Updated: December 1st, 2020
3.1 We may collect the following Personal Information from or about you, where the information is reasonably necessary for our business purposes, including to provide our Services to you:
name, gender and date of birth
driver’s licence or passport details, and Medicare card details
phone number, email address, residential address and previous address
credit information that may be relevant to a correction request or a complaint that is raised through Flux
any other information that you provide to us or authorise us to collect in connection with a specific Service offered on the Flux Website
4.1 Personal Information about you may be collected by us in a number of circumstances, including if you:
register with us by creating an account;
use our Services;
lodge an enquiry with us by email or telephone;
complete any surveys that we issue; or (e) contact us for any reason, including with support queries.
4.2 We collect Personal Information from you directly, unless it is unreasonable or impracticable to do so or if we collect it from the following:
Third parties that support our Services – we may collect Personal Information from the following third parties:
(a) a Credit Reporting Body (on your behalf);
(b) suppliers who supply services to us;
(c) our referrers and advertisers;
(d) social media service providers; and
(e) publicly maintained records;
Bank(s) – Win the Week enables you to participate in our weekly game. To do so, we access information relating to all of your chosen Bank account. If you use Win the Week, in order to make this Service efficient, Flux and/or Basiq (one of our Related Body Corporate) may extract:
- all information available from your Bank(s) using your Bank credentials (even if you only request to see part of that information at any particular time, for example, by selecting specific chosen accounts); and
- that information on each day that you log into your Flux account; and
Related Bodies Corporate – we may access Personal Information from our Related Bodies Corporate in order to receive specialised services in connection with the Services that we provide to you.
4.3 We also collect, use, store and disclose non-identifiable information relating to your use of the Flux Website and our Services.
5.1 Primary purpose: We collect Personal Information for the primary purpose of being able to operate our business, including to provide our Services to you. If you do not provide all of the Personal Information we request (or authorise us to collect that information), you may not be able to use our Services. Collection of Personal Information for the primary purpose of the Services includes:
to assess, process and manage your application to use our services – including for identity verification purposes (this includes utilising identity verification service providers and providing identity verification information to a Credit Reporting Body to confirm your identity and current contact details);
to enable you to get your credit score and other Credit Information from a Credit Reporting Body (as well as updates when certain Credit Information changes occur), and to enable you to request a Credit Reporting Body to correct and update the Credit Information it holds about you;
to verify whether you are a director of a registered Australian company in order to notify you, and confirm, that you are eligible to use Flux for Business, to enable you to get your Business Credit Information from a Credit Reporting Body (as well as Business Credit Information Alerts when certain Business Credit Information changes occur);
to assist you to obtain information from credit and or service providers where permitted by you;
to enable you to see your chosen Bank accounts in one place, if you use Flux Insights; and
5.2 Additional purposes: In addition to those above, we collect Personal Information so that we can carry out the following actions:
to provide you with a more targeted experience when you use our Services;
to validate, update and/or enhance our products, services and databases (including those of our Related Bodies Corporate);
to undertake research, analytics and/or benchmarking;
to identify and understand user needs;
to connect future publicly available data sets into our services;
for our business development and marketing purposes – for example, see clause 7 below;
to send you, and display on the Flux Website, details about products and services and special offers that might interest you, from us and from third parties – see clause 11 below;
for any other purpose you have consented to or which is permitted under the Privacy Laws; and
for internal record keeping, audit and compliance purposes and to comply with our legal and regulatory obligations.
6.1 You authorise us to disclose Personal Information to any of our Related Bodies Corporates for the purposes set out in clause 5. In addition, we may disclose Personal Information to:
Credit Reporting Body – if you request your credit score or other Credit Information using the Flux Website – refer to clause 6.2 below;
Basiq – if you use Win the Week – refer to clause 6.3 below;
Our service providers – such as identity verification service providers, Google Analytics (refer to clause 6.4 below), social media & IT suppliers/contractors, identity theft monitoring service providers, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who need to have access to your Personal Information to provide their services to us
Organisations that provide products or services used or marketed by us – including intermediaries, trustee companies, financial institutions and securitisers;
Other – (i) our employees or contractors to the extent reasonably necessary to fulfil our obligations to you; (ii) anyone considering acquiring an interest in our business or assets; (iii) other entities or persons to the extent reasonably necessary for the purposes set out in clause 5 above; (iv) any law enforcement, legal, government or regulatory agency, where such disclosure is required or authorised by law; and (v) other individuals or companies authorised by you.
6.7 You acknowledge that we do not control and are not responsible for any use of Personal Information by any third party that you disclosure, or authorise us to disclose, your Personal Information to.
From time to time we may use your Personal Information which we hold to provide you with:
7.1 current information about our services, informative articles, offers you may find of interest, changes to our organisation, or new products or services being offered by us or third party (Marketing Communications).
7.2 By providing us with your Personal Information, you consent to us (including our Related Bodies Corporate) using your information to contact you on an ongoing basis for these purposes, including by mail, email, SMS, social media, telephone and other electronic means
7.3 If you do not wish to receive Marketing Communications, you may at any time unsubscribe from receiving Marketing Communications by responding via the channel in which you received the Marketing Communication. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
8.1 Personal Information that we collect is either held by us at our offices in Australia or on our behalf. Some information we hold may be stored in “the cloud” in databases on our behalf locally or overseas.
8.2 Please be aware that where your Personal Information is disclosed to a third party service provider, credit provider or other entity, they also may use cloud based processes located outside of Australia or New Zealand. We do not control where these service providers may allow Personal Information to be accessible including overseas.
10.1 We may use technology known as a “cookie” to collect statistical information about you when using internet browsing, mobile or tablet applications. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the Flux Website, allowing it to remember you the next time you visit and provide a more meaningful experience.
11.1 We will use all reasonable endeavours to keep your Personal Information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your Personal Information being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information, please contact us immediately using the contact details below.
11.2 Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving Personal Information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Law requirements.
12.1 It is important to our relationship that the Personal Information we hold about you is accurate and up to date.
12.2 You may request access to any of the Personal Information we hold about you at any time. To request access to the Personal Information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
12.3 We will respond to your request within a reasonable period of time and, where reasonable and practicable, grant access to the information in the manner requested. An explanation will be provided to you if we deny you access to your Personal Information we hold.
12.4 If you consider that any information we hold about you is incorrect, you should contact us to request that it is updated. Please let us know if there are any changes to the Personal Information you have provided to us. While we take reasonable steps to ensure that the Personal Information held by us is up to date, we will generally rely on you to assist by informing us if the information we hold about you is inaccurate or incomplete.
13.1 You may request further information about the way we manage your Personal Information or lodge a complaint by contacting us using the contact details below.
13.2 We will deal with any complaint by investigating the complaint, and providing a response to the complainant within 30 days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree an alternative time frame with you.
13.3 Please be aware that we are member of the Australian Financial Complaints Authority (AFCA). If you have a complaint with us that remains unresolved you may refer this matter to AFCA.