Privacy Policy

The protection of your personal information is very important to us. This Privacy Policy explains how we may collect, hold, use and disclose your personal information (including credit information) when you visit our websites, mobile apps, official media platforms, apply for or use our services or products through us or our authorised third parties or communicate with us in any way in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APP).

This Privacy Policy is to be read in conjunction with the Privacy Consent Form, a copy of which is available by contacting us.

For the purposes of this Privacy Policy, 'we' and ‘us’ means Monoova Limited ACN 660 380 370, Monoova Australia Pty Ltd ACN 612645 495, Monoova Global Payments Pty Ltd ABN 77 106 249 852, Monoova Services Pty Ltd ABN 77 656 074 645, Monoova Payments Pty Ltd t/as Monoova ABN 38 126015 and their related bodies corporate and affiliates. By providing us with your personal information you consent to us using and handling your information in accordance with this Privacy Policy. If you provide any personal information about another individual then we rely upon you to inform him or her of the details contained in our Privacy Policy.

To the extent that our website contains links to other websites which are provided for your convenience, we are only responsible for the privacy practices and security of our website. We recommend that you check the privacy and security policies and procedures of each and every other website or application that you visit or use.

Types of personal information we may collect from you

“Personal Information” as defined under the Privacy Act, means information or an opinion about an identified individual, or an individual who is reasonable identifiable whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. The kinds of personal information we collect and hold about you depends on the circumstances of collection and the nature of your dealings with us.

We may collect and hold the following kinds of personal information about our customers and applicants:

  • your identification information, including name, date of birth, address, telephone number, email address or other contact details, driver licence particulars, occupation and other information requested and/or provided by you and people nominated by you when you made your application for our products or services;
  • information we may require to identify you, including as required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act),which may include details or copies of your driver licence or passport;
  • personal information about you to record a security interest on the Personal Property Securities Register pursuant to the Personal Property Securities Act 2009 details of products or services that we provide or have been requested to provide to you, including information about the ongoing management and activity of the products or services we have provided;
  • information (including credit information, as defined in the Privacy Act) relevant to the provision of products or services to you, including information about your financial position, such as details of assets and liabilities, details of income and proof of financial position;
  • other information relevant to our relationship with you, including name and contact details of your professional advisers or representatives such as your solicitor or accountant; your referees or guarantors; and information contained in identity documents that you may provide to us (such as the names of your family members);
  • records of our interactions with you, including by telephone, email and online;
  • publicly available information; and
  • your enquiries or complaints.

We may also:

  • collect and hold the following kinds of personal information about contractors, service providers and suppliers: name, job title, business contact details of company representatives with whom we deal, financial information and banking details; and
  • in the context of our recruitment process for employees and contractors, we collect and hold personal information including the following kinds: name, email address, telephone number, address, financial details (including banking details), date of birth, history with us (including communications between us), citizenship, employment references, civil, credit and criminal records, driver license information, education and employment history.

If we are not provided with this personal information, then we may be unable to provide you with our products or services.

We will not collect information about you that is “sensitive information” which includes information about your health, biometrics, genetics, ethnic background, sexual preferences, criminal records, religious belief, religious affiliations, philosophical believes, professional memberships, trade memberships, political memberships and opinions unless you provide your consent, or we are authorised or required to do so by law.

Electronic Identification Verification

Under the AML/CTF Act, we may be required to disclose your name, telephone number, residential address and date of birth to a third party including a Credit Reporting Body (CRB) in order to verify your identity electronically. If you are an individual, we will obtain your consent before we disclose this information to any third party including a CRB. If you do not consent to have your identity verified electronically, you will be required to provide us with certified copies of your identification documents to us.

If we are unable to verify your identity, we will be unable to provide our services to you.

How we collect personal information

We collect personal information (including credit information) directly from you in our Monoova Application Form as well as our Privacy Consent Form.

We may also supplement the information that you provide to us with other personal information (including credit information) that we obtain from our dealings with you or which we receive from other organisations, such as:

  • CRBs in relation to certain credit information (for example, relating to the officeholders of your business);
  • publicly available sources, including public registers and social media, and personal insolvency information about you entered or recorded in the National Personal Insolvency Index;
  • government authorities; and
  • our related bodies corporate.
  • Further, we may collect personal information about an individual from third parties who have applied for a product or service, for example:
  • where a company is an applicant and details of the company’s officeholders or account signatories are provided to us by the individual(s) applying on behalf of the company;
  • where a trustee is an applicant and details of the trustees and beneficiaries are provided to us by the individual(s) applying on behalf of the trust; or
  • where an applicant provides the details of their professional advisers

How we use and disclose your personal information

We collect, hold, use and disclose your personal information (including credit information) for a variety of business purposes in order to provide our products and services to you, including:

  • assessing and processing any application you make for our products or services, including assessing the credit risks relating to your business or the ability for you to meet your payment obligations;
  • providing you the products and services we offer in the course of our business;
  • administering and managing all products or services we provide to you;
  • performing other administrative tasks including, staff training, undertaking planning, research and statistical analysis, systems development and testing;
  • answering an enquiry you make or responding to a complaint made by you in respect of a product or service;
  • conducting data analytics to help us improve our products and services;
  • verifying your identity and complying with our legal and regulatory obligations;
  • facilitating our internal business operations, including audits, record-keeping, file reviews and portfolio analysis;
  • analysing products and customer needs, including inviting you to participate in customer surveys;
  • informing you of products and services provided by us, our related bodies corporate or our preferred providers which we consider may be of value or interest to you, unless you tell or have previously told us not to;
  • managing overdue payments and recovering overdue amounts you owe us where you have failed to meet your payment obligations to us;
  • detecting and preventing fraud, security threats or other illegal or malicious   behaviour or managing disputes;
  • assessing and considering applications from prospective job applicants, contractors and service providers; and
  • as otherwise stated in this Privacy Policy.
  • In order to provide our services to you, we may appoint other organisations to carry out data processing activities on our behalf. All third parties are given access to the information they need to perform their function, but are not permitted to use your information for other purposes. Third parties who we may disclose personal information to include:
  • organisations that we are affiliated with;
  • specific third parties that you have authorised to receive information held by us;
  • other third parties where it is necessary or desirable to provide you with our services,
  • our employees, related bodies corporate or external service providers in relation to the operation of our website or business (such as mailing houses, printing companies, IT, advertising, marketing, web hosting providers, IT systems, data entry service providers, professional advisors and consultants);
  • relevant authorities or enforcement bodies where we reasonably believe that such disclosure is necessary to bring legal action against anyone who has breached our terms and conditions or engaged in any unlawful activity;
  • entities we propose to merge with or be acquired by; or
  • other organisations for the purpose of the detection and prevention of fraud, security threats or other illegal or malicious  behaviour or managing disputes, including to Sift Science, Inc (in accordance with the Sift Privacy Notice)
  • any other person where we are otherwise required or permitted to by any law, including under the Privacy Act.

Disclosure of your personal information overseas

We may disclose your personal information, and by providing personal information to us you consent to us, transferring, storing and processing your information in countries other than your own.

A third party to whom we give your personal information may not be in your country of residency or may transfer and store that information outside that country (Overseas Recipient).

If you are a resident in Australia, we will take reasonable steps to ensure that an Overseas Recipient does not breach the APPs, Overseas Recipients are not bound by the APPs and you agree that subclause 8.1 of the APPs does not apply to the disclosure of your personal information to an Overseas Recipient. If an Overseas Recipient handles your information in breach of the APPs, you will not be able to seek redress under the Privacy Act. The practical effects or risks associated with the disclosure may include that you may not be able to seek redress in the jurisdiction of the Overseas Recipient or the Overseas Recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

Access and Correction of your information

You have the right to access your personal information and requests for information about our privacy policy are welcomed.

You can contact us to update or correct your personal information by emailing the Privacy Officer at privacy@monoova.com.

We may require that you verify your identity before information we hold is disclosed to you. We may refuse to provide you with information that we hold about you in certain circumstances set out in the Privacy Act. If we do, w will write to you to let you know why your request has been denied or limited unless, having regards to the grounds for refusal, it would be unreasonable for us to do so.

If you believe that any personal information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email the privacy officer.‍

Disclosure of credit information to CRBs

The CRB that we currently use is Equifax: www.equifax.com.au. The law requires us to advise you or otherwise ensure that you are aware of certain ‘notifiable matters’. The CRB in which we use contain their own credit reporting policies outlining how they deal with your information. Such policies are outlined on their respective websites and via the details provided below:

Equifax Australia Information Services and Solutions Pty Limited
Mail:          GPO Box 3352, Sydney NSW 2001
Phone:       138 332 (free call)
Website:    https://www.equifax.com.au/  

A copy of Equifax's credit information management policy may be obtained by contacting them by filling our their form. You have the right to request CRBs not to:

  • use your credit-related information to determine your eligibility to receive direct marketing from credit providers; and
  • use or disclose your credit-related information, if you have been or are likely to be a victim of fraud.

Direct Marketing

We may use and disclose your personal information to inform you about products or services we think might be of interest to you. We may also disclose your personal information to our related bodies corporate and preferred providers (together referred to as the Related Companies) so that they may inform you about products and services.

You may opt out of receiving direct marketing messages at any time by following the opt out instructions in those messages. Please contact our Privacy Officer to change your marketing preferences for our services or the services of Related Companies.

We will not sell, distribute or lease your Information to third parties unless we have your permission or are required or expressly permitted by law to do so.

Complaints

How to make a complaint

You can make a complaint to us in any of the following ways:

  • Telephone 1300 656 157
  • Email complaints@monoova.com
  • Writing:
    ‍
    Monoova
    GPO Box 3352
    Sydney NSW 2001
    Attention: Complaints Manager

When making your complaint please tell us:

  • your name
  • how you wish us to contact you (for example, by phone, email)
  • what your complaint is about; and
  • what you are seeking to resolve your complaint.

If you need help to make or manage your complaint, you can appoint someone (for example, a relative or friend) to represent you.

Please note that we will need your authority to speak to any representative that you appoint. Please allow up to 20 business days for a response to your complaint. If you are not satisfied with our response, you have the right to escalate your complaint.

Acknowledgement

We will acknowledge receipt of your complaint in writing within one business day, or as soon as practicable and try to resolve it as quickly as possible. When acknowledging your complaint, we will also have regard to any preferences you have communicated to us in relation to the way in which you wish for us to communicate with you.

Investigation of your complaint

If we cannot resolve your complaint immediately, we will need some time to investigate your concerns. We may also request that you provide us with further information to assist with our investigation.

Outcome of your complaint

We will provide you with our written reasons for the outcome of your complaint no later than 20 business days after receiving your complaint. Our response will also inform you of your right to escalate your complaint to the Australian Financial Complaints Authority (AFCA). AFCA offers a free and independent dispute resolution for financial complaints to individuals and small businesses.

If we reject your complaint (whether in full or in part), our response will:

  • identify and address the issues you raised in your complaint;
  • set out our findings on the material questions of fact raised in your complaint, making reference to the relevant supporting information; and
  • provide a sufficient level of detail in order for you to understand the reasons for our decision so that you can decide whether to escalate the complaint to AFCA or another forum.

Delay in providing a response

If we are not able to provide our response to you on time because your complaint is complex or because of circumstances beyond our control, we will write to you to explain the reasons for the delay and inform you of your right to complain to AFCA and provide you with AFCA’s contact details.

Escalating your complaint

If you are not satisfied with our response to your complaint, you can escalate your complaint to AFCA. AFCA You can contact AFCA using the following details quoting our AFCA membership number (#29468):

  • Email: info@afca.org.au
  • Phone: 1800 931 678(or +61 1800 931 678 if calling from overseas)
  • Online: www.afca.org.au
  • Mail: GPO Box 3,Melbourne, VIC, 3001

You can also contact The Office of the Australian Information Commissioner at:
‍
The Office of the Australian Information Commissioner
‍Mail: GPO Box 2999,
Canberra, ACT, 2601
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au  
‍
For more information, please read our Complaints Section on our website.

Storage and Security

Your personal (including credit information) may be held in physical or electronic form on our systems or the systems of our service providers. In order to assist with the prevention of unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

No information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against un-authorised disclosures of information, we cannot assure you that information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Please notify us immediately if there is any unauthorised use of your account by any other Internet user or any other breach of security. For the purposes of viewing our website you may have a user name and password. You are responsible for the security and confidentiality of your password and log-in information.

Tracking technology  

Each time you visit one of our websites, our server collects some anonymous information such as the type of browser and system you are using, the date and time of your visit, the address of the website you have been directed from and your server’s IP address. We may use this information to evaluate and improve our website performance.

Where you visit our website, use or services or products for which we provide online, we may use cookies from time to time. Cookies are text files placed in your computer's browser to store your preferences. However, once you choose to furnish us with personally identifiable information, this information may be linked to the data stored in the cookie.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any personal identifiable information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of our website.

We may use web beacons on our website from time to time. Web beacons (also known as clear gifs) are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may also collect website data from the devices of end users through application programming interfaces, JavaScript snippets, SDKs and other technologies (Snippets) placed on our customer’s websites and applications which may include device identifiers and device information (e.g. page URL, referrer, number of fonts, OS) and other technical information.

Links to other websites

Our website may contain links toother websites of interest (Third Party Websites) and we may display content or information from other websites within frames on our website (Third Party Content).  We do not have any control over those Third Party Websites or the Third Party Content. We are not responsible for or liable for the handling, use, disclosure,  protection and/or privacy of any personal information which you provide or which has been collected whilst visiting Third Party Websites, and such websites are not governed by this Privacy Policy.

Changes to the Privacy Policy

We may revise this Privacy Policy from time to time by publishing it on our website and will be effective as from the publishing date. If you have any questions relating to this Privacy Policy, please contact our Privacy Officer.

Contact Details

If you would like more information about our approach to privacy, or if you wish to contact us regarding the information set out in this Privacy Policy, please contact us:

  • By email:   privacy@monoova.com
  • By phone:  1300 858 904
  • By post: GPO Box 3352, Sydney NSW 2001
  • Date: 27 June 2023