Frollo is your financial companion that effortlessly automates your finances to assist in achieving your financial goals and get MORE from your money. We take your privacy seriously.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
What personal information do we collect?
We may collect the following types of personal information:
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- credit card information;
- employment details;
- information about your financial circumstances and objectives;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
- register on our website or app;
- communicate with us through correspondence, chats, email, surveys or when you share information with us from other social applications, services or websites; and/or
- interact with our Services, sites, content and advertising.
Visitors may choose to visit our website anonymously. However, refusal to provide certain personal information may prevent visitors from engaging in certain activities.
Why do we collect, use and disclose personal information?
The primary purpose is to enable you to access and use our Services. Other purposes for which we may use your personal information include:
to operate, protect, improve and optimise our Services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing; to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you; to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting; to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and/or to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
We may also disclose or license your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
You are licensing to Frollo and its service providers any information, data, passwords, materials or other content (collectively, “Content”) you provide to us or through the Services. Frollo and its service providers may use, modify, display, distribute and create new material using such Content to provide the service to you. Frollo and its service providers may also use, sell, license, reproduce, distribute and disclose aggregate, non-personally identifiable information that is derived through your use of the Services. By submitting Content, you automatically agree, or promise that the owner of such Content has expressly agreed that, without any particular time limit, and without the payment of any fees, Frollo and its service providers may use the Content for the purposes set out above. As between Frollo and its service providers, Frollo owns your confidential account information.
Frollo may use anonymous and aggregated data from our customers, and disclose this in a non-personally identifiable manner to third parties, including other users in order to provide them benchmarks for comparing themselves against the broader Frollo community.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act and may continue after you stop using the Services. You may opt-out of receiving marketing materials from us by contacting us by email (firstname.lastname@example.org) or by using the opt-out facilities provided in any communication (e.g. the unsubscribe link).
To whom do we disclose your personal information?
- our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents;
- payment systems operators (eg merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- our sponsors or promoters of any competition that we conduct via our Services;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to third party suppliers and cloud providers located in other countries.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
Web browser cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We use commercially reasonable efforts to protect your information from any unlawful access or misuse. We have implemented a technology system, applications, security operations and procedures to protect your information. This includes certified secure cloud services, firewalls, encryption and authentication protocols. We regularly re-evaluate these operations and procedures and adapt them as necessary, to deal with new challenges and emerging issues.
Third party websites
Accessing or correcting your personal information
You can access or correct the personal information we hold about you by contacting us (see the details below). Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why (for example, we may refuse to give you access to your information if giving access would have an unreasonable impact on the privacy of other individuals, if you request for access is frivolous or vexatious, or if the information relates to existing or anticipated legal proceedings). We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
You may cancel your account at any time by contacting us via email (email@example.com). Once you have requested us to cancel your account, to the extent reasonably possible, all information and credentials will be deleted from our systems, and nothing will be retained other than as required by law. However, portions of your information, consisting of aggregate data derived from your account information, may remain on our production servers indefinitely. Your data may also remain on a backup server or media. We keep these backups to ensure our continued ability to provide the Services to you in the event of malfunction or damage to our primary production servers. Please note that simply deleting the app will not give effect to termination and deletion of your information.
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us via email (firstname.lastname@example.org). Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
It is our intention to resolve your complaint to your satisfaction. However, if you feel that your complaint has not been satisfactorily addressed or that it is taking too long to resolve your complaint, you are entitled to contact the Office of the Australian Information Commissioner (OAIC), on 1300 363 992 or the other contact details on the OAIC’s website (http://www.oaic.gov.au), who may investigate your complaint further.