This document explains how Tuxedo Money Solutions Pty Ltd (ABN: 21 166 665 050) and our group companies protect the privacy of your personal information. Tuxedo Money Solutions Pty Ltd ("we" “our” and “us”) includes:
- Tuxedo Money Solutions Limited Registered in England, Company Number,05674773, and
- Tuxedo MoneyPlus Limited Registered in England, Company Number 05831827
We recognise the importance of protecting your privacy and are committed to ensuring that the highest standards of security are applied to the personal information you give to us and that it is collected and managed with diligence and care.
Our aim is to comply at all times with privacy laws (incorporating the Australian Privacy Principles) that apply to us. If you have a comment, query or complaint regarding a privacy matter, we encourage you to discuss it with us.
When you apply for a product or service from us (or one of our distributors), you will be asked for personal information that is needed to process your application. The information that you provide will only be used for the purposes described at the time of your application and as outlined in our Terms and Conditions that apply to that particular product or service. If you do not give us your personal information, we may not be able to supply you with our products or services.
We usually collect personal information directly from you. Sometimes we collect or confirm this information from a third party such as a credit reporting agency. We will have used reasonable efforts to obtain your consent to do this.
We collect personal information that includes details such as your:
- date of birth
- contact details (such as phone and fax numbers, e-mail addresses)
- financial information about you such as information about your use of financial products and services which you acquire from or through us, your income and savings
- credit reports from credit reporting agencies
- employment details
We use your personal information in order to:
• Check your eligibility for and provide you with our products and services (including situations where we are an authorised representative for another product issuer);
- Administer and manage the products and services we provide to you (including providing goods, services or information you have requested), marketing, customer services and profiling your purchase preferences. We will disclose your personal information to our service providers and distributors for these purposes;
- Communicate with you and assist you with your inquiries or concerns;
- Verify your identity and undertake customer due diligence in order to comply with our obligations under anti-money laundering laws;
- Consider whether or not we have other services or products which may possibly meet your needs, and to notify you about these;
• Learn from the way you use our products and services, for example from the transactions you make;
- Perform our regular and necessary business functions (such as internal audit investigations, performance reporting, research, product development and planning).
- Comply with our legal or regulatory obligations.
When you visit our websites, either we or our service provider will record information (such as your computer's IP address and top level domain name, the type of browser you are using, the date, time and pages accessed) in relation to your visit for statistical purposes. This information is collected as aggregated data and the user remains anonymous. We do not attempt to identify users of our websites except where we specifically ask for your personal information, which includes online banking and online services provided to our business partners.
We may share your personal information within the wider Tuxedo Group. Different companies within the Tuxedo Group provide different services. The Tuxedo Group includes our UK parent company Tuxedo Money Solutions Limited and its subsidiaries. Although we do not sell your personal information to outside companies, we do work with third parties, and in certain circumstances may share personal information with them too, for example where they help us to provide you with our products and services, or where you have requested or have consented to us doing so, for example marketing third party products. We will not share your personal information with a third party for marketing third party products if you tell us not to. Where your personal information is disclosed to third parties, we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles in the Privacy Act 1988.
Types of third parties include:
• parties involved in providing, managing or administering your products or services such as third party suppliers, printers, postal services, authorised representatives and our legal, tax, audit and accountancy advisers;
• parties maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems;
• strategic retail partners who distribute our product to their customers, for example, the STA Travel ISIC CashFLEX card;
• any of your advisers, which may include lawyers, executors, administrators, trustees or attorneys;
• parties involved in the payments system including financial institutions, merchants and payment organisations.
We may also disclose your personal information to third parties in circumstances where:
• we must fulfil our legal obligations (for example, disclosure to Australian (and international) enforcement bodies such as the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre (AUSTRAC), Centrelink or the Courts);
• it is in the public interest (that is, to protect our interests or where we have a duty to the public to disclose, or where it is necessary in proceedings before a court or tribunal) and where a crime or fraud is committed or is suspected; or
Some of the organisations mentioned above who are involved in the collection and use of your personal information and to whom it may be disclosed are located overseas. We will only give them secure access to your personal information to the extent they need to do their job. These overseas companies are involved in providing services such as data storage, processing, and customer and technical support, and they do it from countries like the UK, France and India.
We maintain effective control of your information at all times, including by ensuring that parties located overseas are subject to strict controls that limit access and subsequent handling of your information to the extent strictly necessary to perform the relevant function and protect your information from unauthorised use and disclosure.
Access and correction
If you ask us, we will usually give you access to the personal information we hold about you. We will always confirm your identity before giving access to your personal information.
You can ask for access by contacting us (see below).There are circumstances under Australian privacy laws where we may not give you access to the personal information we hold about you. For example, we can’t give you access if it would unreasonably affect someone else’s privacy or if giving you access poses a serious threat to someone’s life, health or safety.
There is generally no cost for accessing the personal information we hold about you, unless the request is complex or resource intensive. If there is a charge, it will be reasonable and we will let you know what it is going to be so that you can agree to it before we go ahead.
We aim to keep the personal information we hold about you accurate, up-to-date and complete. If you think our records need to be corrected, please contact us (see below).
Opting out of product promotions
We will make sure that any marketing emails, texts and letters that we send to you clearly tell you how to opt out, or alternatively, you can contact us (see below). If you do opt out, we will continue to provide information in relation to your existing accounts or facilities only, including new features or products related to these accounts/facilities.
Storage and security of your personal information
We will take reasonable steps to keep the personal information that we hold about you secure to ensure that it is protected from loss, unauthorised access, use, modification or disclosure.
We will never send emails to you requesting security or any other confidential information.
Your personal information is stored within secure systems that are protected in controlled facilities. Our employees and authorised agents are obliged to respect the confidentiality of any personal information held by us.
We use our best efforts to ensure that information received via our websites remains secured within our systems. We are regularly reviewing developments in online security; however users should be aware that there are inherent risks in transmitting information across the internet. Information transmitted via our websites is protected by a 128-bit encryption technology.
Sometimes cookies are used by a third party service provider who we have an agreement with to monitor the success of our marketing campaigns. The third party service provider uses the cookies to collect information such as when you visited our site, your browser type and the server that your computer is logged in to.
The information is used in an aggregate form and generally no personal information is collected by the third party service provider. Our agreements with these third parties ensure this information is only used to carry out functions on our behalf, and if any personal information is collected the confidentially of that information is maintained.
Most internet web browsers are pre-set to accept cookies to enable full use of websites that employ them. However, if you do not wish to receive any cookies you may configure your browser to reject them or receive a warning when cookies are being used. In some instances, this may mean that you will not be able to use some or all of the services provided on our websites. However you may still be able to access information only pages.
Changes to this policy
Privacy concerns or complaints
You can find out more about our complaint process and complaint handling policy by contacting us (see below). If you make a complaint about privacy, we will acknowledge receipt of your complaint, and try to investigate and respond to you within 30 days. If you remain unhappy with the outcome, you can lodge a complaint with Financial Ombudsman Service:
Mail: Financial Ombudsman Service, GPO Box 3, Melbourne, VIC, 3001
Phone: 1300 78 08 08
Fax: 03 9613 6399
Website: www.fos.org.au Ombudsman.
Postal Address: Tuxedo Money Solutions, GPO Box 82, Melbourne VIC 3001
Further information about privacy
You can find more information about privacy (including information about specific issues, answers to frequently asked questions and links to the 10 National Privacy Principles) on the Office of the Privacy Commissioner's website at www.privacy.gov.au.
Date of Publication March 2014.
Copyright Tuxedo Money Solutions Pty Ltd (ABN: 21 166 665 050)