persons who need access to the personal information in order to carry out their functions and duties. We also maintain physical security measures to protect the use and storage of physical records containing personal information. If your personal information can no longer be used for a purpose permitted under the Act, we will take reasonable steps to destroy the personal information or ensure that it is de-identified.

4. Usage information and cookies
We collect limited information ( “Usage Information”) about how people use our services, including our online resources, in order to track such use and to maintain and improve our services. Usage Information collected may include:

  • server addresses;
  • top level domain names;
  • the date and time of visits;
  • pages access and documents downloaded;
  • previous sites visited;
  • if the person has visited our website before;
  • types of browsers used; and
  • how you use our services

When you access our website or app, we may use software embedded in our website (such as JavaScript) or app, and we may place small data files (or cookies) on your computer or other device, to collect information about which pages you view and functions you access, how you reach them, what you do when you visit or use them, the length of time you spend using them, and how we perform in providing our services to you. We may also use similar and other means to track usage data in relation to our services . You may decline our cookies if your browser, browser add-on or device permits, but doing so may interfere with your use of our services.

Usage Information will be aggregated with other users and will not be associated with an identifiable person.

You may wish to contact and deal with us anonymously or by use of a pseudonym, however, there may be circumstances where we cannot allow this, including situations where the law requires us to deal with individuals who have identified themselves or where it is impracticable for us to be dealing with individuals who have not identified themselves. Furthermore, please note that certain parts of our services may not function or be accessible if you choose to contact or deal with us anonymously or through the use of a pseudonym.
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5. The Purposes for Which We Collect, Hold, Use and Disclose Personal Information

We collect your personal information so that we can carry out our one or more of our business operations, functions or activities or as otherwise required by law. Further, we may collect your personal information as part of the provision of our services to you, including your membership with us. Some examples of situations when we collect personal information include:

  • communicating with you in relation to the use of our services;
  • setting up and configuring your membership and account with us;
  • improving our services;
  • recording and maintaining your details for our internal and billing purposes;
  • providing you with information regarding our services;
  • providing you with support in relation to the use of our services;
  • delivering targeted marketing regarding new services and o ffers that we believe may be of interest to you;
  • collecting fees and payments owing to us;
  • responding to your enquiries and concerns and resolving disputes;
  • communicating with you in regards to a breach of the terms and conditions
    applicable to the use of our services; and
  • communicating with you in regards to a data breach.
  • We will not use or disclose your personal information for a purpose (secondary purpose) other than the main reason for which it was originally collected (primary purpose), unless one of the following exceptions apply:
  • you have consented to the use or disclosure of your personal information for the secondary purpose;
  • you would reasonably expect us to use or disclose your personal information for the secondary purpose and the other purpose is related to, or directly related to in the case of sensitive information, the primary purpose;
  • the use or disclosure of your personal information is required or authorised by or under applicable law or a court/tribunal order; or
  • the use or disclosure is otherwise permitted by the Act (for example, as a necessary part of an investigation of suspected unlawful activity).

In carrying out our business, we may need to disclose your personal information to others, including:

  • to our related entities; and
  • to service providers including information technology service providers, printers and distributors of marketing material, credit reporting agencies, creditors, bankers, financiers, credit providers, mortgage insurers or trade insurers, and external business advisers (such as auditors and lawyers).

We may also be required to disclose your personal information to a third party who is involved in a dealing or proposed dealing (including a sale) of all or part of our assets or business. However, we do not sell personal information to other organisations.

We may use your personal information to send you marketing and promotional information. We will provide you with an opportunity to opt-out of receiving such information. Unless you exercise your right to opt-out of such communication, you will be taken to have consented to the receipt of similar information communications from us if the future.

6. How You Can Access Your Personal Information That We Hold and Seek the Correction of Such Information

We will endeavour to give you access to your personal information unless there are legal reasons why we cannot do so. We do not have to provide you with access to your personal information if:

  • we believe there is a threat to life or public safety;
  • there is an unreasonable impact on the privacy of other individuals;
  • the request is frivolous or vexatious;
  • it would prejudice commercial negotiations, legal proceedings, enforcement
    activities or appropriate action being taken in respect of a suspected unlawful activity or serious misconduct; or
  • it would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process.

You can ask us to access your personal information that we hold by contacting us using the contact information set out below in section 10. . We will endeavour to respond to your request to provide access to your personal information within 30 days and you agree that we may charge you reasonable costs incurred in supplying you with access to this personal information, in which case we will advise you of these costs in advance of providing you access to this information.

You must ensure that the personal information you provide to us is accurate, up-to-date and complete. If you believe that personal information we hold about you may not be complete, accurate and up-to-date, please contact us using the contact information set out below in section 10 so we can update your details. You accept that we will take reasonable steps to verify your identity before granting access or making corrections to or deletion of your personal information.

7. How You Can Complain About a Breach of the APPs and How We Will Deal With Such a Complaint

If you feel that we have breached our obligations in the handling, use or disclosure of your personal information, you may raise a complaint. We encourage you to contact us in writing, including as much detail about the issue as possible, by contacting us using the contact information set out below in section 10.

We will investigate the circumstances included in the complaint and respond within a reasonable time (and in any event, the time required by the Act, if applicable) regarding our findings and actions following this investigation.

We will treat your complaint confidentially and, after investigating your complaint, discuss the ways in which we can remedy the situation.

8. Which Overseas Recipients and Countries Are We Likely to Disclose Personal Information to

We may need to share some of your personal information with third parties outside Australia. We may store your information in cloud or other types of networked or electronic storage which may be located overseas, in which case we retain effective control of your personal information.,.

9 If we disclose your personal information to overseas recipients, we will we will take reasonable steps to ensure that those recipients do not breach the APPs in relation to your personal information – we will satisfy this obligation by requiring the recipient to agree to comply with the APPs in relation to your personal information. However, to the extent permitted by law, we will not be liable if the recipient breaches the APPs in respect of your personal information. Further, we will only disclose your personal information to an overseas recipient in accordance with the primary purpose for which we collected your personal information or if one of the exceptions in section 4 above applies in relation to the disclosure. We may disclose your personal information to overseas recipients located in the following countries United States of America.

Contact us

If you have any questions this policy or if you have any further queries about our management of your personal information, if you wish to update or correct your personal information that we hold, make a complaint, or if you suspect that there has been a data breach, please contact us using one of the methods set out below:

Privacy Officer
Financial Mindfulness
Email: [email protected]financialmindfulness.com.au
Address: Level 5, 155 Clarence Street, Sydney NSW 2000

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