Effective November, 2017
Our privacy commitment
We are bound by the Privacy Act 1988 and other legislation surrounding the collection of your information.
The Privacy Act 1988 sets out a number of Australian Privacy Principles (APPs). Our aim is to both support these principles and ensure that we comply with them. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at http://www.oaic.gov.au.
How we collect information
Investon Group collects personal information in a number of ways. These include:
Directly from you, when you attend a face-to-face interview;
Directly from you, when you provide information through a data collection form;
Directly from you, when you provide information by phone;
Directly from you via an email, the internet, or a mobile app; and
Directly from your creditors, or any other relevant third party, once authorisation has been provided by you.
Via our related entities associated with the Investon Group.
Via our external service providers, where they collect or process personal information on our behalf.
Where you decline to provide us with personal information, or refuse us authorisation to collect information from a third party, this may affect our actions in setting up or otherwise providing you with our services, and your level of service may be diminished.
You may choose to contact us anonymously where it is lawful and practicable to do so – for example, if you telephone us requesting our postal address. You will also be able to use our public website anonymously. However, if you do not identify yourself, we will only be able to give you general information and we may not be able to provide the full services you need.
What kind of information we collect
We collect only relevant information about you that is needed to establish and maintain your account and services, or as otherwise necessary to conduct our business, as the law allows and/or requires us to collect. We may collect personal and financial information about you that is “non-public”. The information we collect varies depending on the accounts and services you request and use.
We are likely to collect personal information, such as your contact details and other identifying information, necessary for our business dealings with you. This may include your name, email address, postal/residential address, telephone number, and how you heard about Investon Group. We may also collect further personal information, such as your current financial status, credit history, how many dependants you have, your employment status and other such information. We will also collect your financial information, including details about your income, expenditures, bank accounts and payment details. In some circumstances, we will be required to collect government identifiers, such as your tax file number, Medicare number and/ or pension card number.
Without your consent, we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership status of professional or trade associations, membership status of a trade union, or details of health, disability, sexual orientation, or criminal record. This is subject to some exceptions, including where the collection is required or allowed by law, and when the information is necessary for the establishment, exercise or defence of a legal claim. We understand that this information is sensitive, and our staff are trained to treat any sensitive information we have collected as highly confidential.
Anonymous analytical information such as gender and age brackets may be collected when you browse our website. This is managed through Google Analytics. No information collected in this way will be identifiable as relating to a particular individual. If you wish to opt out, please see the section below titled ‘Our website security’.
As mentioned above, we may also receive information from your creditors. This information may be used to assist with negotiations or ongoing budgeting for the particular payments in question. You can speak to your creditors about their privacy policies, including which information they can and cannot provide to Investon Group.
Please be advised that if you provide inaccurate or incomplete information, we may not be able to provide you with the products or services you are seeking. Further to this, if in its dealings with you, Investon Group becomes aware that you are engaged in illegal activity, we will be obliged to report this to the relevant authorities.
Why we collect information and how may it be used
We need to collect some information from you so that we can provide you with an appropriate service, which will primarily involve helping you with your budgeting needs, and dealing with lenders and other creditors on your behalf. We also need to collect certain personal information so that we are sure we can identify you appropriately and act within the requirements of the Privacy Act.
Certain laws, such as the Australian Anti-Money Laundering and Counter-Terrorism Financing Act 2006, may require us to collect personal information about you.
The information you provide to us, or which we otherwise collect about you, will be used primarily to set up and manage your account, and deal with lenders and other creditors on your behalf. Much of your information would be provided for a specific purpose, and in that case it would be used primarily for that purpose. For example, any of your payment details or bank account details which you provide so that we can make bill payments on your behalf would be used exclusively to make bill payments, and for no other purpose.
We use information gathered to tailor your budget to your needs, make arrangements with creditors, and provide you with the service you require.
From time to time we may also use the information gathered from you to perform statistical and demographic analyses of our client base so that we can improve our services and match our business model to our clients’ needs.
Where appropriate your information may be used to advise you of products or services we offer which we believe might suit your needs. This may include utilising your email address to send you emails or target online advertising. If at any stage you wish to stop receiving direct marketing material, you may contact us with this request. We maintain a register for those individuals who do not wish to receive marketing material. You may also unsubscribe by visiting - http://www.investon.com.au/unsubscribe
Keeping your information up to date
Investon Group takes reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up to date. To ensure that we are able to maintain this level of accuracy and completeness, we ask that you:
Inform us of any errors in your personal information as soon as possible; and
Update us with any changes to your personal information as soon as possible.
Keeping your private information secure
Investon Group is committed to keeping your personal information secure and confidential. We use a combination of technologies, systems and processes to control and limit access to your information. Your personal information is stored across multiple locations within the Investon Group database for better security and further control over who has access to your records. We can refer to this information collectively as your “client file”. These files are accessible to authorised personnel only. They are stored on a secure computer database owned and operated by Investon Group, and protected by security systems that monitor, control and protect access. All computer-based information is protected through the use of access passwords, and data is backed up regularly.
All of our staff are trained to respect client privacy, and they are only given access to the information necessary to perform their jobs and provide service to you, to the extent practical for their individual job roles. No one, except our employees and our service providers, has regular access to the Investon Group computer system and records storage, and we have internal physical, electronic and procedural safeguards to protect the information you provide us and the information we collect about you.
We provide many methods of communication for your privacy, including a secure password-protected online messaging tool, and discreet environments for confidential discussions. We will continue to review our internal security controls to safeguard your member information as we employ new technology in the future.
Accessing your information
You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) using the contact details set out below, and we will endeavour to provide you with access to that personal information. Access to the requested personal information may include: providing you with copies, providing you with the opportunity for inspection, or providing you with a summary. If you believe that any of the personal information we hold is incorrect, you may request a correction.
We will never charge you for placing a request to access your personal information, and, in most circumstances, we will not charge you for providing such access. However, if you request information which is of a particularly large volume or is otherwise onerous, Investon Group reserves the right to charge a reasonable fee to compensate us for time spent servicing your request.
It is a legislative requirement that we keep all personal information and records for a period of seven (7) years.
Should you cease to be a client of ours, we will maintain your personal information on or off site, in a secure manner, for seven (7) years. After this time, the information will be destroyed.
You are welcome to access your personal information at any stage within this seven (7) year period by making a request in the manner set out above.
Some exceptions exist where we will not provide you with access to your personal information. We will not provide you with a copy of your personal file if:
Providing access would pose a serious threat to the life or health of a person;
Providing access would have an unreasonable impact on the privacy of others;
The request for access is frivolous or vexatious;
The information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
Providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
Providing access would be unlawful;
Denying access is required or authorised by or under law;
Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body, or an enforcement body requests that access not be provided on the grounds of national security.
Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal. All applications for access of personal information can be addressed to the:
2/30 Dellamarta Road
Wangara WA 6152
How we may disclose your information
We may disclose your personal information to organisations outside of Investon Group. The organisations to which we disclose information may include:
To our related entities in the Investon Group group of companies, as permitted by section 13B of the Privacy Act.
Compliance consultants to ensure that our representatives are meeting our compliance standards;
Your professional advisors, including your solicitor or accountant, as authorised by you;
Our external service providers and other third parties that assist us to provide our services to you;
Your lenders and other creditors;
Government and regulatory authorities and other organisations, as required or authorised by law - for example, to government or regulatory bodies for purposes related to the prevention of money laundering, public health or safety, the prevention or detection of unlawful activities or to protect public revenue;
Third parties for the purpose of resolving complaints or disputes, including beyond the end of your contract;
Product planning and development officers;
Research bodies for the purpose of improving our current and future services;
Third parties for the purpose of securing credit on your behalf, as authorised by you;
Your creditors with whom we are making payment arrangements; and
Relevant authorities, if we have reason to believe that you or another person is in danger.
In the event that we propose to sell part or all of our business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them outside of the due diligence process.
We may need to transfer some of your information overseas if we are making an arrangement with an overseas creditor on your behalf. The information we may transfer includes your identifying details, such as name, date of birth and address; details of other payments you are required to make; and information about changes in your personal and financial situation, only to the extent necessary to make the payment arrangement.
From time to time, Investon Group uses overseas third party service providers to assist with activities such as data collection, processing, analysis and storage, marketing optimisation, contract provision and sending surveys or emails to many clients at once. At this time, our main third party providers include Myprosperity Pty Ltd, Adobe Sign, SurveyMonkey, JotForm and MailChimp. Please be advised that these companies may have different privacy policies to Investon Group. However, we will only use third party providers which are trusted and are vigilant with your information.
Accordingly, Investon Group is likely to disclose personal information to overseas recipients. Although it is not practicable to specify all countries where such overseas recipients are located, Investon Group does frequently deal with service providers located in the United States of America, the Philippines and the United Kingdom. Please note that if Investon Group discloses your personal information to an overseas recipient, that organisation may be subject to different privacy laws, and may not be bound by the Australian Privacy Principles. You can contact these creditors directly to discuss their privacy policies. We will not pass your details to any overseas recipient unless:
we reasonably believe that the recipient of the information is subject to a law, or binding scheme, that has the effect of protecting the information in way that, overall, is at least substantially similar to the way in which the Australian Privacy Principles protect the information, and there are mechanisms which you can access to take action to enforce that protection;
we have first taken such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your information;
you have consented to the disclosure; or
the disclosure is otherwise required, authorised or permissible by law.
Although in certain circumstances we are required to collect government identifiers, such as your tax file number, Medicare number or pension card number, we do not use or disclose this information, other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party. This may include disclosing this information to government departments which are acting as your creditors.
Our website security
On our websites and mobile app, you may apply for services or access your existing budget, and you may communicate with us via web message. You may also access site information without revealing your personal identity. We use multiple levels of security to protect the information you provide us online. The application information we accept online relies on industry standard “Secure Sockets Layer” (SSL) encryption to secure your transaction information and communication. Investon Group's computer system uses software programs to create summary statistics, which are used for such purposes as assessing which information is of most and least interest to members, determining technical design specifications, and identifying system performance or problem areas.
Our websites utilise cookies to provide you with a better user experience. Cookies are small pieces of information that a site or its service provider transfers to your computer’s hard drive through your web browser. Cookies enable us to recognise your browser, and capture and remember certain information. Most browsers allow you to disable cookies. Please refer to the help menu on your browser for more information.
We use first-party cookies and third-party cookies to help us compile and monitor aggregate data about site traffic and site interaction. This will allow us to offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers may use the information collected on our behalf to help us conduct and improve our business.
Staying secure online
Your online security relies on our actions and your actions. We will do everything we can to protect your privacy, but there are also measures that you can take. Here are some tips to help you maximise your online security:
Make sure you regularly use and update an anti-virus program, a firewall, and an anti-spyware program. Using these products for your security will help to protect your computer and your personal information.
It is important to protect your login details and password for our members’ website. Pick a password that will not be easily guessed by anyone else. We recommend using a combination of lower and uppercase letters, symbols and numbers for maximum security.
Memorise your password and destroy any documents that show your login details. If you do choose to keep a written copy of your login details and password, do not keep the information where it may be easily accessed by others. Should you forget your online password, you may contact Investon Group using the contact details below. A representative will only be able to reset your password after verifying your identity using a series of security questions.
If you believe your online security has been breached, please contact Investon Group straight away.
You can contact us by post or online, using the below details:
Postal Address: 2/30 Dellamarta Road, Wangara WA 6152
Investon Group is closed on national public holidays.
Existing clients can also send online messages through our secure client site.
If you wish to ask a question, give feedback, or make a complaint about any potential breach of your privacy rights, please contact Investon Group using any of the contact details above. Any complaints will be responded to within seven (7) days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.