Privacy - Flamingo

Flamingo Privacy Policy

At Flamingo Tech (hereafter referred to as “Flamingo”/“we”/“our”/“us”), we are committed to safeguarding your privacy, and herein, we want to make sure that this Privacy Policy (“Policy”) is easily understandable for our Users. We hope you read through the Policy thoroughly enough and learn how we serve you.

Definitions

“Flamingo” (hereafter referred to as “Flamingo”/”our Platform”/”the Platform”/”the App”/ “our Product”) means our financial management platform or app;
“Flamingo Registration Information” means your full name, email address, and your password for Flamingo account;
“You” or “Your” means the individual who uses Flamingo;
“User(s)/Consumer(s)” means the registered user for Flamingo, and, where applicable, also includes any entity on whose behalf that person registers to use Flamingo;
“Data” means any data provided by you or with your authority into the App, or data obtained via your authorization (including transaction information);
“Personal Information” means information about a specific individual or an individual who is reasonably identifiable. This information may include a User’s name, signature, address, telephone number, date of birth, email address, bank account details, and employment details;
“Account Credentials” means the combination of access code, access number, user token, client number, email address, password, secondary password, and/or security number/code (as applicable) associated with the online banking services offered by your bank or other financial institution in respect of your Bank Account;
“Account Information” means day-to-day transactional information (including all debit and credit operations) in respect of your Bank Account;
“Bank Account” means a deposit or loan account that you maintain with an Australian bank or another Australian financial institution;
“Mobile Device” means a mobile phone, tablet, or another internet-enabled device that is compatible with Flamingo and has access to an internet connection; and
The words “including,” “concerning,” “for example,” “such as,” and similar terms or expressions are not words of limitation.

Introduction

This Policy highlights our privacy practices and how we may collect and use the information acquired on our digital Platform. By using our Platform or voluntarily providing personal information to us, you accept the terms and conditions of this Policy. This Policy applies to information collected by our Platform and provides answers to the following questions:

What information do we collect?
How do we collect your information?
How do we use your information?
How long do we keep your information?
When do we disclose your information?
How can you access, update, or correct your information?
When do we refuse your request to access Personal Information?
What are your Privacy Rights as a User of our Platform?
What is your responsibility as the User?
How can you make a privacy complaint?
Contact Us
Disclaimer

The privacy and security of our Users is of utmost importance to us. We value the trust you put in us by sharing your personal information, and we want to reciprocate that by adequately protecting your information. It is important to us that you understand the steps we have taken to maintain that trust and secure your information.

What information do we collect?

We collect your personal and financial information during your registration process and as you engage with different features on our Platform.

Personal information collected during registration includes:

your email address;
your first name, and
your last name
Annual income

Information collected when you attach your bank account with our Platform:

Account Credentials – this includes account information from all bank accounts that you provide account credentials for and is necessary to unlock advanced features of the Platform.

Other information: Due to the nature of Flamingo, we may collect and hold additional Personal Information or other information about you. We may also secure share this information with a third party if required or necessary and can include but is not limited to:

your date of birth, address, and contact details;
information about your financial situation, health, and goals, including your assets, liabilities, income, expenditure, taxation information, insurance, and superannuation;
the Data you send and receive by using Flamingo, as well as the type and quality of that Data;
your GPS location;
the dates on which and the times at which you use Flamingo, including the duration of such use;
the type of operating system and/or other software or firmware used by your Mobile Device;
the IP address and the MAC address of your Mobile Device.

Tax File Number

Your tax file number is only collected, held, used, and disclosed in accordance with the Privacy Act 1988 (Cth), the Privacy (Tax File Number) Rule 2015, the Tax Administration Act 1953 (Cth), and any other applicable laws (as amended from time to time). Still abiding by the laws, we will take reasonable steps to ensure that you are informed when:

a taxation law or other applicable law authorizes us to request or collect your tax file number;
the purpose(s) for which your tax file number is requested and collected; and
the consequences of declining to provide your tax file number.

How do we collect your information?

We may collect your information in some or all of these ways depending upon your usage of our Platform:

We collect information directly from the user:

at the time of registering with Flamingo;
at the time of using Flamingo;
at the time of participation in contests, giveaways, and other promotions via the Platform;
when you participate in one of our surveys;
when you contact us with a query;
when you synchronize your Bank Account with Flamingo;
when you authorize third parties to disclose your information to us;
from publicly available sources of information; and
when we are authorised or required by law to do so.

Please note that while you have the right not to divulge your information to us, certain features of our App will not be available to you if you do so. However, where possible and lawful, we will give you the option to interact with us anonymously or using a pseudonym and choose to provide or decline the request for certain information.

How do we use your information?

Our primary reason to collect your information is, of course, to provide our App to you, which may include:

sharing our Product information with you;
helping you enjoy our Platform to the fullest; and
personalizing the experience for you.

Additionally, we also collect, save, use, and disclose your information to fulfill other parts of our business activities which you allow us to collect, save, use and disclose for the purposes described in the Policy, including:

to verify your identity for access and control of your Flamingo account;
to carry out our business operations and activities smoothly and uninterrupted;
to offer more advanced or upcoming features to you based on your interests and history;
to communicate with you via email alerts sharing your Account Information, a summary of your activities, and periodic Flamingo newsletters;
to provide Product updates and support;
to conduct research, analysis, and surveys;
to understand User behavior and improve and further develop our Platform;
to comply with legal, statutory and regulatory requirements;
for similar purposes where it would make sense for us to collect, save, use, and disclose your information within reasonable boundaries; and
for any other purposes where, with your consent, we may need to communicate with you and share notifications from time to time.

We may also use your information to market and promote our Product to you and, based on your consent, allow our business partners to market and promote their products to you, which we find will be of interest to you. These activities will primarily be done using your email address unless you choose to opt-out following the “Unsubscribe” instructions shared with you in email communication.

How long do we keep your information?

We keep your information for as long as you want to keep using our Platform and/or keep getting our Product alerts. You can choose to discontinue using our Platform anytime and remove your Data from our database. With such a request, your Data will be permanently erased from our database, and our Platform will no longer be available to you.

However, a portion of your information will still remain in our aggregate data derived from your Account Information as well as our R&D activity. Your information may also remain within our backup servers for an indefinite period. We keep this Data backup to ensure continuity of our operations in the event of a malfunction or disruption of our primary servers.

When do we disclose your information?

We may disclose your information, as required, with:

our related bodies corporate, business partners, and affiliates;
third-parties, including our vendors and service providers that help us offer our Platform to you, which may include sending emails to you on our behalf or hosting and operatic specific features of Flamingo;
any bodies that are authorized by law to obtain your information from us.
in the event that part or all of Flamingo Tech is purchased, sold, or otherwise transferred, or is in the process of such a transaction where it will be necessary to share user information for evaluation purposes, and it will be a part of transferred business assets.

Please note that we may also disclose your personal information to our overseas partners, vendors, and service providers for administrative purposes, data storage, and research and development purposes.

The locations where we store and process your Data may change at any point in time as our business needs change, our operations expand, and/or if we engage new service providers in the future.

However, you can rest assured that before disclosing your personal information to overseas parties, we will take every possible step to ensure that:

your privacy and security will not be breached;
the overseas party will comply with the Privacy Laws; and/or
the overseas party will be bound by law or a binding scheme to protect your information in a manner that is overall substantially similar to what you have consented to in this Policy.

Please note that whenever we disclose your information to these entities, it is done so based on our security and privacy practices. These entities:

are bound by confidentiality obligations to observe security requirements;
are bound by our contract only to use your information for the purposes of the information was shared with them, and not use it in any other way;
may face disciplinary action, termination of the contract, and/or legal proceedings upon failure to follow the obligations.

We may also mask your information so you cannot be identified when disclosing your information to several other entities, including:

advertisers and agencies for their commercial, marketing, promotional, and research purposes;
approved organizations that conduct consumer research into money consumption habits; and
other flamingo Users to help them make money decisions by comparing their personal financial situation with Users falling in the same category and broader community.

Our masking practices involve:

removing personal identifiers; and
removing or altering any information that may result in your identification.

How can you access, update, or correct your information?

If your personal information changes in any way, you can always update the details via the App or contact the Flamingo team at [email protected].

In the event that you want to access or make corrections to your information stored with us, you may contact us at [email protected].

We may charge you a nominal administrative fee for granting access to your saved information upon such a request.

When do we refuse your request to access Personal Information?

We will not accept your request to access your information in the below mentioned incidents in light of the rules set out by the Australian Privacy Principles:

if granting you access may result in an impact on the privacy of other individuals;
if you approach us with an unreasonable request regarding changes in your information; and
if the information you want to access relates to an ongoing or anticipated legal action.

However, we will send you a written explanation highlighting the reason(s) behind our refusal if we decline your request to access, update or correct your information as mentioned above or any other reasons.

What are your Privacy Rights as a User of our Platform?

Here is a summary of your principal rights under Privacy Laws:

to request to get the details of the information, we have on you at any time;
the right to access your personal information and expect a response within 30 days of making the request;
the right to make corrections to your personal information;
the right to remove your information from our database (where we have no legitimate business or legal requirement to keep and/or process your personal information);
the right to approach a supervisory authority with a complaint against us; and
the right to withdraw your consent regarding the use of your personal information (where we have no legitimate business or legal requirement to keep and/or process your personal information).

As mentioned above, this is just a summary of your Consumer Privacy Rights. We have not included all the details here because of their complex or lengthy nature.

If you seek a full explanation of your rights, you can go through the relevant laws and regulations and seek guidance from the concerned regulatory authorities.

What is your responsibility as the User?

As a consumer of any service, it is both your right and responsibility to know the contract details you are getting into. We would recommend you to:

read the Australian Privacy Laws and Regulations; and
go over our Policy and keep a record (a screenshot) of this policy as of the time of your registration as a reference to our privacy contract details. It is also our recommendation to check this page every few months to catch up on any updates or changes to the policy.

How can you make a privacy complaint?

If you wish to approach us with a privacy complaint on account of negligence on our part or if you feel that we are not fully complying with the Australian Privacy Principles, you may contact us at [email protected]. We will try our best to rectify your concerns in a prompt manner within an estimated timeframe of which we will notify you.

We are committed to resolving your complaints. However, if you are still unsatisfied with our explanation or feel that your complaint has not been thoroughly addressed or the response is taking too long, you are entitled to approach the Office of the Australian Information Commissioner (OAIC) for further investigation into your complaint.

You can get the contact details for the office on the OAIC’s website (oaic.gov.au)

Contact Us

If you have any other questions, comments, concerns, or feedback to share, please do so at [email protected]. We will get back to you as soon as possible.

Disclaimer

Our privacy policy may change from time to time on account of technological updates, legislative changes, operational changes at our end, and to keep our privacy policy-relevant in today’s dynamic environment. You can always view the latest updates on this page or via the App.