This Privacy Policy applies to ClearScore Australia Pty Ltd (ACN 624 386 330) (“ClearScore”), in relation to the provision of our Financial Insights Services (as defined in our Financial Insights Terms) and explains how we collect, manage and use personal information about users of our Financial Insights Service. By “personal information” we mean information that is associated with a specific person and can be used to reasonably identify that person. Personal information does not include information that has been made anonymous, and cannot reasonably identify a specific person.
We respect your privacy and protecting your personal information is paramount. ClearScore is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
ClearScore’s partners, third party suppliers/ service providers (together, our “Partners”) are independent of ClearScore and may have privacy policies which differ from ours. Our Partners are responsible for their own privacy policies and privacy practices. Please contact our Partners directly for further information on their privacy policies.
In this Privacy Policy, references to "we", "our" or "us" are references to ClearScore, references to "you" and "your" means each natural or legal person who uses or accesses our Financial Insights Service, and references to our website include references to our apps as they relate to our Financial Insights Service. Please read this Privacy Policy carefully before using or accessing the Financial Insights Service. By using or accessing the Financial Insights Service you are accepting and consenting to the practices described in this Privacy Policy.
This Privacy Policy together with our Financial Insights Terms and Conditions ("Financial Insights Terms") applies when you use and access our Financial Insights Service. The ClearScore Privacy and Cookies Policy applies to your use of ClearScore services generally. If there is any conflict between this Privacy Policy and the Financial Insights Terms or Privacy and Cookies Policy, this Privacy Policy will prevail in relation to your use of the Financial Insights Service.
We collect your personal information directly from you but in some circumstances we may also collect information about you from other third parties as described in this section. We only collect information about you that is necessary for us to provide you with our Financial Insights Service and to comply with our legal obligations. This section describes the kinds of personal information we collect. Information you give us.
If you wish to use our Financial Insights Service, you will need to register with us as a ClearScore user and provide us with the minimum amount of information about you. If you choose to withhold some or all of your information, we will not able to provide you with the full functionality of our Financial Insights Service.
As a user of our Financial Insights Service, you may give us information about you when you use and access our Financial Insights Service and when you communicate with us. This includes information you input during registration by answering specific questions on our website, providing us with feedback, participating in surveys, and when you can you report a problem.
The information you give us may include:
- Your personal and contact details. This may include your name, address, email address, phone number and date of birth;
- If you consent to us accessing your account on your behalf, your username and account log in details for that account (“authentication details”) via a secure API provided by our service provider Talefin Pty Ltd (ACN 632 551 770), so that the bank, credit union, building society or financial service provider (“Account Provider”) can identify you to access your records. Please note that the authentication details are encrypted and only accessed when allowing your account data to be retrieved and passed to us in accordance with this Privacy Policy and the Financial Insights Terms.
- Your account provider(s).
- Your monthly income and expenditure
- Your financial goals. This may include information about significant life events (e.g. planning for retirement or a career change)
- Your budgets. This may include information about unexpected changes to your financial situation. Information that we will receive from your Account Provider.
- Your account type and details. This may include your name, date when your account was opened, the account fees and charges)
- Your account number and BSB
- Your account balance and account transactions (incoming and outgoing) and other details from your account, such as standing orders or direct debits;
- in the case of loan account (such as credit cards, home loans or personal loans) information about the credit limit, available funds, arrears, interest rate, repayment amount and hardship, any fees, payment dates, and term of the loan. ;
Sensitive information. Sensitive information is personal information about your racial or ethnic origin, political opinions, religious beliefs, trade union membership, or information relating to your health, sex life or sexual orientation. These information are subject to additional requirements under the Privacy Act 1988 (Cth). When we collect sensitive information, we will only do so with your consent or where otherwise lawfully permitted. The categorisation of some of your transactions may be indicative of your religious or political beliefs or trade union membership (for example, if you pay membership for a political party or trade union or make a donation to a religious organisation).
Information we collect about you. We will collect your information during your access to and use of the Financial Insights Service predominantly in digital format including:
- the details regarding the interaction and communications made between us including when you use and access our Financial Insights Service, make an enquiry or complaint and provide feedback. We also collect any phone number used to call our customer service number;
- technical information including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Financial Insights Service (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, licks, and mouse-overs), and methods used to browse away from our Financial Insights Service.
Information we receive from other sources. We may receive information about you from third parties if you use any part of our Financial Insights Service. We work closely with third parties (for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them. Information collected from cookies. We collect information about your use of our Financial Insights Service through our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Privacy and Cookies Policy.
We will use the information we hold about you to provide you with our Financial Insights Service, obtain quotes from credit providers, improve all of our services, administer your account and communicate with you as well as to manage our business and to comply with our legal obligations. We will also use the information on an anonymous or aggregated basis for research, profiling, analytical purposes.
This section lists the ways we may use your information. While this list is not exhaustive, any purpose outside of this list will be consistent with those permitted under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
Information you give us or we collect from other third parties.
We will use this information to:
- Process your registration as a user
- Analyse and report on your account data in order to identify and inform you of credit products that we consider are likely to interest you to enhance our services
- Contact you to ask you to provide your consent for us to access your account in accordance with our Financial Insights Terms (including by contacting you via app ‘push’ notification with relevant information about our Financial Insights Services, such as notifications about providing your consent for us to access your account)
- Assist you with pre-filling application forms of credit products you choose to apply for
- Verify your identity as part of our identity authentication process
- Where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you
- Notify you about changes to our Financial Insights Service
- Ensure compliance with your requests for the exercise of your rights
- Manage our communications with you in relation to your queries or complaints
- Review your interaction with us to ensure that content of our Financial Insights Service is presented in the most effective manner for you and your device
- Creating aggregated and anonymised research data and selling it to our Partners from which all personal information is removed. This information does not allow any party to identify you.
Information we collect about you based on your use of our Financial Insights Service.
We will use this information to:
- Administer our Financial Insights Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- Manage our risks and prevent, detect and investigate fraudulent activities
- Manage our business including managing our testing systems and processes and our corporate governance and audit
- Improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
- Keep our Financial Insights Service safe and secure and to prevent fraud
- Feature products or services that may be of interest
Data analytics.
We will use the information we hold about you to:
- analyse information about you on a personalised or aggregated basis to further tailor our Financial Insights Service experience to you, to help us understand user behaviour including how Financial Insights Service is used, improve our Financial Insights Service and develop products that better meet our user’s needs and behaviours, and for marketing purposes;
- aggregate your information with other users and with other data on an anonymous basis for our and our business partners’ data analytical and reporting purposes;
- verify the accuracy of data that we hold about you and create a better understanding of you as user;
- provide you with a better service by conducting statistical analysis and system testing to understand your needs;
- take steps to protect your information against loss or damage, theft or unauthorised access;
- identify behaviour patterns when we use information about you, your spending and your use of the Financial Insights Services in conjunction with other users in an anonymised format;
- understand and manage our business and risks.
We may use and disclose your information to others to ensure the provision to you of our Financial Insights Service, any information you request and for the purposes for which it is collected (as set out in the section “How we use your information”). We will share your information where we have your permission to do so in accordance with this Privacy Policy or where we believe it is necessary for a legitimate reason connected to our Financial Insights Service. Subject to the requirements of the Australian Privacy Principles, we may also use and disclose your information for any other related purpose that you would reasonably expect the information to be used or disclosed.
Group companies. We may share your information for the purposes described above with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, including in the UK, in order to provide our Financial Insights Service and facilitate our group operations.
Our Partners. We may share your information with providers of products on our platform, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products. We may share your information with our partners to:
- assess your probability of being accepted for a product;
- allow us or our Partner to conduct analysis with the intent to better understand the market or to provide you with better products and services in the future, and/or for segmentation purposes;
- pre-fill an application form with the product provider;
- conduct income or identity verification;
- prevent fraud.
Our Partners will retain the information that was provided with your consent when you searched or applied for credit while you were using our Financial Insights Service. Our Partners will manage your information in accordance with their own privacy policies in accordance with the Privacy Act 1988 (Cth).
Selected third parties. We may share your information with selected third parties including:
- third parties which enable us to provide you with the Financial Insights Service such as Talefin Pty Ltd (ACN 632 551 770), cloud back-up and server hosting providers, IT software and third parties that provide communication services and identity verification services, and commercially available third party databases;
- if we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets (or the buyer or seller’s advisers);
- if we or part or all of our assets are acquired by a third party, in which case information held by us about our users of our Financial Insights Service will be one of the transferred assets;
- if we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our Financial Insights Terms and other agreements; or
- to protect the rights, property, or safety of ClearScore (or any of our group companies), our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
- advertisers that require your information, to perform services on our behalf, including selecting and serving relevant adverts;
- market research organisations engaged by us to undertake customer satisfaction surveys and market research
Fraud Prevention Agencies. We will share your information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. We and other organisations may access and use the information recorded by fraud prevention agencies from other countries.
Government and law enforcement agencies. We may share your information with government and law enforcement agencies in order for us to comply with our legal obligations. Law enforcement agencies may access and use information we share with fraud prevention agencies.
##How long we keep your information for How long we keep your information will depend on the purpose for which it was collected, our obligations, your actions and whether the use or disclosure of your information is permitted by the Privacy Act 1988 (Cth). We will only retain your personal information for as long as is necessary for those purposes. When we no longer need your personal information, we take reasonable steps to destroy or anonymise it.
In regards to personal information about your account retrieved with your consent from an Account Provider, we will retain it in the following manner:
- if you allow your consent to lapse without revoking or renewing it, we will retain your account information for a period of 12 months after the date your consent lapsed. After this period, your account information will be permanently erased or fully anonymised. You can always renew your consent before the end of the 12 month period;
- if you actively opt to revoke your consent and unlink your account from our Financial Insights Service, we will immediately erase or fully anonymised all of your account information;
- if you continue to use our Financial Insights Service and provide your consent when requested, we will retain your account information for at a maximum of least 7 years from the date of the original consent.
Your other personal information collected in accordance with this Financial Insights Privacy Policy will be kept for a maximum period of 7 years after it is no longer required to provide you with our Financial Insights Service..
##How we protect your information We take the security of your information very seriously and use strict procedures to protect it when you use or access our Financial Insights Service. All information you provide to us is stored on our secure servers.
We do our best to protect your personal information, but we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage. Where possible, we try to only process your information within Australia. If we or our service providers transfer your information outside of Australia, we always require that appropriate safeguards compliant with the Privacy Act 1988 (Cth) and the Australian Privacy Principles are in place to protect your information.
We will provide you with the necessary tools and contact details to be able to exercise your rights regarding the information that we hold about you. However, please note that in some cases, exceptions apply to the exercise of these rights and you may not be able to exercise them in all circumstances. For the exercise of any of your rights, please contact our privacy officer. You will be able to:
Request access to your information. You have the right to access to any information that we hold about you. We will need to validate the identity of anyone making an access request to ensure that we do not provide your information to anyone who does not have a right to that information. If you are seeking information about another person’s behalf, we will require the authorisation from that individual.
We will take reasonable steps to provide you with access as soon as practicable (typically within 30 days from your request) unless we need more time. If we do need more time, we will let you know.
We will not provide you with access to your information if we consider there is a reason under the Privacy Act 1988 (Cth) or other law to withhold the information. For example, we will not give you access to information that would have unreasonable impact on the privacy of another individual. If we do not provide you access to your information we will provide you with a written notice including the reasons for the refusal and the mechanisms available to you to complain about our decision.
We do not charge a fee for lodging an access request but a reasonable fee may be payable for providing you with access. If there is a fee, we will let you know how much it is likely to be so you can choose if you wish to go ahead.
Request to correct your information. We recognise the accuracy of the information we hold about you is critical to our Financial Insights Service so we encourage you to correct any inaccurate or incomplete information. You will usually be able to correct any information that we hold about you that is inaccurate or incomplete through the settings in your ClearScore account. Some information we receive about you from your Account Provider can only be corrected by them.
If you are seeking to correct information on another person’s behalf, we will require authorisation from that individual. We will take reasonable steps to make a correction as soon as practicable (typically within 30 days from your request) unless we need more time. If we require more time, we will let you know.
If we correct your information, we will notify organisations with whom we had previously shared your information with about the correction unless it is impracticable or unlawful to do so.
If we do not agree with a request to correct information we hold about you, we will provide you with a written notice including our reasons and the mechanisms available to you to complain about our decision. You can ask us to include a statement with the information that states that you believe it is inaccurate, out-of-date, incomplete, irrelevant or misleading.
We do not charge a fee for lodging a correction request, making a correction or associating the statement with your information.
Right to withdraw consent. If you have given your consent for us to access your account information, you have the right to withdraw your consent at any time. This can be done by unlinking your account from our Financial Insights Service by logging into your ClearScore account and updating your settings. For more information about how to unlink your account, please refer to the Financial Insights Terms and Conditions.
##Changes we make to our privacy policy Any changes we may make to our Financial Insights Privacy Policy will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes.
##Your right to lodge a complaint If you believe how we collect, hold, use and/or disclose your information does not comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles or the Privacy (Credit Reporting) Code 2014, we urge you to raise this with our privacy officer.
We will investigate all complaints and provide you with a written response as soon as practicable.
If however, you are not satisfied with our response to any complaints you raise with us, you can contact the Office of the Australian Information Commissioner as follows:
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au (be aware that email is not encrypted, if you are concerned about this, use the privacy complaints online form)
Mail: GPO Box 5128, Sydney NSW
Fax: 02 9284 9466
##Contact us You can address any questions, comments, complaints or requests regarding this Privacy Policy to our privacy officer at privacy@clearscore.com.au