Privacy Policy

1

INTRODUCTION

1.1 This Privacy Policy was last updated on 6 July 2016.
1.2 Pocketbook Australia Pty Ltd (ACN 162 562 110) (Pocketbook, we, us and 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 For the purposes of this Privacy Policy:

  • 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;
  • Account Information” means day-to-day transactional information (including all debit and credit operations) in respect of Your Bank Account;
  • Bank Account” means a deposit or loan account that You maintain with an Australian bank or another Australian financial institution;
  • Mobile App” means the Pocketbook Mobile Device application;
  • Mobile Device” means a mobile phone, tablet or other internet-enabled device that is compatible with the Service and has, or has access to, an internet connection;
  • Personal Information” means information about an identified individual or an individual who is reasonably identifiable. Common examples are an individual’s name, signature, address, telephone number, date of birth, email address, bank account details and employment details;
  • Pocketbook Registration Information” means Your email address and Your password for Your Pocketbook account;
  • Service” means the services provided by the Web App and/or the Mobile App;
  • Web App” means the Pocketbook web application which may be accessed at https://getpocketbook.com/;
  • You” or “Your” means the individual who uses the Web App and/or the Mobile App; and
  • the words “includes”, “including”, “for example”, “such as” and similar terms or expressions are not words of limitation.
1.4 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.

2

THE KINDS OF INFORMATION THAT WE COLLECT AND HOLD

2.1 Certain features of the Service are made available to You without the need to register or to provide any of Your Personal Information to us. However, other features of the Service require You to register as a Pocketbook account holder.
Registration
2.2 When You register as a Pocketbook account holder, we will collect Personal Information such as Your email address, Your first name and Your last name (depending on whether you register via the Mobile App or the Web App).
Account Credentials
2.3 In order to benefit from the full functionality of the Service, You must provide us with Your Account Credentials. By doing so, You will enable us to link Your Pocketbook account with Your Bank Account. For clarity, Account Information will be collected from all Bank Accounts for which You provide Account Credentials.
Other Information
2.4 Due to the nature of the Service, from time to time, we may collect and hold additional Personal Information or other information about You. This can include:

  • Your address, date of birth and contact details;
  • information about Your financial circumstances and objectives, including Your assets, liabilities, income, expenditure, taxation information, insurance, superannuation and investment preferences;
  • the type of operating system and/or other software or firmware used by Your computer or Mobile Device;
  • the data You send and receive by using the Service, as well as the type and quality of that data;
  • your GPS location;
  • the dates on which and the times at which You use the Service, including the duration of such use; and
  • the IP address and the MAC address of Your computer or Mobile Device.

This is not an exhaustive list. For example, in certain cases we may also collect Your tax file number.

Tax File Number
2.5 We will only collect, hold, use and disclose Your tax file number in accordance with the Privacy Act 1988 (Cth), the Privacy (Tax File Number) Rule 2015, the Tax Administration Act 1953 (Cth) and other applicable laws (as amended from time to time). Without limiting our obligations under those laws, we will take reasonable steps to ensure that You are informed of:

  • the taxation law or other applicable law which authorises us to request or collect Your tax file number;
  • the purpose(s) for which Your tax file number is requested and collected; and
  • the consequences of declining to quote Your tax file number.

3

HOW WE COLLECT INFORMATION?

3.1 We may collect Your information in a number of ways including:

  • directly from You, such as:
    • when You provide information to us when You register to use the Service;
    • when You use the Service;
    • when You participate in contests, giveaways and other promotions via the Wed App or the Mobile App;
    • when You participate in one of our surveys; or
    • when You contact us with an enquiry on a request;
  • through the Service, when You synchronise Your Pocketbook account with Your Bank Account;
  • from third-parties You authorise to disclose Your information to us;
  • from publicly available sources of information;
  • when we are legally authorised or required to do so; or
  • through digital communications, such as when You visit our website.
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.
4.2 We use various technical solutions, security controls and internal procedures to help us protect Your information. For example:

  • we use a combination of firewall barriers, encryption techniques and authentication procedures:
    • to maintain the security of Your online session; and
    • to protect Your information, the Pocketbook accounts and our systems from misuse, interference and loss, and from unauthorised access, modification or disclosure;
  • when You register as a Pocketbook account hold, we require a password from You for Your privacy and security;
  • we transmit information such as Your Registration Information or Your Account Credentials only securely;
  • from the time You log in to use the Service, the communications between Your computer or Mobile Device and the Web App or Mobile App are encrypted. This enables client and server applications to communicate in a way that is designed to prevent eavesdropping, tampering and message forgery; and
  • we test the Web App and the Mobile App regularly for any failure points that would allow hacking.
4.3 For clarity, these precautions apply only to the Service. We exercise no control over how Your information is stored, maintained or displayed by third-parties or on third-party websites.
About Your password
4.4 You are responsible for maintaining the confidentiality of Your Pocketbook Registration Information.
4.5 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 8 characters in length. You must not provide Your Pocketbook Registration Information to any third-party. If You believe that Your Pocketbook Registration Information may have been stolen or been made known to others, You must contact us immediately at hello@getpocketbook.com. In any event, You should change Your password immediately via the Web App or the Mobile App. We are not responsible if someone accesses Your Pocketbook account if they have obtained Your Pocketbook Registration Information from You or as a result of Your breach of this Privacy Policy or the Pocketbook Terms of Use.
4.6 If You have a security related concern, please contact us at hello@getpocketbook.com. We will work closely with You to ensure a rapid and personal response to Your concerns.

5

HOW DO WE USE YOUR INFORMATION?

5.1 Our main purpose for collecting information about You is:

  • to provide the Service to You;
  • to provide You with information about the Service;
  • to assist You with enquires; and
  • to better service Your needs.
5.2 In order to do that effectively, we may use Your information for a range of different purposes including:

  • for our business operations and for purposes that are related to one or more of our functions and activities;
  • to verify Your identity and to allow You to access and use the Web App and/or the Mobile App;
  • to communicate with You (such as by providing weekly summaries of Your Account Information and by sending You email alerts and Pocketbook newsletters);
  • to provide support and Service updates;
  • to gain an understanding of Your needs so that we may improve and develop the Service;
  • to personalise Your experience with the Service and our website;
  • to perform research and analysis (including to conduct surveys);
  • to comply with our legal, statutory and regulatory obligations;
  • for direct marketing purposes (in this respect, see paragraph 3 below); and
  • 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 the Service, until You opt-out. You may opt-out by emailing us at hello@getpocketbook.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 with entities outside of our organisation. These may include:

  • our related bodies corporate, business partners, associates and affiliates;
  • 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 the Service); and
  • anyone who is authorised by law to obtain information about You from us.
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. If they fail to meet these obligations, they may be subject to disciplinary action, termination of contract and/or criminal prosecution.
6.3 Our contracts with the entities to which we disclose Your information:

  • outline the appropriate use and handling of Your information; and
  • 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 do not share information with entities which are located, or have operations, outside of Australia. However, should this change in the future, we will seek Your consent and we will deal with that change in accordance with all applicable laws.
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, including:

  • advertisers and other third-parties for their commercial, marketing, research and promotional purposes;
  • organisations approved by us that conduct research into consumer spending; and
  • other users of the Service for the purpose of comparing their personal financial situation against that of the broader community.
6.6 Our de-identification procedure involves:

  • removing personal identifiers;
  • removing or altering other information that may allow You to be identified; and
  • continuously assessing and managing the risk of re-identification.

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 Pocketbook account, Your data will be permanently expunged from our primary production servers and further access to Your Pocketbook 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 Web App or the Mobile App. Otherwise please contact us at hello@getpocketbook.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 hello@getpocketbook.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.
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 Pocketbook offer or to help better determine which Pocketbook offers to serve to You. 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 the Service 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 Service usage and improve the Service.
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 Web App or the Mobile 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 the Service, You consent to the collection of Your information by those methods.
Third parties offerings
9.6 There are a number of products and services offered by third-parties, advertised through the Service, that may be complementary to Your use of the Service. If You choose to use these separate products or services, disclose information to the providers, or grant them permission to collect information about You, then their use of Your information will governed by their own privacy policies.
9.7 If You click on a link to a third-party website, we encourage You to check the privacy policy of that website.
9.8 We may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third-party website. We use this information to improve the quality of our offer and to customise the content available from the Service.

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

WE POST UPDATES ON OUR WEBSITE WHENEVER THERE IS A CHANGE TO THIS POLICY

11.1 We update this Privacy Policy periodically to take into account new laws and 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.
11.2 Any information we hold is governed by the most recent version of the policy. You should check this page periodically to ensure that You are familiar with any changes made to this Privacy Policy.

12

HOW TO MAKE A PRIVACY COMPLAINT?

12.1 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 hello@getpocketbook.com.
12.2 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.
12.3 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.

13

CONTACT US IF YOU HAVE ANY QUESTIONS OR CONCERNS

13.1 If You have questions, comments, concerns or feedback regarding this Privacy Policy or any other privacy or security concern, send an email to hello@getpocketbook.com.