Mogo Holdings Pty Ltd (“Mogo”, “we”, “us” or “our”) provide data, analytics and insight solutions to organisations to make more informed decisions about their current or potential customers in real time. Upon receiving the customer’s consent to do so, Mogo captures unstructured customer data from the customer’s bank accounts, analyses it and shares it with the organisation (the Service). No bank account log in information (including passwords) are kept by Mogo beyond the point of accessing the account for data capture.
Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and any related privacy codes. Where we are an accredited data recipient for the purposes of the Consumer Data Right (CDR), then the applicable privacy safeguards in respect of CDR data may apply instead to that data. You can find a copy of our CDR data management policy on our website.
This Policy outlines how we collect, use, disclose and store your personal information and lets you know how you can access that information. This Policy applies to our obligations when handling information in Australia.
Please read this Policy carefully and contact us using the details below if you have questions:
Our postal contact details are:
11 York Street
If you continue using our services, then we will treat your use as your consent to us handling your personal information in accordance with this Policy.
3. INFORMATION WE MAY COLLECT FROM YOU
The type of personal information we collect depends on the circumstances of its collection and the nature of your dealings with us. We may collect and process your name, date of birth, address, your business name or the organisation you work for, information contained in any communications between you and us as well as financial information such as the details of your bank accounts including balances and transaction information that you authorise financial services organisation to provide to us through your use of the Service.
You are under no obligation to provide any such information. However, if you should choose to withhold such information, we may not be able to provide you or your chosen or proposed financial services organisation with the Service.
We also collect other information including the type of internet browser or mobile device you use, any website from which you have come to the website, your IP address, your operating system and information gathered through internet cookies, which are automatically recognised by our web server.
We do not collect any special categories of personal data about you, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or information about your health (except to the extent that this type of information can be derived from your financial information). In the unlikely event that we do collect sensitive information, we will not specifically use it as part of the Services but if you allow us (for example, for accessibility purposes), we may use it to enable you to use our platform.
4. USES MADE OF YOUR INFORMATION
We use your personal information in order to provide the Service to you or to your chosen or proposed organisation.
Some ways we use your personal information are:
(a) for the purpose for which the personal information was originally collected, including for the provision of our Services;
(b) to identify and interact with you;
(c) to perform administrative and operational functions;
(d) to comply with any legal or regulatory requirements, including any purpose authorised or required by an Australian law, court or tribunal; and
(e) for any other purpose for which you give your consent.
In relation to the personal information of contractors or prospective staff members, we collect personal information for purposes including to:
(a) enable us to carry out our recruitment functions;
(b) correspond with you;
(c) fulfil the terms of any contractual relationship; and
(d) ensure that you can perform your duties.
5. HOW WE COLLECT YOUR PERSONAL INFORMATION?
You give it to us
We collect personal information directly from you when you:
(a) use the Services;
(b) apply for a product or service with any organisation with which we have a relationship to provide our Services;
(c) interact or share personal information with us via our platform and social media;
(d) communicate with us directly.
We collect it
We may also collect your personal information from third parties including your established financial service providers.
We will generally obtain consent from the owner of personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct.
We endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.
6. INFORMATION SHARING
We may disclose statistics about users of the Service and the website to prospective partners, customers and other reputable third parties, but these statistics will include no personally identifiable information.
We may disclose your personal information to any of our affiliates, service providers, or to our agents or sub-contractors who assist us in providing the Services and the website. All such third parties will only use your personal information to the extent necessary to perform their functions and will be required by us to implement measures to protect your personal information.
In the event that we undergo a reorganisation or are sold to a third party, you agree that any personal information that we hold about you may be transferred to that reorganised entity or third party.
We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Services or our website.
We do not send information to third parties that are located outside of Australia except as it may relate to the provision of the Services to you (including to recipients in the United Kingdom), or to your current or proposed financial services provider.
7. USING YOUR PERSONAL INFORMATION FOR DIRECT MARKETING
From time to time, we may use your personal information to contact you to promote and market our products and Services.
You can opt-out from being contacted for direct marketing purposes by contacting us at support-AU@mogoplus.com or by using the unsubscribe facility included in the direct marketing communication. Once we receive a request to opt-out from receiving marketing information, we will stop sending such information within a reasonable amount of time.
We do not as a matter of course market directly to the end users, customers or potential customers of the organisations we provide Services to.
8. STORAGE OF YOUR PERSONAL INFORMATION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We destroy or de-identify personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.
No bank account login information (including passwords) are kept by Mogo beyond the moment of accessing the accounts consented for data capture. Once the data capture is complete, we exit the individual’s accounts and no further log in information is kept.
9. SECURITY OF YOUR PERSONAL INFORMATION
We have security measures in place to help us protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information.
We have put in place procedures to deal with any suspected personal data breach and will notify you where we are legally required to do so.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit from a financial institution whilst it is in transit over the internet and any such submission is at your own risk.
If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details set out in this Policy. We take privacy complaints seriously. If you make a complaint, we will respond within a reasonable timeframe to acknowledge your complaint. We will try to resolve your complaint within 14 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint. We will then investigate your complaint and write to you to explain our decision as soon as practicable.
If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at www.oaic.gov.au.
If you wish to exercise any of these rights, you should send an email to support-AU@mogoplus.com.
We may, from time to time, amend this Policy. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our website. By continuing to use the services following any changes, you will be deemed to have agreed to such changes.
Last Updated: 26 May 2021