smartMonday Privacy Policy
Updated 28 January 2022

“smartMonday” (also referred to as “we”, “us” or “our”)

means:

• smartMonday Solutions Limited ABN 48 002 288 646; and

• Smart Future Trust ABN 68 964 712 340.

“smartMonday Website”

means a website or mobile application owned or operate by smartMonday (including https://smartmonday.com.au/).

“APP”

means the Australian Privacy Principles contained in Schedule 1 of the Act.

“Authorised Representative”

means a person authorised in accordance with sections 916A and 916B of the Corporations Act 2001 (Cth) to provide financial services on behalf of an Australian Financial Services Licence holder.

“Privacy Act”

means Privacy Act 1988 (Cth) or any replacement law.

“Privacy Policy”

means this smartMonday Privacy Policy.

Collecting your personal information

the type of information we may collect and how we collect it;

Using and disclosing your personal information

the ways in which and the purposes for which we may use and disclose your information;

Cross-border disclosures of your personal information

our approach to disclosing your information to overseas recipients;

Holding and storing your personal information

the ways we hold, store and secure your information;

Accessing and correcting your personal information

how you access and change information we hold about you; and

Resolving your privacy issues

how to raise any issues with our management of your information in accordance with the APPs, and how to opt-out.

What is personal information?

Personal information is information or an opinion that allows others to identify you. This includes your name, gender, contact details, as well as your health and financial information.

Why do we collect your personal information?

We will generally collect personal information that is reasonably necessary to offer and administer our services and products.
Our services and products include the provision of superannuation.

We may also collect personal information to:

• identify and interact with you;

• be able to develop and identify products and services that may interest you;

• perform administrative or operational functions;

• conduct market or customer satisfaction research;

• develop, establish and administer alliances and other arrangements with other organisations in relation to the promotion, administration and use of our respective products and services;

• comply with any legal requirements, including any purpose authorised or required by an Australian law, court or tribunal; or

• for any other purpose for which you give your consent.

If you are not a customer but interact with smartMonday, we may collect information to identify and interact with you.

If you are a contractor or prospective staff member, we may collect:
information to allow us to carry out our recruitment functions, to correspond with you, to fulfil the terms of any contractual relationship and/or to ensure that you can perform your duties.

What type of information can we collect from you?

The type of information we collect will depend on the type of product or service you request. Generally, we collect information such as your name, phone number, residential address, date of birth, gender, financial and employment details and benefit coverage.

For some of our products and services, we may also need to collect sensitive information about you. This may include information about your criminal convictions or heath information in relation to life, heath, professional liability and workers compensation insurance, employee benefit programs, membership of professional or trade associations and sexual preferences. We will generally only collect and hold such sensitive information where reasonably necessary to perform our engagement and with your consent.

If you are not a customer but interact with smartMonday, we may collect information you have provided in communications we have with you and about your access and use of our website, including browser session data, device and network information, statistics on page views, acquisition sources, search queries, browsing behaviour and information gathered through internet cookies.

If you are a contractor or prospective staff member, we may collect: name, email address and phone number.

• your nationality and which countries you hold citizenship of.

• educational details, such as schools you have attended, any qualifications you have received, transcripts and/or English language test results.

• employment details, such as a CV, qualifications attained or examples of work.

What can happen if you don’t provide us with your information, or provide us with information that is incomplete or inaccurate?

If you do not provide the information we request, you would like to remain anonymous or you want to use a pseudonym, we or those involved with the provision of the service or product may not be able to provide the appropriate type or level of service or product.

How do we collect this information?

Unless impracticable or unreasonable to do so, we will collect information directly from you. This may occur, for instance, when you contact us by telephone, email, online or letter in order to complete a product or service application, or any other kind of administrative form. Our emails may contain automatic features that collect personal information.

If we are permitted by law to do so, we may collect information about you from Third Parties. We may collect this information from third parties such as our affiliates, Authorised Representatives, or other third parties such as employers, insurance companies, financial institutions, medical professionals, law enforcement, dispute resolution, statutory and regulatory bodies, marketing lists and industry databases, publicly available sources or other government bodies.

Upon your request, we will take reasonable steps to let you know how we have sourced your personal information, unless it is obvious from the circumstances that you would know or would reasonably expect us to have the information (such as where we are dealing with your advisers).

Are there any other ways smartMonday can collect your personal information?

smartMonday may also collect information by online means when you:

• Visit smartMonday’s Website
  smartMonday may collect information during your visit to smartMonday’s Website through the use of cookie technology.
  smartMonday’s Website may contain links to other sites which are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy statement. We encourage you to read the privacy statements on other websites you visit. smartMonday is not responsible for the content or privacy practices of linked sites or any use of those sites.

• Register for events
  We may ask you for some or all of the following types of information when you register for events, request services, manage accounts, access various content and features or directly visit our websites:

• contact information, such as name, e-mail address, postal address, phone number and mobile number;

• user name, password, password reminder questions and password answers;

• communication preferences, such as which newsletters you would like to receive;

• search queries;

• contact information about others when you refer a friend to a particular site or service (note: this information is used solely to facilitate requested communications); and

• information posted in community discussions and other interactive online features.

This information will be used to administer your attendance at the event, to make you aware of other events that we believe you may be interested in, and to provide your contact details to event sponsors in relation to products or services discussed at the event. If you do not want to be contacted about other events or about the products or services discussed at the event, please select the marketing opt-out option.

• Engage with smartMonday through Social Media
  You can engage with us through social media websites or through features such as plug-ins or applications on smartMonday’s Website that integrate with social media sites. You may also choose to link your account with us to third party social media sites.
  
  When you link your account or engage with us on or through third party social media sites, plug-ins, or applications, you may allow us and our affiliates to have ongoing access to certain information from your social media account (e.g., name, e-mail address, photo, gender, birthday, the posts or the 'likes' you make).
  
  If you post information when you interact with our websites through social media sites, plug-ins or other applications, depending on your privacy settings, this information may become public on the Internet. You can control what information you share through privacy settings available on some social media sites. For more information about how you can customise your privacy settings and how third party social media sites handle your personally identifiable information, please refer to their privacy help guides, privacy statements and terms of use.

• Access our Websites through Mobile Devices
  If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier and your location information.
  
  When you provide us your mobile device phone number as your contact phone number, you consent to the use of your mobile device phone number for the purposes identified in this Statement. If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose.

How do we notify you and obtain your consent?

In most cases, we will obtain your consent to handle your personal information either at the time you engage us to provide you with a product or service, or as soon as practicable.

If you provide us with information about other individuals (such as employees, dependents etc.) you must obtain their consent for us to use their information in accordance with our Privacy Policy prior to your disclosure to us or otherwise let us know if this is not the case.

Modifying your consent and opting-out of marketing

We may use your personal information to contact you to promote and market our products and services. You may modify or withdraw your consent, or opt-out of receiving direct marketing at any time by contacting the Privacy Officer (irini@myfuturesuper.com.au).
If you receive electronic communications, such as an e-newsletter, you may unsubscribe at any time by following the instructions included in the communication.
If you previously chose to receive push notifications on your mobile device, you may manage your preferences either through your device or the application settings. Alternatively, you may uninstall the application by using the uninstall process available on your mobile device.
To prevent the use of cookies and the associated advertising, you need to adjust the settings on your browser to refuse all cookies.
Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.

How do we deal with unsolicited information?

Where we receive information that we have not requested (“unsolicited information”), we will determine whether that information is reasonably necessary for our functions or activities. If it is, we will handle the information in the same way that we handle information we have requested. If not, we will take steps to destroy or de-identify the information.

How can your personal information be used and disclosed?

We will generally only use and disclose your personal information for the purpose that it was collected for, any related purpose that you would reasonably expect us to use or disclose it for, for the purpose of analytics, or as permitted under this Privacy Policy or under any law.
smartMonday otherwise has a duty to maintain the confidentiality of its clients’ information unless disclosure is permitted with your consent or compelled under any law.

Your information may be used for the following purposes:

• to provide the information, products or services you requested;

• to determine your eligibility and process applications for products and services you have requested;

• to provide information and services you requested;

• to understand and assess your ongoing needs, and to offer products and services to meet those needs;

• to carry out client communication, service, billing and administration;

• to arrange premium funding;

• to administer claims;

• to conduct data analysis and data analytics;

• to monitor and train;

• to develop new services;

• to defend a complaint raised through the Australian Financial Complaints Authority (AFCA);

• to market products and services; and

• to conduct processing necessary to fulfil contractual obligations for the individual.

We will only use and disclose your sensitive information for the purpose it was collected for, for any other directly related purpose that you would reasonably expect us to use it for, or in accordance with a law or regulation. With your consent, we may use or disclose your information for additional purposes from time to time.
In addition to our affiliates, we may also disclose personal information to third parties such as our contractors, agents and service providers when we outsource certain functions, including market research, marketing, claims handling and recruitment. This would also include our third party storage providers whom we may use from time to time to store information physically or electronically.

When do we disclose your personal information?

We may disclose your information to our affiliates or third party service providers to assist us in providing, managing and administering our services and products, such as:

• insurance broking and insurance products - business partners, including insurers, reinsurers, other insurance intermediaries, insurance reference bureaux, medical service providers, fraud detection agencies, other advisers such as loss adjusters, lawyers and accountants and others involved in the claim handling process;

• superannuation administrators and service providers;

• our Authorised Representatives;

• authorised service providers, including IT service providers; and

• external IT service providers, infrastructure and other third parties where required by law.

What is our approach to disclosing your information to third parties and overseas recipients?

smartMonday may disclose personal information to overseas entities that are necessary to assist us in providing the relevant services and products to our clients or to enable them to offer their products and services to you.

For instance, we disclose personal information to the relevant product provider and their representatives, our agents and contractors and related companies (including our Authorised Representatives). We generally limit such use and disclosure of any personal information to the specific purpose for which it was supplied.

We may also disclose personal information to third parties such as our contractors, agents and service providers when we outsource certain functions, including market research, direct marketing, claims handling and recruitment. This would also include our third party storage providers, whom we may use from time to time to store information physically or electronically.

Our affiliates and third parties may be based locally or they may be overseas. Locations include, but are not limited to, the United States of America, the United Kingdom, Ireland, Singapore, India and the Philippines.

In these circumstances, smartMonday will generally take reasonable steps to ensure that we have arrangements in place with such parties that prevent them from using or disclosing personal information for any purposes other than our own.

How can I access and correct my information?

We take reasonable steps to ensure the personal information that we collect, hold and disclose is accurate, up to date and complete. You should contact us to update your personal information or advise us if the personal information we hold is not accurate, up to date or complete.

You can access or update your personal information as follows:

1. if you have created a profile or an account on our website, you can update your information once you log in;

2. contact our Privacy Officer (irini@myfuturesuper.com.au);

3. if you receive electronic communications, such as an e-newsletter, you may unsubscribe at any time by following the instructions included in the communication;

4. if you previously chose to receive push notifications on your mobile device, you may manage your preferences either through your device or the application settings. Alternatively, you may uninstall the application by using the uninstall process available on your mobile device; and

5. as described in our Cookie Notice, you may adjust your browser settings to accept or refuse cookies.

If we do not provide you with access or refuse to update your information, we will provide you with the reason for refusal and inform you of any exceptions relied upon.

Your request to provide information will be dealt with in a reasonable time from receipt of your request and we may recover from you our reasonable cost of supplying you with this information.