PRIVACY POLICY

Privacy

This privacy policy (this policy) sets out how Volt Group companies (each “we”, “us”) manage personal information, including credit-related information, we collect about you. Volt Bank Limited ACN 622 375 722 is a Volt Group company.
The policy was prepared in November 2018.

If you have any feedback on this policy, or you wish to contact us, please email us at privacy@voltbank.com.au. We look forward to hearing from you.
We may vary this policy from time to time. We will ensure that the most updated version is on our website. We invite you to check the policy on the website from time to time.

Personal information and personal data

Personal information in Australia

In Australia, personal information is information or an opinion about you or from which you can reasonably be identified.
When we collect and use personal information about you in Australia, we manage that personal information under this privacy policy, the Privacy Act, the Australian Privacy Principles (APPs) in the Act and any APP Code we follow.

Personal data in the European Economic Area and Switzerland

The General Data Protection Regulation (GDPR) regulates the way we process information, from which you can be identified or from which you are identifiable, that we collect about you while you reside in a country in the European Economic Area (EEA) or Switzerland. There is a list of EEA countries at the end of this section.
This policy refers to that information as “personal data”. The term “personal information” in this policy also includes that “personal data”.
For GDPR purposes, we process personal data about you when we collect and use that personal data. Also, we are the controller of that personal data.
When we collect personal data, we manage that personal data under this policy, the GDPR and any other law that applies to processing that personal data.
If we process personal data about you, there is more information about particular rights the GDPR gives you under the heading “Processing Personal Data under the GDPR” later in this policy.
The EEA countries are:
Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, the United Kingdom, Iceland, Liechtenstein and Norway.
Collecting personal information
We collect personal information about you when we take a record of that personal information.
We collect personal information about you only where we need to or where that personal information is related directly to Volt Group functions or activities. For example, we may collect personal information about you to:

We or our service providers may collect personal information about you including:

If you are a Volt Bank customer, we may collect other personal information about you from dealing with you to help us conduct our banking activities efficiently.
If you participate in Volt Labs activities, we may collect other personal information about you to:

Credit information

If you:

we may exchange personal information about you with credit reporting bodies.
That information may include the following information about you:

We may use information we get about you from a financial institution or credit reporting body or information we derive from that information to assess your application for credit from us or to assess your ongoing ability to repay a loan or to invite you to apply for another product or service from us.

Why we collect personal information

To help manage our banker-customer relationship

We will collect personal information about you only if we reasonably need that information for our banking functions and activities. For example, we collect personal information about you so we can:

So you can assist us to build a bank

If you wish to participate or are participating in Volt Labs activities, we will collect personal information about you only if we reasonably need that information for those activities. For example, we may collect personal information about you so:

Our service providers

Our service providers may collect information about your use of our website, products or services or participating in Volt Labs activities for purposes including:

The law

We may collect personal information about you because the law requires us to do so. For example, the law requires us to collect personal information about you to:

How we collect personal information

Mostly, we collect personal information about you from you. We may collect personal information about you from other sources, like when:

We may collect information about you when you participate in Volt Labs activities.
Sometimes, we collect personal information about you that is available publicly or from others who:

Cookies

We use cookies to personalise content and ads to make our website and our apps easier for you to use. We also share cookie information with third parties to assist us to direct advertising and to analyse data relating to use of our website and our apps.
For more information on how we use cookies and tracking tags, please visit our Cookie Preference Centre by clicking on the Cookie Settings (on the consent banner) and review your cookie settings in there. If you would like more information about cookies in general, please visit Cookiepedia.

Unsolicited personal information

If we receive personal information about you that we did not request, we will consider whether we need that information for our banking functions and activities. If not, we will destroy that information or ensure it does not identify you.


What if you do not give us your personal information?

If we do not collect personal information about you, we may not be able to:

Dealing with us anonymously

You may be able to use our website to find out information about us, our products and services or participate in Volt Labs activities by using a pseudonym or without identifying yourself.
However, due to the nature of the banking products and services we supply, the law requires us to identify you when we make our banking products available to you or supply our banking services to you.

Information about other people

If you tell us personal information about another person, we ask that you:

How we use your personal information


We may use personal information about you to:

That correspondence is direct marketing. You can tell us to stop sending you direct marketing. Please see below for our contact details.

Stopping direct marketing

You can ask us any time to stop sending you direct marketing information. When we email you with direct marketing, you can respond by clicking unsubscribe and we will stop sending you direct marketing. We do not charge you a fee for asking us to stop direct marketing.
Also, we will not call you with marketing offers if you are on the “Do Not Call” register. You can register on the “Do Not Call” register at www.donotcall.gov.au or phoning 1300 792 958.

Disclosing personal information

We may exchange personal information about you with:

Those suppliers may:

Our arrangements with suppliers will limit use of your personal information to the services they supply to us. We will ask suppliers to ensure their arrangements with contractors limit the contractors’ use of your personal information to help the suppliers to perform services for us.
We will require suppliers to return, destroy or de-identify personal information about you that they hold or their sub-contractors hold when they cease performing services for us. If you want information on how those suppliers manage your personal information, please email us at privacy@voltbank.com.au;

Google Analytics

Without limiting who we may exchange personal information about you with, we use Google Analytics services to improve and analyse website and app experiences.
We may share information with Google for that purpose.  When you use:

Google uses the information Volt or Volt Labs shares with them to help us understand how you engage with the Volt website and the Volt Labs app.  Also, Google may use that information to:

If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on (https://tools.google.com/dlpage/gaoptout).
Also, please read Google’s Privacy Policy (https://policies.google.com/privacy) to learn more about how Google processes data.


Disclosing personal information overseas

We will store  information in Australia whenever possible.  However, if there is a need to store information overseas (for example, if a service is not available in Australia)  we may disclose personal information about you to overseas entities that assist us to conduct our business. It may be necessary for those overseas entities to disclose your personal information under foreign law.
Some of the entities we disclose personal information to are situated in the USA, Switzerland, India and the Philippines.. There may be other overseas jurisdictions, we cannot identify now, in which those overseas entities may hold your personal information. If those entities need to host your personal information overseas we tokenise or hash or take other steps to protect the security of that personal information for better data protection.
We are responsible for any failures by overseas entities to manage your personal information in accordance with the APPs.


Use of Government identifiers

We do not use Government related identifiers (such as tax file numbers or medicare card numbers) to identify you in our records. We may collect and use some of your Government related identifiers, but only for reasons permitted by the Privacy Act, the Australian Privacy Principles (APPs) in the Act or any APP Code we follow. For example, we may use those identifiers to help us to check your identity before we make banking products available to you.


Security of your personal information

We will take steps reasonably available to us to protect your personal information from:

We will do this by ensuring that access to your personal information is password protected and available only to those of our employees that need to use, disclose or manage it under this policy.
Personal information that we can’t protect is personal information that you share with us on our social media channels such as email addresses and first and last names. 

Access to your personal information


You can ask for access to the personal information we hold about you. We may ask you to detail the information you require, if you want only some of that personal information.
If you want to access the personal information we hold about you, please email us at privacy@voltbank.com.au.

You may also want to access personal information (including credit-related personal information) we have disclosed about you to third parties or to make a complaint to those third parties. The privacy policies of those third parties will tell you how you can make an access request or a complaint to them.

Generally, we will give you access to the information you request. There may be some circumstances, permitted by the APPs, in which we will not give you that access. For example, we may not give you access to information where:

We will give you written reasons if we refuse to give you access to personal information you request, unless there are reasonable grounds (such as confidentiality obligations we owe) for not giving you those reasons. In any case, we will give you an explanation if we do not give you access to information because of a commercially sensitive decision-making process.
We will give you access to the information you request in the manner you request (for example, by email), if we are reasonably able to do so. If we are not able to do so or if we have a reason for not giving you access to all the information you request, we will work with you to give you access to personal information we hold about you in a way that meets your needs and our needs.
We will respond to any request you make for access to the personal information we hold about you within a reasonable time after you make the request. The time it takes will depend on the amount of information you seek and whether we have to make more enquiries of you to clarify your request. We expect to respond to any request you make for access within 30 days after we receive your request.
Depending on the amount of information you request, we may charge you a fee for organising the information you request from us. We will give you an estimate of the fee before we organise the information. Then, we can work with you to check whether you wish to limit your request to reduce the charges.


Correcting your personal information

We take steps, reasonably available to us, to ensure that the personal information we hold about you is accurate, up-to-date and complete. To assist us, we ask that you contact us and update the personal details we hold about you (for example, your name, address and contact details), if those details change. You can contact us by email to privacy@voltbank.com.au.
You may consider that the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading. You can request us to correct the personal information we hold about you by email to privacy@voltbank.com.au.
If we receive your request to correct information but consider that the information does not need correcting, we will give you a written notice setting out our reasons. Also, we will give you details of how you can:

We will respond to any correction request you make within a reasonable time after you make the request.
We will not charge you for correcting or associating a statement to personal information at your request.


Complaints

If you have a complaint about the way we manage the personal information we hold about you, please email us at privacy@voltbank.com.au.
If we cannot resolve your complaint in a manner that is satisfactory to you and within 30 days of receiving your complaint, we will tell you how you can take your complaint to the external dispute resolution scheme of which we are a member or the Office of the Australian Information Commissioner (OAIC).
We are a member of the Australian Financial Complaints Authority (AFCA). You can lodge a complaint with AFCA by visiting the AFCA website at www.afca.org.au.
You can make a complaint to the OAIC by using the privacy complaint form available at www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint and submitting it online, by post, fax or email.
It is free to make a complaint to us, AFCA or the OAIC.


Data breach reporting

We will comply with any relevant laws to notify you and a regulator that the security of the personal information we hold about you has been breached.


Processing Personal Data Under General Data Protection Regulation (GDPR)

Processing personal data

Just a reminder: “personal data” is information, from which you can be identified or from which you are identifiable, that we collect about you while you reside in a country in the European Economic Area (EEA) or Switzerland.
In addition to other reasons set out in this policy, we may process personal data about you because:

Retaining personal data


We will retain personal data about you only for as long as is necessary for the purposes set out in this policy. We will retain and use that personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.


Transferring personal data

We may transfer personal data about you to, and maintain it on, computers located outside of your State, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
We may transfer that personal data to Australia and process it there or to other jurisdictions. Also, please read the particulars under the heading Disclosing personal information overseas in this policy.
We will take all steps reasonably necessary to ensure that personal data about you is treated securely and in accordance with this policy and no transfer of that personal data will take place to an organization or a country, unless there are adequate controls in place including the security of that personal data.


Data Protection Rights Under the GDPR

If you are a resident of an EEA country or Switzerland, you have certain data protection rights with respect to personal data we collect about you while you reside in that country.
We will take reasonable steps to allow you to correct, amend, delete, or limit the use of that personal data. If you wish to do so, please email us at privacy@voltbank.com.au.
If you wish to know what personal data we hold about you and if you want us to remove that personal data from our systems, please contact us.
You can contact us and exercise the following rights in relation to the personal data we hold about you:

We may ask you to verify your identity before responding to any of those requests.


Complaints

You have the right to complain to a data protection authority about our collection and use of personal data we hold about you. For more information, please contact your local data protection authority in the country (an EEA country or Switzerland) of which you were a resident when we collected personal data about you.

 

 
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