1 Privacy generally
In collecting, holding, using, disclosing and otherwise managing your personal information, Island Spirit will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
2 Kinds of personal information collected
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our services or as a result of our other interactions or dealings with you, Island Spirit may collect your personal information.
The kinds of personal information that Island Spirit collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Island Spirit collects may include:
(a) if you register an account with us, your contact information such as your name, address, telephone number, email address and date of birth;
(b) in order for us to provide our services to you, your financial information, including:
(i) your bank account credentials, transactional histories, account numbers, account balances and account limits;
(ii) general identity information including the names and addresses of account holders;
(iii) your credit card information, including transactional histories, balances and limits; and
(iv) information about your financial circumstances and objectives, including your assets, liabilities, income, expenditure and investment preferences;
(c) when you purchase our services:
(i) information relevant to those services, such as your billing information; and
(ii) information regarding your purchasing history with Island Spirit or your other dealings with Island Spirit in relation to our services; and
(d) any information required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the Anti-Money Laundering and Counter-Terrorism Financing Rules.
Island Spirit may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.
3 How we collect personal information
Generally, Island Spirit collects your personal information directly from you. For example, Island Spirit may collect your personal information:
when you register for an account with us, request information or services or otherwise provide us with your details;
where you download or use our apps;
when you purchase our services;
where you use our website or other services or otherwise interact with us;
when you complete a survey or enter a promotion or competition; or
if you post information to any of our social media sites.
There may be occasions when Island Spirit collects your personal information from someone other than you, for example:
from your bank or other relevant financial institutions in order to provide our services to you;
from third parties you authorise to disclose your information to us;
from a publicly maintained record or other publicly available sources of information including social media and similar websites; and
from third parties for identity verification purposes or when performing any checks required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or other similar laws.
Generally, Island Spirit will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.
4 Purposes for which personal information is used
Generally speaking, Island Spirit collects and uses personal information so that we can develop, improve and promote our services and conduct our business of providing investment services and online budgeting services which assist users to understand their spending and save.
Some examples of the purposes for which Island Spirit collects, holds, uses and discloses your personal information include to:
enable us to supply you with information you request from us;
supply our services to you, including online budgeting, investment services and other related services;
facilitate you investing in our platforms;
personalise your experience with our services;
conduct promotions, competitions, giveaways and events;
contact you to obtain your feedback regarding our services or to conduct other market research;
undertake direct marketing (as detailed in paragraph 5 below);
analyse information we collect so that we can administer, support, improve and develop our business and the services we offer; and
comply with the obligations of Island Spirit under any applicable laws.
In addition to the purposes listed above, Island Spirit may use your personal information for other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.
Where personal information is used or disclosed, Island Spirit takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Island Spirit. However, without certain information from you, Island Spirit may not be able to provide services or information to you or may be limited in how we can interact with you.
5 Direct marketing
6 Disclosure of personal information
related companies of Island Spirit;
our service providers, contractors and other third parties that provide products or services to us (including our technology service providers, payment processors, verification services and administration service providers);
other third parties that are integral to the provision of our services (including your financial institutions);
third party service providers for identity verification or Anti-Money Laundering compliance related purposes;
people or entities considering acquiring an interest in Island Spirit’ business or assets;
other parties who invest in or acquire an interest in Island Spirit;
Island Spirit’ professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
Government authorities where required by law.
Island Spirit may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.
If you post information or other content to public sections of our website or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
7 Overseas disclosures
8 Links to other websites
10 Security of personal information
Island Spirit takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
Island Spirit will destroy or de-identify personal information in circumstances where it is no longer required, unless Island Spirit is otherwise required or authorised by law to retain the information.
Where you have an account with us, you are responsible for maintaining the confidentiality of your user name and password. You will be responsible for all uses of your account, whether or not authorised by you. You agree to immediately notify Island Spirit of any unauthorised use of your user name or password.
11 Access and correction
Island Spirit takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
Where you have an account with us, you can update your personal information by logging into your account and editing your profile.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Island Spirit. If at any time you would like to access or correct the personal information that Island Spirit holds about you, or you would like more information on Island Spirit’ approach to privacy, please contact the Island Spirit Privacy Officer using the details set out in paragraph 12 below. Island Spirit will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
Island Spirit requests that you be reasonably specific about the information you require; and
Island Spirit may charge you a reasonable administration fee, which reflects and will not exceed the cost to Island Spirit for providing access in accordance with your request.
Island Spirit will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Island Spirit refuses your request to access or correct your personal information, Island Spirit will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with Island Spirit’ refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
12 Contacting Island Spirit
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Island Spirit’ Privacy Officer using any of the following contact details:
Post: Suite 440 / 70 Douglas Pde, Williamstown VIC 3016, Australia
13 Privacy complaints
Please direct all privacy complaints to Island Spirit’ Privacy Officer. At all times, privacy complaints:
will be treated seriously;
will be dealt with promptly;
will be dealt with in a confidential manner; and
will not affect your existing obligations or affect the commercial arrangements between you and Island Spirit.
Island Spirit will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless Island Spirit informs you otherwise and seeks your agreement in writing.
Island Spirit’ Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Island Spirit will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.