Privacy Policy
SkyBudget Pty Ltd ACN 641 463 934 (referred to hereafter as “we”, “us” or “our”) provides an online service that allows you to easily better understand your spending (“SkyBudget”). More information about using SkyBudget is available here: https://SkyBudgetapp.com/terms-of-use/. SkyBudget consolidates and tracks your financial information on the SkyBudget app (“the App”) available on the SkyBudget website https://SkyBudgetApp.com (“the Website”). Based on this information, SkyBudget may also present information relating to third party products or services.
1. INTRODUCTION
1.1 This Privacy Policy was last updated on 13 May 2020.
1.2 SkyBudget Pty Ltd ACN 641 463 934 (SkyBudget, we, us and our) (referred to hereafter as “we”, “us” or “our”) is committed to maintaining the confidentiality, integrity and security of the Personal Information that we collect, hold, use and disclose. This Privacy Policy explains how we manage Personal Information and other information about You.
1.3 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.
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2. THE KINDS OF INFORMATION THAT WE COLLECT AND HOLD
2.1 Overview
We may collect both personal and sensitive information from You.
Personal information is any information about you that identifies you or by which your identity may be reasonably determined. The kinds of personal information that may be collected from you includes, but is not limited to, your full name, address, phone number, email address and payment details. By collecting this personal information, we are able to contact you when necessary, identify and protect your information from unauthorised use and provide the best possible service.
Sensitive information includes information or an opinion about an individual’s race, religion, political or trade association, among others. We will only collect sensitive information in circumstances where you have consented to the collection and if the information is reasonably necessary for us to provide our services.
Registration
2.2 When You register as a SkyBudget User, we will collect Personal Information such as Your email address, Your first name and Your last name.
Account Credentials
2.3 In order to benefit from the full functionality of SkyBudget, You must provide us with Your Account Credentials. By doing so, You will enable us to link Your SkyBudget account with Your Bank Account. For clarity, Account Information will be collected from all Bank Accounts for which You provide Account Credentials.
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Other Information
2.4 Due to the nature of SkyBudget, from time to time, we may collect and hold additional Personal Information or other information about You. This information may be secured shared with a third party if required or necessary and can include:
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Your address, date of birth and contact details;
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information about Your financial circumstances and objectives, including Your assets, liabilities, income, expenditure, taxation information, insurance, superannuation and investment preferences;
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the type of operating system and/or other software or firmware used by Your computer or Mobile Device;
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the Data You send and receive by using SkyBudget, as well as the type and quality of that Data;
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your GPS location;
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the dates on which and the times at which You use SkyBudget, including the duration of such use; and
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the IP address and the MAC address of Your computer or Mobile Device.
This is not an exhaustive list.
3. HOW WE COLLECT INFORMATION?
3.1 We may collect Your information in a number of ways including:
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directly from You, such as:
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when You provide information to us when You register to use SkyBudget;
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when You use SkyBudget;
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when You participate in contests, giveaways and other promotions via the Website or the App;
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when You participate in one of our surveys; or
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when You contact us with an enquiry or a request;
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through SkyBudget, when You synchronise Your SkyBudget account with Your Bank Account;
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from third-parties You authorise to disclose Your information to us;
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from publicly available sources of information;
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when we are legally authorised or required to do so; or
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through digital communications, such as when You visit our Website.
Where you provide us with Personal Information of third parties (for example, your spouse) you warrant to us that the relevant individuals have consented to you disclosing their personal information to us.
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3.2 You have a right not to provide information to us. We will give You the opportunity to provide or to decline to provide information and, where practicable and lawful, we will allow You to interact with us anonymously or by using a pseudonym. 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.
4. HOW DO WE HOLD YOUR INFORMATION?
4.1 We take the privacy and security of Your information seriously.
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4.2 We hold personal information
Physically:
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on our premises;
Electronically:
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on internal servers;
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with third party storage providers in Australia and the USA.
Our agreements with third party service providers contain obligations relating to confidentiality and security.
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4.3 We use various technical solutions, security controls and internal procedures to help us protect Your information. For example:
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we use a combination of firewall barriers, encryption techniques and authentication procedures:
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to maintain the security of Your online session; and
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to protect Your information, the SkyBudget accounts and our systems from misuse, interference and loss, and from unauthorised access, modification or disclosure;
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when You register as a SkyBudget User, we require a password from You for Your privacy and security;
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we transmit information such as Your Registration Information or Your Account Credentials only securely;
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from the time You log in to use SkyBudget, the communications between Your computer or Mobile Device and SkyBudget are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery; and
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we test the Website and the App regularly for any failure points that would allow hacking.
4.4 For clarity, these precautions apply only to SkyBudget. We exercise no control over how Your information is stored, maintained or displayed by third-parties or on third-party websites.
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About Your password
4.5 You are responsible for maintaining the confidentiality of Your SkyBudget Registration Information.
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4.6 We maintain strict rules to help prevent others from guessing Your password. We also recommend that You change Your password periodically. Your password must be at least 6 characters in length, both upper and lower case and contain at last one special character. You must not provide Your SkyBudget Registration Information to any third-party. If You believe that Your SkyBudget Registration Information may have been stolen or been made known to others, You must contact us immediately at admin@SkyBudgetapp.com. In any event, You should change Your password immediately via the Website or App. We are not responsible if someone accesses Your SkyBudget account if they have obtained Your SkyBudget Registration Information from You or as a result of Your breach of this Privacy Policy or the SkyBudget Terms of Use.
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4.7 If You have a security related concern, please contact us at admin@SkyBudgetapp.com. We will work closely with You to ensure a rapid and personal response to Your concerns.
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5. HOW DO WE USE YOUR INFORMATION?
5.1 We collect Your personal information for purposes including:
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supplying to you the services which you have requested, including as applicable, providing SkyBudget to You;
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to provide You with information about SkyBudget;
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to assist You with enquires; and
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to better service Your needs.
Personal information is used only for the purpose for which it is submitted or for such other secondary purposes that are related to that purpose, unless we disclose other uses in this privacy policy or at the time of collection.
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5.2 We collect, hold, use and disclose your personal information primarily to fulfil our business functions and activities as described in our Privacy Policy, and you consent and authorise us and our service providers to collect, hold, use and disclose that information for the purposes described in our Privacy Policy, and for the following purposes:
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for our business operations and for purposes that are related to one or more of our functions and activities;
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to verify Your identity and to allow You to access and use the Website or the App;
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to communicate with You (such as by providing weekly summaries of Your Account Information and by sending You email alerts and SkyBudget newsletters);
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to provide support and SkyBudget updates;
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to gain an understanding of Your needs so that we may improve and develop SkyBudget;
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to personalise Your experience with SkyBudget and our Website;
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to perform research and analysis (including to conduct surveys);
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to comply with our legal, statutory and regulatory obligations;
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for any other purpose which it would be reasonable to expect that we would collect, hold, use and disclose your information for; and
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subject to Your consent, for other purposes which may be notified to You from time to time.
Direct Marketing
5.3 We may use Your information so that we and our business partners can promote and market products and/or services that we think may be of interest to You (including products and/or services provided by a third-party). This marketing may be carried out in a variety of ways (including by email or by customising online content) and may continue after You stop using SkyBudget, until You opt-out. You may opt-out by emailing us at admin@SkyBudgetapp.com or by following the “unsubscribe” instructions in any email communication You receive from us.
6. HOW DO WE DISCLOSE YOUR INFORMATION?
6.1 From time to time, we may disclose Your information to a person outside of our organisation:
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Where necessary in connection with the purpose for which it was collected, for example:
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our related bodies corporate, business partners, associates and affiliates for the purpose of providing services to You;
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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 SkyBudget); and
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if you consent to the disclosure; or
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If required by law; or
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otherwise as permitted by the Privacy Act 1988 (Cth).
6.2 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.
6.3 Our contracts with the entities to which we disclose Your information:
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outline the appropriate use and handling of Your information; and
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prohibit them from using any of Your information for purposes other than those for which they have received Your information.
Overseas disclosure
6.4 We may disclose personal information to our external service providers for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. We may disclose your personal information to entities located outside of Australia, including our data hosting and Cloud-based IT service providers and other external technology partners and service providers located in the United States.
De-identified information
6.5 We may de-identify Your Personal Information or aggregate it in such a way that it cannot be used to identify You. We may disclose de-identified information to several entities as permitted under the Privacy Act 1988 (Cth), including:
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third-parties for their commercial, marketing, research and promotional purposes;
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organisations approved by us that conduct research into consumer spending; and
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other users of SkyBudget for the purpose of comparing their personal financial situation against that of the broader community.
6.6 Our de-identification procedure involves:
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removing personal identifiers;
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removing or altering other information that may allow You to be identified; and
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continuously assessing and managing the risk of re-identification.
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7. HOW LONG DO WE KEEP YOUR INFORMATION?
7.1 Your Data is Yours. You can remove it anytime You want. When You request us to delete Your SkyBudget account, Your Data will be permanently expunged from our primary production servers and further access to Your SkyBudget account will not be possible. We will also promptly disconnect any connection we had established to Your Account Information and delete all Account Credentials.
7.2 However, portions of Your Data, consisting of aggregate Data derived from Your Account Information, may remain on our production servers indefinitely. Your Data may also remain on a backup server or media. We keep these backups to ensure our continued ability to provide the Service to You in the event of malfunction or damage to our primary production servers.
8. HOW TO ACCESS, UPDATE OR CORRECT YOUR INFORMATION?
8.1 If Your Personal Information changes, You may update it at any time via the Website or the App. Otherwise please contact us at admin@SkyBudgetapp.com.
8.2 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 admin@SkyBudgetapp.com.
8.3 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.
8.4 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.
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8.5 We may charge You an administrative fee for providing access to Your information in response to a request.
9. PRIVACY AND THE INTERNET
Cookies, web and mobile analytics
9.1 We may gather information about You through cookie technology. For example, we may assign a cookie to You to limit the amount of times You see a particular SkyBudget offer or to help better determine which SkyBudget offers to serve to You or to track your activity on a merchant website to confirm your eligibility for any reward earned via SkyBudget Rewards. Please note that most Internet browsers will allow You to stop cookies from being stored on Your device and to delete cookies stored on Your device. However, if You choose to eliminate cookies, the full functionality of SkyBudget may be impaired for You.
9.2 We encode our cookies so that only we can interpret the information stored in them.
9.3 We also use web and mobile analytics, including using Google Advertising ID. For example, Web beacons are images embedded in a web page or email for the purpose of measuring and analysing a website’s usage and activity. We, or third-party service providers acting on our behalf, may use web beacons to help us analyse SkyBudget usage and improve SkyBudget.
9.4 We may use third-party service providers to help us analyse certain online activities. For example, these service providers may help us measure the performance of our online campaigns or analyse visitor activity on the Website or the App. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any Personal Information about our customers with these third-party service providers, and these service providers do not collect such information on our behalf.
9.5 For clarity, the information provided by web beacons and cookies may personally identify You. By using SkyBudget, You consent to the collection of Your information by those methods.
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We will take all reasonable precautions and measures to maintain the security and privacy of your Personal Information. This includes using the very best in hardware, software, and security practices available to us.
10. YOUR DATA MAY BE TRANSFERRED UPON CHANGE OF CONTROL
10.1 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.
11. EMAIL COMMUNICATIONS
11.1 We will correspond with you by email where you consent to that occurring. Where you communicate with us by email, or provide us with your email address, you are taken to have consented to us communicating with you by email (unless you explicitly tell us otherwise). Email may not be a secure way to communicate your personal information to us and as such, we recommend that personal information should be delivered to us through secure means.
12. WE POST UPDATES ON OUR WEBSITE AND THE APP WHENEVER THERE IS A CHANGE TO THIS POLICY
12.1 We may update this Privacy Policy from time to time to account for legislative updates and developments in technology, changes to our operations and practices, and to make sure our policy remains appropriate in its changing environment. The date of the last revision appears at the top of the policy.
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12.2 Any information we hold is governed by the most recent version of this Privacy Policy. You should check this page periodically to ensure that You are familiar with any changes made to this Privacy Policy.
13. HOW TO MAKE A PRIVACY COMPLAINT?
13.1 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 admin@SkyBudgetapp.com.
13.2 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.
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13.3 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.
14. CONTACT US IF YOU HAVE ANY QUESTIONS OR CONCERNS
14.1 If You have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, send an email to admin@SkyBudgetapp.com.
15. DEFINITIONS
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“Data” means any data inputted by You or with Your authority into the Website, or data acquired via your authorisation (including your transaction information);
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“User” means the registered user for SkyBudget, and, where the context permits, includes any entity on whose behalf that person registers to use SkyBudget;
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“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;
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“Account Information” means day-to-day transactional information (including all debit and credit operations) in respect of Your Bank Account;
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“Bank Account” means a deposit or loan account that You maintain with an Australian bank or another Australian financial institution;
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“Mobile Device” means a mobile phone, tablet or other internet-enabled device that is compatible with SkyBudget and has, or has access to, an internet connection;
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“Personal Information” means any information about You that identifies you or by which your identity may be reasonably determined. . Common examples are an individual’s name, signature, address, telephone number, date of birth, email address, bank account details and employment details;
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“SkyBudget Registration Information” means Your email address and Your password for Your SkyBudget account;
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“You” or “Your” means the individual who uses the Website or App; and
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the words “includes”, “including”, “for example”, “such as” and similar terms or expressions are not words of limitation.