The privacy of your Personal Information is important to Amalagam Holdings Pty Ltd ACN 643 971 439 trading as Qubix Money (we, us or our). We respect your rights to privacy and rights under the Privacy Act and are committed to complying with the requirements of the Privacy Legislation in the collection and handling of your Personal Information.
This policy explains how we collect, retain, process, share, transfer and handle your Personal Information and describes the kinds of Personal Information we collect, use, disclose and our purposes for doing so.
We use some defined terms in this policy which are set out at clause 11 below.
Personal Information is information which may be used to reasonably identify you. For example, your name, address, date of birth, gender, email address, telephone number are generally considered to be Personal Information. Personal Information may include information we collect about your individual preferences. We do not collect any sensitive Personal Information about you.
This policy applies to your Personal Information when you use our Platforms and interact generally with us but does not apply to Third Party Sites. We are not responsible for the privacy policies or content of Third Party Sites.
For the avoidance of doubt, unless stated otherwise, this policy will govern our collection of your Personal Information irrespective of the place where it is collected.
This policy may be updated from time to time and the most up to date version will be published on our Website. We encourage you to check our Website periodically to ensure that you are aware of our current policy.
2. Why we collect Personal Information
When you visit our Platforms, we collect Personal Information so that we can provide you with products and services and improve and customise your experience with us. We only collect Personal Information if it is reasonably necessary for us to carry out our functions and activities.
The purposes for which we collect and hold your Personal Information include:
to deliver our products and services to you;
- to confirm your identity and process your transactions through our App;
- to manage our relationship with you, evaluate our business performance and build our customer database;
- to provide you with information about our products, services, functions, events or activities, including location specific offers where you elect to share your location with us on your device;
- to enable you to participate in any promotion, competition, survey and/or enable you to subscribe to mailing lists/newsletters and interact or follow our Social Media;
- to respond to your requests and seek your feedback;
- to conduct research, compare information for accuracy and verification purposes, compile or analyse statistics relevant to the operations of our business;
- to facilitate our internal business operations, including fulfilment of any legal and regulatory requirements and monitoring, analysing and improving the performance and functionality of our Platforms and investigating breaches of or enforcement of any legal terms applicable to our App;
- to protect our property, our Platforms, or our legal rights including to create backups of our business records;
- to manage risk and protect our Platforms from fraud by verifying your identity and helping to detect and prevent fraudulent use of our Platforms;
- for the direct marketing purposes as set out below; and
- to manage our business, including analysing data collected from our Platforms concerning visits and activities of users on our Platforms. This analysis helps us run our Platforms more efficiently and improve and personalise your experience online. We use information from third party services such as Google Analytics and Facebook Pixel to help further improve your experience in using our Website.
3. What Personal Information do we collect?
The kinds of Personal Information we collect will depend on the type of interaction you have with us. Generally, the kinds of Personal Information we collect may include:
- your name, address (postal and residential), email address, telephone number(s), date of birth and gender when you register with us via our App;
- information from third party sources such as data providers and credit organisations, where permitted by law;
- details of the device you have used to access any part of our Platforms, including carrier/operating system, connection type, IP address, mobile payment methods, interaction with other retail technology such as use of NFC Tags or QR Codes which information may be collected and used by us automatically if you use our Platforms, through the browser on your device or otherwise;
- demographic information;
- location data;
- your connections with others whose personal information we may collect or hold;
- credit card, debit card, PayPal, AliPay, WeChat Pay, Bizcore or any other online payment methods or gateways and direct debit details for your bank account in order to process the transactions on the App; and
- transaction details relating to your use of our products, services or rewards.
Your telephone calls to us may also be recorded for training and quality assurance purposes.
4. With whom do we share Personal Information?
- to our related entities, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other third parties to satisfy the purposes for which the information was collected (as outlined in clause 2.2 of this policy) or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;
- to other parties to transactions when you make a purchase (such as our partners and your credit card provider). You may opt-out from sharing your details with a particular partner by sending an email to firstname.lastname@example.org specifying the name(s) of the partner that you do not wish to have access to your personal information. For information regarding opting out of direct marketing using your personal information see clause 8;
- to third parties, including those in the marketing and advertising sectors, to use your information in order to let you know about goods and services which may be of interest to you in accordance with the SPAM Act 2003 (Cth) and the Privacy Act;
- to third parties who help us analyse the information we collect so that we can administer, support, improve or develop our business and the services we provide to you;
- if the disclosure is required by a law, or legal process, requested by a government agency or other third parties pursuant to a subpoena, court or other legal process with which we are required to comply;
- to any other person, with your consent (express or implied); and
- to facilitate the sale of all or a substantial part of our assets or business or to companies with which we propose to merge or who propose to acquire us and their advisers.
5. How we collect and store data and transmit Personal Information
We usually collect and store information in paper, physical and electronic form provided by you in person or when you communicate with us by telephone, email, our Platforms, letter, facsimile or other means, including when:
- you contact us over the phone;
- we provide you with our services via telephone, email or our Platforms;
- we provide you with assistance or support for our products or services;
- you participate in our functions, events or activities or on our social media pages;
- you request that we provide you with information concerning our products or services;
- you upload or submit information to access a rewards program or to submit a review; or
- you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products or services.
Where practicable we will only collect information from you personally. However, we will also collect your Personal Information through our partners and third parties who supply services to us.
Please note that we use our own and third party computer servers including our Website hosts, App hosts, data backups and payment gateway(s), which may be located overseas and your Personal Information will likely be stored and transmitted Overseas as part of the normal operation of our business.
We also collect information from your computer or mobile device automatically when you browse our Platforms. This information may include:
- the date and time of your visit;
- your domain;
- operating system;
- the server your computer or mobile is using to access our Platforms;
- your browser and version number;
- search terms you have entered to find our Website or access our Platforms;
- pages and links you have accessed both on our Website and on other websites;
- the last website you visited;
- the device you use to access our App; and
- your IP Address.
While we do not use some of this information to identify you personally, we may record certain information about your use of our Website such as which pages you visit and the time and date of your visit.
It may be possible for us to identify you from information collected automatically from your visit(s) to our Website. If you have registered an account with us, we will able to identify you through your user name and password when you log into our App. Further, if you access our Platforms via links in an email we have sent you, we will be able to identify you.
The device you use to access our Platforms may collect information about you including your location using longitude and latitude co-ordinates obtained through GPS, Wi-Fi or cell site tri-angulation. For information about your ability to restrict the collection and use of such information, please use the settings available on your device.
We may use statistical analytics software tools such as Google Analytics, Firebase and Facebook Pixel and software known as cookies which transmit data Overseas. To our knowledge, Google Analytics does not identify individual users or associate your IP Address with any other data held by Google.
6. How we protect your Personal Information
We will endeavour to take all reasonable steps to keep secure and protect any Personal Information which we hold about you, including:
- securing our physical premises and digital storage media;
- using Secure Socket Layer for all data transmission;
- conducting regular security audits and penetration testing;
- placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure; and
- taking regular back-ups of our electronic systems.
Notwithstanding that we will take all reasonable steps to keep your Personal Information secure, data transmission over the internet is never guaranteed to be completely secure. We do not warrant the security of any information you transmit to us or from any online services.
8. How we use Personal Information for communicating with you and direct marketing
We may communicate with you by phone, email, SMS or push notification, to inform you about existing and new products and services that may be of interest to you.
We will ensure that any e-mail that you are sent by us as direct marketing complies with the SPAM Act 2003 (Cth) and contain an ‘unsubscribe’ option so that you can remove yourself from any further marketing communications. To opt-out of communications via SMS, reply with “STOP”. You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however this setting will prevent you from receiving other messages from us via push notification. You may also opt-out of receiving marketing materials from us using the contact details set out below.
You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavour to remove your details from our direct marketing list within 5 working days.
Our direct marketing list may be operated by software and servers located Overseas and your Personal Information may be sent Overseas as part of our marketing.
We will also send communications that are required or necessary to send to users of Platforms that contain information about important changes or developments to or the operation of our Platforms or as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.
9. Not identifying yourself
It may be impracticable to deal with you on an anonymous basis or using a pseudonym.
We may be able to provide you with limited information in the absence of your identifying yourself but generally we will be unable to provide you with any information, goods and/or services unless you have identified yourself.
10. How to access or correct your Personal Information or make an enquiry or complaint
- access would pose a serious threat to the life, health or safety of any individual;
- access would have an unreasonable impact on the privacy of others;
- the request for access is frivolous or vexatious;
- the information relates to existing or anticipated legal proceedings between you and us and the information would not otherwise be accessible by the process of discovery;
- giving access would reveal our intentions in relation to negotiations with you;
- giving access would be unlawful;
- denying access is required or authorised by or under an Australia law or a court/tribunal;
- the information relates to commercial sensitive decision making process; or
- giving access would prejudice enforcement related action.
- We may (depending on the request) charge you a fee to access the Personal Information. We will inform you of any fees payable in respect of accessing your Personal Information prior to actioning your request. All requests for Personal Information will be handled within 30 days after the request is made.
- the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing email@example.com; or writing to GPO Box 5218 Sydney NSW 2001; or
- the Privacy Commissioner in your State or Territory.
11. Definitions used in this policy
- App means the Qubix Money mobile application.
- Australian Privacy Principles or APPs means the principles set out in Schedule 1 to the Privacy Act.
- IP Address means a number automatically assigned to your computer which is required when you are using the internet and which may be able to be used to identify you.
- Overseas means United States of America.
- Personal Information has the meaning set out in the Privacy Act.
- Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time.
- Privacy Legislation means such laws as may place requirements on the handling of Personal Information under the Privacy Act and the Australian Privacy Principles.
- Platforms means our Website and / or App.
- Social Media means our social media accounts including those located on LinkedIn, Twitter [pending], Facebook, Instagram, Tik Tok [pending].[ND1]
- Third Party Sites means online websites or services that we do not own or control, including websites of our partners
- Website https://www.qubixmoney.com and/or any other website as we may operate from time to time.
- we, our, us and similar terms means Amalagam Holdings Pty Ltd ACN 643 971 439 and our related entities.
- you, your and similar terms means, as the context requires (1) you, when you use our Platforms; and/or (2) you, during your dealings with us as a customer; and/or (3) any agent providing your Personal information to us; and/or (4) any agent dealing with us on your behalf.