Privacy Policy

We are committed to protecting your privacy and confidentiality in accordance with the Australian Privacy Principles ('APPs'), Credit Reporting Privacy Code and Privacy Act 1988 (Cth) ('Privacy Act'), and it is our prime responsibilities that any personal or sensitive information you provide to us is not used for any other purpose than that intended and expected by you. This Policy outlines how we manage the personal information we hold about our clients and others. It applies to Findex Group Limited and its affiliated entities ('Findex', 'us' or 'we'), including its related bodies corporate (as that term is defined under the Corporations Act 2001(Cth)).

What information do we collect and hold?

We will only collect personal information about you when you have knowingly provided that information to us or authorised a third party to provide that information to us, or where collection is otherwise permitted under the Privacy Act as amended from time to time. 

Personal information includes any information or opinion about an identified individual, or an individual who is reasonably identifiable from their information. The information or opinion will still be personal information whether it is true or not and regardless of whether we have kept a record of it. 

We may ask for identification information. This information includes and is not limited to: name, address, contact details, date of birth and tax file number, and may also include additional identifiers such as online identifiers or biometric identifiers where required to verify identity. 

We may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints a client makes and, if they make an insurance claim, collecting additional information to assess the claim, including information reasonably necessary to investigate or respond to a serious privacy complaint or data incident in line with updated regulatory obligations. 

The collection of sensitive information is restricted by the Privacy Act. This includes information about religion, racial or ethnic origin, political opinions, criminal record, and sexual orientation. It also includes health information and biometric information, and other categories of sensitive information defined under the Privacy Act. 

Generally, we only collect this sort of information if it is necessary to provide a specific product or service and you have consented to that collection. For example, we may collect health information about you to process a claim under an insurance policy or collect voice biometric information to verify identity or authorise transactions, or where required or authorised by law in certain circumstances. 

What if you choose not to provide some information?

We may be unable to provide services if we do not have all the relevant information required to deliver such services and meet our regulatory obligations under relevant legislations. 

For what purposes do we collect, hold, use and disclose personal information?

The main reason we collect, use, hold and disclose personal information are:

• to check whether a client is eligible for the product or service; 

• to assist where online applications are not completed; 

• to develop and implement methodologies, services, products and technology (including artificial intelligence (‘AI’) and machine learning enabled technology), and for use in providing our services, conducting research, benchmarking, and undertaking studies 

• to provide the product or service; and 

• to help to manage the product or service.

We may use information to comply with legislative or regulatory requirements in any jurisdiction, to respond to, investigate, notify any data breach or prevent fraud, crime or other activity that may cause harm in relation to its products or services and to help run the business. We may also use information to tell you about products or services that we feel may be of interest to you. 

We may also use information for secondary purposes reasonably related to the provision of the products or services, including for AI processing, provided that such use is consistent with the Privacy Act and client consent obligations. 

How do we hold and protect your information?

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. Much of the information we hold about you will be stored electronically in secure data centres, which are located in Australia, and owned by either us or external service providers. This does not include third parties backing up or mirroring data in overseas jurisdictions. Some information we hold about you will be stored in paper files and these files may be held in secure offsite storage. We use a range of physical and electronic security measures to protect the security of the personal information they hold. 

We take reasonable steps to destroy or permanently de-identify any personal information after it can no longer be used. 

Will we disclose the information we collect to anyone?

We may provide personal information about you to external organisations, AI systems providers, cloud providers or outsourced service providers engaged by us. This may include recipients which are located outside Australia, for example, a global financial institution whereby you have given us permission to make enquiries on your behalf. 

If we disclose your personal information to external organisations, overseas recipients or utilise AI systems in connection with the provision of the services, we will take reasonable steps to ensure that the external organisations, overseas recipients or AI system providers handle your personal information in accordance with the Privacy Act and only use the personal information we disclose to them for the specific role we ask them to perform, unless you have specifically consented to us not taking such steps.  

If you do not wish your personal information to be input into any AI system, you must expressly require us not to do so by contacting us (using the contact details at the end of this policy). 

We may also disclose your personal information to others where: 

• We are required or authorised by law or where we have a public duty to do so; 

• You may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or 

• We are otherwise permitted to disclose the information under the Privacy Act. 

Do we use or disclose personal information for marketing?

We will use personal information to offer you products and services we believe may interest you, but will not do so if you tell us not to. We may offer you products and services by various means, including mail, telephone, email, SMS or other electronic means, such as through social media or targeted advertising through our website. 

We may also disclose your personal information to external companies who assist us to market our products and services to you, such as a mailing house. 

If you do not wish to receive marketing offers from us, you must expressly require us not to do so by contacting us (using the contact details at the end of this policy). 

Do we collect personal information electronically?

We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications and other digital platforms or online interactions. 

Each time you visit one of our websites, we collect information about your use of the website, which may include the following:

• The date and time of visits;

• Which pages are viewed;

• how users navigate through the site and interact with pages (including fields completed in forms and applications completed);

• location information about users;

• information about the device used to visit our website;

• IP addresses; and

• other online identifiers.

We use technology called cookies whenever you visit our websites. Cookies are small pieces of information stored on your hard drive or in memory. Cookies can record information about your visits to the site, allowing it to remember them the next time you visit and provide a more meaningful experience. Cookies are designed so that they cannot be sent to another site, or be retrieved by any non-Findex site. We may also use other similar technologies (such as pixels, tags, heatmap or analytics tools) in accordance with the relevant legal requirements. 

How can you check, update or change the information we are holding?

Under the Privacy Act, you have a right to seek access to information which we hold about you; although, there are some exceptions to this. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. To do so, you must contact us by contacting us (using the contact details at the end of this policy). 

We do not charge for receiving a request for access to personal information or for complying with a correction request. We do however reserve the right to charge you for all reasonable costs and outgoings specifically incurred in meeting your request for information. We will inform you of any such costs before proceeding.

Tell us what you think

We welcome your questions and comments about privacy. If you have any concerns or complaints, please write to our Privacy Officer at PO Box 446, Flinders Lane Melbourne VIC 8009. 

We will handle privacy complaints in accordance with our internal complaints procedures and any applicable legislative and regulatory requirements. 

If you are not satisfied with our response to your privacy complaint, you have the right to contact the Office of the Australian Information Commissioner (‘OAIC’). The OAIC may investigate your complaint and has powers to seek penalties for serious breaches of the Privacy Act. 

This Policy may change from time to time. To request a copy of the complete Policy, please do not hesitate to contact us or visit our website for the most current version.