Privacy Policy
Scale App Pty Ltd
Privacy Policy and Collection Statement
Introduction
Scale App Pty Ltd (ACN 670 421 459) (referred to as Scale App, we, our, us) is bound by the Privacy Act 1988 (‘the Privacy Act’), including the Australian Privacy Principles (‘APPs’), and recognises the importance of ensuring the confidentiality and security of your personal information.
All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by Scale App must abide by this Privacy Policy and Collection Statement (‘Privacy Policy’). Scale App makes this Privacy Policy available free of charge at www.scaleapp.com.au
In this Privacy Policy:
Disclosure of information means providing information to persons outside of ##.
Personal information means information or an opinion relating to an individual, which can be used to identify that individual.
Privacy Officer means the contact person within Scale App for questions or complaints regarding Scale App’s handling of personal information.
Sensitive information is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information.
Use of information means use of information within Scale App.
What kind of personal information do we collect and hold?
We may collect and hold a range of personal information about you to provide you with our services, including:
name;
residential address;
phone numbers;
email addresses;
employment and occupation details;
marital status;
banking or credit card details required for processing payment;
property title, ownership and transfer details
property tenancy and registered lease details
details about your driver’s licence and other identification documents;
financial information, including details of:
financial history;
your investments;
your other assets;
your loans and other liabilities;
your cashflows, income and expenses;
taxation information; and
superannuation information.
How do we collect personal information?
We generally collect personal information directly from you. This may take place in a number of ways, such as when you:
set up your profile in the Scale App mobile app;
subscribe to our newsletters or other updates;
complete a contact form on our website;
comment or interact with our social media accounts;
provide us with information about you or a property you own in the Scale App mobile app;
provide us with payment details to pay for your subscription fees; or
call us or send us correspondence.
If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services or meet your needs appropriately. For example, while a full-strength profile is not necessary to enable functionality on the Scale App mobile app, certain features (such as simulations) will be limited in their capacity to provide you with accurate and detailed analysis without an accurately completed profile.
Third party suppliers
We may also collect personal information about you or properties you own from a third party, such as electronic verification services, referrers and marketing agencies. We also source publicly available information from third parties including real estate listing portals, real estate agents, government departments or agencies, local councils and authorities. If so, we will take reasonable steps to ensure that you are made aware of this Privacy Policy.
Sensitive information
We will not collect sensitive information about you without your consent, unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.
Use of pseudonyms
We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for Scale App to deal with individuals who are not identified.
Unsolicited personal information
We may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other personal information.
Who do we collect personal information about?
The personal information we may collect and hold includes (but is not limited to) personal information about:
users of the Scale App mobile app;
potential users of the Scale App mobile app;
visitors to our website;
service providers or suppliers;
prospective employees, employees and contractors; and
other third parties with whom we come into contact.
Website collection
We collect personal information when we receive completed online generated forms from our website www.scaleapp.com.au . We may also use third parties to analyse traffic at that website, which may involve the use of cookies. Information collected through such analysis is anonymous. You can view and access our Privacy Policy by clicking on the privacy button on our website.
Use of cookies
We use cookies on our website to store user preferences, improve website performance, understand how users interact with our website, to compile aggregate data about our website traffic, including where our website visitors are located, and interaction so that we can offer better user experiences. We will delete all data obtained through cookies every 2 weeks.
Cookies do not contain personal information but can be used to identify a person when combined with other information. Cookies are small text files which are transferred to your computer’s hard drive through your web browser that enables our website to recognise your browser and capture and remember certain information.
As we use website cookies, we have a created a ‘pop up’ message on our website, which states:
This website uses cookies for analytics and personalised content. By using this website, you agree to the use of cookies in accordance with our Privacy Policy [OK].
You can withdraw or modify your consent to our use of cookies at any time. If you no longer wish to accept cookies, you can use your web browser settings to accept, refuse, adjust and delete cookies. To do this, follow the instructions provided by your browser. Please note that if you set your browser to refuse cookies, you may not be able to use all of the features of our website.
Use of analytics
We also use third party analytics on the site, such as Google Analytics and ActiveCampaign. We may use other third party analytics services from time to time. We do not pass any personally identifiable information through this function, however, the data we collect may be combined with other information which may be identifiable to you.
Why do we collect and hold personal information?
We may use and disclose the information we collect about you for the following purposes:
provide you with our products and services, including features of the Scale App mobile application such as:
user profile set up and updates
ID verification
personal cashflow tracking and projections
user profile and account linking
information sharing with trusted advisers
tailored feasibility reports
personal net wealth tracking
performance and cashflow metrics
scenario simulation tools
oversight of personal financial metrics including borrowing power and repayments
access to information and educational resources
review and meet your ongoing needs;
provide you with information we believe may be relevant or of interest to you;
let you know about other products or services offered by us or our commercial partners, send you information about special offers or invite you to events;
to enable our commercial partners to contact you about their products or services;
consider any concerns or complaints you may have;
comply with relevant laws, regulations and other legal obligations; and
help us improve the products and services offered to our customers and enhance our overall business.
We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.
Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.
If we are verifying your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), you may ask us to provide an alternative means of identify verification by contacting Scale App’s Privacy Officer – see section 18 of this Privacy Policy for contact details.
Who might we disclose personal information to?
We may disclose personal information to:
a related entity of Scale App;
an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors or other advisers;
organisations involved in a transfer or sale of all or part of our assets or business;
organisations involved in managing payments, including payment merchants and other financial institutions such as banks;
regulatory bodies, government agencies, law enforcement bodies and courts; or
other persons or bodies as required by law.
If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues, and we will make third parties aware of this Privacy Policy.
We may also disclose personal information where you have expressly authorised the disclosure. For example, if you:
request to link your Scale App mobile app profile with your spouse or partner;
request to send information about your borrowing power to your mortgage broker; or
consent to us disclosing your personal information to our commercial partners so they can let you know about their products and services.
Sending information overseas
We do not disclose personal information overseas.
We will not send personal information to recipients outside of Australia unless:
we have taken reasonable steps to ensure that the recipient does not breach the Act and the APPs;
the recipient is subject to an information privacy scheme similar to the Privacy Act; or
the individual has consented to the disclosure.
If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.
Management of personal information
We recognise the importance of securing the personal information of our customers. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.
Your personal information is generally stored in our computer database, including our cloud storage databases. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:
passwords are required to access the system, and passwords are routinely checked;
data ownership is clearly defined;
we change employees’ access capabilities when they are assigned to a new position;
employees have restricted access to certain sections of the system;
the system automatically logs and reviews all unauthorised access attempts;
unauthorised employees are barred from updating and editing personal information;
all computers which contain personal information are secured both physically and electronically;
data is encrypted during transmission over the network; and
printing of documents containing personal information is limited.
Where our employees work remotely or from home, we implement the following additional security measures:
two-factor authentication is enabled for all remote working arrangements;
password complexity is enforced, and employees are required to change their password at regular intervals;
we ensure that employees only have access to personal information which is directly relevant to their duties;
employees are not permitted to work in public spaces;
we use audit trails and audit logs to track access to an individual’s personal information by an employee;
we monitor access to personal information, and will investigate and take appropriate action if any instances of unauthorised access by employees are detected;
employees must ensure that screens are angled so that they cannot be used by anyone else, and are locked when not in use;
employees must ensure that no other member of their household uses their work device;
employees must store devices in a safe location when not in use;
employees may not make hard copies of documents containing personal information, nor may they email documents containing personal information to their personal email accounts; and
employees may not disclose an individual’s personal information to colleagues or third parties via personal chat groups.
Direct marketing
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
the personal information does not include sensitive information; and
you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
we provide a simple way of opting out of direct marketing; and
you have not requested to opt out of receiving direct marketing from us.
If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.
We may disclose your personal information for the purposes of facilitating direct marketing by other organisations if you consent for us to do so.
You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations. We must give effect to the request within a reasonable period of time. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.
Identifiers
We do not adopt identifiers assigned by the Government (such as drivers’ licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.
How do we keep personal information accurate and up-to-date?
We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date. Please note that if we have collected your personal information via the Scale App mobile application, we rely on you to keep your profile information accurate.
We encourage you to contact us to update any personal information we hold about you, including by updating your profile information in the Scale App mobile application. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting the information.
Accessing your personal information
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Scale App’s Privacy Officer. We will provide access within 30 days of the individual’s request. If we refuse to provide the information, we will provide reasons for the refusal.
We will require identity verification and specification of what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
Updates to this Privacy Policy
This Privacy Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment.
Responsibilities
It is the responsibility of management to inform employees and other relevant third parties about this Privacy Policy. Management must ensure that employees and other relevant third parties are advised of any changes to this Privacy Policy. All new employees are to be provided with timely and appropriate access to this Privacy Policy, and all employees are provided with training in relation to appropriate handling of personal information. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.
Non-compliance and disciplinary actions
Privacy breaches must be reported to management by employees and relevant third parties. Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.
Making a complaint
We have an effective complaint handling process in place to manage privacy risks and issues.
The complaints handling process involves:
identifying (and addressing) any systemic/ongoing compliance problems;
increasing consumer confidence in our privacy procedures; and
helping to build and preserve our reputation and business.
You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
If you have any questions about this Privacy Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:
writing – 115 of Level 10, 131 Macquarie Street, Sydney NSW 2000
emailing – accounts@scaleapp.com.au
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:
telephoning – 1300 363 992
writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
online submission – https://forms.business.gov.au/smartforms/landing.htm?formCode=APC_PC
Contractual arrangements with third parties
We ensure that all contractual arrangements with third parties adequately address privacy issues, and we make third parties aware of this Privacy Policy.
Third parties will be required to implement policies in relation to the management of your personal information in accordance with the Privacy Act. These policies include:
regulating the collection, use and disclosure of personal and sensitive information;
de-identifying personal and sensitive information wherever possible;
ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.
Your rights
This Privacy Policy contains information about how:
you may access the personal information we hold about you;
you may seek the correction of your personal information;
you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
you may complain about a breach of the Privacy Act, including the APPs; and
we will deal with a privacy complaint.
