Hero Wallet Privacy Policy

NOTE:

This policy was superseded on 11.11.2022. It was integrated into our standard privacy policy which you can find here. 

Who are we?

‘We’, ‘us’ and ‘our’ refer to EMPLOYMENT HERO FINANCIAL SERVICES PTY LTD ABN 58 606 879 663 (Employment Hero)and/or our related  bodies corporate as defined in the Corporations Act 2001 (Cth) and listed in our current list of Affiliates available at https://employmenthero.com/uk/legals/privacy-policy/data-processing/subprocessors/.

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Our commitment to protecting your privacy

We understand how important it is to keep your personal information safe and secure. This document sets out our commitment in respect of the personal information we hold about you and what we do with that information.

Any personal information we collect will only be used for the purposes we have collected it for or as allowed under law. It is important to us that you are confident that we’ll treat your information in a way which ensures its protection.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles (APPs) and Part IIIA of the Privacy Act 1988 (Privacy Act) which regulates consumer credit reporting in Australia, and any other relevant law.

Privacy Collection Statement

This policy also includes our Privacy Collection Statement for your review and acceptance before we deal with your personal information.

The law requires us to notify you of certain things regarding the collection of your personal information.

We collect  and use your personal information from your employment record as provided by you, to prepopulate the digital application, on the mobile app. We may also collect information from you directly.

We may also collect information from third parties and share information about you for the purposes of marketing products and services to you.

We share your personal information with our payments partner Hay Ltd (Hay), to verify your identity and to enable us to monitor suspicious or fraudulent activity in relation to our services . If  Employment Hero and Hay share your information with a third party organisation it will only  be related to the provision of services to you, such as  for providing online verification of your identity and to service providers based in the US and UK who provide risk assessment and transaction monitoring (PEPs and sanctions checking).

By giving us your personal information, you agree to us collecting, using and disclosing your personal information in accordance with this Privacy Policy. We understand that the privacy of your personal information is extremely important to you.

This Privacy Policy explains how we handle your personal information (we call this “personal information” in this document) so it’s important you read it carefully.

We will need to update this Privacy Policy as we evolve but we want you to know when we change it so you can make sure you continue to be ok with how we handle your information. We will tell you about changes via the Employment Hero, Hero Wallet App.

Issue Date: 28/04/2022 V1.0

01 What personal information do we collect?

The information we may collect from you includes:

• First, middle and last names,
• residential and mailing address,
• email address,
• date of birth,
• gender,
• telephone numbers;
• details of your interactions with us;
• internet protocol address;
• location information;
• information about the type of device and operating system used by you;
• bank account details or debit card details;
• Driver Licence,
• Passport,
• Medicare number,
• any other relevant information that you give to us for the purpose of providing you with our products.

We may collect this information either directly from you or from other people. We may collect information when you:

• use the Employment Hero Hero Wallet App;
• visit the Employment Hero website;
• submit electronic forms with us;
• participate in an online chat or phone call with us; and
• otherwise correspond with us.

We may collect this information either directly from you or from other people. We may collect information when you:

• use the Employment Hero Hero Wallet App;
• visit the Employment Hero website;
• submit electronic forms with us;
• participate in an online chat or phone call with us; and
• otherwise correspond with us.

We may collect information about you, including where you are not our customer but are associated with a customer, from that customer, through fraud/ transaction monitoring systems implemented by us or from publicly available sources such as registers maintained by the Australian Securities and Investments Commission and ABN Lookup or made available by third parties.

02 Why do we collect, use and disclose your personal information?

We may collect, hold, use and disclose your personal information:

• to provide our products;
• to send service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested;
• to identify and control or minimise risks to our services;
• to enable us to monitor suspicious or fraudulent activity in relation to our services;
• to provide information to our professional advisers to help us comply with legal, accounting, or security requirements;
• where we believe it is necessary to comply with, protect or enforce our legal rights, interests and the interests of others, including in connection with legal claims or disputes, compliance, regulatory and audit functions, prevention of fraud and ensuring
• data security;
• to verify your identity
• for any purpose you have consented to at the time of collection
• as required or permitted by law
• to allow third parties to provide additional services or products to you.

You don’t have to provide the personal information we request, however if you don’t, we may not be able to provide you with the products or services you want us to provide or provide you with information about these products or services.

03 Do we use your personal information for direct marketing?

Yes. We may send you direct marketing communications in the following ways:

• Personalised Emails and push notifications – about Employment Hero products services and offers that may interest you.
• Social Media and Advertising Platforms – Employment hero may share your information, such as your name, email address and app events with social media and advertising platforms, to allow Employment Hero to advertise to you and others like you and to conduct analytics.

You can opt-out of receiving marketing from us by contacting us (see below) or by using the opt-out facility provided in Employment Hero Hero Wallet marketing emails.

04 To whom do we disclose your personal information?

We may disclose personal information for the purposes described earlier in this document to:

• Hay Ltd
• our related bodies corporates or Affiliates;
• third party suppliers and service providers in connection with providing our products and services;
• payment systems operators;
• banks or other financial institutions;
• anyone who buys our business;
• specific people who you authorise to receive information we hold;
• government agencies, regulatory bodies and law enforcement agencies, or as required or permitted by law.

05 Do we disclose personal information outside Australia?

We may disclose personal information outside of Australia to our service providers who provide risk assessment and transaction monitoring (PEP’s and sanctions checking) who are based in the United Kingdom and the United States of America. These providers include ComplyAdvantage and Twilio.

We will 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.

06 Using our website and 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.

What are cookies? 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.

07 How do we keep your information safe?

While we collect and store card data for the purpose of payments and funding. All payment card information is stored by a compliant service provider, GPS (Global Processing Services). None of this information is stored by Employment Hero.

We will hold your personal information in electronic form. We are committed to ensuring your personal information is safe and protected from accidental loss or alteration, inappropriate access, misuse or theft. We take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. As well as technical, physical and organisational controls, we recognise that a well-trained, informed and security alert workforce minimises privacy risks from human error and/or threats from malicious actors.

For example we:

• train our staff about how to keep your information safe and secure;
• have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised access to our systems;
• have building security measures in place;
• destroy and de-identify data when it is no longer required.

We require our service providers to implement appropriate industry standard security measures and only permit them to process your personal information for specific purposes in accordance with our contractual instructions.

However, we do not provide any guarantees in relation to the security of your personal  information.

08 Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

09 Accessing or correcting your information

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your information.

You can also request confirmation from us as to whether we are processing your personal information.

If you think that any information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected. You can also correct your personal information via the Employment Hero Hero Wallet App.

10 Do we disclose information to credit reporting bodies?

We do not disclose any of your information to credit reporting bodies.

11 Data retention

The period of time we keep your information will depend on the type of information we hold about you. Generally, your information will be retained while we have an ongoing relationship and for a period of 7 years afterwards, or such other period of time as required under specific legislation relating to the type of information held (for example under the Anti-Money Laundering and Terrorism-Financing Act 2006 (Cth)).

12 Making a complaint

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 using the details set out below. Please include key information about you so we can identify you and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

If you are not satisfied with how we have dealt with your complaint you can contact the Office of the Australian Information Commissioner using any of the following details:

1300 363 992

oaic.gov.au

GPO Box 5218, Sydney 2001, NSW

13 Contact us

For further information about our Privacy Policy or practices, or to access or correct your information, or make a complaint, please contact us using the details set out below:

PRIVACY OFFICER

Herowallethelp@employmenthero.com

Issued by EMPLOYMENT HERO FINANCIAL SERVICES PTY LTD

Issue Date: 28/04/2022  V1.0