Privacy Policy
Updated 14 December 2021
This Privacy Policy applies to Instreet Investment Limited (ABN 44 128 813 016, AFSL 434776), the Corporate Authorised Representative: Raiz Invest Australia Limited (ACN 604 402 815) and its affiliates (Raiz, we, us, our) and explains how we handle personal information and comply with the requirements of applicable privacy laws (Privacy Laws). If you have further questions relating to this Privacy Policy please contact us using the contact information at section 11 below.
We recognise the importance of your privacy, and that you have rights to access and correct your personal information, and understand how it is collected, held, used and disclosed. This Privacy Policy outlines how we handle your personal information, and your privacy rights.
Types of personal information collected
We collect personal information from existing and potential customers, prospective employees and other individuals. We use that information for the purposes identified in this Privacy Policy and as permitted under Privacy Laws.
The types of personal information we will collect from you will depend on the circumstances in which that information is collected. It may include:
contact details (eg. your name, residential and postal address, email, phone number);
demographic information, including age/date of birth, nationality and gender;
identity information, including driver’s licence details, tax file number (where you choose to provide it), securityholder reference number, holder identification number, other government identity details and biometric information (eg. fingerprint and face ID);
financial information, which may include bank account details, credit or debit card details, superannuation details, tax residency and details about your spending activities and financial and trade history;
risk assessment information, including political affiliations and suspicious activity;
recruitment information, if you are a current or prospective team member, including work and education history, reference and background checks, and results of health, aptitude and psychometric tests;
usage and activity information regarding the accessing and use of Raiz websites, Apps and services, including investment activity and patterns, information submitted, pages viewed, links and content accessed, referring site/link, page navigation and the dates and times of visits;
device/browser information, in relation to any devices and browsers used to access our websites, Apps and services, including device type, browser type, general location, IP address and device identifiers;
purchase and transaction information, including information about purchases linked to your account;
a. preferences, interests and opinions relevant to our services and business;
records of communications with or relating to us, including emails, telephone calls, online chat, social media messages and posts, and other online communications; and
any other information you provide to us.
How personal information is collected
The ways we may collect personal information include when you:
submit information to us (including via the Raiz website or App or email), e.g. when you register a user account, retrieve log-in information, or request a new password;
request a product provided by Raiz;
register to receive email subscriptions or publications through the Raiz website or App;
receive services from us. This may include us accessing information held by your financial institution or other third parties that we have relationships with;
register your funding and round-up account with us. This allows us to view the transactions made by you with participating merchants, and to receive historical transaction data from the participating merchants;
use the Raiz websites or Apps;
contact or communicate with us (e.g. through the website, App, or by email or phone) or request that we contact you;
make purchases using cards or accounts linked to your Raiz account;
participate in surveys, promotions or competitions run by or with the support of Raiz; or
use of the Raiz Rewards platform where your payment details or purchasing transactions are used for cashback rewards.
We may also collect personal information:
from your organisation;
from your authorised representatives;
from other third parties such as those listed in section 3.3;
from publicly available sources of information or databases; and
by creating new information such as analysis, commentary, reports and reviews.
You may choose to provide us with access to certain personal information stored by third parties such as social media sites and financial institutions. The information we may receive varies by site and is controlled by that site.
If you do not provide us with the information we request, our ability to supply you with products or services, or to otherwise fulfil the purpose for which you have provided your information may be limited. For example, a refusal to provide any personal information required as part of the recruitment process may affect the success of your application in the absence of reasonable justification.
Use and disclosure of personal information
Our main purposes for collecting, holding, using and disclosing personal information are the following:
to supply and tailor products, services and information to customers. This may include exchanging transaction details with third parties, participating merchants and payment card networks to determine whether you have qualified for or earned an offer linked to your funding and round-up accounts or associated (bank account);
to obtain products and services from our suppliers;
to respond to enquiries from existing or prospective customers seeking information about our products or services;
to conduct research, understand our customers and improve the products and services that we supply to you;
to carry out processes associated with the services we provide, including fraud screening, identity verification, records management/updating, quality assurance, electronic funds transfers and account monitoring;
to process and assess employment applications, and train and manage our team;
to enforce agreements between you and Raiz;
to conduct competitions and trade promotions;
a. to comply with laws, credit card rules and our policy requirements;1
to protect the safety and security of our customers, team, sites, systems and assets;
for the purposes of conducting analysis about the deployment and use of our products and services and the technology that supports our products and services, in Australia or elsewhere;
to manage our relationship with you, including dealing with complaints;
to protect and defend our legal rights;
to prevent, identify, manage, report and respond to suspected unlawful activity or misconduct; and
to provide information to, and respond to queries from, shareholders, suppliers or third parties involved in any proposed or agreed business restructures, mergers and acquisitions, and to facilitate any related transitional and business integration activities.
1 We are required or authorised by various laws to collect personal information, including the Privacy Act, Corporations Act, Anti-Money Laundering and Counter-Terrorism Financing Act, Superannuation Industry (Supervision) Act, Australian Securities and Investments Commission Act, Autonomous Sanctions Act, Spam Act, Surveillance Devices acts, Telecommunications (Interception and Access) Act, Income Tax Assessment acts and other tax laws.
To the extent permitted by law, we may aggregate information that we collect and use it for purposes outside the scope of this Privacy Policy. Any aggregated data used for those purposes will have all personally identifiable information removed in accordance with Privacy Laws.
We may share your personal information with:
other Raiz entities and related companies;
the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification (e.g. Illion), off-site security storage, electronic funds transfer, account monitoring, account aggregation, investigation, background checking, research, data, marketing, social media and technology services;
your representatives and agents;
our lawyers and other professional advisors;
financial institutions, merchants and payment card networks that we use to provide you with services, or that we may partner with to create and offer a product or service (eg. super fund trustees);
stock exchanges and share registry providers;
third party retailers from whom you have made purchases as part of a promotion linked to your Raiz account;
parties who refer you to us (e.g. financial advisors);
companies who may invest in us;
law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Raiz.
The parties to which we may disclose personal information may be located outside Australia including in the United States of America, Japan and Singapore.
Direct marketing
To the extent permitted by law, we may use personal information you have provided to us to send you information about your account and our services or other matters or material that you may be interested in. We will only contact you for the purposes of direct marketing, if you have consented to receive such messages or where otherwise lawful to do so.
If you receive promotional information from us and do not wish to receive this information any longer, please contact us directly, or use the unsubscribe facilities included in our marketing communications.
If you have an account with Raiz, we will use your personal information to send you service messages containing important information about your account. These messages are an important part of the service that we provide to you and will be sent to you as long as you hold an account with us.
With your consent, or where otherwise permitted by law, we may provide your personal information to third parties who offer goods or services that you may be interested in. These third parties may contact you directly in relation to those goods or services. If you choose to receive any goods or services from those third parties, those goods or services will be provided pursuant to the terms and conditions and privacy policy of that third party, independently of Raiz.
Digital Technologies
We may use digital technologies such as cookies, location services, web server logs and web beacons in connection with the Raiz website and app, social media pages and other digital portals. Some of these technologies may operate without collecting or using any personal information.
We sometimes use cookie technology on our websites to improve the operation and functionality of our websites. Cookies are pieces of information that a website transfers to your device for record keeping purposes and are a necessary part of facilitating online transactions. Most web browsers are set to accept cookies. Cookies are useful to remember browsers that have previously visited the site, estimate our number of members and determine overall traffic patterns through our websites.
If you do not wish to receive any cookies you may set your browser to refuse cookies. This may mean you will not be able to take full advantage of the services on our website.
Our website may use Google services such as Google Analytics or other third parties from time to time. For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/.
Links to other websites
Our websites may contain links to third party websites. These linked sites are not under our control and we are not responsible for the content of those sites nor are those sites subject to our Privacy Policy. Before disclosing your personal information on any other website we recommend that you examine the terms and conditions and Privacy Policy of the relevant site. Raiz is not responsible for any practices on linked websites that might breach your privacy.
Employee Information
This Privacy Policy does not apply to the handling of information about employees by us. For information about our practices relating to employee information please contact support@raizinvest.com.au.
Recruitment
If you send us an application for a position, this information will be used to assess your application. This information may be disclosed to related bodies corporate and service providers for purposes such as:
aptitude, psychological and medical testing;
background checks; and
other human resources management activities.
As part of the application process you may be asked for your specific consent to the use and disclosure of certain personal information about any pre-employment medical examination or any aptitude or psychological testing. We may also ask you to consent to the disclosure of your personal information to those people who you nominated to provide references.
A refusal to provide any of this information, or to consent to its proposed disclosure may affect the success of your application.
Accessing and correcting the information we keep about you
If at any time you want to access any personal information we hold about you, you are welcome to request access by contacting us at support@raizinvest.com.au. Our records of that information will usually be made available to you within 30 days.
If at any time you wish to change personal information that we hold about you because it is inaccurate or out of date, please either update your account information directly via our website or App, or contact us at support@raizinvest.com.au.
If you wish to have your personal information deleted, you may contact us at support@raizinvest.com.au. Please note that deleting some or all of your personal information may limit our ability to provide services to you.
We may limit or reject your requests above in certain cases, where we have a legal basis for doing so.
Storage and security of your personal information
We take reasonable steps to keep secure any information which we hold about you, whether in physical or electronic form, and to keep this information accurate, up to date and complete. Electronic records of personal information are stored on secure servers that are protected in controlled facilities. We require our employees and data processors to respect the confidentiality of any personal information held by us.
If we become aware of unauthorised access to or disclosure of your personal information that we hold we will take appropriate steps to rectify the data breach and will notify you where applicable in accordance with the requirements of the Privacy Laws.
Contacting us
If you have any concerns or complaints about how we handle your personal information, or if you have any questions about this Privacy Policy, please contact us:
Raiz Invest Australia Limited
C/O Compliance Officer
Level 9, 2 Bulletin Place,
Sydney, NSW, 2000
support@raizinvest.com.auIn most cases we will ask that you put your request in writing (including email) to us. We will investigate your complaint and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint satisfactorily, you may have the right, depending on the jurisdiction, to make a complaint to the applicable regulator or complaints scheme.
Future changes
We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the policy on our website. If at any point we decide to use personal information in a manner materially different from that stated at the time it was collected we will notify users by email or via a prominent notice on our website or App, and where necessary we will seek the prior consent of our users.
