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Privacy Policy

myBIG AUSTRALIA PRIVACY POLICY

Last updated: 5 November 2021

This document (privacy policy) sets out how myBIG Australia Pty Ltd ACN 650 687 924 (myBIG, we, us and our) collects, uses, discloses and otherwise handles personal information (as defined in this document) that we collect from you, including through your access to and use of our website located at www.mybig.com.au (Website).

We take our privacy obligations under the Privacy Act 1988 (Cth) seriously, and we acknowledge and recognise that the protection of the privacy of your personal information is important and required under Australian law. This privacy policy will be made available to you at no charge to you.

We reserve the right to amend, modify, change, replace or update this privacy policy from time to time. We will make the privacy policy (as amended, modified, changes, replaced or updated) available on the Website. We encourage you to regularly review the Website to ensure that you are familiar with our current privacy policy.

1. Information we collect

For the purposes of this privacy policy, “personal information” means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not. As described in detail below, we may collect certain personal information about you in connection with your use of, or your submissions to, the Website. We may collect one or more of the following type(s) of personal information:

1.1 your name and other information that may be used to identify you;

1.2 your mail and/or street address information;

1.3 your email address;

1.4 your telephone number (including land line and mobile number);

1.5 where you subscribe to any services provided through the Website, your credit card and bank account information;

1.6 information about your business and personal circumstances;

1.7 information you provide to us when completing client surveys, questionnaires and promotions;

1.8 your device identity and type, your IP address, geo-location information, page view statistics, advertising data and standard web log information; and

1.9 any other information that can be used (either singly or in combination with other information) to identify you.

2. How we collect personal information

We collect personal information in a number of ways, as explained in further detail below. While we use reasonable efforts to collect personal information about you directly from you, we may also collect personal information about you from third parties. We may collect personal information as follows:

2.1 When you communicate with us, sign up for materials, and interact with us via the Website: We may collect personal information when you communicate with us or submit information to us. We may also collect personal information when you interact with our Website or utilise Website features, and when you sign up to receive newsletters, updates or other information.

2.2 When we leverage and/or collect cookies, device IDs, location data, data from the environment and data from other tracking technologies: We may collect personal information using cookies and other technologies (such as web beacons, device IDs, geo-location information, HTML5 local storage, Flash cookies and IP addresses). For further information, please refer to the section below dealing with “Use of cookies and similar technologies”.

2.3 When we collect personal information from third parties or publicly available sources. In certain circumstances, we may obtain certain personal information about you from third party sources. We may combine your personal information with data we obtain from our services, other users and third parties.

2.4 When we supply you with products and/or services that you have purchased from us, including via the Website.

3. Anonymity and pseudonymity

Where it is lawful and reasonable for you to do so, you have the right to deal with us on an anonymous or pseudonymous basis. As permitted by law, and subject to the following, we will give you the option of not identifying yourself, or of using a pseudonym, in dealing with us.

However, if you choose to interact with us in an anonymous or pseudonymous fashion, or you do not provide us with personal information on request, then we may be unable to provide you with the products or services you request.

Further, we reserve the right to verify your identity in certain circumstances. For example, we may need to verify your identity when you request that we provide certain products or services to you, in order to liaise with other service providers and in order to comply with our statutory and regulatory obligations. Additionally, when you request access to or correction of the personal information we hold about you, or when you wish to make a complaint regarding how we have handled your personal information, we reserve the right to verify your identity and contact details in order to facilitate our satisfaction of your access or correction request, or to investigate and to deal with your complaint.

We may create de-identified or anonymous data from personal information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of de-identified or anonymised data is not subject to this privacy policy.

4. Receipt of unsolicited personal information

Generally, we only collect personal information when it is specifically requested or when we take active steps to collect that information. From time to time, however, personal information about an individual may be provided or volunteered to us on an unsolicited basis. Where we receive personal information on an unsolicited basis, then (in accordance with our statutory obligations), we will promptly determine whether such personal information could lawfully have been collected had we requested the personal information or otherwise had actively sought the provision of such personal information.

5. Use of cookies and similar technologies

The Website uses cookies and similar technologies to improve user experience, for performance and analytics and to improve our content, products and services. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalisation and performance/analytics. When you visit the Website, we may also automatically collect certain information about your device (including information about your web browser, IP address, your geographic location and time zone). Additionally, as you browse the Website, we collect information about individual web-pages or products on the Website that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We also use cookies and similar technologies for purposes of marketing and advertising.

A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web-page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and to distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track Personal Data previously entered by a web user on the Site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. Cookies can remember login information, preferences, and similar information.

Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data.

We may also use web beacons or ‘pixels’, and in certain circumstances, we may collect IP addresses, and information regarding screen resolution, browser software and operating system types, clickstream patterns, dates and times that the Site is accessed, and other categories of data.

If you want to block the use and saving of cookies from the Site onto your computer’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Site and its external serving vendors, or use the cookie control system, if available upon first visit. Please note that if you choose to erase or block your cookies, certain parts of our Site may not function correctly or at all. For information on how to disable cookies, please refer to your browser’s documentation.

Our Site may use the following technologies to implement cookies and pixels:

5.1 Google Analytics: In order to ensure that the content from the Site remains up-to-date, user-oriented and comprehensive, the Site employs Google Analytics, a web-analysis tool from Google, Inc. (“Google”) that enables us to optimize our services for you. Google Analytics uses cookies that track your preferences during your visit to our websites. This allows us to simply navigation, for example, thereby helping us to make the Site more user-friendly. The information that is generated in this process (including the IP address) is anonymized, making personal identification impossible. An evaluation for reporting purposes is carried out only after the anonymization process. The data generated by this cookie is usually transferred and stored on a server in the USA. As a user of the Site, you always have the option of disabling cookies in your browser settings. Most browsers allow cookies as a default setting. Should you change this setting, this may disrupt certain functions of our websites. Furthermore, you can prevent Google's acquisition and processing of the information that is generated by the cookie and concerns your activity on the website (including your IP address) by downloading and installing a browser plug-in. In this process, your IP-Address is in a first step reduced to Countries in the European Union or other Countries in the European Economic Community. The actual link to the tool is: http://tools.google.com/dlpage/gaoptout?hl=us.Further information on the terms of use and the privacy options of Google are available on:
http://www.google.com/analytics/terms/us.html

5.2 Google AdWords. As an AdWords customer, the Site uses Google conversion tracking by Google on some pages. This means that Google AdWords places a cookie on your computer (“conversion cookie”) if you have accessed our webpage via a Google ad. These cookies become invalid after 30 days. If you visit certain pages on our website and the cookie has not yet expired, we and Google can recognize that someone has clicked on an ad and been directed to our page as a result thereof. Each AdWords customer receives a different cookie. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected with the help of the conversion cookie allows us to prepare conversion statistics to optimize our services. AdWords customers know, for instance, the total number of customers who have clicked on their ad and been redirected to a page with a conversion tracking tag. But they do not receive any information by which users can be personally identified. If you do not want to participate in the tracking, you can prevent the placement of the necessary cookie – for instance through a browser setting that deactivates the automatic placement of cookies in general. “You can also deactivate conversion tracking cookies by setting your browser to block cookies from the domain googleadservices.com.

5.3 Google Remarketing. Moreover, the Site uses Google’s Remarketing technology on some pages. With this technology, users who have already visited our web pages and online services and shown in interest in what we have to offer are shown targeted advertising on other websites of the Google Partner network. The ads are displayed through the use of cookies, by means of which the user’s behaviour during his or her visit to the website is analyzed and then used for targeted product recommendations and interest-based advertising.

If you do not wish to receive any interest-based advertising, you can deactivate Google’s use of cookies for these purposes by visiting www.google.com/settings/ads. Alternatively, users can deactivate cookies from third party providers by visiting the network advertising initiative’s deactivation page ( www.networkadvertising.org/managing/opt_out.asp).

5.4 Facebook Pixel. The Site uses the “Facebook pixel” provided by the social network Facebook (“Facebook”). As a result, so-called tracking pixels are integrated into our web pages . When you visit our web pages, the tracking pixel will create a direct link between your browser and the Facebook server. Thus, Facebook will receive the information from your browser that our web page was accessed from your device. If you are a Facebook user, Facebook can therefore associate your visit to our pages with your user account. Please note that we as the provider of these web pages are not notified of the content of the data transmitted or of the use thereof by Facebook. We can merely specify the segments of Facebook users (based on criteria such as age, interests) on whose pages we would like our ads to be displayed. Moreover, when this pixel is called up later on from your browser, Facebook can then determine whether an ad on Facebook was successful, for instance whether it has led to an online purchase. We receive from Facebook merely statistical data on this, without any references to a specific individual. This allows us to collect information about the effectiveness of the Facebook ads for statistical and market research purposes. For more information concerning this topic, please see Facebook’s privacy policy at https://www.facebook.com/about/privacy/. Please click here (link: https://www.facebook.com/settings?tab=ads) if you do not wish to have your data collected via the Facebook pixel.

Please note that Google and Facebook have their own privacy policies which are independent of ours. We do not accept any responsibility or liability for these policies. Before using our website, please inform yourself about Google’s privacy policy ( www.google.com/privacy.html) and Facebook’s data policy ( www.facebook.com/about/privacy/).

6. The purposes for which we collect personal information and its uses

We may collect, use, disclose and process personal information for a number of different purposes as set out in detail below. We collect and use personal information for one or more of the following purposes:

6.1 To operate our business and to provide the Website (including to maintain the Website and to communicate with you regarding the Website, such as to provide you with notices regarding changes to the Terms of Use and/or this privacy policy and to enforce our Terms of Use, and to develop, provide and improve the Website, such as to better tailor the features, performance, security and support of the Website and for statistical and analytics purposes in relation to the Website);

6.2 To provide our products, services and information to you, including where we need to provide or disclose personal information about you to our service providers, and to take steps in response to information requests or inquiries you may submit prior to entering into a contract or partnership with us;

6.3 To comply with our contractual and legal obligations, to resolve disputes and to enforce our agreements with third parties;

6.4 For record keeping and administrative purposes, and to consider applications for employment with us;

6.5 For fraud, loss, and other crime prevention purposes;

6.6 For direct marketing purposes, including to enable us to send you marketing and promotional messages and other information that may be of interest to you, via email, SMS, social media or direct mail (subject to you not exercising your right to opt out of your receipt of such messages);

6.7 To assist in the investigation of suspected illegal or wrongful activity, and to protect and to defend our rights and property, or the rights or safety of third parties;

6.8 To comply with laws, regulators, court orders and other legal obligations, or pursuant to legal processes;

6.9 Subject to applicable contractual or legal restrictions, in connection with contemplated reorganisation or an actual reorganisation of our business, in connection with financing, a sale or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting due diligence required to decide whether to proceed with a transaction; and

6.10 To maintain a safe working environment for our staff and contractors.

7. Disclosure of personal information to third parties

We may disclose personal information we collect to third parties but only on an as-needs basis and only to fulfil one or more of the purposes for which we collected the information, any secondary purpose related to the primary purpose(s) of collection, and otherwise as required or authorised by law.

7.1 Your organisation. Where you deal or engage with us on behalf of an organisation, we may disclose some or all of your personal information to other persons from your organisation to operate our business, to provide the Website and to provide our products, services and information to you and your organisation.

7.2 Related bodies corporate. We may disclose some or all of your personal information to our related bodies corporate for the purposes described in this privacy policy. Where we disclose such information with our related bodies corporate, we will require our related bodies corporate to honour this privacy policy.

7.3 Service providers. We may disclose personal information to our business partners, distributors, service providers, marketing providers, and vendors in order to maintain the Website and to provide, improve and personalise the products and services. We may also disclose personal information for other technical and processing functions, such as sending emails on our behalf, technical support, or otherwise operating the Website, for analytics, and for marketing purposes. Such third parties may have access to personal information only as needed to perform their functions for us, and they may not use personal information for other purposes.

7.4 Persons authorised by you. We may disclose some or all of your personal information to persons to whom you authorise us to disclose your personal information.

7.5 As authorised by law. We may also disclose some or all of your personal information to comply with applicable laws and regulations, to respond to a lawful request for information we receive, or as otherwise pursuant to a legal process. We may also use and disclose personal information to establish or exercise our legal rights, to enforce our Terms of Use and other contracts with you or your organisation, this Privacy Policy, or agreements with third parties, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

7.6 Professional advisers, insurers and auditors. We may also disclose some or all of your personal information to our professional advisers (including our lawyers and accountants), our insurers and our auditors for the purpose of our advisers, insurers and auditors completing their obligations owed to us.

8. Our use and disclosure of de-identified or anonymised data. We may create de-identified or anonymised data sets from personal information by removing data components that makes the information personally identifiable to you or through obfuscation or through other means. Our use and/or disclosure of anonymised or de-identified information is not subject to this privacy policy.

9. Links to other websites. Our Website may contain links or otherwise provide access to other websites, mobile applications or Internet locations (Third Party Sites). Our privacy policy does not apply to Third Party Sites. We encourage you to read the privacy policies of any Third Party Site with which you choose to interact.

10. Disclosure of personal information to recipients located outside Australia. We do not currently disclose personal information to a third party recipient located outside Australia. However, we may engage third party service providers (including cloud providers and website hosting providers) that provide some or all of their services to us from location(s) outside Australia. If we do so, we will take reasonable steps to ensure that such service providers deal with the personal information to which they have access in a manner consistent with this privacy policy. If you communicate with us via email, through a social network service or through some other electronic process, the communication may be routed through servers that are located outside Australia and, in relation to a message sent to us through a social network service (such as Twitter or Facebook), the social network provider and its partners may collect, hold and process personal information in a jurisdiction outside Australia.

11. Security. We take reasonable steps to ensure that your personal information is kept secure and protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. We use technical and organisational security measures designed to secure and protect personal information. Please note, however, that we cannot eliminate security risks associated with the storage and transmission of personal information.

12. Quality of personal information. We take reasonable steps to ensure that personal information collected, used and disclosed is accurate, complete and up-to-date. However, the accuracy, completeness and currency of the personal information we hold largely depends on the accuracy of the information you supply to us. If at any time you discover that any personal information held about you is inaccurate, incomplete, outdated, irrelevant or misleading, please contact us to request correction of the information. We will handle a correction request in accordance with the procedures set out in this privacy policy. In doing so, we reserve the right to verify the identity of the person making a correction request before processing the request.

13. Access to and correction of personal information

13.1 We will provide access to your personal information within a reasonable period of time following our receipt of your request, unless an exception applies. The exceptions include: (a) where the access poses a serious threat to the life or health or safety of the individual, public health or public safety; (b) where the request is frivolous or vexatious; (c) where the request relates to existing or anticipated legal proceedings or to current negotiations between you and us; (d) the request is unlawful, would impede or prejudice any investigation of unlawful activity; or (e) where we are required or authorised by or under Australian law or a court/tribunal order to not comply with the request.

13.2 Where we do not provide you with access to your personal information, we will explain to you the reason for denying access and provide details in relation to the relevant complaint process, should you not agree with our reasons.

13.3 While we will not charge a fee for making an access request, we reserve the right to charge a reasonable fee to cover our costs incurred in providing access to your personal information.

13.4 If you can establish that the personal information we hold about you is not accurate, complete or up-to-date, or is irrelevant or misleading, we will take reasonable steps to correct the information. If we have disclosed inaccurate, incomplete, out-of-date, irrelevant or misleading information to a third party, we will take reasonable steps to ensure that the recipient is aware of the correction.

13.5 We may request from you information in order to verify your identity and your connection to the individual about whom you request personal information, if required. Further, we reserve the right to redact information included in the personal information, in order to protect the privacy of other individuals.

14. Complaints procedure. If you any query or complaint about how we have handled your personal information, please contact us, at the details set out below. We will provide a response to you within a reasonable time period following receipt, in accordance with applicable law. We reserve the right to verify the identity of the person making the complaint and to seek (where appropriate or reasonable) further information from the complainant about the circumstances of the complaint. We reserve the right to refuse to investigate or to otherwise deal with a complaint where permitted by law. For example, we may refuse to investigate or to otherwise deal with a complaint if we consider the complaint to be vexatious or frivolous. If you are not satisfied with our determination, then you may escalate the complaint to the Office of the Australian Information Commissioner.

15. Contact us. For further information about our privacy policy or practices, or to request access to or correction of your personal information we hold about you, or to make a complaint, please contact us using the details below:

Email: [email protected]

Mail address: 52 Parramatta Rd, Forest Lodge, NSW 2037