PRIVACY POLICY

Effective date: November 6, 2022

Money Wellbeing Pty Ltd is committed to providing quality services to You and this policy outlines Our ongoing obligations to You in respect of how We manage Your Personal Information.


We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which We collect, use, disclose, store, secure and dispose of Your Personal Information.


A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au.

INTERPRETATION AND DEFINITIONS

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:


  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.


Under Australian Privacy Principles (APPs), You can be referred to as the Data Subject or as the User as you are the individual

using the Service.


  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Money Wellbeing Pty Ltd, PO Box 203, Dapto NSW 2530.


For the purpose of APPs, the Company is the Data Controller.


  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.


  • Account means a unique account created for You to access our Service or parts of our Service.



  • Service refers to the Website.


  • Country refers to: New South Wales, Australia


  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the service is used.


For the purpose of the APPs, Service Providers are considered Data Processors.


  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.



  • Personal Information is any information that relates to an identified or identifiable individual.


For the purposes of APPs, Personal Information means any information relating to You such as a name, an identification number, location data,

online identifier or to one or more factors specific to the physical, physiological genetic, mental economic, cultural or social identity.


Also, Personal Information means any information that identifies, relates to, describes or is capable of being

associated, or could reasonably be linked, directly or indirectly, with You.


  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.


  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.


  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


  • Data Controller, for the purposes of the Australian Privacy Principles (APPs), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Information.


  • Business, for the purpose of the Australian Privacy Principles (APPs), refers to the Company as the legal entity that collects Consumers’ Personal Information and determines the purposes and means of the processing of Consumers’ Personal Information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purpose and means of the processing of consumers’ Personal Information, that does business in Australia.


  • Consumer, for the purpose of the Australian Privacy Principles (APPs), means a natural person who is an Australia resident. A resident, as defined in the law, includes (1) every individual who is in Australia for other than a temporary or transitory purpose, and (2) every individual who is domiciled in Australia or who is outside Australia for a temporary or transitory purpose.


  • Sale, for the purpose of the Australian Privacy Principles (APPs), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal Information to another business or a third party for monetary or other valuable consideration.

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Information

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal Code, City
  • Usage Data

Sensitive Information

Sensitive Information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by Us only:

  • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  • With Your consent; or where required or authorised by law.

Usage Data

Usage Data is collected automatically when using the Service.


Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.


When You access the Service by or through a mobile device, We may collect certain information automatically, including but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.


We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.


You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.


Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.


We use both session and persistent Cookies for the purposes set out below:


  • Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its

features. They help to authenticate Users and prevent fraudulent use of User accounts. Without these Cookies, the services that You have

asked for cannot be provided, and We only use these Cookies to provide You with those services.


  • Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if Users have accepted the use of cookies on the Website.


  • Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your login details or

language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-

enter Your preferences every time You use the Website.


  • Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how Users use the Website. The information

gathered via these Cookies may directly or indirectly identify You as an individual visitor. This is because the information collected is

typically linked to a pseudonymous identifier associated with the Device You use to access the Website. We may also use these Cookies to

test new advertisements, pages, features or new functionality of the Website to see how Our Users react to them.


For more information about the cookies We use and Your choices regarding cookies, please visit Our Cookies Policy.

Use of Your Personal Information

The Company may use Personal Information for the following purposes:


  • To provide and maintain Our Service, including to monitor the usage of Our Service.


  • To manage Your Account: to manage Your registration as a User of the Service. The Personal Information You provide can give You access to different functionalities of the Service that are available to You as a registered User.


  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.


  • To contact You: To contact You by email, telephone call, SMS, or other equivalent form of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.


  • To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.


  • To manage Your requests: To attend and manage Your requests to Us.


We may share Your personal information in the following situations:


  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service, to advertise on third party websites to You after You visited Our Service, for payment processing, to contact You.


  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.


  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.


  • With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.


  • With other users: when You share Personal Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.


Retention of Your Personal Information

The Company will retain Your Personal Information only for as long as is necessary for the purpose set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.


The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this Data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this Data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.


Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.


The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other Personal Information.

Disclosure of Your Personal Information

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Information may be transferred. We will provide notice before Your Personal Information is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Information in the good faith belief that such action is necessary to:


  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability


Security of Your Personal Information

The security of Your Personal Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Information

Service Providers have access to Your Personal Information only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of Our Service.


  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to

track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to

contextualise and personalise the ads of its own advertising network.


You can opt-out of having made Your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics Javascript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.


For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Email Marketing

We may use Your Personal Data to contact You with newsletter, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.


We may use Email Marketing Service Providers to manage and send email to You.


  • GetResponse

GetResponse is an email marketing sending service provided by GetResponse.

For more information on the privacy practices of GetResponse, please visit their Privacy policy: https://www.getresponse.com/legal/privacy.html

  • ActiveCampaign

ActiveCampaign, LLC (“ActiveCampaign”) provides a marketing platform that allows clients to reach their customers, to understand how

their customers interact with those communications and other content, and to customize marketing based on their customers’ interest.


For more information on the privacy practices of ActiveCampaign, please visit their Privacy policy:

https://www.activecampaign.com/legal/privacy-policy

Behavioral Remarketing

The Company uses remarketing services to advertise on third party websites to You after You visited Our Service, We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to Our Service.


  • Facebook

Facebook remarketing service is provided by Facebook Inc.


You can learn more about interest-based advertising from Facebook by visiting this page:

https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook:

https://www.facebook.com/help/568137493302217


Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using Your mobile device settings.


For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).


We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your Personal Information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.


  • Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy


  • PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact us

If You have any questions about this Privacy Policy, You can contact us:


  • By email: team@moneywellbeing.com.au