Privacy Policy - My Money Circle

This privacy policy (Privacy Policy) sets out how My Money Circle ® Pty Ltd ABN 30 679 974 791 trading as My Money Circle® and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)) (we, our, us) collects, stores, uses, protects, shares and discloses your personal information.

This Privacy Policy applies to our website located at www.mymoneycircle.au and its related services, websites, social media pages, tools and applications, including the My Money Circle® web application located at https://app.mymoneycircle.au (together the Website). By visiting or using the Website you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy.

1. Types of Personal Information we collect

   As part of delivering our services we may collect personal information about you as defined under the Privacy Act 1988 (Cth) (Privacy Act). We will only collect personal information where it is reasonably necessary for the performance of our functions or activities. The personal information we collect may include the following:

   • Account information: this includes information that we collect when you register to use our Website by creating an account. The information we collect includes:

     • your full name;
     • your date of birth (month and year);
     • your email address (primary and alternative (optional));
     • your phone number;
     • your company name;
     • your profile photo; and
     • other contact details and any other information you directly give us at the registration stage.

   • User information: this includes information that you have provided to us when using the Website. The information we collect includes:

     • your basic income and expenses information as inputted into the Website;
     • your assets and liabilities balances as inputted into the Website; and
     • any other additional information you provide to us directly or indirectly through your use of the Website. We use such information to assist in providing our services to you.

   • Participant information: Coaching sessions are delivered via Microsoft Teams. These sessions are audio-transcribed (not recorded) to support accurate note-taking and to generate AI-assisted session summaries. Transcripts may include personal or sensitive financial information shared during your session. Transcripts are stored securely and used solely for the purpose of delivering your coaching experience and meeting our legal obligations under financial services law.

   • Client information: this includes information that you have provided to us as a client of ours. The information we collect includes:

     • client business details;
     • client representative details (including employee names, positions and other details as required for us to provide our services);
     • details and any other additional information you provide to us directly or indirectly through your use of the Website. We use such information to assist in providing our services to you.

   • Profile information: this includes any information you choose to store on the Website that will assist us in delivering our services to you and includes information regarding any subscriptions.

   • Payment information: payments are processed on the Website through Stripe (our third party payment gateway). When processing payments, your payment information (including any other information required to process the payment) will be passed to Stripe. If you make payments on our Website, Stripe is responsible for the handling and processing of your personal information, and it is your responsibility to read and agree to the Stripe Privacy Policy (accessible here stripe.com/au/privacy).

   • Website use information: When you use our Website, for example when you contact us, we collect information that enables the Website to be able to run.

   • Marketing use information: this includes information provided to us using a marketing or newsletter sign up form.

   • Surveys: information in connection with client surveys, questionnaires and promotions.

   • Other information: we collect related to your use of the Website: your device identity and type, your browser type, I.P. address, geo-location information (country, city, state), page view statistics, network providers, activity flow (including how you visit website pages, your interactions, URL clicks, page views, button clicks and time spent on the website), advertising data and standard web log information and any other information provided by you to us via our Website or our online presence, or otherwise required by us or provided by you.

2. How we collect Personal Information

   We may collect personal information either directly from you, or from third parties, including where:

   • you register or sign up to the Website;
   • you provide information directly to us through the services or on a hardcopy form;
   • you access or use the Website generally;
   • you participate in a coaching session via Microsoft Teams, which is audio-transcribed (not recorded) using secure transcription tools;
   • you subscribe to any of our newsletters;
   • you contact us through our Website, in person, by phone or in writing;
   • you submit any of our online sign up forms;
   • you deal with us generally via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise;
   • you interact with our Website, social applications, services, content and advertising; and
   • you invest in our business or enquire as to a potential purchase of our business.

   We may also collect your personal information from third parties including:

   • clients (being your employer);
   • referral agencies;
   • government agencies and insurers;
   • third parties who produce any content, advertising, and marketing campaigns for us that you may interact with; and
   • our other service providers and publicly available sources

   Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. By providing personal information about another person to us, you represent that you are legally permitted to do so, and we will not be responsible for verifying any such authorisation.

   Cookies & data tracking technologies

   We may also collect personal information from you when you use or access our services or our social media pages. This may be done through use of web analytics tools, 'cookies' or other similar tracking technologies that allow us to track and analyse your services usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience of the service. Persistent cookies can be removed by following Internet browser help file directions. Cookies may enable automatic logins when you visit in the future and may enable content customisation.

   We may also use third party vendor tracking cookies, including:

   • Google Analytics tracking cookie; and
   • marketing tracking cookies including Active Campaign, Zoom, Calendly and Typeform.

   You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. Alternatively, you may visit the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device's settings.

   Third parties as set out above may use cookies, web beacons, and other storage technologies to collect or receive information from the service and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt out of the collection and use of information for ad targeting using aboutads.info/choices.

3. Use of your Personal Information

   We collect and use your personal information for the following purposes:

   • to operate the Website and provide services or information to you including to:
     • assist in streaming and personalising information for you;
     • enable us to process your personal data;
     • to manage our relationship with you, including information about similar services or terms and conditions or send you an email reminder that a task you have performed on our Website remains uncompleted;
     • enable you to communicate with us regarding your use of the Website;
     • confirm your identity;
     • to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the services to you;
     • communicate with you about your Account, or any transaction;
   • to administer contracts including to negotiate, execute and or manage a contract with you;
   • to be de-identified for the purposes of generating statistical data and improving the Website;
   • for record keeping and administrative purposes, including accounting purposes;
   • to administer, operate, protect, improve and optimise the website and our service offerings and customer experience;
   • to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
   • to enable you to take part in a competition;
   • to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
   • for quality, training and coaching purposes;
   • to securely transcribe and analyse your coaching sessions using artificial intelligence (AI) tools, including Microsoft Azure OpenAI, to generate a session summary and prepare a draft coaching plan. These outputs are reviewed and personalised by your coach before being shared with you. AI is used to support your coaching experience and does not provide financial advice or make decisions about your situation;
   • to send you administrative messages, reminders, technical notices, updates, security alerts, and other information about our products and services requested by you; and
   • to consider an application of employment from you.

   You acknowledge and agree that we may also deal with your personal information in any other manner which is permitted by any agreement that we have in place with you (or your employer), or otherwise in accordance with our other policies we have in place from time to time.

4. Disclosure of your Personal Information

   We may disclose your personal information to third parties for the purposes contained in this Privacy Policy, including without limitation to:

   Service Providers

   We may share your personal information with service providers utilised by us in the provision of the services to:

   • develop and improve our services;
   • provide you with the services;
   • conduct quality assurance testing;
   • provide support; and/or
   • provide other services to us.

   The service providers (and if necessary data processors) include:

   • information technology service providers such as web host providers and analytical providers;
   • mailing houses and such other suppliers that assist in delivering products and services;
   • organisations who carry out credit, fraud and other security checks;
   • payment processors;
   • hosting services;
   • content delivery services;
   • IT support providers;
   • marketing businesses engaged by us to disseminate materials to which recipients have consented; and
   • legal advisers or other professional advisers and consultants.

   Use of Artificial Intelligence (AI)

   We use secure AI technologies, including Microsoft Azure OpenAI, to support the delivery of our financial coaching services. Specifically, AI is used to:

   • Generate summaries of coaching sessions from transcripts,
   • Prepare draft coaching plans, and
   • Assist coaches in delivering personalised support.

   These outputs are always reviewed and edited by your financial coach before being shared with you. AI is never used to provide financial advice or make automated decisions about your financial situation.

   Transcripts and other data processed by AI are stored securely and are not used to train public AI models. We do not sell or share your information for advertising or unrelated purposes.

   For more information on Microsoft's data handling, please refer to:

   • Microsoft Privacy Statement
   • Azure OpenAI Data Privacy

   Affiliates and Acquisitions

   We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (Affiliates), in which case we will require our Affiliates to honour this Privacy Policy. In the event we are involved in a merger, acquisition or sale of assets we may disclose personal information collected by us to such entities that we propose to merge with or be acquired by, and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

   Third parties with your consent and in other circumstances

   We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to, or to third parties where permitted under the Privacy Act or where required in order to provide our services to you. This also includes:

   • your authorised representatives;
   • government and regulatory authorities and other similar organisations, as required or authorised by law or as required as part of the services; and
   • such entities that we propose to merge with or be acquired by.

   We may need to disclose your information to third parties outside of Australia and service providers located internationally in order to enable us to provide the services, this includes service providers and contractors who are located overseas (telephone answering service, data analytics, IT services) and data processing services.

   Where we use a supplier outside of Australia, we will take reasonable steps in the circumstances to ensure that such overseas recipient does not breach the Australian Privacy Principles (except where such steps are not required under the Privacy Act).

   Where you are an employee of a client of ours (or otherwise accessing an account granted by a client of ours) we will also provide that client with aggregated data on user content preferences and logins to report on the performance of the Website and our services from time to time.

   We may also aggregate and/or make anonymous your personal information to make it available for the purposes of generating statistical data for the conducting of research and improving the services.

   Where you leave a review of our services, or if you tag us in any of your own material (including any social media post on your personal account) you grant us a non-exclusive, royalty-free, perpetual, irrevocable and fully sub-licensable right to use, reproduce, modify, adapt, publish, translate and create derivative works from, distribute and display such content through the world in any media.

5. Emails & Marketing

   To provide the services to you, you agree to receive emails from us for the following purposes:

   • notifications about activity on the services (which are set on by default) including order updates, recommendations, and general updates;
   • communication from us or our representatives in connection with the services; and
   • marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing. This includes where you have signed up to our marketing or promotional newsletters.

   By default you will receive these email notifications to your email address you nominate at registration.

6. Storage & security

   We use third-party cloud providers that provide hosting, data storage and secure AI processing services, including Microsoft Azure OpenAI. All data is encrypted and access is restricted to authorised personnel.

   We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measure to protect these systems. However, we cannot guarantee the security of your personal information.

   We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

7. Links

   Our services may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

8. Requesting access or correcting your Personal Information

   Subject to the Privacy Act, you have a right to access and correct any personal information about you that we may hold. If you wish to request access to the personal information, we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

   If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

   If we receive a request from you to access or correct personal information we will respond to you within a reasonable time after receiving your request and in the manner requested by you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for giving access to the information.

9. If we can't collect your Personal Information

   If you do not provide us with the personal information described above, some or all of the following may happen:

   • we may not be able to provide the Website to you, either to the same standard or at all;
   • we may not be able to provide you with information about the Website that you may want; or
   • we may be unable to tailor the content of our Website to your preferences and your experience of our services may not be as enjoyable or useful.

10. Notifiable data breach

    In the event that there is a data breach and we are required to comply with the notification of eligible data breach provisions in Part IIIC of the Privacy Act or any other subsequent sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable data breach procedures in compliance with the Privacy Act and relevant laws.

11. Updates

    This Privacy Policy may be updated by us from time to time, and the updated Privacy Policy will apply from the date it is published on our website or otherwise communicated to you. Each time you use our website you should revisit this Privacy Policy and familiarise yourself with any changes. Continued use of our services (including our website) shall indicate your acceptance of any changes.

12. Enquiries, requests & complaints

    Enquiries regarding this Privacy Policy or the personal information we may hold on you, should be addressed with the Privacy Officer, whose contact details are below.

    If you think your personal information, held by us, may have been compromised in any way or you have any other privacy related complaints or issues, you should also raise the matter with the Privacy Officer.

    We will ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.

    If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission, whose contact details are below.

Office of the Australian Information Commission

Contacting us