Privacy Policy

What personal information do we collect?

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• age or date of birth;
• identification information, such as your driver’s licence or passport number;
• 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 website or app or indirectly through your use of our website or app 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; or
• any other personal information that may be required in order to facilitate your dealings with us.

We will only collect sensitive information with your consent.

How do we collect personal information?

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

• register on our website or app
• communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; or
• interact with our sites, services, content and advertising.

If you do not provide the information requested by us, we may not be able to provide you with our services.

There may be occasions when information is collected from third parties for example through our business partners or from a publicly maintained record. For example, we may collect location information through our app which you have downloaded on your mobile phone.

Why do we collect your personal information?

We collect your personal information to be able to provide our service to you including to enable us to verify your identity and details so we can provide our service to you.

How do we use your personal information?

We use your personal information for the purpose for which it has been provided, for reasonably related secondary purposes, any other purpose you have consented to and any other purpose permitted under the Privacy Act. This may include using your personal information for the following purposes:

• to enable you to access and use our products and services;
• to be used for identity verification purposes, which may involve the use of third-party systems;
• to operate, protect, improve and optimise our website, app, 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 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; and
• 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.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our financial products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. By providing us with your personal information, you consent to us and our business partners using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS and telephone. 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).

Third Party Software/Service Providers

We may use AppsFlyer and Hotjar, which are analytics solution. AppsFlyer provides attribution and marketing analytics services (“Services“) that enable advertisers and developers (collectively, “Customer(s)“) to: (i) measure and analyse the effectiveness of their marketing campaigns by understanding which marketing campaigns contributed to the download/installation of their mobile applications (“Applications“) or such other conversion metric (e.g. relaunch of Application); and (ii) measure and analyse certain events and actions within their Application or websites, such as in-app purchases made by End Users (as defined below). The Services also help our Customers identify and protect against fraudulent behaviour related to their marketing campaigns.

For more details on the information that could be collected visit AppsFlyer’s Privacy Policy or Hotjars' Privacy Policy.

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• our employees and related bodies corporate;
• your agents;
• third party organisations that carry out functions on our behalf;
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
• professional advisers, dealers and agents;
• payment systems operators (eg merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

We may also disclose your personal information 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. By providing us with your personal information, you consent to us disclosing your information to such entities without obtaining your consent on a case by case basis.

Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to our partners with locations in the US and the UK. When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law.

Using our website and cookies

We may collect personal information about you when you use and access our app and website.

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so. We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it may be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

Security

We may hold your personal information in electronic form and your personal information may be stored on behalf of third- party service providers. 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 yourpersonal information. Measures we take to protect your personal information include:

• using appropriate information technology and processes;
• restricting access to your personal information to our employees and those who perform services for us who need your personal information to do what we have engaged them to do;
• using computer and network security systems with appropriate firewalls, encryption technology and passwords for the protection of electronic files; and
• securely destroying or “de-identifying” personal information if we no longer require it subject to our legal obligations to keep some information for certain prescribed periods.

We do our very best to protect the security of your personal information.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access toall of your personal information and, where this is the case, we will tell you why. 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. We will generally rely on you to assist us in informing us if the information we hold about youis inaccurate or incomplete.

Making a complaint and correcting your information

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 or want to correct the information we hold about you, you can contact us using the details set out below. 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.

Referral program

Beforepay allows users to invite friends and family to sign up for our Services.Sometimes we offer a promotional value for every friend or family member who signsup through your referral link. To help you do this, we may request you to grant usaccess to your mobile device address book. You can then direct us to send referralemails to contacts you select in your address book. By sendinga referral, you alsoconsent to Beforepay sending your public profile image to the contacts you select toreceive a referral link. By choosing to invite a friend you represent that you havereceived the friend’s consent to provide his or her name and email address with us.Beforepay will use that information to send an email inviting him or her to visit thesite and will store that information to track the success of the referral program andmay send marketing emails. You can also send an SMS with a referral link to yourcontacts. If you use this option, you understand that Beforepay does not control thetiming, content, or recipients of these SMS messages.

Users may not send, publish, or share any false, misleading, or deceptivecommunications in connection with participation in the Referral Program. Suchactions may violate various federal, state, and/or international laws. Users may notsend any referral emails, SMS messages, or other communications to children underthe age of 18.

If you are referred to Beforepay through one of our referral programs, or if someoneattempts to refer you, we may share your name, whether you have already signed upfor Beforepay or not.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

If you require further information about Privacy laws generally, please contact: