1. Our Commitment to You
At Vivi Money Pty Ltd (“Vivi Money,” “Vivi”, “we,” “our,” or “us”), we are committed to protecting
your privacy and ensuring that your information is handled with care.
This privacy policy explains what personal data we collect, why we collect it and
how we protect it. By using our service, you agree to our Privacy Policy.
2. Important Definitions
2.1 Personal Information
Personal Information means any information that identifies or relates to a
particular individual (often referred to as “personally identifiable information”
or “PII”).
Data that has been anonymised or de-identified and cannot be linked with an
individual is not considered Personal Information.
2.2 Service
"Service" or “Product” refers to any website, mobile app, or similar interface
provided to the customer by Vivi Money.
2.3 Service Providers
“Service Providers” help us run our business and provide our products and
services to you. They may include hosting, analytics, database, and
communication providers, as well as security consultants who help us reduce
security vulnerabilities in our software.
2.4 Consumer Data Right
Consumer Data Right (”CDR”, “Open Banking”) is a government-regulated
system that lets you safely share your banking and energy data with trusted
entities like Vivi Money.
Organisations must go through a rigorous vetting process to provide CDR
services to you. The Australian Competition and Consumer Commission (ACCC)
manages this process. CDR is opt-in and you control who can access your CDR
Data and how it is used. More information on CDR can be found here.
Vivi Money is a vetted CDR Representative. We partner with Basiq, an
Accredited Data Recipient, to provide you with secure access to your financial
information under the CDR framework. You can read Basiq's privacy policy
here.
3. Information We Collect and Why
Our guiding principle is to only collect the information we need to provide you
with our Services.
To provide you Services to organise and build your wealth, we collect financial
information, including account information, transactional histories, account
numbers, and balances/limits, as well as general identity data such as your
name, email, phone number and addresses.
We may also collect statistically aggregated information about how both
unregistered and registered users collectively use our Services.
4. How We Use Personal Information
Our use of your personal information will always have a lawful basis, either
because you have consented to our use of your personal information or because
it is reasonably necessary to provide our services and undertake our activities.
We may use your personal information for the following purposes:
To provide products or services you’ve requested. This includes operating
and maintaining the Service, providing customer support, fixing
malfunctions, testing our security systems, and displaying information
regarding your financial accounts.
To enhance and develop the Service: We use your information to create
new features or functions, refine the user experience, and improve the
Service's technical performance.
To communicate with you, and to personalise your experience: We use
your contact information to provide Service notifications and personalise
your experience.
Where we provide personalised services, we may analyse the information
you supply, as well as your activity on our services, so that we can offer a
more relevant, tailored experience.
For direct marketing. If you do not wish to receive such marketing from
us, you can write to us at any time.
For legal compliance purposes.
Carrying out advertising, marketing and educative training or
promotional activities.
To detect and investigate fraud and other unlawful activities.
To provide subscription services which you have consented to receiving
including emails and newsletters.
Helping you identify products or services which may be appropriate for
you.
Referring you to product and service providers.
In connection with a corporate transaction such as a divestiture, merger,
consolidation, or asset sale, or in the unlikely event of bankruptcy.
5. Sharing and Disclosure of Your Personal Information
We do not sell your information or use it for a purpose other than stated in this
policy unless you expressly consent or direct us to do so.
We may also disclose your information to law enforcement, government
officials, or other third parties if required by law or if we believe in good faith
that the disclosure is necessary to prevent physical harm or financial loss, to
report suspected illegal activity, or to investigate violations of our Terms of
Service.
We may also access, hold and use aggregated information about the people that
use our services. Aggregated information won’t identify you or any other
individual but simply provides us with non-personally identifiable data that we’ll
use to improve our services, understand our users’ needs and develop tailored
content. We may disclose this aggregate information to third parties for
purposes including research and publishing statistics related to our business.
Although you would have provided us with the information we aggregate for
these purposes, it won’t identify you or enable you to be personally identified.
6. How We Secure Your Information
Your information is protected by security measures including data encryption,
firewalls, secure coding practices, multi-factor authentication, certified hosting
infrastructure and information access controls.
If you believe your information has been compromised, please contact us
through the Vivi Money app.
7. Location of Data
The infrastructure that powers our Services is primarily located in Australia. We
vet Service Providers to validate that they adhere to our strict security and
privacy standards.
8. Corrections and Access
We aim to ensure personal information is accurate, up-to-date and complete.
Please ensure that you provide us with accurate information.
You have the right to ask for access to personal information that we hold about
you and ask that we correct that personal information. Following your access
request, we must give you access to your personal information and we must
take steps to correct it if we consider it is incorrect, unless we are prevented
from doing so under a relevant law.
We will require you to verify your identity before we give you access to your
information or correct it. If we refuse to give you access, or correct it, we must
notify you in writing of the reasons.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will
always be available on our website. We encourage you to review this policy
periodically to stay informed about how we manage your personal information.
10. Contact Us
If you have any questions, comments, or concerns about this privacy policy,
your data, or your rights with respect to your information, please get in touch
through the app or via our website.
If you need additional information about the Australian Privacy Principles, the
Privacy Law or our obligations you can also access the website of The Office of
the Australian Information Commissioner (https://www.oaic.gov.au/).