Who We Are
Our website address is: swiftid.com.au
SwiftID Pty Ltd ABN 38 645 130 927 (we, us or our) understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our application collection and transfer services to you as a broker or as a client of a broker and when providing our website or a web platform/webform to you (together, our Services).
Types Of Information
Personal information: is information or an opinion, whether true or not and whether recorded in a
material form or not, about an individual who is identified or reasonably identifiable.
Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.
The Information We Collect
Personal information: The types of personal information we may collect about you include:
As a broker (or an authorised user of a broker):
• your name;
• your contact details, including email address, work mailing address, work street
address and/or telephone number;
• the business you work for;
• your role title;
• your
preferences and opinions regarding the customisation process;
• if applicable, your broker
number;
• any feedback, surveys or other information you provide to us;
• any support requests or
other enquires you submit with us and our reply to you;
• if you use our website or a web
platform/webform provided by us, the details as set out below;
• additional personal information that
you provide to us, directly or indirectly, through your use of our Services, associated applications
and/or accounts from which you permit us to collect information; and/or
• any other personal
information requested by us and/or provided by you or a third party.
As a client of a broker:
• your name;
• your date of birth;
• your contact details, including email address, mailing
address, street address and/or telephone number;
• if applicable, your existing bank account details
(i.e. BSB and account number);
• if applicable, details of your role as a trustee, shareholder and/or
company officer;
• if you use our website or a web platform/webform provided by us, the details as
set out below;
• any support requests or other enquires you submit with us and our reply to you;
•
details of or a photograph of (as applicable) your government issued identity documentation (i.e. driver
licence or passport);
• sensitive information:We do not actively request sensitive information about
you. However, when you submit your identity documentation to us we may inadvertently receive your
sensitive information, because the documentation may infer information such as your ethnicity, religious
affiliation or medical conditions. Where you provide such identity documentation to us you consent to us
using and disclosing it for the purpose of verifying your identity as part of the application process.
If at any other time we need to collect sensitive information about you, unless otherwise permitted by
law, we will first obtain your consent and we will only use it as required or authorised by law;
•
additional personal information that you provide to us, directly or indirectly, through your use of our
Services, associated applications and/or accounts from which you permit us to collect information;
and/or
• any other personal information requested by us and/or provided by you or a third party.
As a user of our website or a web platform/webform provided by us:
• your IP address, browser session and geo-location data, device and network information, statistics on
page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information
about your access and use of our Services, including an automated audit log of every action you take
when using our website or a web platform/webform provided by us (i.e. the time and date you log in, the
editing of an application, any documents uploaded);
• and/or any other personal information collected
by third parties that collect and process data for us using technologies such as cookies and pixels.
How We Collect Personal Information
We collect personal information in a variety of ways, including:
• Directly:We collect personal information which you directly provide to us, including when you create an
account on a web platform provided by us or fill in a webform provided by us, if you directly contact us
on our website or when you request our assistance via email, online chat or over the telephone.
•
Indirectly:We may collect personal information which you indirectly provide to us while interacting with
us, such as when you use our website, in emails, over the telephone and in your support requests or
online enquiries.
• From third parties:We collect personal information from third parties, such as
details of whether your identity has been verified and details of your use of our website or a web
platform/webform provided by us from our analytics and cookie providers. See the “Cookies” section below
for more detail on the use of cookies.
Collection And Use Of Personal Information
We may collect, hold, use and disclose personal information for the following purposes:
• to enable you to access and use our Services;
• as a broker (or an authorised user of a
broker):
• to provide you with a login and allow you to log in;
• for advertising and marketing,
including to send you promotional information about our products and services and information that we
consider may be of interest to you;
• as a client of a broker:
• to collect your application
information and provide this to the broker and bank (as applicable);
to verify your identity for the
purpose of your application;
• to contact and communicate with you about our Services;
• for
internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market
research and business development, including to operate and improve our Services and associated
applications;
• to comply with our legal obligations and resolve any disputes that we may have;
•
if you have applied for employment with us; to consider your employment application; and
• if
otherwise required or authorised by law.
Disclosure Of Personal Information To Third Parties
We may disclose your personal information to:
• as a client of a broker (via API):
• the broker (including their authorised users) and the provider
of their back office management system;
• the relevant bank;
• the verification check provider,
such as ID Check or ASIC;
• our third party service providers for the purpose of enabling them to
provide their services to us, including (without limitation) our developers, our IT service providers,
data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving
providers, marketing or advertising providers and professional advisors;
• our employees, contractors
and/or related entities;
• our existing or potential agents or business partners;
• as a broker,
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay
for goods or services we have provided to you;
• anyone to whom our business or assets (or any part
of them) are, or may (in good faith) be, transferred;
• courts, tribunals, regulatory authorities and
law enforcement officers, as required or authorised by law, in connection with any actual or prospective
legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to
collect and process data, such as Google Analytics (To find out how Google uses data when you use third
party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL
Google may use from time to time); and
• any other third parties as required or permitted by law,
such as where we receive a subpoena.
Overseas disclosure: We store all personal information in
Australia. However, where we disclose your personal information to third parties listed above, these
third parties (namely our developers and IT support providers) may store, transfer or access personal
information outside of Australia, including but not limited to, the Philippines.
We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Australian Privacy Principles.
Your Rights And Controlling Your Personal Information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Anonymity: Where practicable (i.e. when you make an initial general enquiry) we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the Office of the Australian Information Commission.
Storage And Security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.
Links To Other Websites
Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Embedded Content From Other Websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who We Share Your Data With
If you request a password reset, your IP address will be included in the reset email.
How Long We Retain Your Data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What Rights You Have Over Your Data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where Your Data Is Sent
Visitor comments may be checked through an automated spam detection service.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
SwiftID Pty Ltd ABN 38 645 130 927
Email: privacy@swiftid.com.au
Last update: 01 December 2020