31st July 2024
1. Introduction
1.1 Money Management Group Pty Ltd (ABN 56 008 131 137) trading as okke (“we”, “us”, or “our”) provides software and services in the information technology and accounting industries. We are bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). We are committed to the protection of your privacy and understand the importance of keeping your personal information and personal financial information (together the “Personal Information”) private and secure.
1.2 Part of our software and services are provided through our website located at www.okokke.com and its directly associated domains (together the “Website”).
1.3 We may require and collect information from users of our Website, software or services (“you” or “your”) including Personal Information in order for you to effectively use our software and services. Personal Information is any information or opinion about you that identifies you or is capable of identifying you, even if it is not true, including information that is in a physical form and information that is not.
1.4 This privacy policy (“Privacy Policy”) provides an overview of how we use, store, disclose, manage, and dispose of your Personal Information whether collected through the Website or otherwise in the course of using our software or services. By using or accessing our Website, software or services you agree to the terms and conditions in this Privacy Policy.
1.5 Personal Information may also include Consumer Data Right (“CDR”) (also known as Open Banking) information about your transactions that we collect on your behalf (and with your consent) for use with our software and services. We are an approved CDR representative of Yodlee, Inc. (“Yodlee”), who is an Accredited Data Recipient (Accreditation Number ADRBNK000061). Our handling of your CDR data is subject to the CDR privacy safeguards, Yodlee’s CDR policy, and our written CDR representative agreement with Yodlee, as required by law.
2. How we collect your Personal Information
2.1 The Personal Information we collect from you will depend on the dealings we have with you, but we will limit the information we collect to what is reasonably necessary for us to provide you with our services and to generally carry on our business.
2.2 We may collect your Personal Information when you:
a) register or create an account on our Website;
b) purchase, order, or engage our software and/or services;
c) subscribe to our mailing list or newsletters;
d) contact us via telephone, short message service (SMS), email, chat boxes or other correspondence, or when you share information with us from other social applications, services or websites;
e) interact with the Website, services, content, or advertising;
f) participate in contests, message boards and chat rooms, and other interactive areas of our Website;
g) lodge a complaint, request help or provide us with feedback; or
h) voluntarily submit your Personal Information, or request it be provided by a third party, to us for any reason.
2.3 When collecting Personal Information, we will take reasonable steps to make you aware of the purposes and reasons underlying the collection of your information, the organisations to which we may disclose your information (if any), the consequences if you fail to provide the requested information, and whether we are likely to disclose your information to overseas recipients.
2.4 In certain circumstances, we may also collect Personal Information from publicly available sources or from other third parties. If we collect Personal Information about you from a third party, we will inform you that we hold such information, where the information came from, how we will use it and disclose it and that you can contact us to access, correct and update your Personal Information. If we receive unsolicited Personal Information about you, we will destroy or deidentify the information as required by law.
2.5 We may also collect and hold sensitive information about you, including health information, your membership to professional or trade associations and your racial or ethnic origin. We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. Sensitive information will only be collected if reasonably necessary for, or directly related to, providing you with our services.
2.6 You do not have to provide us with Personal Information if you do not wish to, this may result in us not being able to adequately respond to your queries or provide you with the requested goods or services.
3. How we store and manage your Personal Information
3.1 We may store your Personal Information in both electronic (on our computer systems, with our Website hosting provider and in some cases, on third party servers which may be locate overseas) and hard-copy form. We will take reasonable steps to protect your Personal Information from misuse, interference, and loss, as well as unauthorised access, modification or disclosure. Secure Socket Layer (SSL) connection encryption and regular backups of our information database protect all our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
3.2 We will destroy or de-identify your Personal Information as soon as it is no longer required by us to provide services to you, as required by law.
3.3 We have a data breach response plan in place. This will allow us to respond to data breaches in an effective and timely manner, and therefore contain such a breach and reduce the risk of unauthorised access, disclosure or loss of Personal Information.
4. How we use your Personal Information
4.1 We will use your Personal Information for the purpose for which we collected it, and for related purposes we consider will be within your reasonable expectations. If we use your Personal Information for any other purpose, we will first obtain your consent before we use your Personal Information (unless we are required or permitted by law to do so without obtaining your permission).
4.2 We generally collect, hold and use your Personal Information to:
a) provide you with our software, materials and/or services and otherwise achieve the purpose for which the information was submitted to us;
b) verify your identity;
c) enable you to access and use our Website, software, materials, and/or services;
d) process any purchases of software and/or services that you may make through our Website or with us directly, including charging, billing and collecting debts to or owed by you;
e) send you service, support and administrative messages, reminders, responses to queries or feedback, updates, security alerts, and information requested by you;
f) communicate with you;
g) comply with our legal and regulatory obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
h) generally carry on and manage our business (which may include a merger, acquisition or sale of our business or all of its assets);
i) administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
j) gain an understanding of your information and communication needs or obtain your feedback or views about our software, materials and/or services in order for us to improve them;
k) maintain and develop our business systems and infrastructure, including testing and upgrading such systems;
l) engage in other activities where required or permitted by law;
m) for purposes specified in our SaaS Terms and Conditions and
n) undertake any purpose related to any of the above.
4.3 We may use your Personal Information for direct marketing purposes. For example, to send you information and offers from us or third parties that may be of interest to you. You may unsubscribe from our direct marketing at any time by contacting us directly or following the instructions in the marketing materials received. If you do not unsubscribe, you will be taken to have consented to continue receiving direct marketing from us.
4.4 Personal Information entered into our online accounting software (including data backed up on our cloud-based server) will not be used by us or disclosed with anyone except as authorised by you, in accordance with clause 4.2 or 4.3 or to provide aggregated information that does not personally identify you (Non-Personal Information). Only you and your nominated representatives (including our authorised support technicians to whom you give authority) have access to your financial database under normal operational circumstances.
5. How we disclose your Personal Information
5.1 We do not routinely disclose your Personal Information to any other person or organisation unless you agree to it. Your Personal Information will only be used for the purpose for which we collect it, or related purposes we consider within your reasonable expectations.
5.2 We may disclose your Personal Information to third parties such as our authorised agents, contractors or subcontractors that provide administrative, technical, and promotional services or as required, authorised, or permitted by law.
5.3 For example, our software and services may include integrated third party services. This includes without limitation, certain services provided by Yodlee, which are integrated with our software. In order for you to use our software and services, we may on your behalf (and with your consent) disclose your Personal Information to Yodlee in order for Yodlee to provide and improve its services and to create and use de‑identified aggregated data from users of its services, as permitted by law.
5.4 In addition, from time to time as we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses. In such transactions, Personal Information may be among the transferred assets. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
5.5 If we propose to disclose your Personal Information for any other purpose, we will first obtain your consent, unless we are required or permitted by law to do so without seeking your permission.
6. Online privacy
This part of our Privacy Policy sets out how we handle your Personal Information that is collected when you use and access our online services.
6.1 Automatic collections and cookies
Our Website server automatically collects various items of information when you use our Website, software or services and may attach a “cookie” to your device’s memory. A “cookie” assists us to store information which is used to improve our Website, software or services and your online experience by monitoring your usage of our Website, software or services and to provide information on items you may be interested in. This information is used for statistical analysis, system administration and similar related purposes; we do not use this information to identify you. Third parties, such as Google Analytics, Facebook, Twitter, LinkedIn, YouTube and Instagram may also use these “cookies” to collect Non-Personal Information about your use of our Website, software or services and may use it to deliver online advertising to you. The settings in your internet browser software can be adjusted to prevent cookies being stored on your device, if required. However, some of the features of our Website, software or services may then not be available to you. If you choose not to have “cookies” placed on any of your devices, please set your browser preference to reject “cookies” before accessing our Website, software or services. If you do so, you may not be able to access certain portions of the Website, software or services and we may not be able to customise the Website, software or services’ features according to your preferences. As we adopt additional technology, we may also gather information through other means.
6.2 Email and message forms
a) We may collect Personal Information from you (such as your name, address, telephone number and email address, and any other Personal Information you volunteer) if you send us an email or if you submit information to us using a contact form from our Website. We will use this Personal Information to contact you and provide you with a response to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such information for any other purpose without your consent.
b) You should also be aware that if you voluntarily disclose Personal Information on message boards or in chat areas, that information may be viewed publicly and may be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. You acknowledge that such activities are beyond our control.
6.3 Social networking
We use social networking services such as Facebook, Instagram, LinkedIn, YouTube and Twitter to communicate with the public about our services. When you communicate with us using these services, we may collect your Personal Information, but we only use it to help us communicate with you and the public. The social networking service may choose to handle your Personal Information for its own purposes and should have their own privacy policy in place, which we encourage you read before making use of the social network service.
6.4 Marketing
We may use Google AdWords/Facebook re-marketing services to advertise our software and/or services on third party websites to you if you have visited our Website, based on your activity on our Website. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.
7 Accessing and correcting your Personal Information
7.1 You may contact us to request access to, or a correction of, your Personal Information held by us within a reasonable time and in the manner requested if it is reasonable and practicable to do so. You will be required to verify your identity before we will allow you to access your Personal Information, for the protection of your privacy and the privacy of others.
7.2 If your Personal Information in our databases is incorrect, incomplete or requires updating, you may notify us of that relevant Personal Information and we will take reasonable steps to correct that Personal Information so that it is accurate, complete and up-to-date within a reasonable time.
8. Overseas transfer of Personal Information
We may engage third party service providers located overseas to provide services to us, this may result in your Personal Information being transferred to locations outside of Australia. By providing your Personal Information to us, you consent to us disclosing your Personal Information to any such overseas recipients for purposes necessary or useful for the operation of our business and you further agree that APP 8.1 will not apply to such disclosures. You acknowledge that if an overseas recipient of your Personal Information breaches the APPs, that overseas entity will not be bound by and you will not be able to seek redress under the Privacy Act.
9. Changes to our Privacy Policy
We reserve the right to amend this Privacy Policy at any time (without notice to you) by uploading the updated Privacy Policy to our Website. We encourage you to read our Privacy Policy each time you deal with us so that you are aware of any changes made to it.
10. Complaints
10.1 If you believe that a breach of your privacy has occurred or you otherwise have a complaint or question about our use or management of your Personal Information or this Privacy Policy, we encourage you to contact our Privacy Officer to discuss your concerns using the contact details below:
Privacy Officer
Address: Level 5, 144 North Terrace, Adelaide SA 5000
Phone: 08 8275 2050
Email: hello@okokke.com
