Privacy Policy

This Privacy Policy (“Policy”) applies to Earnr Holdings Pty Ltd ACN 637 125 421, all subsidiaries and related companies including Earnr Australia Pty Ltd ACN 650 455 486 (“Earnr”) our affiliates and product issuing partners and their related companies; collectively ("we", "us", "our"). Some of our partners and affiliates may have separate, but consistent policies.

We are committed adhering to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”). We recognise the importance of your privacy, and that you have a right to control how your personal information is collected and used. Our Policy outlines how we handle your information, and how you can contact us in relation to any personal information we hold about you.

1.
Personal information we collect
1.1

We collect personal information from existing and potential customers, prospective employees and other individuals and use that information for the purposes identified in this Policy.

1.2

We collect personal information from existing and potential customers, prospective employees and other individuals and use that information for the purposes identified in this Policy.

•
Contact details (eg. your name, address, email, phone number);
•
information required for you to open an account with us, receive services from or do business with us. This information may include:
○
Contact details (eg. your name, address, email, phone number);
○
Information in identification documents
○
Information about shareholders, beneficiaries and beneficial owners
○
Tax file numbers and other government-issued identification numbers
○
Date of birth and gender
○
Details about your spouse, children and other family members
○
Bank account details including bank account details that you link to your account
○
Details about your bank account balances and spending activities, account interest and financial history;
•
personal information that allows us to tailor the services we make available to you;
•
information required as part of a recruitment process;
•
information regarding the use of the Earnr websites or apps, including website users' IP addresses and the dates and times of visits.
1.3

We usually collect personal information when you:

a.
Submit information to us including via the Earnr website or app (the “Platform”), eg. when you express interest in a product or service, register an account, retrieve log-in information, or request a new password;
b.
request a product arranged, dealt or issued by Earnr;
c.
submit information through the Platform;
d.
register for email subscriptions or publications through the Platform;
e.
receive services from us. This may include us accessing information held by your financial institution or other third parties that we have relationships with;
f.
use Earnr websites or apps;
g.
deal with us (through the Platform, by email, phone or in person) or request that we contact you;
h.
participate in referral arrangements, promotions or competitions run by Earnr or with the support of Earnr.
1.4

Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from a publicly available record or from your personal representative. Or you may choose to provide us with access to certain personal information stored by third parties such as social media sites. The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Earnr account and authorising Earnr to have access to this information, you agree that Earnr may collect, store and use this information in accordance with this Privacy Policy.

1.5

If we receive information about you from someone else, we will take reasonable steps to make you aware of the fact and circumstances of the collection.

2.
Providing personal information about someone else
2.1

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with their personal information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy.

3.
Use and disclosure of personal information
3.1

Our main purposes for collecting, holding, using and disclosing personal information are:

a.
to promote, arrange or deal in products and services;
b.
to respond to enquiries from customers or prospective customers, in relation to products or services;
c.
to improve products and services;
d.
to carry out processes associated with products or services, including processing applications, compliance reviews and audits, fraud screening, electronic funds transfers and account monitoring;
e.
To verify your identity, including under anti-money laundering laws, which involve disclosure of your personal information to service providers, government or regulatory bodies, or other information holders and repositories
f.
to process and assess employment applications;
g.
to enforce agreements between you and Earnr;
h.
to conduct competitions and promotions;
i.
to comply with legal or regulatory obligations and our policy requirements;
j.
for the purposes of conducting analysis about the deployment and use of products and services and the technology that supports our products and services, in Australia or elsewhere;
k.
as part of an actual or proposed novation, acquisition, disposition, merger or de-merger of a business or entering into an alliance, joint venture or referral arrangement;
l.
for any other business related purpose.
3.2

If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you with the services or products we were engaged to perform.

3.3

We may share your personal information with:

a.
our product partners and affiliates; and related companies;
b.
your financial advisers or other professional advisers;
c.
financial institutions that we use to provide products or services, or that we may partner with to create and offer a product or service;
d.
suppliers and service providers who help with our business operations including in relation to administration, auditing, due diligence, fraud prevention, identity verification, marketing, and technology services;
e.
parties who may invest in us or as part of an actual or proposed novation, acquisition, disposition, merger or de-merger of a business or entering into an alliance, joint venture or referral arrangement;
f.
government authorities where required by law, or other third parties pursuant to a subpoena, court order, or other legal process or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent financial loss, to report suspected illegal or fraudulent activity or to investigate suspected violations of our Terms and Conditions.
3.4

In carrying out our business, it may be necessary to share information about you with our related companies, our product partners and their related companies, and service issuers or organisations that provide services to us. This includes third parties from whom you have engaged Earnr via as part of a promotion or otherwise.

3.5

We may aggregate information that we collect and use it for purposes outside the scope of this Privacy Policy. Any aggregated data used for those purposes will have all personally identifiable information removed.

3.6

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.

4.
Information outside the jurisdiction of collection
4.1

We may disclose personal information outside the jurisdiction of collection but only to the extent it is necessary to perform our business functions or activities. In the conduct of our business we may transfer and disclose personal information to contracted service providers and organisations with whom we partner to provide services and whose data warehouses may be located outside Australia (notwithstanding at the date of this Privacy Policy all data we handle and store is processed and located within Australia).

4.2

Your information will be protected by the prevailing jurisdiction and not by Australian Privacy Principals. Earnr conducts extensive due diligence on any overseas organisation which receives personal information held by Earnr and requires a contractual arrangement protecting your personal information.

5.
Direct communication
5.1

If you have an account with Earnr, we will use your personal information to send you messages containing important information about your account. These messages are an important part of the service that we provide to you and will be sent to you as long as you hold an account with us. Customers with an account cannot opt-out of receiving these messages.

5.2

We may use personal information you have provided to us to send you information about your account and other products, services or material that you may be interested in.

5.3

If you receive promotional information from us and do not wish to receive this information any longer, please contact us directly, or use the unsubscribe facilities included in our marketing communications.

6.
Information storage and security
6.1

We take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate, up to date and complete. Your information is stored on bank grade secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal information held by us. We may also utilise third party storage providers (such as internet or ‘cloud’ based storage), all data we handled and stored is currently processed and located in Australia. If this were to change, you should be aware your information will be protected by the prevailing jurisdiction and not by Australian Privacy Principals. Please refer to Section 4 of this agreement regarding the due diligence Earnr conducts.

6.2

If we become aware of unauthorised access, or unintentional disclosure of your personal information we will take appropriate steps to rectify the data breach and will notify you in accordance with the requirements of the Privacy Laws.

7.
Digital technologies
7.1

We may use digital technologies such as cookies, location services, web server logs & IP addresses, in connection with the Platform, social media pages and other digital portals. Some of these technologies may operate without collecting or using any personal information.

7.2

The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser settings to either refuse to accept all cookies or to notify you when you have received a cookie. You may also delete cookies from your device at any time. However, if you refuse to accept cookies, you may not be able to access or use all of the features available on our website.

8.
Links to third party websites
8.1

Our websites may contain links to third party websites. These sites are not under our control and not subject to our Policy. You should view the terms and conditions and privacy policy of the relevant site. Earnr is not responsible for any practices on linked websites that might breach your privacy.

9.
Recruitment and Careers at Earnr
9.1

If you send us an application for a position, or express interest in careers with Earnr, this information will be used to assess your fit and / or application. This information may be disclosed to our related parties and service providers for purposes such as aptitude, psychological and medical testing; and other human resources management activities.

10.
Recruitment and Careers at Earnr
10.1

If at any time you want to know exactly what personal information we hold about you are welcome to request access to your record by contacting us at hello@earnr.com.au. Subject to any limitation by law, and us having confirmed your identity in a manner satisfactory to us, we will provide you with a physical or digital copy of personal information or invite you to inspect the information.

10.2

If at any time you wish to change personal information that we hold about you because it is inaccurate or out of date, please either update your account information directly through our websites or app, or contact us at hello@earnr.com.au and we will amend this record. If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we require it for legal reasons.

11.
Retention of information
11.1

When we no longer need to use your information, or are no longer required to retain it by law, regulation or policies, we will take steps to properly de-identify or destroy it.

12.
Contact details and complaints
12.1

If you have a query in relation to this privacy policy or any concerns or complaints about how we handle your personal information, please contact us by writing or via email:

Privacy Officer
Earnr Holdings Pty Ltd
Level 2, 11 York Street
Sydney, NSW, 2000
hello@earnr.com.au

12.2

In the case of a complaint in most cases we will ask you to put your request in writing to us. We will investigate your complaint and will endeavour to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint within 30 days of receiving it in writing or if you are dissatisfied with the response that you receive from us, you may have the right, to make a complaint to the Office of the Australian Information Commissioner.

13.
Future changes
13.1

Our Privacy Policy may change from time to time. Before providing us with personal information, please review the Privacy Policy on our website.

Last updated October 2021