1derful Privacy Policy

This Privacy Policy applies to 1derful Pty Ltd (referred to as "we", "our" or "us"). We respect your rights to privacy under the Privacy Act 1988 (Cth) (the "PrivacyAct") and the Australian Privacy Principles ("APPs"). We comply with all their requirements in respect of the collection, management and use of your personal information, and the management of data breaches under the Notifiable Data Breach scheme set out in the Privacy Act.

We also comply with other applicable law and regulatory guidance, including those relating to the Consumer DataRights under the Competition and Consumer (Consumer Data Right) Rules 2020(Cth) in our role as authorised data recipient.

We are also bound by Part IIIA of thePrivacy Act, which regulates consumer credit reporting in Australia and is supported by the Privacy Regulation 2013 (Cth) and the Privacy (CreditReporting) Code 2014.

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What is your personal information?

When used in this Privacy Policy, the term “personal information” has the same meaning as that in thePrivacy Act. In general terms, it is any information or an opinion from which your identity is apparent or can reasonably be ascertained, for example, your name, date of birth, address, contact details such as telephone number and email address, and profession or occupation.

Some types of personal information are also designated as 'sensitive information', and these are subject to additional protections under the Privacy Act. For example, these can include information about your health, your political opinions, professional or political or religious affiliations or memberships, your criminal record, and genetics and/or biometrics. There are other types of sensitive information as well.

What is credit information?

The term "credit information" is defined in the Privacy Act and relates to an individual’s credit history, current credit arrangements, credit worthiness and credit-related dealings with us.

The term "credit eligibility information" includes:

credit reporting information, as defined in the Privacy Act, provided by credit reporting bodies about an individual; and
credit worthiness information about an individual, which we derive from credit reporting information.

What personal and credit information do we collect and hold?

The types of personal and credit information that we may collect about you will depend on the purpose for which the personal and credit information is being collected.

We may collect a range of personal information, including:

your name;
your mailing or street address;
your e-mail address;
a telephone contact number for you;
your age or birth date;
your profession, occupation or job title;
your financial and credit-related information, such as the full bank account numbers and/or credit or debit card numbers that you link to your 1derful account or give us when you use our services;
your marital status;
government-related identifiers (such as your tax file number*, your driver’s licence number, your Medicare number and your passport number);
the products and services you have purchased or which you have enquired about ,together with any additional information necessary to deliver those products and services and to respond to your enquiries;
any additional information relating to you that you provide to us directly through our websites or indirectly including through use of our websites, through our representatives or otherwise;
information that you provide to us through our service centre, customer surveys or visits by our representatives from time to time; and
credit information and credit eligibility information about you directly (this Such information may include details of your debts and payment commitments, whether you have been bankrupt, your consumer credit liability information, default and payment information and similar information).

*Please know that while we may collect or hold Government-related identifiers, we do not use them as a means of identifying you. In particular, use and disclosure of tax file numbers are strictly regulated by tax laws and the Privacy Act.

We may also collect the following types of sensitive information in certain circumstances:

in relation to Anti Money Laundering transaction monitoring by our service providers, criminal convictions, offences and political opinions where returned from a relevant search by our third party supplier - Comply Advantage.

We may also collect some information that is not captured by the “personal information” definition because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

How do we collect your personal information?

We generally collect your personal information directly from you, including when you:

apply or set up an account with us;
access or use our websites or applications;
subscribe to or enquire about our services;
sign up to receive news and offers, promotions, or events;
enter surveys, competitions, promotions or requesting information or material from us;
make inquiries about us or our products or services or otherwise communicate with us by email, by telephone, in person, via a website or otherwise; and
apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable for us to do so, we will only collect personal information about you from you direct, and not from third parties. In limited circumstances, we may collect personal information about you from publicly available sources, from credit reporting bodies, from your employer or from a third party supplier who provides products or services to us.

Can you choose not to disclose your personal information?

If you contact us to make a general enquiry about us or our business or services, you do not have to identify yourself or provide any personal information. Alternatively, you can also notify us that you wish to deal with us using a pseudonym.

However, if we are not able to collect personal information about you, we may not be able to provide you with the information or assistance, or the services that you require. For example, we will not be able to send you information you have requested, if you have not provided us with a valid emai laddress or telephone number.

How do we use your personal information?

Generally, we use your personal information for purposes connected with our business.

Some of the purposes for which we use personal information we receive are as follows:

to provide our services to our customers or to receive goods or services from third parties;
to enable the proper operation and functionality of our services;
to verify your identity (for example, if you request access to the personal information we hold about you);
to consider you for a job with us (whether as an employee or contractor) or another relationship with us;
to communicate with you, and to address any issues or complaints that we or you may have regarding our relationship;
for direct marketing purposes (see the "Direct Marketing" section below); and
to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

We may also useor disclose your personal information for our administrative, marketing(including direct marketing), planning, product or service development, qualitycontrol, survey and research purposes and for other purposes to which you haveconsented, and as otherwise permitted or required by law.

To whom do we disclose your personal information?

We may discloseyour personal information to third parties in connection with the purposesdescribed above (see the "How do we use your personal information?"section).

This may include disclosing your personal information to the followingthird parties:

our related companies;
any potential third party acquirer of our business or assets, and advisors to that third party;
our professional advisers (such as our lawyers, accountants or auditors) and insurers;
our employees, contractors and third party service providers who assist us in performing our functions and activities (for instance payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers);
organisations who conduct promotional, research or marketing activities for us;
third parties to whom you have authorised us to disclose your information (e.g. referees);
credit reporting bodies to obtain an assessment of whether that information matches the information held by the credit reporting body in order to verify your identity as required under anti-money laundering laws. The credit reporting body may provide us with that assessment and use your personal information and the personal information of other individuals, to prepare that assessment. In Australia, at the time of writing this document, we use the Mastercard digital ID service for this purpose, and it has its own privacy policy, which is available at: https://idservice.com/en/home.html. We will notify you if we are unable to verify your identity through this process. If you do not want to use this process to verify your identity, please contact us using our contact information below;
Apple, Google and Samsung as outlined in the "Apple, Google, and Samsung Pay exchange" section below; and
other persons as required or permitted by law.

If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that those third parties only use your personal information as reasonably required for the purpose of the disclosure, and in a manner that is consistent with applicablel aws (for example, where commercially practical, by including suitable privacy and confidentiality clauses in our agreement with the third party service providers to whom we would disclose personal information).

Apple, Google, and Samsung Pay exchange

We may exchange information about you withApple, Google, Samsung and MasterCard in order for you to add your Virtual Card to the Apple Pay, Google Pay or Samsung Pay exchanges, and to facilitate Orders you make using your Virtual Card. By adding your Virtual Card on supported devices and/or using Apple Pay, Google Pay or Samsung Pay exchange, you consent to your information to be shared with Apple, Google or Samsung (as the case maybe) for use and disclosure in accordance with their respective privacy policy(available on their website), and Apple, Google or Samsung to provide us with information, for any purpose relating to your use of your Virtual Card, including to enable us to provide customer support, conduct fraud and risk assessment, improve our services and products and comply with applicable laws and regulations.

Consent

You authorise us (and any third parties providing services on our behalf) to disclose to third parties, to the extent required by any applicable laws or regulations, any information in relation to you and your Account in accordance with our Privacy Policy. In addition, you acknowledge that we reserve the right to report any negative activity on yourAccount (including late payments, missed payments, defaults or charge backs) to credit reporting bodies.

Cookies

In some cases, we may also collect your personal information through the use of cookies. By using our website, you are consenting to our use of cookies. In this context, “cookie” is a small summary files containing a unique ID numbers that refers to your computer. This enables our web servers to recognize your computer and for us to personalise aspects of our website for you (for instance, to greet you each time you visit our website without bothering you with a request to register or log in) and also enables us to keep track of pages and products you view so that, if you consent, we can send you news about these products.

We also use cookies to measure traffic patterns, to determine which areas of our site have been visited and to measure interaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

Your browser may give you the ability to control cookies and you can change your cookie settings at any time.The types of cookies which may be blocked depends on your browser and the type of cookie. However, declining our cookies may impede or de-personalise your use of our website and our services, and may limit the functionality we can provide when you visit or use our website. If you continue without changing your settings, we will assume that you are happy to receive all cookies on the website. Further, not all of the tracking that we have described in this policy will stop if you choose to block or delete cookies. For example, some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, and so we are not currently set up to respond to those signals.

We may log IP addresses (i.e. the electronic addresses of computers that are connected to the Internet) of computers that interact with our systems to analyse trends, to administer our website, to track users movements, and to gather broad demographic information.

Online advertising and Google analytics

We may work with online advertising partners to provide you with ads that are relevant and useful for you, including ads located on or through our website from third parties. We may use information collected by us or by third parties to provide you with these ads, which may be based on your activities on our website or on third party websites.If you access any third party websites through our website and if those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.Where you access a third party website via a link from our website, cookie information, and information about your preferences or other information you have provided about yourself may be shared between us and the third party.

We may advertise on third party websites. When you access our website after viewing one of our advertisements on a third party website, the advertising company may collect information on how you utilise our website (for example, which pages you viewed) and whether you commenced or completed an online application or other online form.

We may use Google Analytics website measurement software and systems to assist in tracking traffic patterns to and from our website, aggregating anonymous information about visits to our website, and randomly and anonymously surveying users of our website. That system is used to collect information on our network such as the number of page views, the number of unique visitors, how long visitors spend on the website and any affiliated websites when they do visit, and common entry and exit points into and from our website and any affiliated websites. Random anonymous surveys are also used to collect further information about our users.

This non-personal information is aggregated usingGoogle Analytics, and is then used by us in our analysis of our website and any affiliated websites. The Google Analytics data is also accessible by media organisations and research companies for the purpose of conducting industry comparisons with other websites. Our website is coded with a small piece ofGoogle Analytics code that is not visible to you when you read that page. The software stores a cookie in your browser (if you have enabled cookies) which contains a unique identifier to allow us to track the number of unique visitors to our website and any affiliated websites. This information is collected and aggregated by Google Analytics, and is not used to identify you personally, and no personal information is stored about you via this process.

In addition to Google Analytics, we may also use other third party analytics tools including Amplitude (an analytics service provided by Amplitude Inc.) to monitor, analyse and collect information about your use of the website. Your browser may allow you to disable this feature, however you may not be able to fully use all of the functions of the website if you do so.

For more information about our online advertisingpartner and its cookies, including information about how to opt out of these technologies, you may visit http://optout.aboutads.info. You may also optout of the Google Analytics feature by downloading and installing aBrowser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Does your personal information stay in Australia?

We also maydisclose personal information to third party suppliers and service providerslocated overseas for some of the purposes listed above. By providing us withyour details, you consent to your personal information being disclosed in thismanner.

We takereasonable steps to ensure that the overseas recipients of your personalinformation do not breach the privacy obligations relating to your personalinformation.

We may discloseyour personal information to entities located outside of Australia, includingthe following:

our data hosting and other IT service providers located in Singapore, Asia
other third parties located in Singapore, Ireland, Romania, United Kingdom, Europe including Belgium, Germany and the Netherlands and Singapore, the United States of America.

Except where anexception applies under the Privacy Act or other relevant legislation, we willtake commercially reasonable steps to ensure that overseas recipients to whomwe disclose personal information do not breach the Australian PrivacyPrinciples or the Privacy Act in relation to such information.

How long do we retain yourpersonal information?

Generally, wewill retain your personal information for the period necessary for the purposesfor which your personal information was collected unless a longer retentionperiod is required by law or if it is reasonably necessary for us to complywith our legal obligations, to resolve a dispute or to maintain security.

For instance, we may retain your personal informationafter you have closed your Account for a period of time, for thefollowing purposes:

to collect any fees you may still owe;
to resolve disputes with you or to troubleshoot issues which may have arisen;
to assist with any investigations and prevent fraud or risk;
to enforce any agreement that we have with you; and
to take other actions as required or permitted by law.

Your personal information will not be shared, sold,rented or disclosed other than as described in this Privacy Policy.

Access from third partywebsites

Once you have established an Account with us,you might access your Account from our website, or you might do so from thirdparty websites or via a third party app which are not controlled by us. If youdo so, then any information you provide may be shared with that third party.These third party websites or apps will be governed by their own privacypolicies. Please review these privacy policies before sharing your personalinformation, as we are not, and will not be, responsible for the conduct orinformation practices of that third party

How can you access andcorrect your personal information?

You may ask for access to any personalinformation we hold about you at any time by contacting us (details below). Wherewe hold information that you are entitled to access in accordance with thePrivacy Act, we will try to provide you with suitable means of accessing it(for example, by mailing or emailing it to you). We may charge you forproviding the information in response to your request for access, provided thatthe charge is no more than the cost of that response (which excludes our costsof obtaining related legal advice or other advice).

There may be instances where we cannot grantyou access to the personal information we hold. For example, we may needto refuse access if we are required or authorised to refuse access by law. Ifthat happens, we will advise you in writing of the reasons for the refusalwithin 30 days of receipt of your request, together with information about howyou can complain about our refusal if you wish to do so.

If you believe that personal information thatwe hold about you is incorrect, incomplete or inaccurate, or that it needsupdating, then you may ask us to amend it. We will consider whether theinformation requires amendment. If we do not agree that there are groundsfor amendment, we will give you advise you in writing with the reasons for therefusal within 30 days of receipt of your request, together withinformation about how you can complain about our refusal if you wish to do so.

Resolving your privacy concerns and complaints

If you have any questions about our PrivacyPolicy, or if you have concerns about how we handle your personalinformation (including credit related personal information), then you can contactus using the contact information below. In that case we would ask that youprovide details of any incident so that we can investigate it.

Our representative will contact youwithin a reasonable time after hearing from you to answer your questionsand discuss your concerns.

If you have a complaint, we willacknowledge it within 7 Business Days of receiving it. We will then try toresolve your complaint within 30 days of receiving the complaint (or a longerperiod if you agree in writing). If we cannot resolve your complaint withinthis time frame, we will:

inform you of the delay before the end of the period;
provide you with reasons for the delay;
provide you with an expected time frame to resolve the complaint and seek your agreement to the extension;
inform you that under the Privacy Act, you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information, and provide you with their contact details; and
inform you that you may lodge your complaint to the Australian Financial Complaints Authority (relating to either the provision of credit or credit reporting information in general), and provide you with their contact details.

Direct marketing

We will only send you direct marketing communications (which may be through the mail, or by SMS or email), including offers any news and exclusive offers, promotions, or events, where you have consented to us doing so.

. If you have signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the "unsubscribe" link at the bottom of the message or other opt-out facilities in the direct marketing communication. You can also log-in to your account to opt-out and update your marketing preferences at anytime.

Even after you opt-out or update yourmarketing preferences, please allow us sufficient time to process the change toyour marketing preferences. Unless otherwise required to process yourrequests earlier by law, it may take up to 5 days for us to process youropt out requests in relation to receipt of electronic marketing materials suchas emails and SMS, and up to 30 days for all other marketing-relatedrequests.

Even after you’ve opted-out of receivingmarketing communications from us, we may still contact you for transactional orinformational purposes. These include, for example, customer service issues,returns or product related inquiries, outstanding payment inquiries, surveys orrecalls, or any questions regarding a specific order.

Protecting your personal information

We take reasonable steps using physical, technical, and administrative security measures to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in this policy

We review our security procedures to protect your personal information periodically and will implement new technology and updated methods from time to time as we consider appropriate. Only authorised personnel will have access to your personal information on a need-to-know basis.

Please be aware that, as our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us is transmitted at your own risk

Changes to our privacy policy

We may change this Privacy Policy fromtime to time. Any updated versions of this Privacy Policy will be effective onthe date we post it on the website. We may also inform you via email orotherwise of any material changes to this Privacy Policy that may impact you

Other Important Notes

A target market determination must bemade publicly available before any person distributes a financial product thatis subject to the design and distribution obligations. You will be able toreview our TMDs on this website when distribution commences.

How to contact us

If you have a query, concern or complaintabout the manner in which your personal information has been collected orhandled by us or would like to ask for access to or correction of the personalinformation we hold about you, please contact using the details provided below:

1derful Pty Ltd

Attention: Privacy Officer

PO Box 3471

Wareemba NSW 2046

hello@1derful.io

Last updated: July 2022