Dated 20 November 2023
At CBA New Digital Businesses Pty Ltd trading as Credit Savvy Australia (“Credit Savvy”, “We” and “Us” and “Our”), We understand how important it is to keep any personal information We have about Our users, including visitors browsing the Credit Savvy website (www.creditsavvy.com.au) (“Website”) or the Credit Savvy app (“App”) and registered members of the Website or App (“You” and “Your”) private, protected and safe. We are committed to protecting the personal information of individuals with whom We deal with.
You can be confident that We comply with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles for the protection and use of personal information. This Credit Savvy Privacy Policy (“Privacy Policy”) outlines how We can collect, use, hold and disclose Your personal information.
Please read through this Privacy Policy carefully prior to accessing or using the Website or the App. Your access or use of the Website or the App indicates that You understand the content of this Privacy Policy and any other related policies, notices, representations or additional terms applicable to the Website or the App, including the Credit Savvy Terms of Use. The personal information We seek to collect about You is necessary for the service We provide. If You do not provide Us all of the information We require, We may not be able to deliver Our service to You.
If You are a visitor on the Website or using the ‘take a peek feature’ on the App, We will not store any personal information You input into the Website or the App.
If You register as a member with Us, We will collect personal information directly from You. This will include identification information such as Your full name, address, contact details, date of birth, and Your identity documents, such as Your drivers licence, passport, or Medicare card details.
Interaction information will also be collected directly from You. This includes details of your interaction with us, such as if you decide to tell us more about yourself so that We can better tailor your experience (e.g. your offer preferences).
Throughout Your membership with Us, We may collect credit reporting information about You. Details of the type of credit information We receive from Experian Australia Credit Services Pty Ltd ABN 12 150 305 838 (“Experian”) is outlined in detail in the Credit Savvy Terms of Use.
We may from time to time receive and store certain automatic non-identifiable information relating to Your use of, and behaviour on the Website or the App. This information is commonly referred to as “clickstream” information. For example, We may record information such as the areas of the Website or the App accessed by You, the time, date and URL of the pages requested by You, Your browser software, Your device ID, Your IP address, and/or the previous website that You have linked to the Website or the App from. The recording of such information enables Us to identify the areas of the Website or the App that are most popular and to tailor the Website or the App accordingly.
We will use Your personal information for the reason We collected it and in order to provide You with Our services.
We collect, use and exchange Your information so that We can:
We may send Your information to recipients located overseas, including to service providers and other third parties who operate or hold data outside Australia. The purposes for which We may send Your information overseas include for identity verification purposes, filtering, hosting or storage purposes, reporting and analytical purposes, and for system development testing purposes. We may also send Your information overseas to complete a particular matter or where this is required by laws and regulations of Australia or another country.
When We send Your information overseas, it is likely to be to one of the following countries: Argentina, the USA, the United Kingdom, the Republic of Ireland, Germany, and/or France.
Where We send Your information to overseas service providers, We make sure there are arrangements in place to protect Your information
Improvements in technology enable organisations, like Us, to collect and use information to get a more integrated view of users and provide better products and services. We may combine non-identifiable user information with information available from a wide variety of external sources (for example census or Australian Bureau of Statistics data) to analyse the data in order to gain useful insights which can be used for any purpose.
In addition, We may provide data insights or related reports to trusted third-parties, for example to a financial institution to help them understand their customers better. These are based on aggregated information and do not contain any information that identifies You.
We use personal information and credit reporting information We collect about You to provide direct marketing offers on products and services We think may be of interest to You, unless You tell Us not to. This may be in the form of an email or other electronic means. You may at any time choose not to receive these direct marketing communications. If this is the case, please log into Your account at www.creditsavvy.com.au and edit the subscription preferences in Your Account Settings.
Generally, We disclose personal information to organisations that help Us provide Our services to You. These may include:
These organisations include Vix Verify, Microsoft Corp. (Azure), The Rocket Science Group LLC(Mailchimp), IDMatch (Document Verification Service), Auth0 (Multi-Factor Authentication), Twilio Inc (SendGrid), HubSpot Inc. and Intercom. For more information about how they use and handle Your personal information, please refer to their privacy policies.
We may also provide personal information about You to external organisations in circumstances where We are required or authorised by law, or with Your express consent.
Any credit-related information which We obtain about You from Experian will not be passed onto any banks, credit unions, credit providers or mortgage brokers (“Product Providers”), unless expressly consented to by You.
We take great care with the information We hold about You. Our aim is to ensure that any details are securely protected from misuse, interference and loss, and unauthorised access, modification or disclosure. We will take reasonable care to make sure that We keep Your information in an accurate, complete and up-to-date manner.
The Website and the App is professionally hosted and operates in a secure environment. The Website and the App uses encryption techniques to enhance Your privacy and security when using the Website and the App. You should however be aware that there is always an inherent risk in transmitting Your personal information via the internet.
We will hold Your information for as long as You are an active member of Our service and Our service remains available. Upon termination/cancellation of Your membership, We will remove Your account from Our service within 7 days. Experian may continue to send Us credit-related updates during this time. We may retain Your information for up to 30 days, after which Your information will be destroyed or de-identified.
We may also retain database backups which may contain personal information We have collected from You under this Privacy Policy. This information may be retained for the purposes of complying with applicable laws or for Our own security policies. We may continue to retain de-identified information for analytical and reporting purposes.
If you no longer wish for us to hold your information you may ask us to delete your personal data by contacting us at contact@creditsavvy.com.au. Credit Savvy will take reasonable steps to destroy or de-identify this data unless there is a business or legal requirement for us to retain it.
You can access and view the personal information We hold about You in the Account Settings section on the Website. If You are having trouble accessing Your Account Settings, You can also contact Us and ask to view Your information. There is no fee to ask Us for Your personal information. We try to make Your personal information available within 30 days after You ask Us for it. Before We give You the information, We will need to confirm Your identity. In some cases, We may refuse access or only give You access to certain information. If We do this, We’ll write to You explaining Our decision.
Please note, We will not include on the Website or the App Your previous address details or Your date of birth for security purposes.
If You wish to access a copy of Your full free Experian credit report, please visit Experian’s website at www.experian.com.au.
It is important for Us, and for You, that the information We hold is accurate and up-to-date. We allow You to edit certain parts of Your personal information, including Your password, email address and home address details in the Account Settings section on the Website. We might contact You periodically or prompt You to update Your personal information when You log into the Website. If Your information isn’t correct or needs updating, let Us know straight away so We can assist You in updating Your information. You can find information on how to contact Us under the Contact Us section of this Privacy Policy.
If You wish to update any other information We hold about You (including Your name, if changed), please terminate Your current membership and resubscribe to the Website using Your updated information. Please note, for security purposes, We require You wait 30 days after terminating Your current membership before resubscribing to the service.
If You think there is a mistake with Your credit reporting information, then it is important to first check Your credit report which You can obtain from Experian. If any details are wrong, You can ask either Experian or Your credit provider to have them corrected.
Cookies are small data files that are downloaded from Our web servers and stored on Your hard drive. A cookie is a string of letters and numbers that uniquely identifies the computer You are using, and the membership details You may have used to register at the Website.
Cookies are used on the Website to track Your journey through Our Website. The type of cookie We use collects no personal information at all. This simply allows Us to see at a glance which pages and information are of most interest to visitors and members. Most browsers can be configured to refuse to accept cookies. You can also delete cookies, however, doing so may hinder Your access to valuable areas of information within Our Website.
We may use “Remarketing” with Google Analytics and other platforms such as Facebook Retargeting to advertise online. This will utilise different cookies. Third-party vendors, including Google, Facebook and media agencies, show Our ads on websites across the internet. These third-party vendors use the cookies on the Website only to inform, optimise and serve ads based on Your past visits to the Website.
The App uses Your device’s storage to collect Your device information, such as Your device ID, and to remember Your login details while the App is open on Your device. To delete Your device information, You will need to delete or uninstall the App from Your device
We use Google Analytics features based on Display Advertising. You can opt-out of Google Analytics Advertising Feature by using the Ad Settings. In addition, You can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics.
We use Google Analytics Demographics and Interest-Reporting to understand the spread of age ranges, gender, and geographic locations of Our users. This enables Us to tailor the Website, content and Our marketing around Our users’ interests.
We may use “Remarketing” with Google Analytics to advertise online. This will utilise different cookies. Third-party vendors, including Google and media agencies, show Our ads on websites across the internet. These third-party vendors use the cookies on the Website to inform, optimise and serve ads based on Your past visits to the Website.
We provide You with links from Our Website to other third-party sites. The provision of a link does not imply any endorsement, nor can We accept responsibility for the conduct of third-parties linked to Our Website. Once You transfer from Our Website to another website, We are not responsible for the conduct or practices of those third-party websites. When You transfer to another website and before disclosing Your personal information on that website, You should check the applicable privacy policy of that website.
Sometimes We update Our Privacy Policy. Any modifications will be effective immediately upon posting the amended Privacy Policy on the Website or the App. We may contact You or notify You when You log into the Website or the App that there have been changes to Our Privacy Policy. You can always find the most up-to-date version on the Website at www.creditsavvy.com.au/privacy-policy.
Please contact Us if You:
You can do so by sending Us an email at contact@creditsavvy.com.au.
Our registered business address is:
CBA New Digital Businesses Pty Ltd trading as Credit Savvy Australia
Ground Floor Tower 1
201 Sussex Street
Sydney NSW 2000
We will make every reasonable effort to investigate Your concern and notify You of the outcome as quickly as possible. If You are unhappy with Our response, You can contact The Office of the Australian Information Commissioner at:
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001
Email: enquiries@oaic.gov.au
www.oaic.gov.au
If You have a concern or complaint about how We have handled Your personal information, let Us know and We’ll try to fix it. You can make a complaint via Our online form or by emailing Us at contact@creditsavvy.com.au. We try to get things right the first time – but if We don’t, We’ll do Our best to sort it out.
Once the complaint has been received, We’ll look into the issue and try to resolve it as soon as possible. If We can’t, We’ll write to You to let You know how We’ll manage the complaint. You can find more about how We handle complaints in Our Complaints Policy.
If You’re not satisfied with how We manage Your complaint or Our decision after You’ve been through Our internal complaints process, the Australian Financial Complaints Authority (AFCA) offers a free independent dispute resolution service for consumer and small business customers of financial service providers.
Australian Financial Complaints Authority (AFCA)
Website: www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
Postal Address: Australian Financial Complaints Authority, GPO Box 3, Melbourne, VIC, 3001
If Your complaint is about how We handle Your personal information, You can also contact the Office of the Australian Information Commissioner (OAIC).
Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992
Postal Address: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW, 2001