1. PRIVACY STATEMENT
Cash Pal (“we”, “our”, “us”) is a trading name of Leadpal PTY LTD (ABN 15 625 489 161), Australian Credit Licence 507797. We understand that you are concerned about your privacy, along with the confidentiality and security of any personal information that you provide to us. We consider your privacy to be important and take our responsibility to protect it seriously.
2. Collecting Personal Information
Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. We usually collect personal information about an individual from that individual. We collect personal information from a wide variety of sources including:
(a) through this website www.cashpal.com.au or any of our other websites;
(b) from other interactions with us, whether by telephone, email, ordinary mail or any other electronic or online means; and/or
(c) through any of our other business activities or events.
Personal information collected by us typically includes an individual’s:
(a) full name;
(b) contact details such as mobile number, telephone number and email address;
(d) physical or residential address;
(e) qualifications and education;
(g) credit information, which may include your bank statement data, bank account details and credit requests you have made with us; and
(h) all logs, which may include information such as your internet protocol (IP) address, browser type, browser version, clickstream data, referring URLs, the pages of our websites that you visit, the time spent on any pages of our websites and other log related information relating to your use of any of our websites.
3. Use of personal information
We automatically gather information to monitor your use of our websites and the provision of our referral services to you. In general we use personal information for evaluating, improving, personalising and developing our business. More specifically we use personal information:
(a) for maintaining our relationships with those that we provide our referral services to;
(b) for administering, managing and delivering the referral services we provide;
(c) for improving our referral services including our websites;
(d) for our own internal research and statistical purposes;
(e) to provide to entities that manage and administer finance you have requested through us;
(f) to promote and market products and/or services provided by us or our associated entities that we believe will be of interest and/or benefit to you; and
(g) to provide to other entities so that they may promote and market products and/or services to you that we believe will be of interest and/or benefit to you.
Other than for purposes referred to above, unless we are legally required or compelled by a law enforcement or government agency, we will not disclose your personal information to any third party without your consent.
4. Disclosure of personal information
Before we disclose your personal information, we will take reasonable steps to satisfy ourselves that:
(a) only personal information that is necessary for the recipient to properly perform the function they notified us of will be shared;
(b) the recipient has a commitment to protecting your personal information from use outside the function that they have notified us of;
(c) you have been notified under this Policy that your personal information may be disclosed in this way.
5. Direct marketing
Where your personal informal is being used for promotional or marketing purposes, whether provided by us, an associated entity or a third party against your wishes, you may at any time decline to receive further offers by opting out.
Please be aware that opting out of a direct marketing communication will only unsubscribe you from the enterprise that sent you the communication. Please let us know if you want to unsubscribe from all direct marketing that originates from us by emailing firstname.lastname@example.org.
6. Government identifiers
We do not generally collect or hold government identifiers (i.e. passport number, licence number, Medicare number or tax file number). Where we do, such information will not be disclosed to non-associated entities without your express consent.
7. Sensitive information
Sensitive information is personal information regarding:
(a) racial or ethnic origin;
(b) political opinions;
(c) membership of a political association;
(d) religious beliefs or affiliations
(e) philosophical beliefs;
(f) membership of a professional or trade association;
(g) membership of a trade union;
(h) sexual orientation or practices;
(i) criminal record.
We will not generally collect or hold sensitive information, where we do, such information will not be disclosed to non-associated entities without your express consent.
8. Protecting your personal information
8.1 Steps we take
We take reasonable steps to protect personal information we hold from:
(a) misuse, interference and loss; and
(b) unauthorised access, modification or disclosure.
The precautionary steps we take to protect personal information include:
(a) adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;
(b) adoption of procedural and personnel measures for limiting access to personal information by our staff;
(c) reviewing our information collection, storage and processing practices; and
(d) such other security measures we consider reasonable and appropriate from time to time.
Notwithstanding that we use our best endeavours to protect all personal information we collect and hold, please be aware that we unfortunately cannot guarantee its complete security and will not be responsible where it is obtained by illegal third party actions.
8.2 Deleting your personal information
When personal information is no longer required to be kept by us, we will take reasonable steps to destroy or delete the personal information in a confidential manner.
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some features of our products and services.
10. Web beacons
Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.
Unlike cookies which are stored on the user’s computer hard drive, web beacons are embedded invisibly on web pages (or in e-mail).
Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.
Like many sites, we use web beacons to collect information which is done in accordance with this policy.
11. Overseas disclosure
11.1 Server locations
We store all personal information that we collect on Amazon Web Servers located in Sydney Australia and the USA.
11.2 Disclosure for analytics
We may use Google Analytics to track your usage of our websites. Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of the Site, to prepare reports on the Site’s activities and share them with other Google services.
11.3 Consent to overseas disclosure
Other than as contemplated in this clause 11, we will only disclose your personal information to an overseas recipient if:
(a) you consent to the transfer; or
(b) the disclosure of the information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.
We will take reasonable steps to ensure such overseas recipients do not breach the Australian Privacy Principles (APP’s) or are subject to laws or a scheme substantially similar to the APP’s.
12. Third parties
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites, products or services whatsoever. You should be aware that your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.
13. Accessing and updating your personal information
13.1 Access to Personal Information
We will provide you with access to your personal information held by us unless:
(a) giving access would be unlawful; or
(b) denying access is required under the Privacy Act or any other applicable law.
13.2 Request for Access
If you would like access to your personal information aside from your account information, you must contact us in writing making such a request. You may contact us via email at email@example.com. Following receipt of your request, we will contact you and either provide you with the information you have sought, or return to you with an explanation detailing why we will not provide you with the information.
13.3 Amending your personal information
If you wish to amend personal information that we hold, please contact us to request the amendment. You may contact us by emailing firstname.lastname@example.org. If we elect not to correct your information, we will notify you, within a reasonable time, of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the Privacy Act.
If you wish to have your personal information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
14. International users
If you are located outside of Australia and choose to provide your personal information to us, your personal information will be transferred to Australia and processed in accordance with this Policy.
We strive to ensure our compliance with this Policy and to regularly review our practices against it.
If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to make a complaint at email@example.com. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.
If you are dissatisfied with our response to your complaint you may make a further complaint to the Office of the Australian Information Commissioner about the handling of your personal information. Information on making a privacy complaint can be found on their website at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.
We reserve the right to vary this Policy from time to time to ensure that we remain up to date with market expectations, the law and technological advances. Any variations made will be updated on our websites. It is your responsibility to check our Policy periodically to ensure you are aware of any changes made to it.
17. Further information
For any further information about this Policy please contact us by emailing firstname.lastname@example.org.