Legal
Privacy Policy
Smartcent Pty Ltd
Last updated: 1 July 2024
If you have any privacy concerns we can be contacted at Customer Care
We do not train AI on information input or output by our users.
1. Privacy Valuing
Privacy and Data Protection is at the core of our mission to deliver exceptional service while respecting the confidentiality and integrity of our users’ information.
a) Privacy and Data Protection
We understand the sensitivity of the personal and financial data you entrust to us and are committed to protecting it with the highest standards of security and compliance.
b) We Value Privacy
This Privacy Policy applies to all personal information collected by Smartcent Pty Ltd via the Smartcent Platform.
We place the utmost importance on protecting your privacy and your careful attention to security is also very important.
2. Information We Protect
Certain types of information are protected by law and there are regulatory guidelines on the types of information that can be collected and how it can be used.
a) What is “personal information”?
The Privacy Act 1988 (Cth) currently defines “personal information” as 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 a material form or not.
If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.
b) What is “sensitive information”?
Personal information can be collected without consent – unless it is sensitive information.
The Privacy Act 1988 (Cth) currently defines “sensitive information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable regarding their:
- Racial or ethnic origin;
- Political opinions;
- Membership of a political association;
- Religious beliefs or affiliations;
- Philosophical beliefs
- Membership of a professional or trade association;
- Membership of a trade union;
- Sexual preferences or practices; or
- Criminal record.
Sensitive information includes financial information which is further legally regulated. Please note that in some cases sensitive information may only be collected with consent.
We are determined to protect your sensitive information and we will only collect such information where we make it clear that it is optional for you to input that information.
c) What is “financial information” in the context of our service?
In our privacy policy, “financial information” refers to personal financial data that we collect, process, and present to you.
This includes:
i) Financial data you directly input into our system;
ii) Information we collect from your linked accounts with your explicit authorisation;
iii) Your income, expenses, assets, and liabilities;
iv) Transaction history from connected bank accounts and credit cards;
v) Transaction information that you manually upload.
vi) Investment portfolio details you’ve provided or we’ve imported with your permission;
vii) Credit score information (if you’ve authorised us to access it);
Viii)Your financial goals and preferences as indicated in our system;
ix) Budgeting information you’ve set up within our service;
x) Bill payment history and scheduled payments;
xi) Any categories of spending or saving you’ve defined;
xii) Historical trends in your financial behaviour based on the data you’ve allowed us to collect;
xiii) Any other personal financial information you’ve chosen to share with our service.
d) Use of Financial Information
It’s important to note that:
i) We collect and process this information to provide you with a comprehensive view of your financial situation.
ii) The information we present is a collation and organisation of data you’ve provided or authorised us to collect.
iii) While we present your personal financial information, we do not provide licensed financial advice.
iv) Our service is intended to help you understand and manage your finances, but it should not be considered a substitute for professional financial advice.
v) We employ strict security measures to protect your personal financial information.
vi) You control what information is shared with our service and can adjust your preferences at any time.
For personalised financial advice, we recommend consulting with a licensed financial professional.
3. Information We Collect
We may collect personal information from you whenever you input such information into our platform.
a) Other Collection Methods
We collect cookies from your computer which enable us to tell when you use the platform and also to help customise your user experience.
As a general rule, our cookies are carefully designed so it is not possible to personally identify you.
b) Information Types
The kind of personal information that we collect from you will depend on how you use our platform.
In line with the Australian Privacy Principles we endeavour to minimise the data we collect.
4. Data Protection
We use tried and proven data encrypted to protect your financial records and your personal information.
a) Data Encryption
We store your financial information temporarily under multiple levels of ‘strong encryption’.
b) Controlled Use
There are only two known circumstance where financial information may leave the platform against a person’s wishes:
i) if your login details are compromised – it remains your responsibility to keep your own login details secure; and
ii) if we are compelled to make such disclosures under a valid court order.
c) Data Protection
Data exploits are becoming increasingly common despite the best efforts of security experts, governments, and law enforcement agencies worldwide.
While we believe our encryption and other security measures will provide a high standard of protection, unknown circumstances could arise if new and novel security exploits were illegally used against the platform.
Please refer to our Data Breach Policy.
d) Proven Security Protection
The security methods we use are commonly deployed in the blockchain and cryptocurrency industry to securely protect many billions of dollars worth of investments.
There is currently no known way to break the ‘strong encryption’ (AES256) that we use to protect your data and this means your financial records and personal information are inaccessible to anyone except you while you are logged in.
e) Where Data is Stored
All personal and financial information is stored with multiple levels of encryption and can never be viewed by anyone other than you or those to whom you grant access or where the information is used, with your consent, in relation to resolving a complaint or to fix an issue.
f) Artificial Intelligence Constraints
Due to the nature of processing data through AI and Large Language Models, information must be temporarily held in an unencrypted state. This is true of any Large Language Model.
We take multiple security measures to ensure that this state is cryptographically protected and never visible.
g) Data Collection and Use
We only collect information that is necessary to provide our services, including personal identification, financial information, and usage data.
As discussed above, this information is used to personalise your experience, improve our platform, and communicate effectively about your care, and to let you know if there are any changes to our services.
h) Data Security
Our platform employs state-of-the-art security measures, including encryption, firewalls, and secure server facilities to protect your information from unauthorised access, disclosure, alteration, or destruction.
We regularly update our security practices and work closely with third party infrastructure providers to defend against emerging threats.
i) Third Party Reliance
We live in an integrated world and our ability to provide our services to you depends on the privacy practices of certain third party providers that we work with.
We will limit the information we provide to such entities and we will endeavour to ensure they abide by similar privacy policies but, to the full extent permitted by law, we disclaim any liability for any error or failure on the part of such a third party entity.
j) Further Information
Please contact us if you have any related questions or concerns.
5) User Rights
You have the right to access, correct, or delete your personal information at any time.
a) Privacy Tools
We provide tools and settings to manage your data and privacy preferences, and we will also promptly inform you of any data breaches that may affect your personal information.
b) Consent and Control
Your privacy is respected at every level of our operations. We will not use or share your personal information without your explicit consent, except as required by law or to provide the services you have requested.
Please be assured that we respect your control and you can change your consent at any time.
c) Transparency and Communication
We believe that transparency and open communication are foundational to building trust and accountability with our users.
We are dedicated to being clear about our practices, policies, and the choices available to our users.
6. Our Policies
We commit to clearly communicating with you about any changes to our policies or practices and will aim to do so in clear and understandable language.
a) Change Notification
Prior to changes taking effect, we will notify you through our platform, email, or other direct communication methods, allowing you to review the changes and make informed decisions.
Please periodically check to see if changes have been made as we may do so without notifying you.
b) User Feedback
We actively encourage and value feedback from our users as it plays a crucial role in our continuous improvement process.
You can contact us through multiple channels provided on our platform to share their feedback, concerns, or suggestions.
c) Transparency Reports
We will publish annual transparency reports detailing any general and non-identifiable information about requests for user data by legal authorities, data breaches, and our responses to these events.
It is our clear intention that these reports will affirm our commitment to user privacy and data protection.
7. Ethical Standards
Our business is built on a foundation of integrity, respect for individual privacy, and the promotion of user welfare.
a) Our Ethical Commitments
Our commitment to ethical standards is unwavering, guiding our operations, our interactions with users, and our business practices.
b) Integrity in Operations
We conduct our business with the highest level of integrity, adhering to legal and ethical standards in all our operations.
This includes compliance with applicable privacy, and data protection laws and regulations.
c) Respect and Dignity
We treat all users with respect and dignity, recognising the importance of their data and the trust they place in us.
That is why we aim to design our platform so it is inclusive, accessible, and free from discrimination.
d) User Welfare
Our primary concern is the welfare of our users. We strive to ensure that our platform not only meets their needs, but to also contribute positively to their safety, and privacy.
8. Accountability
We hold ourselves accountable for adhering to these ethical standards and we are committed to regular audits, user feedback, and continuous learning to uphold our ethical commitments.
a) Collection of Sensitive and Financial Information
We collect sensitive and financial information to allow temporary storage and retrieval where that is necessary for the effective delivery of general financial information.
b) Access and correction
Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct any inaccurate personal information subject to certain exceptions.
If you would like to obtain such access, please contact us.
c) Complaint procedure
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below.
d) Consultation
All complaints will be considered by our company and we may seek further information from you to clarify your concerns.
If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem.
If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
e) Overseas transfer
International cloud storage systems will be used, but your personal information will not be disclosed to recipients outside Australia unless you expressly request us to do so.
Please take care as if you request us to transfer your personal information to an overseas recipient, as any overseas recipient will not be required to comply with the Australian Privacy Principles.
Where we act on your instructions we will not be liable for any mishandling of your information in those circumstances.