Overview

We provide budgeting and cashflow tracking training and Virtual Moneysoft Support to Financial Professionals and their clients (Individuals) using online courses and via our Moneysoft white labelled software (https://yscprofessional.moneysoft.com.au/).

Whether you are an individual or a financial professional, we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This policy describes how we currently collect, handle, use and disclose personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

We do not need to collect sensitive information about you and we will not do so unless we are required to do so by law or unless you provide consent. Sensitive information includes information about your race or ethnicity, political opinions, religious beliefs, criminal record, sexual information, health or biometric information. We will not collect your tax file number.

We will not destroy or de-identify any personal information that is provided to us.

The personal information we collect and hold – Individuals

When you visit our website or use our services, we only collect personal information about you that you provide to us.

Individuals can only register for our services via an invitation from a Financial Professional. When you register, we ask you for your first and last name and email address.

You do not have to give us your real first and last name; you can choose to remain anonymous by giving us a pseudonym (you will remain anonymous unless of course identity information such as your name is in your email address or is in your financial information).

The personal information we collect and hold – Financial Professionals

When Financial Professionals register for our services we also ask for your business name, phone number, business address, ABN or ACN.

How we collect your personal information

Generally, we collect your personal information by the following means:

Directly from you, Individuals and Financial Professionals may provide us with their personal information in a number of ways including:

If you subscribe to our email list, or when registering for our online course (Your Spending Coach) or virtual Moneysoft support services (e.g. if a Financial Professional asks us to prepare and manage Moneysoft on behalf of their Individual clients). Although we do not intend to collect personal information from an individual’s financial accounts, it is possible that in some circumstances, financial account information may contain personal information.

Anonymity

When individuals register for our services, you do not have to give us your real name. You do have to give us a valid email address in order to register for our services. Provided you are not reasonably identifiable from your email address (or any other information we collect), you can remain anonymous.

Although financial professionals are not required to give us a real name, you have to give us your company name and ABN or ACN, and email address and so you cannot remain wholly anonymous.

The purposes for which we collect, hold and use and disclose your personal information

The main purposes for which we collect, hold, use and disclose your personal information are:

  • To provide you with information about our products or services;
  • To consider your request for our products or services;
  • To provide you with access to our products or services;
  • To provide information to people who an individual has authorised to receive that information (e.g. an Individual client of a Financial Professional);
  • Our arrangements with other organisations to perform administrative and operational tasks including management of any Individuals Moneysoft account and;

As required by relevant laws, regulations and codes.

We also use your information to manage your ongoing requirements and our relationship with you. We will generally communicate with you electronically, unless you tell us that you do not wish to receive electronic communications.

Who we may disclose your personal information to

Other than the following, we do not sell, license or redistribute your personal information to others. We may disclose your personal information to:

  • Our related bodies corporate;
  • People an Individual has authorised to receive that information (such as a financial professional and our outsourced service providers);
  • Our outsourced service providers (e.g., TOA Global who provide us with team members to manage all Moneysoft work);
  • Participants in the payments system to process your payments (including payment organisations and merchants);
  • Others if we are required to do so by law or under other circumstances permitted by the Privacy Act.

Aggregated information

Aggregated information only contains anonymised personal account information or data; i.e. it does not contain information that could be used to identify an individual. Examples of aggregated information might include the number of people who use our services and the type of accounts and number of accounts in use with our services.

We may use, redistribute and disclose non-sensitive, non-personal, aggregated information obtained in relation to our services to third parties such as other users of the service who want to compare their information to the community of users.

Overseas disclosure

Some of our outsourced service providers are located overseas. We use the following providers:

TOA Global – who provide us with support staff for the purpose of managing Individuals and Financial Professionals Moneysoft accounts.  TOA Global are located in the Philippines. TOA Global has offices in the Philippines and Australia.  TOA Global’s Privacy Policy can be read here

Dropbox – who provide us with document storage.  Dropbox are located in the United States of America and their Privacy Policy can be read here

We do not intentionally disclose personal information to an overseas service provider, but it may happen if personal information is in an individual’s name and email address they use to subscribe to our service, or in an account name or transaction records or account access information.

In the future we may use other service providers that are located outside of Australia. We will update our Privacy Policy if we do so. If they are not regulated by laws which protect your information in a way that is similar to the Privacy Act, we will seek your consent before disclosing your information to them.

How we hold and protect personal information

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal reporting or document retention requirements.

We hold the personal information we collect in physical and electronic records. We maintain physical, electronic and procedural safeguards to guard it.

How long we keep information for

Individuals and Financial Professionals can delete their personal information at any time. Simply contact us via email and we will remove any information we have from our database. Once information is deleted, this action cannot be reversed, as the information is erased.

We may keep aggregated information that does not contain personal information. More information about this is given above.

Notifiable Data Breaches

Your Spending Coach complies with the requirements of the Privacy Amendment (Notifiable Data Breaches) Act 2017. In accordance with this Act, where we are aware of any instance of a data breach, we shall immediately take steps to contain and remediate the data breach as well as undertake a reasonable and expeditious assessment to determine if the data breach is likely to result in serious harm to any individual affected.

Where the assessment presents reasonable grounds to believe an eligible data breach has occurred, we will promptly notify individuals at likely risk of serious harm. The Commissioner shall also be notified as soon as practicable through a statement about the eligible data breach.

The notification to affected individuals and the Commissioner shall include the following information:

  • The identity and contact details of the organisation
  • A description of the data breach
  • The kinds of information concerned
  • Recommendations about the steps individuals should take in response to the data breach

A full review will be conducted to evaluate the cause of the data breach, the success of our response and to identify and implement improvements to prevent or minimise the risk of future data breaches.

Web and mobile data

We use technology to collect anonymous information about the use of our website and mobile app, for example when you browse our website, our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes, to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.

We use “cookies” to collect this anonymous data. Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it, they allow the website to recognise your computer when you return in the future.

Services offered by third parties

If you provide your information to third parties (such as by registering for services offered by a third party), then our Privacy Policy will not apply to how that third party manages your personal information. You should read that third party’s privacy policy.

Access and correction

If you can show that that the personal information we hold about you is not complete and up to date, we will take reasonable steps to ensure it is accurate, complete and up to date.

If you wish to access or correct your personal information please write to:

The Privacy Manager

Experience Wealth Pty Ltd t/as Your Spending Coach

Suite 311, Level 3 / 120 Bay St

Port Melbourne VIC 3207

Alternatively, please email us at moneycoaches@experiencewealth.com.au or phone us on 03 9646 5252 (in Australia).

We do not charge for receiving a request for access to personal information or for complying with a correction request.

Complaints

If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us.

We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.

We aim to resolve complaints as quickly as possible. We strive to resolve complaints within five business days but some complaints take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.

If you are unhappy with our response, there are other bodies you can go to.

The Financial Ombudsman Service (FOS) can consider most privacy complaints involving providers of financial services.

FOS can be contacted at:
Financial Ombudsman Service
GPO Box 3 Melbourne VIC 3001
Phone: 1300 78 08 08
www.fos.org.au

Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information.

The Commissioner can be contacted at:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au

Updating our Privacy Policy

We may update this Privacy Policy at any time by publishing it on our website.

Tell us what you think

We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact the Privacy Manager at the contact details given above.

 Meaning of words

“We”, “Us” or “Our”

means Experience Wealth Pty Ltd ABN 95 132 046 354  trading as Your Spending Coach.

“Data”

means any data inputted by You or with Your authority into the Website.

“Virtual Moneysoft Support”

means the provision of outsourced Moneysoft ongoing personal financial (spending, savings, budgeting and cashflow) coaching (as may be changed or updated from time to time by Us) made available to You by Us

“Moneysoft”

means Moneysoft Pty Limited ABN 86 152 058 627.  For more information on how Moneysoft uses your data please visit the Moneysoft privacy policy available on their website.

“You”

means the Individual or Financial Professional and where the context permits “Your” has a corresponding meaning.