Your privacy is important to us.
moneyvase understands and appreciates that you are concerned about your privacy, including the confidentiality and security of the information we may gain about you online.
moneyvase operates under ABN 92 646 710 670 (referred to hereafter as “we”, “us” or “our”) provides an online service that allows you to easily better understand your spending (“moneyvase”). moneyvase consolidates and tracks your financial information on the moneyvase app (“the App”). Based on this information, moneyvase may also present information relating to third party products or services.
1 Introduction
1.1 We are committed to maintaining the confidentiality, integrity and security of the Personal Information that we collect, hold, use and disclose. This Privacy Policy explains how we manage Personal Information and other information about You.
2 The information that we collect and hold
2.1 When You register as a moneyvase User, we will collect Personal Information such as your email, mobile, year of birth, your first name and your last name.
2.2 In order to benefit from the full functionality of moneyvase, you must provide us with your account credentials. By doing so, you will enable us to link your moneyvase account with your bank account. For clarity, account Information will be collected from all bank accounts or financial institutions for which you provide account credentials.
2.3 Due to the nature of moneyvase, from time to time, we may collect and hold additional personal information or other information about you. This information may be secured shared with a third party if required or necessary and can include:
- 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 Moneyvase, as well as the type and quality of that Data;
- your GPS location;
- the dates on which and the times at which You use Moneyvase, including the duration of such use; and
- the IP address and the MAC address of Your computer or Mobile Device.
This is not an exhaustive list.
2.4 If you are a visitor to moneyvase, we do not collect personal or sensitive information from or about you from the unsecure areas of the moneyvase website. If you are a visitor who does not log in to the moneyvase service with a username and password, you therefore remain anonymous. We might collect metadata such as the date and time of each unique visit, any pages viewed, and any content downloaded. They also log the number of times Website visitors click on content featured on the website. This information is collected only to further develop the moneyvase service and improve the facilities and/or services we are able to offer.
moneyvase may also ask you for additional information about, for instance, your experience of the moneyvase service or your purchasing habits or offer you the opportunity to participate in promotions and giveaways. Any information submitted in relation to these activities will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules for those promotions and giveaways.
You consent to our use of your account Credentials, as your authorised agent for the purpose of accessing your account information from third party financial institutions (e.g., banks, mortgage brokers, and superannuation funds) in order to provide you with the services you access through moneyvase.
You acknowledge that when we use your account credentials we can access your account information with third party financial institutions on your behalf and in doing so you may not be in compliance with the terms and conditions of your financial institution. If you have any concerns or questions, you should contact your financial institution.
When moneyvase collects your personal information it is held digitally on secure servers accessible by moneyvase staff only and in accordance with our Privacy Policy.
moneyvase doesn’t ask for, use or disclose government related identifiers of an individual (e.g., your tax file number).
3 How do we collect information?
3.1 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 moneyvase;
– when you use the moneyvase;
– when you participate in one of our surveys; or any event via the Website or the App;
– when you contact us; - through moneyvase, when you synchronise your moneyvase account with your bank account and financial institution;
- 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.
3.2 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 or the level of service on which we pride ourselves.
4 How do we hold your information?
4.1 We take the privacy and security of your information seriously.
4.2 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:
– to maintain the security of Your online session; and
– to protect your information, the moneyvase accounts and our systems from misuse, interference and loss, and from unauthorised access, modification or disclosure; - when you register as a moneyvase user, two-way authentication is required ie your mobile number or email for registration;
- we transmit information such as your registration information or your account credentials only securely;
- from the time you log in to use moneyvase, the information between your computer or mobile device are encrypted. This enables client and server applications to communicate in a way that is designed to prevent tampering and hacking; and
- we test the App and the Website for any failure points that would allow hacking by using different type of firewalls and security algorithms.
- Reviews and adopts new developments in electronic security and encryption technologies. We are using authentic security protocols and effective firewalls to protect your data and to increase security.
4.3 For clarity, these precautions apply only to moneyvase. We exercise no control over how your information is stored, maintained or displayed by third-parties or on third-party websites.
4.4 You are responsible for maintaining the confidentiality of your moneyvase registration Information.
4.5 We maintain strict rules to help prevent others from guessing your password. We also recommend that you change your password periodically. Your password must be at least 8 characters in length. We also maintain strict rules and two-way authentication to make your account secure. You must not provide your moneyvase registration Information to any third-party. If you believe that your moneyvase registration Information may have been stolen or been made known to others, you must contact us immediately at support@moneyvase.com. In any event, you should change your password immediately via the App or Website. We are not responsible if someone accesses your moneyvase account if they have obtained your moneyvase registration Information from you or as a result of your breach of this Privacy Policy or the moneyvase Terms of Use.
4.6 If You have a security related concern, please contact us at support@moneyvase.com. We will work closely with You to ensure a rapid and personal response to your concerns.
5 How do we use your information?
5.1 Our main purpose for collecting information about you is:
- to provide moneyvase to you;
- to provide you with information about moneyvase;
- to assist you with enquires; and
- to better service your needs.
However, the more you tell us the more we can help you. If you choose not to provide some information you may be unable to use some of the features we offer.
5.2 We collect, hold, use and disclose your personal information primarily to fulfil our business functions and activities as described in our Privacy Policy, and you consent and authorise us and our service providers to collect, hold, use and disclose that information for the purposes described in our Privacy Policy, and for the following purposes:
- 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 the App or the Website;
- to communicate with you (such as by summaries of your account information and by sending you email alerts and moneyvase newsletters);
- to provide support and moneyvase updates;
- to gain an understanding of your needs so that we may improve and develop moneyvase;
- to personalise your experience with moneyvase, our App and 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 below);
- for any other purpose which it would be reasonable to expect that we would collect, hold, use and disclose your information for; and
- subject to your consent, for other purposes which may be notified to you from time to time.
5.3 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 moneyvase, until you opt-out. You may opt-out by following the “unsubscribe” instructions in any email communication you receive from us.
We will not disclose your personal information to any other person or use your personal information for any other purpose, unless authorised or required by law.
6 How do we disclose your information?
6.1 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 moneyvase); and
- anyone who is authorised by law to obtain information about you from us.
6.2 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.
6.3 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 disclose your Account Credentials to Yodlee Inc (“Yodlee”), our account aggregation service provider, headquartered in California, United Sates. Yodlee is a leading financial services and technology provider. Yodlee maintains offices in the United States, the United Kingdom and India. The disclosure of this information to Yodlee is strictly governed by our privacy and security obligations to you, and is necessary as Yodlee provides the means by which you can link your financial data to your moneyvase account.
You consent to our disclosure of this information as your authorised agent for the purpose of allowing Yodlee to access your Account Information with third party financial institutions (e.g., banks, mortgage brokers, and superannuation funds) in order to allow us to provide you with the services you request. When Yodlee accesses your account information your identity is not directly ascertainable from the transaction data which is part of your account information.
6.4 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 moneyvase for the purpose of comparing their personal financial situation against that of the broader community.
6.5 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 do we keep your information?
7.1 Your data is yours. You can remove it anytime you want. When you request us to delete your moneyvase account, your data will be permanently expunged from our primary production servers and further access to your moneyvase account will not be possible. We will also promptly disconnect any connection we had established to your account information and delete all account credentials.
7.2 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?
8.1 If your personal information changes, you may update it at any time via the App or the Website.
8.2 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.
9 Privacy and the internet
9.1 We may gather information about you through cookie technology. For example, we may assign a cookie to you to limit the number of times you see a particular moneyvase offer or to help better determine which moneyvase offers to serve to you or to track your activity on a merchant website. 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 moneyvase may be impaired for you.
9.2 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 moneyvase usage and improve moneyvase.
9.3 We may use third-party service providers to help us analyse certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyse visitor activity on the App or the Website. We may permit these service providers to use cookies and other technologies to perform these services for us.
9.4 For clarity, the information provided by web beacons and cookies may personally identify you. By using moneyvase, you consent to the collection of your information by those methods.
9.5 There are a number of products and services offered by third-parties, advertised through moneyvase that may be complementary to your use of moneyvase. If you choose to use these separate products or services, disclose information to the providers, or grant them permission to collect information about you, then their use of your information will be governed by their own privacy policies.
9.6 When you click on a link to a third-party website, we encourage you to check the privacy policy of that website.
9.7 We may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third-party website. We use this information to improve the quality of our offer and to customise the content available from moneyvase.
9.8 It is necessary for moneyvase to collect the Internet Protocol (IP) address (i.e., the identifier for your computer when you are using the Internet) of website users for their interaction with various parts of the moneyvase service. In the case that moneyvase has recorded your IP address, such as when you log in. Your IP address will not be used by us or released to any third party except in relation to issues pertaining to security, inappropriate behaviour and/or fraud, which may include issues such as unauthorised access to your computer, our systems, or fraudulent transactions.
9.9 We will take all reasonable precautions and measures to maintain the security and privacy of your personal information. However, due to the nature of the Internet and the nature of the systems and technology available at the current time, it is unfortunate that breaches of security are still possible. Therefore, we cannot guarantee that your information will be completely secure, and to the maximum extent permitted by law we cannot be held liable for any loss or damage arising out of a breach of security.
10 Your data may be transferred upon change of control
10.1 Personal Information may be transferred to a third-party as a result of a sale, acquisition, merger, reorganisation or other change of control affecting us. If we sell, merge or transfer any part of our business, part of the sale may include your personal information.
11 We post updates on our website and the app whenever there is a change to this policy
11.1 We may update this Privacy Policy from time to time to account for legislative updates and developments in technology, changes to our operations and practices, and to make sure our policy remains appropriate in its changing environment.
11.2 Any information we hold is governed by the most recent version of this Privacy Policy. You should check this page periodically to ensure that you are familiar with any changes made to this Privacy Policy.
12 Definitions
12.1
- “Data” means any data inputted by you or with your authority into the Website, or data acquired via your authorisation (including your transaction information);
- “User” means the registered user for moneyvase, and, where the context permits, includes any entity on whose behalf that person registers to use moneyvase;
- “Account Credentials” means the combination of access code, access number, client number, 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;
- “Bank Account” means a deposit or loan account that you maintain with an Australian bank or another Australian financial institution;
- “Mobile Device” means a mobile phone, tablet or other internet-enabled device that is compatible with moneyvase and has, or has access to, an internet connection;
- “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 details and employment details;
- “moneyvase registration information” means your mobile number or email address and your password for your Moneyvase account;
- “You” or “Your” means the individual who uses the App or Website; and
- the words “includes”, “including”, “for example”, “such as” and similar terms or expressions are not words of limitation.