PRIVACY POLICY

 

In this Privacy Policy, 'us', 'we' or 'our' means Earnd Pty Ltd (ABN 46 625 490 968). We respect, and are committed to protecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. We adhere to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).

 

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time. Please check our website for updates. You may elect to deal with us anonymously, but due to the nature of our Earnd services, we may not be able to assist you.

 

The type of personal information that Earnd collects and holds

 

Personal information includes information or an opinion about an individual that is reasonably identifiable. Earnd may collect your name and contact details, your employment and salary details, updates about when you have earnt your salary, identification details that we require to identify you under the AML Laws, details of your loan(s), details of your repayment history, your bank account details through which you receive loan payments, information about your device location and identity, your Earnd platform usage information and other information that you provide to us in connection with your Earnd profile or your EarndPay loan. Generally, we will only collect sensitive information if it is necessary, and if you provide this information to us.

 

How Earnd collects and holds personal information

 

Earnd will collect information from you directly through your EarndPay profile registration interaction, through your use of EarndPay’s platform and apps and when you give us information at other times. Earnd has an integration with your employer’s system through which it may confirm your employment, confirm your authority to use EarndPay in connection with your employer, receive updates about your earned salary and collect information about loan repayments.

 

We may on occasions collect information from third parties, such our accredited vendors and service providers, or from a publicly maintained record. If you provide personal information to us about another person, you must ensure that you are authorised to disclose that information to us and that the individual has provided the consents set out in this Privacy Policy in respect of how we will deal with their personal information.

 

The purposes for which Earnd collects, holds, uses and discloses personal information

 

We use your personal information for the purpose for which it has been provided, for reasonably related secondary purposes, for other purposes for which you have consented, and for other purposes permitted under the Privacy Act. This may include using your personal information for the following purposes:

●     to enable you to access and use EarndPay or our other services;

●     for identity verification purposes, which may involve the use of third party systems, and matching information against government or official identification sources;

●     to service your EarndPay product, give you notices, and give you service information;

●     to operate, protect, improve and optimise our website, app, business and our users' experience, such as to perform analytics, conduct research and for advertising and marketing;

●     unless you have opted out, to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners, that we think you may find interesting; 

●     to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

●     in connection with our funding, ownership or business operational needs; and

●     to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

 

We and/or our selected business partners may use your personal information to send you direct marketing communications and information about our financial products and services. This may take the form of postal or digital communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g., an unsubscribe link).

 

Who may we disclose personal information to

 

We may disclose personal information for the purposes described in this Privacy Policy to:

●     our employees and related bodies corporate;

●     credit reporting bodies as described in our Statement of Notifiable Matters; https://earnd.com/legal/statement_of_notifiable_matters

●     your employer who is a participant under the EarndPay program;

●     third party suppliers and service providers (including technology providers, system optimising services and our financial service providers);

●     professional advisers, dealers and agents;

●     our existing or potential agents, business partners or partners and investors;

●     our sponsors or promoters of any competition that we conduct via our services;

●     anyone to whom our assets or businesses (or any part of them) are transferred;

●     third parties authorised by you to receive information held by us; and/or

●     other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

 

By providing us with your personal information, and using our platform, you consent to us disclosing your information to these entities without obtaining your consent on a case by case basis.

 

Default information

 

Default information is information about a payment (including a part payment) that is at least 60 days overdue, is an amount of $150 or over, and that we are entitled to recover. We may disclose default information about you to a Credit Reporting Body after giving you any notices that we are required to give. This could affect your credit score, and impact your ability to access future credit.

 

Offshore disclosure

 

We host our web services on an Australia-based cloud, and do not send personal information to offshore recipients. However, it is possible that parties to whom you have authorised us to disclose your personal information, such as your employer or a service provider, may disclose personal information offshore. The relevant countries are unknown to us at the time of preparing this Policy. Where applicable, we take reasonable steps to require our service providers to protect your personal information in accordance with the Privacy Act.

 

Security

 

We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a variety of physical, administrative, contractual, personnel, verification controls and technical measures to protect your personal information. Even so, given the nature of technology, we cannot guarantee the security of your personal information.

 

How to access and seek correction of your personal information

 

To access, seek or request personal information that we hold about you, please contact us. If we are unable to give you access, or if we decline to amend your personal information, we will give you a written reply describing our reason. We will need to verify your identity prior to providing your personal information.

 

You may also amend your personal information through your EarndPay profile.

How to complain if you feel that we have not complied with privacy laws, and how we will respond

 

If you feel that we have fallen short of the standards required under the Privacy Act, please contact us in writing, and provide full details about your concern to enable us to investigate. We will attempt to resolve your concern within a reasonable timeframe, and at least within 45 days. We will contact you if we need more information, and will give you a final written reply with our resolution.

 

Our contact details

 

The Earnd Privacy Officer, Level 18, 167 Macquarie Street Sydney, NSW 2000, privacy@earnd.com.au

 

You can also contact the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au or by calling 1300 363 992.

 

If you are unsatisfied with our handling of your complaint, you may contact our External Dispute Resolution scheme, which is the Australian Financial Complaints Authority (AFCA) at info@afc.org.au or by phone on 1800 931 678.

 

Requesting a copy of this policy

 

You may ask us to provide you with a copy of this policy free of charge in another format such as email or post. Please contact us on our details above to make such a request.

 

This Privacy Policy was last updated on 10 June 2019.