Citro Privacy Policy
Retail individual
July 2024 | Version 2.0
Issued by Hay Limited ABN 34 629 037 403
Australian Financial Services Licence No. 515459
This document outlines Citrus Innovations Pty Ltd trading as Citro (Citro)’s policy on handling the personal information that we collect about our customers.
We are committed to protecting your privacy. When we request personal information, we will explain why we need it, how it will be used and who we may share it with. At all times we will comply with the terms of this policy when handling your personal information. This policy answers the following questions about privacy at Citro.
Contents
Why do we need your personal information?
Will my personal information be used for direct marketing?
What happens if I do not provide information that has been requested?
What types of personal information do we collect?
How do we collect personal information?
Can you remain anonymous or use a pseudonym when dealing with us?
How do we protect your personal information?
Who do we share personal information with?
Do we send personal information to overseas recipients?
How do we update your personal information?
How can you contact us about privacy?
How do you find out about your personal information we hold?
How can you make a complaint about privacy?
How can you escalate unresolved privacy complaints?
Why do we need your personal information?
Protecting your personal information is important to us and we will only collect the information necessary to enable us to provide our products and/or services to you. We understand some information is more sensitive so we will be clear about why we are collecting it, what we intend to use it for and how we will protect it.
In this policy, personal information is any information that could identify you or be used to establish your identity.
We collect, hold, use and disclose personal information so we can establish, manage and administer the products and services provided by us, and comply with legal and regulatory obligations. We may also use and disclose your information for purposes related to those mentioned above such as:
– Assisting with your questions and complaints
– Arranging for services to be provided by third parties
– Enhancing our customer service and productoptions
– Internal operations, such as record keeping, data analytics, auditing or training
– enabling us to engage in market research and analysis for or on behalf of our clients, including to determine the behaviours and needs of potential customers, identify the target market for existing or potential products or services, validate hypotheses regarding product functionalities and service offerings, and assess the viability of our clients’ products or services
– to otherwise assist clients by providing them with information and support
– to help us to manage and enhance products or services we provide to you
– to promote and market our products and services to you
– to personalise and customise your experiences on our website
– to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners, as well as further opportunities to engage in market research and analysis exercises
– to conduct research for the purposes of improving existing products or services or creating new products or services
– to help us research the needs of our clients to enable us to market our products and services with a better understanding of your needs and the needs of clients generally
– to provide for the safety and security of workers and onsite visitors
Will my personal information be used for direct marketing?
We use and disclose your personal information to keep you informed about the range of products and services we offer.
You can opt-out of receiving direct marketing information from us at any time (refer to section ‘How can you contact us about privacy?).
What happens if I do not provide information that has been requested?
It’s your choice whether to provide your personal information. However, if you don’t, we may be unable to fulfil your request for a specific product or service or be unable to identify you to protect you against fraud.
What types of personal information do we collect?
We may ask for a range of personal information, limited to what we need, to assist us in providing you with relevant financial products and services. The information we request could include (but is not limited to) name, address, date of birth, contact details, gender, geographic location, current address, email address, employment details, domicile and citizenship status, occupation and employment details and information from social media accounts and profiles.
How do we collect personal information?
Most of the personal information we collect will be directly from you. We gather this information either through the online application forms or other forms that you complete and submit to us (in writing and digitally), and by recording the information you provide via phone calls. We may also collect your personal information from third parties such as social media platforms including Meta.
Can you remain anonymous or use a pseudonym when dealing with us?
If you wish to remain anonymous or to use a pseudonym whendealing with us, we may be able to provide you with limited information orservices. However, in many cases it will not be possible for us to assist youwith your specific needs if you wish to remain anonymous or use a pseudonym.
How do we protect your personal information?
Whether your personal information is gathered through online or other methods, we take steps to store your information securely. We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats.
We take a number of steps to protect personal information from misuse, loss, unauthorised access, modification or improper disclosure. These include training our staff and financial advisers who handle personal information on the importance of maintaining the confidentiality of personal information and the privacy of individuals.
In the unlikely event of a data breach we have measures in place to manage and respond. This includes the notification to impacted individuals, regulatory bodies and other data protection authorities.
Do we send personal information to overseas recipients?
Some of the entities that we share information with may be located in, or have operations in, other countries. This means that your information might end up stored or accessed in overseas countries including, but not limited to, United States of America, Germany, Ireland, Netherlands, Singapore, Japan, United Kingdom, Fiji, New Zealand, Philippines and South Africa.
When we send your personal information to overseas recipients, we make sure appropriate data handling and security arrangements are in place.
How do we update your personal information?
We will update your personal information if you contact us. In most cases you can update your personal information online via our website or over the phone.
We may update your personal information if we believe the personal information we hold is incomplete or out of date. We could seek to correct or complete our records by gathering data from other sources such as public records and other organisations.
How can you contact us about privacy?
You can contact us by:
Phone 1300 869 596
Email support@joincitro.com.au
If you would like to:
– Seek more information about anything contained in this policy, or to request a printed copy of this policy
– Update or correct your personal information
– Opt out of receiving direct marketing material
– Ask about anything or correcting the personal information we hold about you; or
– Make a privacy related complaint
How do you find out about your personal information we hold?
You can access the personal and credit information that we hold about you by emailing to privacy@joincitro.com.au or writing to us at Citrus Innovations Attn: Managing Director, Level 25, 50 Bridge Street, Sydney, NSW, 2000. We’ll do our best to respond within 30 days. If it is going to take longer, we’ll let you know and agree to more time.
There are some situations where we are allowed to refuse or limit your access to information, for example when the information is commercially sensitive. If that happens, we’ll write to you and let you know why.
There is no charge for making a request to access your personal information. However, in some cases there may be a charge to cover the time we spend locating, compiling and explaining the information you ask for. If there is a charge, we will provide an estimate prior to any action and confirm that you wish for us to proceed.
How can you make a complaint about privacy?
If you ever have an issue or complaint in relation to privacy, please contact us via the channels listed at the start of this section.
We take privacy related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest and fair in dealing with your concerns. We’ll contact you within five (5) working days of receiving your complaint to let you know what actions we are taking regarding the matter.
How can you escalate unresolved privacy complaints?
If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you can ask for your concerns to be escalated to the AMP Privacy Officer by:
Email support@joincitro.com.au
Mail Citrus Innovations Pty Ltd, Attn: Managing Director, Level 25, 50 Bridge Street, Sydney, NSW, 2000
Alternatively, you can contact an external body:
– If your complaint is about how we handle your personal information you can contact the Office of the Australian Information Commissioner (OAIC) on:
– 1300 363 992
Links to third party websites
Our website has links to external third party websites that may benefit the user.
External websites should contain their own privacy statements and we recommend that you review them when using their websites. Please note, third party websites are not covered by this policy and these sites are not subject to Citro’s privacy standards and procedures.
Website analytics
Website analytic measurement software is used to assist in tracking traffic patterns to and from our websites, anonymously surveying users of the sites. The system is used to collect such information as the number of unique visitors, how long those visitors spend on the website when they do visit and common entry and exit points into and from the website.
The non-personal information is collected and aggregated by third party software and provided to us to assist in our analysis of our website.
About this policy
This policy is effective 25 July 2024. We will update this policy when our information handling practices change and any amendments will apply to the information we hold at the time of the update. We will post the updated policy on our website. We encourage you to check our website from time to time to view our current policy or contact us for a printed copy.