- “Account Credentials” means the combination of access code, email address, password, secondary password and/or security number (as applicable) which You use to access the online banking services offered by Your bank or other financial institution in respect of Your Bank Account;
- “Account Information” means day-to-day transactional information (including all debit and credit operations) in respect of Your Bank Account;
- “Australian Privacy Principles” are set out in Schedule 1 of the Privacy Act 1988;
- “Bank Account” means a deposit or loan account that You maintain with an Australian bank or another Australian financial institution;
- “Personal Information” means information about an identified individual or an individual who is reasonably identifiable. Common examples are an individual’s name, signature, address, telephone number, date of birth, email address, bank account credentials and employment details;
- “Membership Information” means Your email address and Your password for Your Fu account;
- “Service” means the services provided by Fu;
- “You” or “Your” means the individual who uses the Fu Service.
Our privacy and security procedures aim to (1) prevent identity theft and (2) secure the Personal Information that we hold. We regularly re-evaluate those procedures and adapt them, as necessary, to deal with new challenges and emerging issues. We strive to implement best-practice security standards.
2. The kinds of information that we collect and hold
Certain features of the Service are made available to You without the need to register or to provide any of Your Personal Information to us. However, other features of the Service require You to register as a Fu Member.
When You register as a Fu Member, we will collect Personal Information such as Your email address.
In order to use the Service, You are required to provide us with read only access to Your bank account. Account Information will be collected from all Bank Accounts for which You provide Account Credentials.
Due to the nature of the Service, from time to time, we may collect and hold additional Personal Information or other information about You. This can include but is not limited to:
- Your address, date of birth and contact details;
- information about Your financial circumstances and objectives, including Your assets, liabilities, income, expenditure, taxation information, insurance, superannuation and investment preferences;
- the type of operating system and/or other software or firmware used by Your computer or Mobile Device;
- the data You send and receive by using the Service, as well as the type and quality of that data; your GPS location;
- the dates on which and the times at which You use the Service, including the duration of such use; and
- the IP address and the MAC address of Your computer or Mobile Device.
3. How we collect information?
We may collect Your information in a number of ways including:
- directly from You, such as:
- when You provide information to us when You register to use the Service;
- when You use the Service;
- when You participate in one of our surveys; or
- when You contact us with an enquiry on a request;
- through the Service, when You synchronise Your Fu account with Your Bank Account;
- from third-parties You authorise to disclose Your information to us;
- from publicly available sources of information;
- when we are legally authorised or required to do so; or
- through digital communications, such as when You visit our website.
You have a right not to provide information to us. We will give You the opportunity to provide or to decline to provide information and, where practicable and lawful, we will allow You to interact with us anonymously or by using a pseudonym. However, if You choose not to provide certain information about You, we may not be able to provide You with the service You request.
4. How do we hold your information?
We use various technical solutions, security controls and internal procedures to help us protect Your information. For example:
- we use a combination of firewall barriers, encryption techniques and authentication procedures;
- when You register for a Fu Membership, we require a password from You for Your privacy and security;
- we transmit information such as Your Membership Information or Your Account Credentials only securely;
- we test the Service regularly for any failure points that would allow hacking.
For clarity, these precautions apply only to the Service. We exercise no control over how Your information is stored, maintained or displayed by third-parties or on third-party websites.
About your password
You are responsible for maintaining the confidentiality of Your Membership Information.
We maintain strict rules to help prevent others from guessing Your password. We also recommend that You change Your password periodically. If You believe that Your Membership Information may have been stolen or been made known to others, You must contact us immediately at email@example.com.
5. How do we use your information?
Our main purpose for collecting information about You is:
- to provide the Service to You;
- to provide You with information about the Service;
- to assist You with enquiries; and
- to better service Your needs.
In order to do that effectively, we may use Your information for a range of different purposes including:
- for our business operations and for purposes that are related to one or more of our functions and activities;
- to verify Your identity and to allow You to access and use Fu Services
- to communicate with You;
- to provide support and Service updates;
- to gain an understanding of Your needs so that we may improve and develop the Service;
- to personalise Your experience with the Service and our website;
- to perform research and analysis (including to conduct surveys);
- to comply with our legal, statutory and regulatory obligations;
- for direct marketing purposes (in this respect, see paragraph 3 below); and subject to Your consent, for other purposes which may be notified to You from time to time.
We may use Your information so that we and our business partners can promote and market products and/or services that we think may be of interest to You (including products and/or services provided by a third-party). This marketing may be carried out in a variety of ways (including by email or by customising online content) and may continue after You stop using the Service, until You opt-out. You may opt-out at any time by following the “unsubscribe” instructions within our communications. If you require support to unsubscribe from promotional products and services, contact us at firstname.lastname@example.org.
6. How do we disclose your information?
From time to time, we may disclose Your information with entities outside of our organisation. These may include:
- our related bodies corporate, business partners, associates and affiliates;
- third-parties who provide services to us, such as vendors or service providers that help us provide the Service to You (including by sending email messages on our behalf or by hosting and operating particular features or functionalities of the Service); and
- anyone who is authorised by law to obtain information about You from us.
The entities to which we disclose Your information have been selected in accordance with our security policies and practices, and are bound by confidentiality obligations. If they fail to meet these obligations, they may be subject to disciplinary action, termination of contract and/or criminal prosecution.
Our contracts with the entities to which we disclose Your information:
- outline the appropriate use and handling of Your information; and
- prohibit them from using any of Your information for purposes other than those for which they have received Your information.
We may de-identify Your Personal Information or aggregate it in such a way that it cannot be used to identify You. We may disclose de-identified information to several entities, including:
- advertisers and other third-parties for their commercial, marketing, research and promotional purposes;
- organisations approved by us that conduct research into consumer spending; and
- other users of the Service for the purpose of comparing their personal financial situation against that of the broader community.
Our de-identification procedure involves:
- removing personal identifiers;
- removing or altering other information that may allow You to be identified; and
- continuously assessing and managing the risk of re-identification.
7. How long do we keep your information?
Your data is Yours. You can remove it anytime You want. When You request us to delete Your Fu account, Your data will be permanently expunged from our primary production servers and further access to Your Fu account will not be possible. We will also promptly disconnect any connection we had established to Your Account Information and delete all Account Credentials.
However, portions of Your data, consisting of aggregate data derived from Your Account Information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. We keep these backups to ensure our continued ability to provide the Service to You in the event of malfunction or damage to our primary production servers.
8. How to access, update or correct your information?
If Your Personal Information changes, You may update it at any time via Fu.
If You wish to access any of Your information that we hold or You would like to correct any errors in that information, You may contact us at email@example.com.
The Australian Privacy Principles set out a number of rules in respect of accessing, updating and correcting Your information. For example, we may refuse to give You access to Your information if giving access would have an unreasonable impact on the privacy of other individuals, if Your request for access is frivolous or vexatious, or if the information relates to existing or anticipated legal proceedings.
If we refuse to give You access to, or update, or correct Your Personal Information, we will provide You with a written explanation including the reasons for our refusal.
We may charge You an administrative fee for providing access to Your information in response to a request.
9. Privacy and the internet
Cookies, web and mobile analytics
We may gather information about You through cookie technology. For example, we may assign a cookie to You to limit the amount of times You see a particular Fu offer or to help better determine which Fu offers to serve to You. Please note that most Internet browsers will allow You to stop cookies from being stored on Your device and to delete cookies stored on Your device. However, if You choose to eliminate cookies, the full functionality of the Service may be impaired for You.
We encode our cookies so that only we can interpret the information stored in them.
We also use web and mobile analytics, including using Google Advertising ID. For example, Web beacons are images embedded in a web page or email for the purpose of measuring and analysing a website’s usage and activity. We, or third-party service providers acting on our behalf, may use Web beacons to help us analyse Service usage and improve the Service.
10. We post updates on our website whenever there is a change to this policy
11. How to make a privacy complaint?
If You wish to notify us of any privacy complaint You may have against us, including if You think that we have failed to comply with the Australian Privacy Principles, You may contact us at firstname.lastname@example.org.
If You are not satisfied with the manner in which we have dealt with your complaint, you may refer it to the Office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by:-