Privacy Policy

Last updated 1 May 2019

Flare HR Pty Ltd (ABN 46 607 120 892) (Flare HR) owns and operates the Flare HR Management and Benefits Platform (Flare HR Platform).

EPI-USE Managed Solutions Pty Ltd trading as “FlarePay” (ABN 92 100 495 663) (FlarePay) owns and operates the FlarePay Platform, which is accessed via the Flare HR Platform.

Flare Financial Services Pty Ltd (ABN 16 612 284 081) provides financial literacy services to members of the Flare HR platform and the wider Flare HR community.

Simple Financial Choices Pty Ltd (ABN 58 629 890 900) is the Sub-Promoter of Simple Choice Super and a Distributor of the Future Super Superannuation Fund.

Each of Flare HR, FlarePay, Flare Financial Services and Simple Financial Choices are bound severally by this Privacy Policy, which has been combined solely for your convenience as a single reference point.

 

In this Privacy Policy:

• us, we or our means Flare HR, FlarePay, Flare Financial Services and Simple Financial Choices; and
• platform means the Flare HR Platform and the FlarePay Platform.

To make things a bit easier for you, we have included simple summaries in green.  You should read the entire policy so you don’t miss anything important.

We take your privacy very seriously.  This policy sets out what you need to know about how we collect, use, store and disclose your personal information. 

This Privacy Policy sets outs out how we collect, use, store and disclose your personal information in accordance with the Australian Privacy Principles in the Privacy Act.

By providing personal information to us, you agree to our collection, use and disclosure of your personal information in accordance with this Policy, Platform Terms of Use and any other arrangements that apply between us.

If you choose not to provide us with the personal information we request, we may not be able to provide you with access to our platform, products or services, or more information about them.

Make sure you keep up to date with any changes to our policy.

We may change our Privacy Policy from time to time by publishing changes to it on the platform (available at www.flarehr.com/legal). By continuing to use and access our platform, you agree to these changes. We encourage you to check the platform periodically to ensure that you are aware of our current Privacy Policy.

How do we collect information about you?

We collect info from you, your employer and our business partners.

We collect personal information from:

• You: when you use the platform, access our services and communicate with us;
• Your employer: when they register you as a platform user and use the platform to administer their human resources and payroll functions; and
• Our business partners: when you access products and services from them via the platform.

What information do we collect?

We collect all the usual info; contact details and information about your identity. We also collect other types of info so you can use our platform and access our services.    

The types of personal information we may collect about you include:

• Information about your identity;
  • Including your name, age, date of birth, gender, and tax file number.
• Photos for your platform profile picture;
• Information to verify your identity and to determine whether you can work for your employer;
  • Including driver's licence number and copies of your driver's licence, passports, visas, other identification documents or your digital signature (for when you sign documents via the platform).
• Contact information;
  • Including mailing and street addresses, email addresses, telephone numbers and other contact details;
• Information about your personal circumstances;
  • Including your marital status, dependants and smoker status.
• Your platform preferences and how you use the platform;
  • Including your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, IP address and standard web log information.
• Employment information;
  • Including your employment history, position title, qualifications, contracts, employment benefits and entitlements (e.g. salary, leave entitlements and superannuation), resume details, training data, performance metrics, memberships and associations.
• Financial information;
  • Including bank details, information about your membership with other super funds or other information about your financial circumstances.
• Information related to any products and services you enquire about, select or we have provided to you via the platform; and
• Any information you provide us, our representatives or our business partners.

We may also collect sensitive information (e.g. health information). We will only collect this information with your consent and when it is necessary for our business purposes.

How do we use your information?

We collect info about you to personalise your platform experience, improve our services and communicate with you.

We may collect, hold, use and disclose your personal information to:

• Enable you to access and use the platform, our products and our services;
• Contact and communicate with you;
• Enable your employer and its nominated personnel to administer your employer's human resources and payroll functions;
• Provide you with information about our products and services and the products and services of our business partners;
• Operate, protect, improve and optimise our platform, products, services, business and user experience;
• Send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you;
• Send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our carefully selected and trusted business partners;
• Administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
• Comply with our legal obligations, resolve any disputes we may have with our users and enforce our agreements with third parties.

We are always working to improve our platform, products, services and consumer insights to give you the best customer experience. We may provide information about you to third parties as part of a data analytics process. If we do, it will be aggregated and anonymous information that does not identify individuals.

Do we use your personal information for marketing?

One of the neat things about the platform is you can access a range of products and services. If you don’t want us to send you info about these products and services, tell us and we will stop.

If you are a customer, from time to time we may send you marketing information about products and services offered by us and our business partners, which we think may be of interest to you. We may send this information to you by email or post.

If you do not want to receive marketing information, please opt out by adjusting your account settings using the opt-out facilities provided (e.g. an unsubscribe link) or contacting us using the details set out below.

We will only use or disclose sensitive information about you for marketing if you have consented to this.

To whom do we disclose your personal information?

From time to time we may need to share your info with people listed in this policy. We won’t share your info with any other person unless you consent to it. 

We may disclose personal information for the purposes described in this Privacy Policy to:

• Our employees and related bodies corporate;
• Your employer;
• Third party suppliers and service providers, such as information technology suppliers and communication suppliers;
• Payment systems operators;
• Anyone to whom our assets or businesses (or any part of them) are transferred;
• Specific third parties authorised by you to receive information held by us; and/or
• Government agencies, regulatory bodies, law enforcement agencies or other persons when required, authorised or permitted by law.

Government related identifiers

We will only disclose government identifiers if we can or must.

We may collect and hold government related identifiers (such as your tax file number) as an agent for your employerand your super fund. We will not disclose any government related identifiers other than at the direction of your employer or as required or permitted by law.

Disclosure of information outside Australia

Where personal information is stored overseas, we will ensure that there are arrangements in place to protect it.

Personal information captured on the platform is hosted in Microsoft Azure data centres located in Sydney and Melbourne.

Where commercially feasible, we contract with other software vendors in Australia, who are subject to the Australian Privacy Principles.

Like many leading companies in Australia, from time to time, we may engage global enterprise software vendors to support our internal operations (e.g. Salesforce or SAP). In such circumstances, personal information held by these vendors may be stored outside of Australia.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia. We will take all reasonable steps and use our best endeavours to ensure any such vendors comply with the Australian Privacy Principles or are subject to similar requirements to protect personal information overseas.

Storage and security

We care about the safety of your info and do what we can to protect it.

We may hold your personal information in either electronic or hard copy form. We take the storage and security of your information seriously, and will take all reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a range of physical, administrative, personnel and technical measures to protect your personal information.

Electronic data collected by us is hosted primarily in Australia, but may in certain circumstances be hosted overseas. Access to the hosting platform and production database is tightly controlled, with limited access to security credentials.

Your personal information is only retained for as long as necessary to fulfil the purpose/s for which it was collected, unless we are required to retain the information for a certain period of time under an Australian law or court or tribunal order. Once no longer required, we take such steps as are reasonable in the circumstances to destroy or permanently de-identify your personal information.

We apply best practice in our security measures but we cannot guarantee the security of your personal information. If there is a breach of our security, we will investigate it, let any affected users know, and take all other appropriate steps relevant in the circumstances.

Using the platform and cookies

To provide the platform and make your user experience as enjoyable as possible, we collect certain info about how you use the platform. 

We may record certain information about your use of the platform including which parts of the platform you visit, the time and date of your visit, and the internet protocol address assigned to your computer.

We may also use 'cookies' or browser information on the platform to help us track your use of the platform, remember your preferences, enable us to collect data, monitor the effectiveness of our platform, and advertise our products and services or those of our trusted business partners.

Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but some features of the platform may not function properly if you do so.

Links

To make things super convenient our platform includes links to other websites. There are heaps of website links out there. If we post one on the platform, we can’t control what happens on the other end.

The platform may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ to ours, so we encourage you to read them before using those websites.

Social media platforms

Whilst we may use social networking platforms for communications, we won’t ask you to supply personal information publicly over these platforms. Sometimes we’ll invite you to send your details to us via private messaging, for example, to answer a question you have raised.

Any personal information that you contribute to the publicly accessible sections of social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with our privacy standards.

What happens when you contact us?

We must be certain of your identity before we can discuss your account with you. If you contact us to discuss your account, you must be able to prove your identity. This ensures that we are able to protect your personal information by only giving it to you or someone who can prove that they are lawfully authorised to act on your behalf.

If you have a general enquiry that does not involve discussing your personal information, you do not have to provide identification. In these situations, you will be able to deal with us without identifying yourself.

Accessing or correcting your personal information

Feel free to contact us to access your info or fix any mistakes.

You can access the personal information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why.

We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Making a complaint

Contact us about any privacy complaints.

If you think we have breached the Privacy Act or you wish to make a complaint about the way we have handled your personal information, you can contact us. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you within a reasonable period of time.

If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Contact us

Want to chat all things privacy, reach out anytime.

You can contact us to find out more, access or correct your personal information or make a complaint using the details below:

FlareHR Platform, Flare Financial Services and Simple Financial Choices

Phone: 1300 352 734
Email: [email protected]
Post: Flare HR Privacy Officer
Flare HR

1-3 Munn Street
Miller’s Point NSW 2000, Australia

FlarePay Platform

Phone: +61 8904 9344
Email: [email protected]
Post: FlarePay Privacy Officer
C/- EPI-USE Managed Solutions Pty Ltd
Level 50, 360 Elizabeth Street, Melbourne, Victoria 3000, Australia