This is the privacy policy for MOMA Technologies Pty Ltd (ACN 657 360 113) (UBOMI, we, our, us). We respect your right to privacy and are committed to safeguarding the privacy of our customers and website visitors.

We are or will be bound by the Privacy Act 1988 (Cth) (Privacy Act), which sets out a number of principles concerning the privacy of individuals and businesses.

The purpose of this Privacy Policy is to tell you what kinds of personal information we may gather or hold about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of that information, your ability to access or correct that information and how you may complain should you believe we have breached our privacy obligations.

Please read this Privacy Policy carefully. Please contact us if you have any questions – our contact details are at the end of this Privacy Policy.

By providing us with your personal information, you indicate to us that you have had sufficient opportunity to access this Privacy Policy and that you have read and accepted it. If you do not wish to provide personal information to us, then you do not have to do so. However, it may affect our ability to provide services to you.

• Collection of Personal information 

We will, from time to time, receive and store personal information you enter onto our website and our UBOMI mobile financial wellness software application (the “App”), provide to us directly or give to us in other forms.

What is personal information?
“Personal information” is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. “Credit related information” is a subset of personal information related to your creditworthiness.

What kinds of personal information do we collect and hold?
The personal information we may collect and hold varies and is dependent on the nature of our dealings with you. The kinds of personal information can include but is not limited to:

1. name;
2. contact details, including residential address, postal address, telephone number and email address;
3. Photographic Identification – including numbers and expiry dates;
4. information about your use of our products or services, or those of our related entities;
5. any information you voluntarily provide through the use of our budgeting services;
6. information about your shopping/advertising preferences;
7. financial information, including assets, liabilities, income, expenditure and employment;
8. payment information, including bank account details and credit/debit card details;
9. preferences and opinions that you provide in response to surveys commissioned by us; and
10. information about your use of our website and App.

The credit related information we may collect and hold varies. Information can include but is not limited to:

1. details of credit (including the name of each relevant credit provider) that you have applied for, the type and amount of that credit and the fact that a credit provider, mortgage insurer or trade insurer has sought information about you from a credit reporting body (“CRB”) in relation to an application;
2. credit liability information, being details of credit that you have or had including the credit provider, the type of credit, the day on which it was entered into, terms or conditions that relate to the repayment of the amount of credit, the maximum amount of credit available and the day on which the credit is terminated or otherwise ceases;
3. default information, which includes details of payments (over $150) more than 60 days overdue in relation to credit which you, as a borrower, have failed to make;
4. payment information, which includes details of the date on which you have paid overdue amounts that were previously recorded as default information with a CRB;
5. whether in another credit provider’s opinion you have committed a serious credit infringement;
6. new arrangement information which includes a statement that the terms or conditions of your credit (in relation to which default information or a serious credit infringement has been disclosed to a CRB) have been varied or that you have been provided with new credit;
7. court proceedings information, which includes information about a judgement against you in proceedings that relate to any credit that has been provided to, or applied for, by you;
8. personal insolvency information, which includes information about any procedures under the Bankruptcy Act which relate to you;
9. certain publically available information;
10. scores and other information relating to your credit worthiness which is derived by CRBs wholly or partly on the basis of the information above; and
11. certain administrative information, such as account numbers.

In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you with our product.

How do we collect your personal information?
Generally, when providing services to our customers, we collect personal information directly from the individuals where reasonable and practical.

We collect personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website or App and when we provide our services to you.

We may receive personal information from third parties, such as services that, with your consent, provide us with banking and other information, your financial institution, publicly available sources of information and our related companies and credit reporting bodies. If we do, we will protect it as set out in this Privacy Policy. We will only collect your personal information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.

• Use of personal information 

We may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.

We collect, hold and use personal information about you:

1. to identify you, conduct customer identification procedures required by law and to communicate with you;
2. to assess your eligibility to obtain our products;
3. for internal record-keeping;
4. to manage the provision of credit;
5. for providing app services including but not limited to, budgeting, deals and discounts;
6. to analyse customer needs, develop customer strategies and improve customer experiences;
7. for our market research and business development activities;
8. for marketing, including direct marketing;
9. to protect you and us from fraud;
10. to run competitions or offer additional benefits to you;
11. to comply with the our legal obligations; and
12. to respond to any queries or complaints you may have.

We may use credit related information that we collect and hold for the purpose of:

1. deriving scores or ratings summarising your credit risk, which we may use as a factor in determining whether you are eligible for any credit product that we offer;
2. establishing and managing our relationship with you;
3. exercising our rights and obligations;
4. performing any administrative operations;
5. collecting payments and other enforcement activities;
6. to participate in the credit reporting system and provide information to a CRB as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code;
7. to meet legal and regulatory requirements;
8. to protect you and us from fraud; and
9. to respond to any queries or complaints you may have.

Some credit related information may only be used or disclosed under the Privacy Act for some of these purposes or in some circumstances.
We may contact you by a variety of measures including, but not limited to telephone, email, SMS, notifications or social media.

• Disclosure of personal information

We may disclose your personal information insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

We may disclose your personal information to:

1. the persons or entities from whom you are purchasing goods or services;
2. other companies related to us;
3. credit reporting bodies and other credit providers, as required by law;
4. third party debt consolidation companies;
5. retailers?
6. Lender?
7. external service providers who assist us in providing products and services to customers;
8. professional service providers and advisors who perform functions on our behalf, such as lawyers;
9. government, regulatory authorities and other organisations as required or authorised by law; and
10. financial institutions for payment processing.

Organisations providing professional services to us are required to keep those dealings and personal information provided by us as confidential unless required to disclose such information by statute or law.

In the case of contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.

By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

• Disclosure to credit reporting bodies

We may disclose certain information about you to credit reporting bodies (CRBs). This information may include credit information and credit eligibility information such as your repayment information or default information. We may disclose that information for the purposes of notifying CRBs or other credit providers of a default by you, ascertaining the status of credit provided to you by us where you are in default with other credit providers, assessing your credit worthiness, credit standing or credit capacity and responding to any queries or complaints you may have. For example, if you fail to meet payment obligations we may disclose this default information about you to a CRB. The CRB may include such information in reports provided to credit providers to assist them in assessing your credit worthiness.
We disclose information to, and may collect information from, the following CRBs:

You have the right to request that the above CRBs do not:

1. Use credit reporting information for the purposes of pre-screening of direct marketing by a credit provider; or
2. Use or disclose credit reporting information if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.

If you would like more information about how the above CRBs manage credit related information you can contact them directly.

If you would like to access or change credit information that we hold about you or have any complaints please contact us in the same way that you would access, change or make a complaint about the other personal information that we hold about you.

• Sensitive information

The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual.

• Holding your personal information

Information that we collect may from time to time may be stored, processed in or transferred between parties located in countries outside of Australia. In the event of this, you will be notified via email.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

• Communication and direct marketing

We may communicate with you by phone, email, SMS or push notification, to inform you about existing and new products and services that may be of interest to you.

We will ensure that any email we send as direct marketing complies with the SPAM Act 2003 (Cth) and contain an ‘unsubscribe’ option so that you can remove yourself from any further marketing communications. To opt-out of communications via SMS, reply with “STOP”. You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however this setting will prevent you from receiving other messages from us via push notification. You may also opt-out of receiving marketing materials from us using the contact details set out below.

You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavour to remove your details from our direct marketing list within a reasonable time (ordinarily 5 working days).

Our direct marketing list may be operated by software and servers located overseas and your Personal Information may be sent overseas as part of our marketing

We will also send communications that are required or necessary to send to users of our Website or App that contain information about important changes or developments to or the operation of the Website or App or as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.

• Overseas disclosure

We may disclose your personal information to our third party service providers for them to help us provide services to you. Our third party service providers may store or access your personal information overseas.

• Retaining personal information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for or as required by law.

We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.

• Use of government related identifiers

We will not use government related identifiers (such as driver’s licence numbers) as our own identifier of individuals. We will only use or disclose such identifiers in the circumstances permitted by the Privacy Act.

• Security of your personal information

We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Our servers have SSL certificates, so all data transferred electronically between you and us is encrypted.

• Access to your personal information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. A small administrative fee may be payable for the provision of information, to cover our reasonable costs of retrieving that information.

If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at hello@ubomi.com.au. We will respond to any request within a reasonable time.

We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date. If we cannot take reasonable steps to correct the information because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of your correction request.

If we refuse to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps that are reasonable in the circumstances to associate that statement with all records containing the relevant information.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. If we cannot provide access to your information, we will generally provide you with the reasons why and the mechanisms to complain about that refusal.

There is no cost involved for you to make a correction request or for the correction of your information.

• Making a complaint and how it will be handled

If you believe that we have breached any obligation under Part IIIA of the Privacy Act from when it applies to us and wish to make a complaint about that breach, please contact us by email at complaints@ubomi.com.au setting out details of the breach. We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint.

It would assist us to ensure we properly understand your complaint, and allow us to respond more promptly, if complaints are made in writing and include as much detail as possible.

We will deal with any complaint in a timely, effective and consistent manner.  We will acknowledge the receipt of your complaint within 7 days, and endeavour to make a decision on the complaint within 30 days after it is received.  If we need more time to resolve your complaint, then we will notify you as to the delay.

If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing enquiries@oaic.gov.au or writing to GPO Box 5218 Sydney NSW 2001.

• Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to complaints@ubomi.com.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint.
If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing enquiries@oaic.gov.au or writing to GPO Box 5218 Sydney NSW 2001.

• Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

• Website

When you visit our website (www.ubomi.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

• App

When you use our App we may collect certain information such as location, activity times. This information is used in an aggregated manner to analyse how people use our App, such that we can improve our service.

• Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.

• Third party sites

Our website and App may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

• Enquiries

If you have any concerns or queries about our Privacy Policy, or if you would like more information about privacy-related issues, please contact us at:
Email: hello@ubomi.com.au
Telephone: (07) 5644 3666