Privacy Policy

Privacy policy

This privacy policy applies to Financy (ABN: 81 647 393 904) (“Financy”, “we”, “our” and “us”).

Financy takes your privacy very seriously. This privacy policy sets out information regarding how we deal with personal information, as defined in the Privacy Act 1988 (Cth) (“Act”), that is collected from you when you visit financy.com.au, and other Financy websites and applications (the “Site”), use our services including Impacter^TM (“Services”) or when you otherwise provide personal information to us. The policy sets out:

• how personal information may be used and disclosed;
• how you can control the use and disclosure of personal information;
• how you can access and correct personal information that we hold about you;
• how you can make a complaint if you think we have not complied with the Act or this privacy policy; and
• how personal information is protected.

If you have any questions about this privacy policy, please contact us.

Your interactions with us

You do not have to provide any personal information to us. However, if you do not provide us with the personal information that we request, we may not be able to provide our services to you.

By using the Site, engaging our Services, seeking our assistance, providing personal information to us, or authorising another person to provide us with personal information, you consent to personal information (including any sensitive information) being collected, held, used, and disclosed by us in accordance with this privacy policy.

Impacter

All information collected via our Impacter service are stored securely in our servers via Google Cloud and remains private and confidential to the organisation. All passwords and login details are encrypted and stored with Google Firebase.

Financy Pty Ltd and Tech for Good Group Pty Ltd in partnership with Morpheus Wealth Pty Ltd as the developers behind Impacter, will be exposed to your information (to the extent required to support the product) and will only publish this information as set out in this policy and our terms. We may also engage contractors to assist with the development and maintenance of Impacter.

Organisation information will be shared on the Impacter platform at an aggregated average level and the organisation will not be identified unless it achieves “Top 10 Performer” status, in which case your organisation’s headline results will be shared next to your organisation name in a table. However personal information of individuals in your organisation will not be shared in this way.

The University of South Australia’s (UniSA) Centre for Workplace Excellence, as academic partner of Financy, will have access to Impacter data for analysis and research purposes in accordance with UniSA’s research ethics policies and the Australian Code for the Responsible Conduct of Research. Data will be de-identified and kept confidential. UniSA will be working with Financy to deliver DEI research-based recommendations back to the Impacter community. This information may also be published more broadly in academic research papers, but it will not identify any Impacter clients without first seeking written permission.

Impacter subscribers will also have the ability to invite organisational members to the platform and they will be able to select the level of access, such as admin, editors or employees.

Where personnel are invited to participate in the Inclusion survey, the information collected will be kept confidential. Only aggregated data collected on individual personnel respondents will be shared with the organisation admins and editors.

Subscribers will also have the ability to invite third party consultants to view their Dashboard results and be able to download reports.

Third-party websites and services not covered

This privacy policy does not apply to personal information collected through any other website or to the practices of companies that Financy does not control. Please note that the Site may contain links to other websites. For example, if you click on an advertisement on the Site and link to another website, then this privacy policy will not apply to any personal information collected on that website. We are not responsible for the privacy practices of other websites or services, and we recommend that you read the privacy policies of each website that you visit or service you use.

What personal information we collect and how we collect it

We endeavour to collect personal information directly from you. However, we may also collect personal information from third parties including your organisation, such as when your organisation invites you to respond to Impacter.

Information we collect may include:

• name
• email address
• business address
• responses you provide in Impacter
• information you provide to other Financy Sites and Services such as in community discussions or interactive online features.

When you visit and interact with the Site, certain information (which may include personal information) may be collected automatically by our Site’s functionality, including:

• the web pages you were visiting immediately before and after you came to the Site;
• web pages and advertisements that you view, and links that you click on, within the Site;
• if you access third-party social networking services (such as Facebook, Linkedin, Youtube, Instagram and Twitter) through the Site, your username and connection lists for those services;
• demographic data, such as age range, and interests;
• advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular ad.

The Site may combine the information that we collect with information we obtain from third-party sources.

If you disclose to us the personal information of another person, you confirm that you have informed that other person about our privacy policy and obtained their consent to the disclosure.

How we use the information that we collect

We collect, hold, use, aggregate and disclose personal information for the purposes for which it was provided to us, as set out in this privacy policy and as permitted or required by law (“Purposes”). We also make available publicly sourced recommendations to subscribers of Impacter based on the information they provide to us.

The Purposes include:

Email Communications: We may use the personal information that we collect to send you e-mail communications, such as editorial updates, helpful tips based on Impacter insights, information about your account or changes to the Site, and with your consent promotional messages about our own or our marketing partners’ products and services. If you signed up for one of our email newsletters, we also will send you the newsletter that you requested. We note that you may unsubscribe from receiving promotional information at any time.

Advertising: In order to provide our Financy readers with free access to our content, we may display advertisements on the Financy Site. This does not include within the Impacter application.

Forum User Accounts: We may use personal information that we collect from messages, conversations or forum posts to fulfil your requests for products, services, and information. For example, we may use your contact information to respond to your customer service requests or we may use your help desk enquiries to improve on our Impacter software.

Statistical Analysis: In order to learn more about how Financy and Impacter application Services are used, we aggregate and analyse the data that we collect. We may use this information, for example, to monitor and analyse use of Impacter to increase features and services’ functionality, and to better tailor our content, design and technology services to suit our visitors’ and subscribers’ needs.

Enforcement: We may use the information that we collect to prevent illegal activities, to enforce the Site’s Terms of Service, and to otherwise protect our rights and the rights of our users.

Recommendations: In order to help our Impacter subscribers with their progress on diversity, equity and inclusion, we make available suggested actions or recommendations based on the information they provide to us. Such recommendations come from publicly available sources and third-party providers which Financy and Impacter may or may not have existing relationships with. Where a third-party relationship does exist, this information is provided to the subscriber.

In addition to the uses identified above, we may use the personal information that we collect for any other purposes disclosed to you at the time we collect personal information, with your consent and/or as permitted or required by law.

Information sharing

Financy values your privacy and will only share personal information provided to Impacter with third parties outside our Financy and Tech For Good Group operations, in accordance with this policy, or if we are required to do so under applicable law. 

Where information is disclosed, this will primarily be done at an aggregated level, where identifiable information is removed. This may occur in the circumstances listed below:

• We may disclose aggregated information to our related entities, service providers and corporate partners;
• We may disclose aggregated information or information that does not directly identify you with third parties to help us develop content, services, and advertising that we hope you will find of interest. Please note that we do not disclose contact information with third parties that advertise on the Site.
• We may employ third parties to perform Site-related services, including database management, maintenance services, analytics, marketing, data processing, and email and text message distribution. These third parties have aggregate level access to personal information only to perform these tasks on our behalf.
• If you choose to engage in public activities on the site, such as posting comments on community message boards, any personal information you submit can be read, collected, or used by others. Please exercise caution when deciding to disclose any personal information in public activities or submissions.
• We may disclose personal information about you in the event that the Site is acquired by or merged with another company, or a similar corporate transaction takes place. However, the Site will notify you by placing a prominent notice on our site or sending a notice to the primary email address specified in your account before personal information about you is transferred and becomes subject to a different privacy policy. In this event, you will be given the option of removing your data from Impacter.
• We may disclose personal information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of the Site’s Terms of Service, or as otherwise permitted or required by law.
• We may disclose personal information about you to respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
• In addition to the scenarios identified above, we may disclose personal information about you for any other purposes disclosed to you at the time we collect personal information about you or pursuant to your consent. Please note that third parties may independently collect information about you, including your IP address and other information (which may include personal information) about the websites you visit and the links you click, through cookies, clicks on links, or other means when you visit or view ads on the Site. For more information, see our section on cookies and other technologies and third-party advertising.

Information Quality

• Financy will review, on a regular basis, its collection and storage practices to ascertain how improvements to accuracy and security can be achieved.

Financy will take steps to destroy or de-identify personal information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.

Information Security

• Financy requires employees and contractors to perform their duties in a manner that is consistent with Financy’s legal responsibilities in relation to privacy.
• Financy will take all reasonable steps to ensure that paper and electronic records containing personal information are stored in facilities that are only accessible by people within Financy or Tech For Good Group who have a genuine “need to know”.
• Financy will review, on a regular basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

Openness

• If you have any queries or concerns about privacy issues, please contact us via email at admin@financy.com.au or impacter@financy.com.au
• Financy will provide an initial response to your query or complaint within 10 business days and will investigate and attempt to resolve your query or complaint within 30 business days where possible.

Third-party services

To customise your experience on the Site and to simplify the Site’s registration process, we provide you with the opportunity to access or interact with third-party services, such as Facebook, LinkedIn, YouTube, Instagram and Twitter. When you connect to the Site through these third-party services, we may disclose personal information about you with these third-party service providers and they may share data about you with us. When you allow us to access your data through a third-party service to create a Site profile, we may use this data for several purposes, including:

• Creating relationships automatically within our system. For example, if you connect to us via a service with a public friend list, like Twitter, we may check to see if any people you follow on Twitter are also Site users. If we find a match, we will replicate your Twitter relationship with those users, setting them to be fans, followers, or friends on our Site.
• Suggesting relationships. For example, if you connect via a service that has a private contact list (like Google and Yahoo!), we check for people in your contacts who are Site users and suggest that you become a fan of these users. This process is not automatic; you must affirmatively choose to become a fan of these suggested users.
• Populating a list of potential friends to whom you can send emails. When users share content with their friends using, for example, the forward-to-a-friend feature on the Site, we may use friend lists from third-party services to create a list of contacts to whom you may choose to send the email message.
• Populating a list of potential friends to whom you can send service-specific messages. For example, we may use friend lists from a third-party service to create a list of contacts to whom you may choose to send an invitation to view an interactive slideshow.
• To enhance and personalize your experience on the Site. When you are connected via a third-party service, we may access certain account information, such as your profile picture, what stories are popular in your network, and what your friends are saying about certain articles or blog posts, in order to enhance and personalize your experience on the Site. In addition, if you connect to a Facebook account, your experience on the Site may be personalized. For example, you may automatically see what stories are popular in your network, and what your friends are saying about particular stories. Please note that you may disconnect third party accounts at any time. Click here for a link to your social profile, where you may set your privacy preferences or disconnect all of your third-party service accounts. You also may be able to modify your privacy settings directly with the third-party service. To modify your Facebook privacy settings, click here. To modify your Twitter privacy settings, click here. Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all third-party service providers.

Your choices

Deactivating your account:

You can close your Impacter account at any time by contacting Financy in writing. When you close your account, your user profile will be disabled. However, aggregated and historical data captured and used in formulating Financy Impacter scores, and any public comments may remain on the Impacter. We have no responsibility to take down, remove, or edit any of your public activities or any submissions that are a result of your public activities. For more information, please review our Terms of Service.

Cookies and other technologies:

In order to improve your experience on our Site and for the purposes of marketing our services on other websites you may visit, we may use cookies or similar functionality. Third party vendors, including Google and Meta, show our marketing material on websites across the Internet, and use cookies to serve ads to you based on your past visits to our Site.

Our Site uses Google Analytics, a website service that enables the tracking of user analytics including but not limited to browser information, operating system information, pages viewed while browsing the Site, Site session times and referring website addresses, and enables us to help understand Site traffic and usage. Information about you regarding your web usage behaviour is held by Google and is subject to its privacy policy which can be viewed here https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008.

We may also use the Google Ads service to enable remarketing services, and Google UserID, demographic and interest reports. Information about you regarding your web usage behaviour is held by Google. Information from Google’s UserID service may be connected to other data that we hold about you.

Our Service may also use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here https://www.facebook.com/customaudiences/app/tos/?ref=u2u.

We may also use other third-party providers. You can opt out of the collection and use of information for ad targeting such as by modifying your browser settings or visiting https://www.networkadvertising.org/optout , http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.

If you opt out of these technologies, you will continue to see advertising displayed on the Site, but the advertising may not be targeted to your interests and some aspects of our Site’s functionality may be affected. Please remember that we do not have access to, or control over, advertisers’ or service providers’ cookies, and the information practices of third parties are not covered by this privacy policy.

For more information on the use of cookies in online advertising, please visit https://www.youronlinechoices.com.au.

Access to personal information

If you choose to share contact information with us, you may update or amend this information by contacting us at admin@financy.com.au or impacter@financy.com.au. You may otherwise access personal information about you that we hold subject to a small number of legal restrictions or exemptions. Where such restrictions or exemptions exist, we will advise you of the reasons if we deny your request for access.

If you wish to access personal information about you that we hold you should contact us at admin@financy.com.au or impacter@financy.com.au and provide us with proof (satisfactory to us) of your identity. While we do not charge you for a request for accessing personal information about you, please be aware that we may charge a reasonable fee (which will be notified to you once you make a request) for our time and costs in complying with your request in the following circumstances:

• if an extended amount of time is required to collate and prepare the material for you; and/or
• if you wish to have personal information about you photocopied/printed by us.

Correction of personal information

We take reasonable steps to ensure that personal information is accurate, complete and up to date. However, we rely on you to advise us of any changes to personal information about you.

Confidentiality and security

We take reasonable steps to protect personal information that we hold from misuse, interference, and loss and from unauthorized access, alteration, and disclosure, including limiting access to personal information about you to employees or service providers who we believe reasonably need to come into contact with that personal information to provide products or services to you or in order to do their jobs. We also have adopted commercially reasonable technical, physical, and administrative procedures to help protect personal information including:

• physical security procedures for access to our business premises; and
• IT security procedures including password protection, firewalls, intrusion detection and site monitoring.

Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Site, but we cannot ensure or warrant the security of any information you transmit to us.

Children

We do not knowingly collect personal information from children. If we learn that we have collected any personal information from a child under 18 years without verifiable parental consent, we will delete that personal information from our database as quickly as possible. If you believe that we may have collected personal information from a child, please contact us at admin@financy.com.au or impacter@financy.com.au

Content

Any performance report on the Financy Impacter is provided for information purposes only and results of past performance have no guarantee of future returns. No assurance is given that you will incur any improved performance by taking action on the suggestions provided in your own business activities and it should not be assumed that you will experience results comparable to those reported. 

Changes to the privacy policy.

We may update this privacy policy at any time to reflect changes in our practices and service offerings. If we modify this privacy policy, we will update the “Effective Date” below. We will notify you of any material changes in the way we treat personal information by placing a prominent notice on our Site or sending a notice to the primary email address specified in your account. Your continued use of the Site, requesting our assistance or your provision of further personal information to us (directly or via an authorized person) after this privacy policy has been modified constitutes your acceptance of and consent to the modified privacy policy.

Questions and suggestions.

If you have questions about this privacy policy, please contact us at admin@financy.com.au or impacter@financy.com.au

Effective date 19^th June 2023

Contacting Financy

If you require further information regarding Financy, contact us:

admin@financy.com.au or impacter@financy.com.au