1. We respect your privacy
Grow My Money Pty Ltd ABN 90 629 681 296 (we, us, our, or GMM), respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors.
You should also review our Terms and Conditions.
“Personal information” is information we hold which is identified, or reasonably identifiable, as being about you.
2. How we collect your personal information
2.1 We collect personal information for the purpose of conducting our business as a provider of our Service, including where you have provided information to us by:
- accessing and using our Platform and/or Service;
- registering or subscribing to our Platform and/or Service;
- providing your account details for our cashback rewards program;
- entering information in our online toolkits;
- posting on any discussion forums or interacting with us on social media;
- changing your email preferences; and
- contacting or interacting with us and providing personal information by any other means, including physically or electronically.
2.2. You have the right not to provide your personal information to us. You may not be able to use our Service, or some features of our Platform or Service, if you choose not to provide this information.
3. Types of personal information we collect
3.1 The personal information that we collect may include:
- your name and contact details, including mobile number, month and year of birth, email address and postcode;
- how you use our Service, including which retailers you choose to shop with and the amount of cashback rewards contributed to your GMM Account (your registered account to login to, and use, our Platform or Service);
- details of your GMM Product Account (the superannuation fund, home mortgage account or other product offered by GMM in the future) for payments;
- any other personal information collected in the course of using our Platform or Service or completing a transaction.
3.2. Where we are required to do so, we may collect, or appoint a service provider to collect, necessary identification information to meet Know Your Customer (KYC) requirements under anti-money laundering and counter terrorism financing regulation. If we, or our service provider, need identification information for KYC requirements, you will receive details of the required information when you go through the KYC process.
3.3. In some circumstances, where it is unreasonable or impracticable to collect information from you, we may collect information about you from a third-party source. For example, we may collect information from a publicly maintained record or from a third-party you have given us permission to contact (such as an accountant, solicitor, superannuation trustee, insurance provider etc).
3.4. We may combine information that we collect directly from you with information obtained from third parties or other sources, where permitted by applicable laws.
4. How we use your personal information
4.1. We collect, hold, and use your personal information to provide our Service to subscribers, improve our Service, maintain and develop our business systems and assist in responding to your feedback or enquiries, as well as for our auditing, marketing, planning and billing purposes.
4.2. We may also contact you to make you aware of new and additional products, competitions, services and opportunities available to you, or to ask if you would like to participate in our surveys or market research.
4.3. We may contact you by various methods including telephone, email or SMS.
4.4. We also use your personal information to compare information for accuracy and to verify it with third parties.
4.5. We may monitor and record our communications with you, including emails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our Platform and Service you ask us about, and in order to meet our legal and regulatory obligations generally.
4.6. We may collect, hold, use, and disclose your personal information for other purposes which are within reasonable expectations or permitted or required by law.
4.7. You may at any time opt-out of receiving marketing material by following the unsubscribe instructions on any marketing communication you receive from us. Removal from any marketing distribution lists may take several business days following the date of your request. Note you will continue to receive account/transactional communications.
4.8. To the extent permitted by applicable law, we retain information about you after the end of your subscription period for our Service. This information will be held and used for as long as permitted for legal, regulatory, fraud prevention and legitimate business purposes.
4.9. When your personal information is no longer required by us, unless we are required by law to retain it, we will take reasonable steps to destroy or de-identity your personal information securely.
5. When we disclose your personal information
5.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, and to Shartru Wealth Management Pty Ltd, the Australian Financial Services Licence holder (the AFSL holder), as reasonably necessary for the purposes set out in this policy.
5.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. The AFSL holder may also need to do so.
5.3. We may also disclose or transfer our records, including personal information, to purchasers or potential purchasers of our business or its assets.
5.4. Where applicable, we will make any international transfers of personal information subject to appropriate or suitable safeguards as required by the Australian Privacy and Personal Information Protection Act 1998 (PPIP Act). Any overseas disclosure does not affect our commitment to safeguarding your personal information and we will take reasonable steps to ensure any overseas recipient complies with the Australian Privacy Principles.
5.5. We are committed to ensuring that the information you provide to us is secure. To minimise the risk of unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. Information security can’t be guaranteed, but if we find any evidence of a security compromise, we’ll take appropriate steps to improve security.
6. Access to your personal information
6.1. Your privacy is important to us. You can access and/or correct your personal information, subject to exceptions allowed by law. If you believe that any information we hold on your file is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us at email@example.com, Ph: 1300 464 010 or Grow My Money Pty Ltd, PO Box 284, Neutral Bay NSW 2089.
6.2. Most of the information we hold on you is available within your GMM Account and can be found by logging in. Should you wish to obtain a copy of the information we hold on your file, we ask that you make a request in writing and allow up to ten (10) business days for the information to be forwarded. We may charge a fee to cover the cost of verifying the application and retrieving, reviewing and copying the required information. If the information sought is extensive, we will advise of the likely cost in advance and can help to refine your request if required.
6.3. You have the right not to provide your personal information to us. You may not be able to use our Service, or some features of our Platform or Service, if you choose not to provide this information.
6.4. We reserve the right to refuse to provide you with information that we hold about you, where permitted by applicable laws.
7. Cookies and data
7.1. When you visit our Platform we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
7.5. We also use the Google Ads service to enable remarketing services, and Google UserID, demographic and interest reports. Information about you regarding your web usage behaviour is held by Google. Information from Google’s UserID service may be connected to other data that we hold about you.
7.6. Our Platform may also use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here https://www.facebook.com/customaudiences/app/tos/?ref=u2u.
7.8. Our Platform may from time to time have links to other websites not owned or controlled by us, which may have their own privacy policies. We don’t endorse those websites and we are not responsible for the privacy practices of other websites.
8. Complaints about privacy
8.1. If you have any complaints about our privacy practices, we encourage you to send in details of your complaint to firstname.lastname@example.org or Grow My Money Pty Ltd, PO Box 284, Neutral Bay NSW 2089. We take complaints very seriously and will respond in writing after receiving written notice of your complaint.
10. Contact Details