Privacy Policy

6. Finder Group Privacy & Cookies Policy

6.1 Introduction

Finder and the Finder Affiliates respect your privacy and share your concern about the security of data you may submit to our website, finder.com.au ("Site") or via the Finder App (together, the "Online Platform"). Our privacy policy (the "Privacy Policy") explains the information we collect, how we use and protect it, how to access and update your information, and how to manage your privacy settings when using the Services and is incorporated by reference into the Finder Terms of Service, which are found here.

6.2 Our Relationship

In the Privacy Policy, users of this Online Platform and holders of Finder Accounts are sometimes referred to in the Privacy Policy as "you" or "your". The applicable operator of the Online Platform is Hive Empire Pty Ltd (ABN 18 118 785 121), trading as finder.com.au, with registered offices at Level 10, 99 York Street, Sydney NSW 2000 and is referred to as "Finder". Hive Empire Pty Ltd (trading as finder.com.au) is part of the Finder Group of companies.

The Finder Affiliates also includes Finder Ventures Pty Ltd (ABN 82 624 472 064) which designs and owns the Finder App and Wallet Ventures Pty Ltd (ABN 11 149 012 653) which owns and owns and operate the digital currency exchange (referred to as "Finder Affiliates") on the Online Platform.

Finder and the Finder Affiliates may be referred to as "we", "us" or "our" in the Privacy Policy (as applicable). Together, you and we may be collectively referred to as "Parties".

We take your privacy seriously. We have published this policy to show we manage the personal information you provide to us when using the Online Platform.

6.3 What does this Privacy Policy cover?

This Privacy Policy applies to your access and use of the Finder site (finder.com.au) and the Finder App (collectively, the "Online Platform") and products and services available on the Online Platform (together, the "Finder Services" or "Site" or "Services").

This Privacy Policy, which forms part of our Terms of Service, describes what personal information we collect, how we use personal information, the circumstances where we may disclose that personal information, how we secure and store personal information, and how to access, update and correct your personal information. We may not be able to provide our Services to you if you do not provide the information we request. By registering an account with us, or by using our Site or Services you agree to our Privacy Policy and the Terms of Service.

6.3.1 What is Personal Information?

Personal information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not.

6.3.2 Changes to this Privacy Policy

We may make changes to our Privacy Policy from time to time by publishing the updates to this website, and those changes become effective 30 days from publication. We may provide separate notification of the updates by email or on our platform. By continuing to use our platform, you consent to the updates.

6.4 How do we use personal information?

We use personal information for legitimate purposes when you use our Services, including:

• to verify your identity or eligibility to use our Services.
• to provide you with access to our Services.
• to communicate with you about your account, including sending important updates about your accounts and transactions, and notifying you of any security incidents.
• to provide you with customer support.
• to communicate with you about products or services we offer, or think that may interest you, with your consent where required by applicable law.
• to consider your application for credit with one of our business partners, if relevant.
• to understand how visitors engage with our Online Platform and Services and to personalise your experience (e.g. remembering your contact details).
• to conduct analytics and research to improve our Services.
• to comply with our legal obligations and to investigate and protect against fraudulent transactions, unauthorised access to Services, and other illegal activities.

6.5 What Personal Information do we collect?

The type of personal information we collect depends on how you are using our Services. We also have different registration account types for our Services:

• Consumer: account for comparison, shopping and personal finance services
• Business: a consumer account with additional Business services (e.g. business finance)
• Partner: account for marketing partners who promote their business
• Advisor: account for brokers and advisors who register to provide services

6.5.1 Basic account information

When you register for a basic account with us, you may provide your:

• name, email address and physical address
• phone number
• date of birth
• employment details

6.5.2 Finder App

When you register for a Finder Account with us in the Finder App, we may also:

• verify your identity and eligibility to use our Services (which requires you to provide us your name, date of birth, and address)
• collect location information from your device to identify merchants in the Finder App (we won't use this information to track you)
• collect credit related information when you apply for credit via Finder
• use your financial transaction and investment data you have shared with us via the Finder App to help you manage your money and show you relevant offers

6.5.3 Identity verification

When you register for certain Finder Services or use certain features of the Finder App which require us to verify your identity, we may collect the following information, which may include:

• personal identification number (e.g. driver's licence, passport or medicare card)
• photograph of your government issued ID
• selfie for us to match with your government issued ID

6.5.4 Credit application

If you wish to apply for credit (like a credit card or personal loan) that's listed on the Online Platform, we may collect or you may be required to provide:

• personal details as detailed above
• date of birth, gender and marital status
• financial information (including income, expenses, assets and liabilities)
• employment details
• any other information which may be relevant to helping our partners assess your eligibility

Additionally, we may collect your credit report and credit-related information with your consent when required by law. If you make an application for credit, when we request a credit report from a credit reporting body, they may include your credit score. For more information about credit reporting, please see Section 6.12.

6.5.5 Finder Wallet

When you use the Finder App and Finder Wallet service operated by Wallet Ventures Pty Ltd, we may:

• verify your identity (which requires you to provide the type of information listed above)
• collect details of your digital currency wallet addresses and any transactions made through the Finder Wallet
• Wallet Ventures Pty Ltd is registered with the Australian Transaction Reports and Analysis Centre (AUSTRAC), Australia's financial intelligence agency, and is required to comply with Australia's Anti-Money Laundering and Counter-Terrorism Financing Legislation (AML/CTF laws). We must collect and verify your identification in accordance with AML/CTF Laws before we can open and maintain a Finder Wallet account for you.

6.5.6 Internet cookies and other tracking information

When you use our Services, we may use the following:

• Cookies: Cookies are small text files that are placed on a user's device when they visit a website. Cookies help to identify the user's device so that we can tailor the user experience, remember your preferences, and identify which parts of our website are used. You can control the use of cookies in your browser settings, but if you disable them, you may not be able to use certain features on our website. Please refer to Section 6.14 below for more information on how we use cookies.
• Analytics tools: We use PostHog for product analytics to understand how users interact with our Services. PostHog collects information such as page views, user actions, session duration, and feature usage. This helps us improve our Services and user experience.
• Log information: We collect internet protocol (IP) addresses and other information such as browser type, internet service provider (ISP), URLs of referring/exit pages, operating system, date/time stamp, click data and the pages you view.
• Usage information: We collect information about how you interact with our Services, such as the links you click.
• Device information: We collect information about the devices you use to access our Services including hardware model, operating system version, unique device identifiers, and mobile network information.
• Social Media: when you interact with our Site through various social media platforms, such as when you "Like", share, or follow us on Facebook or other sites, we may receive information that you permit the social network to share with third parties.

6.5.7 Questions and Surveys

When you complete optional questions and surveys, we may ask you about:

• gender, sexual orientation, ethnic identity and religion
• interests or experiences
• reviews about your experiences with our partners
• products and services you're interested in or currently have

6.5.8 Competitions and promotions

When you enter competitions or participate in promotions, we may collect your name, address, email and phone number. Each promotion may have additional entry or eligibility requirements.

6.5.9 Partner promotions

In some instances, where a business partner offers a specific promotion to Finder or Finder App users, we may collect relevant offer codes and other information to validate your transaction. We won't collect your payment card information.

6.5.10 Contact us form and chat bot

If you correspond with us (or use our chat bot), we may retain the content of email messages or instant chats together with your email address and our responses to help you with future queries. Our chat bot has a save transcript function that you may use to save your conversation.

6.5.11 If you are the representative of a business that works with us, we collect:

• name, email address and physical address
• phone number
• employment details
• bank account details to receive commissions
• login credentials for third party platforms used for reporting

6.6 What information do we receive from third parties?

We may receive information about you from the following third parties. We may match this information with information you provide to us.

6.6.1 From social networks

We provide the option to register and login to our services via social networks including Google and Facebook. If you log in via a social network, we'll request permission to access basic information from that account, such as your name and email. You can stop sharing that information with us at any time by adjusting settings in that social network.

6.6.2 From banks, credit card issuers and payment services in the Finder App

With your consent, the Finder App lets you link bank accounts and payment services and is not a payment method. The type of data collected from these services varies from service provider to service provider but could include account names, balances, holdings, parties, transaction amounts and dates, and security pricing and related information.

To connect these accounts, we may use service providers such as Salt Edge GmbH (registered office at 14A Studenților street, Chișinău, Moldova) and MoneyBrilliant Pty Ltd (Australian Company Number 602 174 655, whose registered office is at Level 38, 71 Eagle Street, Brisbane, QLD, 4000).

When we partner with these aggregation service providers to enable you to connect your financial accounts to the Finder App, the service providers securely connect to your financial account and may cache data from your financial account on our behalf.

6.6.3 From partners

If you apply for, purchase, hold or use products or services featured on our Services, our partners may share information about your eligibility, purchases and claims to provide you with our Services (e.g. to track your application or to pay a cashback reward).

6.6.4 From marketing partners

We may receive information from marketing partners that promote our services including your name, email address and phone number as a result of your participation in surveys or promotions (e.g. from our refer-a-friend program).

6.6.5 From marketing analytics services

We partner with companies who assist with our marketing efforts and measure the success of marketing campaigns. We may use hashed/obfuscated personal information including email addresses, device IDs and browser IDs to analyse and improve our Services. For example, with your consent we may share hashed/obfuscated email addresses with social media platforms for analytics and usage purposes.

We use PostHog as our product analytics platform. PostHog helps us understand user behavior, track feature adoption, and improve our Services. PostHog processes anonymized usage data and does not have access to personally identifiable information unless explicitly provided through our Services.

6.6.6 Identity verification services

For certain services, including Finder App features or Finder Wallet, which require us to verify your identity in compliance with legal obligations, we may use identity verification providers who may share your name, date of birth and address with us.

6.6.7 From Australia Post

We may receive current and forwarding address details from Australia Post to ensure important communications are received.

6.6.8 From other third parties or service providers

We may receive information from other third party service providers that we have engaged for identity verification, fraud prevention or other general business purposes.

6.7 How do we share personal information?

We don't sell your personal information to third parties. In certain circumstances, we may share your personal information outside Finder:

6.7.1 To affiliates, subsidiaries, and related entities

We may share data with our parent, subsidiaries and affiliates as permitted by this Privacy Policy, and related entities that provide services to us.

6.7.2 With your consent

We may share or sell information with your consent or at your direction. This includes situations where:

• you ask us to submit information to partners in connection with an application;
• you ask us to share your business details in our Business Directory; or
• you've won an award or contest and consent to the publication of your name.

6.7.3 To provide or deliver our services

We may share information with third parties to provide Services or features you've requested. For example, when you apply for a product, we may submit the information to the relevant partner/issuer. We may share your information with Australia Post to ensure that we have the most current address details for you.

6.7.4 With service providers and business partners

We share data with third party service providers that perform services on our behalf, which may include:

• providing technical infrastructure services;
• analysing how our Services are used;
• measuring the effectiveness of ads or marketing campaigns;
• providing customer support;
• conducting research and surveys; or
• preventing fraud, spam, or conducting risk assessments.

These providers have limited access to your information to perform these tasks on our behalf and are contractually obligated to use it in a manner consistent with this Privacy Policy.

6.7.5 With our partners

If you apply for, purchase, hold or use products or services featured on our Services, we may share information with business partners about your eligibility, purchases and claims to enable the partner to provide the products or services (e.g. verify that you have purchased a policy so that we can provide you with support or offer a cashback reward).

6.7.6 In aggregated or de-identified form

We may share information in aggregated, de-identified, hashed, obfuscated or anonymised form that cannot be reasonably used to identify you.

6.7.7 For corporate transactions

We may share information as part of a merger, acquisition, or sale of company assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership. If we're involved in such a transaction, you'll 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.

6.7.8 For legal and safety reasons

We may disclose information if we have a good faith belief that disclosure is necessary to:

• comply with a law, regulation, court order, or other legal requirement;
• protect the safety of any person from death or serious bodily injury;
• protect the safety and security of users of our Service;
• prevent fraud or abuse; or
• protect our rights or property.

6.8 International transfers of personal information

Personal Information collected by Finder may be stored and processed in Australia or any other country in which Finder, Finder Affiliates, subsidiaries, or service providers operate.

We use reasonable safeguards including contractual protections for international data transfers.

6.9 How do we secure personal information?

We use industry-standard security measures including firewalls, encrypted passwords, physical restrictions to records, and technological measures.

Our employees are required to maintain the confidentiality of personal information and are prohibited from using it for any reason other than in the provision of our services.

Where we partner with third parties, our contracts include obligations for them to comply with Australian privacy requirements and restrictions on the use of your personal information.

No company can guarantee complete security, so we cannot guarantee that your personal information will never be subject to unauthorised access, misuse, or alteration.

6.10 Children's Privacy

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with our Services.

6.11 Marketing communications, preferences, and opt out

We may contact you for marketing purposes by email, phone, SMS or post. You can request to be removed from our marketing communications at any time by:

• clicking the 'unsubscribe' link in any email communications
• by updating your communications preferences on the Privacy section of your account
• by emailing support@finder.com.au
• by calling us on 1300 077 598 (+61 409 038 109 for overseas callers)

We may continue to send administrative or transactional emails regarding your use of our Services.

6.12 Credit reporting

We have a credit reporting policy which explains how we may use your credit report and credit-related information when we provide you with services and request a credit report from a credit reporting body. The credit reporting policy is available at www.finder.com.au/credit-reporting-policy.

6.13 Access, correction, and deletion of your personal information

You have the right to access, update, correct, or delete certain personal information that we have collected. You can do this by:

• logging into your account and updating your information
• contacting us through the channels listed in Section 6.15

We may need to verify your identity before processing your request. In some cases, we may need to retain certain information for legal purposes or to complete transactions.

6.14 Cookies and tracking technologies

We use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Authenticate your identity
• Analyse trends and monitor usage
• Deliver targeted advertising
• Detect and prevent fraud

Most browsers automatically accept cookies, but you can modify your browser settings to decline cookies. Please note that some features of our Services may not function properly if cookies are disabled.

We also use web beacons (also known as pixel tags or clear GIFs) to help deliver cookies and compile analytics. These may be used in association with cookies to understand how visitors interact with our Services.

Analytics cookies: We use PostHog to collect analytics data about how you use our Services. PostHog uses cookies and similar technologies to track user sessions, page views, and interactions. This data helps us understand user behavior and improve our Services. PostHog's analytics are designed to be privacy-friendly and we configure them to minimize data collection while still providing valuable insights.

6.15 How to contact us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Email: support@finder.com.au
• Phone: 1300 077 598 (+61 409 038 109 for overseas callers)
• Mail: Privacy Officer, Finder, Level 10, 99 York Street, Sydney NSW 2000

6.16 Complaints

If you have a complaint about how we handle your personal information, please contact us using the details above. We will investigate your complaint and respond to you within a reasonable period.

If you're not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

• Phone: 1300 363 992
• Website: www.oaic.gov.au
• Mail: GPO Box 5218, Sydney NSW 2001