- “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 App” means the Longevity App Mobile Device application;
- “Mobile Device” means a mobile phone, tablet or other internet-enabled device that is compatible with the Service 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;
- “Longevity App Registration Information” means Your email address and Your password for Your Longevity App account;
- “Service” means the services provided by the Web App and/or the Mobile App;
- “You” or “Your” means the individual who uses the Web App and/or the Mobile App; and
- the words “includes”, “including”, “for example”, “such as” and similar terms or expressions are not words of limitation.
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.
THE KINDS OF INFORMATION THAT WE COLLECT AND HOLD
Collection of personal information
- contact details (i.e. your name, address, email, phone and facsimile details);
- information required for you to open an account with us or otherwise do business with us including bank account details, and any other relevant financial information;
- information required as part of a recruitment process;
- statistical information regarding the use of the Longevity App websites or Apps, including website users’ IP addresses and the dates and times of visits; and
- information regarding purchases that you make by cards linked to your user account
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 contests, giveaways and other promotions via the Wed App or the Mobile App;
- 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 Longevity App account with Your Bank Accounts;
- 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.
Where practicable, we will collect personal information directly from you. We may also collect personal information about you from third parties such as your financial institution with your authorisation. If we receive information about you from someone else, we will take reasonable steps to ensure you are aware that we have collected personal information about you and the circumstances of the collection.
You have a right not to provide information to us. We will give You the opportunity to provide or to decline to provide information. 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.
HOW WE HOLD YOUR INFORMATION
We take the privacy and security of Your information seriously. 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 Longevity App accounts and our systems from misuse, interference and loss, and from unauthorised access, modification or disclosure;
- when You register as a Longevity App account holder, we require a password from You for Your privacy and security;
- we transmit information such as Your Registration Information or Your Account Credentials only securely;
- from the time You log in to use the Service, the communications between Your Mobile Device and the Mobile App are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery.
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
USE AND DISCLOSURE OF PERSONAL 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 enquires; 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 the Mobile App;
- to communicate with You (such as by sending You email alerts and Longevity App newsletters);
- 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;
- to provide information to, and respond to queries from, shareholders or suppliers;
- subject to Your consent, for other purposes which may be notified to You from time to time.
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.
We do not share information with entities which are located, or have operations, outside of Australia. However, should this change in the future, we will seek Your consent and we will deal with that change in accordance with all applicable laws.
- our business partners, associates and affiliates;
- 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.
HOW TO ACCESS, UPDATE OR CORRECT YOUR INFORMATION?
If Your Personal Information changes, You may update it at any time via the Mobile App. Otherwise please contact us at firstname.lastname@example.org. 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.
OUR WEBSITE PRIVACY PRACTICES
Links to other websites
YOUR DATA MAY BE TRANSFERRED UPON CHANGE OF CONTROL
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.
WE POST UPDATES ON OUR WEBSITE WHENEVER THERE IS A CHANGE TO THIS POLICY
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. We are committed to acknowledging Your complaint in a prompt manner and will give You an estimated timeframe for when we will respond to Your complaint. It is our intention to resolve Your complaint to Your satisfaction. However, if You feel that Your complaint has not been satisfactorily addressed or that it is taking too long to resolve Your complaint, You are entitled to contact the Office of the Australian Information Commissioner (OAIC), on 1300 363 992 or the other contact details on the OAIC’s website (oaic.gov.au), who may investigate Your complaint further.
CONTACT US IF YOU HAVE ANY QUESTIONS OR CONCERNS
© 2018 Longevity App Australia Pty Ltd