FinClear Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website finclear.com.au and any other websites, platforms or applications through which we provide goods or services (Site).

In this Privacy Policy we, us or our means the FinClear group of companies which include FinClear Pty Ltd ABN 63 607164 714; FinClear Execution Ltd 56 061 751102; FinCIear Technology Pty Ltd ABN 34 628 725 191; FinClear Holdings Ltd ABN 53 628 360 323; FinClear Nominees Pty Ltd ABN 32 608 644 024; FinClear Execution Nominees Pty Ltd ACN 607140 027, FinClear Services Pty Ltd ABN 60 136 184 962, FinClear Services Nominees Pty Ltd ABN 38 137 911 730 and FinClear Execution Administration Services Pty Ltd ABN 94117 035 435.

PERSONAL INFORMATION

The types of personal information we may collect about you include:

1. your name;
2. your contact details, including email address, mailing address, street address and/or telephone number;
3. your age and/or date of birth;
4. your demographic information, such as postcode;
5. information you provide to us through customer surveys and interactions with us;
6. details of products and services we have provided to you and/or that you have enquired about, and our response to you;
7. your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
8. information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
9. additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
10. any other personal information requested by us and/or provided by you or a third party.

Tax file numbers and Government identifiers

We may collect information in relation to Government issued identifiers and identity documents such as information from your passport, citizenship, birth, marriage and death certificates for the purpose of verifying your identity.

How we collect your personal information

We may collect these types of personal information directly from you when you:

1. sign up to receive our services or products; or
2. interact with us, including when you use our Site.

We have collected or may also collect your personal information indirectly from third parties or our customers, to enable us to deliver our products and services.

COLLECTION, USE and disclosure OF PERSONAL INFORMATION

We may collect, hold, use and disclose personal information for the following purposes:

1. to enable you to access and use our Site, associated applications and associated social media platforms;
2. to communicate with you, including in relation to updates and changes to any services or products which may affect you;
3. for internal record keeping and administrative purposes, including where required by law.
4. for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
5. to run competitions and/or offer additional benefits to you;
6. for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you. You may ask us, at any time, to stop sending you marketing communications;
7. to comply with our legal obligations including our obligations under the Corporations Act 2001 (Cth);
8. to resolve any disputes that we may have; and
9. to consider your employment application.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

We may disclose personal information to:

1. third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
2. our employees, contractors and/or related entities;

• our existing or potential agents or business partners;

1. sponsors or promoters of any competition we run;
2. anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
3. credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to exercise or defend our legal rights; and
• third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and

1. third parties to collect and process data, such as Google Analytics.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Site and we may be unable to provide you with any products and/or services offered to you.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you by contacting our compliance officer using the details below. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact our compliance officer using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you within a reasonable timeframe, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

You may also make a complaint about our handling of your personal information by submitting a complaint to the Office of the Australian Information Commissioner:

1. using its online privacy compliant form
2. by mail to:

GPO Box 5218

Sydney NSW 2001

• by email to enquiries@oaic.gov.au.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

How we hold your personal information: STORAGE AND SECURITY

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access, disclosure or loss of your personal information, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. In some circumstances, your personal information may be stored by our third party service providers. Where this is the case, we have taken steps to ensure that your personal information that the third party service provider collects is secure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

STORAGE COOKIES AND WEB BEACONS

We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause Our advertisements to appear on your social media and online media feeds as part of Our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFS) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

OUR contact details

You may contact us by:

1. submitting an online form through https://finclear.com.au/contact/;
2. email to info@finclear.com.au;

• calling the following numbers during standard business hours, or sending mail to:

LINKS TO OTHER WEBSITES

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

 AMENDMENTS

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.