Privacy policy

‍

Nine25 Pty Limited ABN 26 644 914 625 (we, us or our), understands that protecting your personal information is important.

‍

This Privacy Policy and Credit Information Policy (Policy) sets out our commitment to protecting the privacy of personal information (including credit information) provided to us, or otherwise collected by us when providing our Platform available at www.nine25.app (Platform) and our software to you (Services) or when otherwise interacting with you including when you apply to use to use our Services.

‍

‍

The information we collect

• your name;
• your username, password and any other information you input to create an account;
• images of you;
• your contact details, including email address, street address and/or telephone number;
• your employer, job title, pay details, payroll system and ATO number;
• your date of birth;
• your other payment details such as bank account details;
• bank transactional information and capture spend information collected by us through our Platform and in your use of our Services;
• your preferences and/or opinions;
• information you provide to us, including through feedback, customer surveys or otherwise;
• your credit information asset out below;
• your sensitive information as set out below;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• support requests submitted to us and our response to you;
• your 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 through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third-party.

‍

Credit information: The term credit information used in this Policy refers to “credit information” and “credit eligibility information” as defined in the Privacy Act 1988 (Cth) (Act).  Credit information is a sub-set of personal information that is given a higher level of protection. The types of specific credit information we may collect about you include:

‍

• information about your credit history;
• the fact that you have applied for credit;
• the amount of credit applied for by you (if any);
• the amount of credit provided to you by us (if any);
• the terms of payment of credit provided to you by us (if any), including any credit term;
• details of your spending history;
• details of your payment history, including details of any default of payments by you including any defaults to our third party providers (e.g. banks) that you use our Services with;
• information regarding credit that was provided to you that has otherwise been discharged;
• information retrieved from any credit referees or guarantors;
• information regarding your personal insolvency;
• information about your involvement in any court proceedings; and
• credit eligibility information, including a credit report and/ or a credit assessment score.

‍

Sensitive information: 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.  We do not actively request sensitive information about you.  If at any 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.

‍

‍

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 e.g. when you register for an account, through the ‘contact us’ form on our Platform or when you request our assistance via email, or over the telephone or use our Services. Additionally, we may collect credit information which you directly provide to us, including through your completion of any application form provided by us or you entering an agreement with us for the supply of our Services.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our Platform, in emails, over the telephone and in your online enquiries. Additionally, we may collect credit information which you indirectly provide to us while interacting with us, such as when you use our Services.
• From third parties: We collect personal information from third parties, such as from your employer, details of your use of our Platform from our analytics and cookie providers and marketing providers and details of your use of our Services from third party providers such as banks. See the “Cookies” section below for more detail on the use of cookies. Additionally, we may collect credit information from third parties, such as our third party providers (e.g. banks) that you use our Services with or from credit information providers to assess your suitability to use our Services.
  ‍

Why we collect, hold, use and disclose personal information

We collect your personal information when you use our software for the following purposes:

• to enable you to access and use our software, including to provide you with a login;
• to provide our Services to you;
• to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
• 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; and/or
• if otherwise required or authorised by law.

‍

We collect your personal information when you visit our Platform for the following purposes:

• to provide our Platform to you;
• to contact and communicate with you about any enquiries you make with us via our Platform;
• if you have applied to use our Services via our Platform, to consider your application;
• for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have; and/or
• if otherwise required or authorised by law.
  ‍

We collect your credit information when you apply to use or use our Services for the following purposes:

• verifying your identity;
• obtaining credit eligibility information from credit reporting bodies to determine your suitability to use our Services;
• assessing your application for credit;
• assessing your credit worthiness, including collecting your payment history in relation to any credit provided by us to you;
• enforcing our rights against you or your guarantors for repayment of any amount owed by you to us;
• providing our Services to you;
• administering your account, including for internal record keeping, administrative, invoicing and billing purposes;
• dealing with complaints or issues you may have in relation to our Services;
• dealing with defaults from third party providers such as banks that you use ourServices with;
• complying with our legal obligations and resolving any disputes that we may have; and
• if otherwise required or authorised by law.

‍

‍

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities;
• our third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) our IT service providers, data storage, web-hosting and server providers, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
• your third party service providers for the purpose of enabling them to provide their services, to you to enable you to use our Services, including (without limitation) to financial institutions and third parties where you use our Services;
• our existing or potential agents or business partners;
• sponsors or promoters of any promotions or competition we run;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• 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 howGoogle uses data when you use third party Platforms or applications, please seewww.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses;
• any other third parties as required or permitted by law, such as where we receive a subpoena; and
• any other third parties where you have consented.

‍

We will not directly disclose your credit information to credit providers or credit reporting bodies.

‍

‍

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.

‍

‍

Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.

‍

We are not likely to disclose credit information to individuals or entities that do not have an Australian link. If we do disclose credit information to individuals or entities that do not have an Australian link, we will update this Credit Information Policy to provide details of the countries in which these entities are located.

‍

‍

Cookies

We may use cookies on our Platform 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. However, they do recognise you when you return to our online Platform and allow third parties, such asGoogle and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Platform 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 ourPlatform or use all our Services.

‍

‍

Your rights and controlling your personal information

Your choice: Please read this 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 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 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.  

‍

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. We will take reasonable steps to provide you with access to the personal information within 30 days of receipt of your access request. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access. Please note, in some situations, we may be legally permitted to withhold access to your personal information.  In relation to credit information, in order for you to have the most up-to-date credit information held about you, we recommend that you request access to the credit reporting information held about you by credit reporting bodies.

‍

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. We will take reasonable steps to correct any information within 30 days of receipt of your correction request or a longer period if agreed with you in writing.Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

‍

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 acknowledge your complaint within 7 days of receipt of your complaint. We will promptly investigate your complaint and will take reasonable steps to respond to you in relation to the complaint within 30 days of receipt of your complaint or a longer period if agreed with you in writing. In our response, we will set out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

‍

‍

Amendments

We may, at any time and at our discretion, vary this Policy by publishing the amended Policy on our Platform.We recommend you check our Platform regularly to ensure you are aware of our current Policy.

‍

For any questions or notices, please contact us at:

‍

Nine25 Pty Limited ABN 26 644 914 625

Email: help@nine25.app

Last update: 26 April 2022