6. Finder Group Privacy & Cookies Policy

6. Finder Group Privacy & Cookies Policy

6.1 Introduction

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

Finder and the affiliated Finder entities 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 Collection of information

We try to only collect personal information which is reasonably necessary for, or directly related to, the particular function or activity we are carrying out. In addition to our requirements for business operation, we are required to collect personal information and verify the identity of users of our Services pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and the Anti-Money Laundering and Counter-Terrorism Financing Rules.

The main way we collect personal information about you is when you give it to us, usually by webform, email, and telephone or when you register or sign in using your Google login details or Apple ID ("linked accounts").

6.4.1 When you register an account:

Information including name, addresses, emails, telephone numbers, Finder member user details where relevant. We may collect other applicable information using a webform.

When you register or sign in to the Online Platform using your Google login details or Apple ID, you give Google or Apple (as applicable) permission to share with us your first name, last name and email address. If you already have a Finder account registered with the same email address, your existing Finder account may be linked with the login details of your linked accounts. For Apple ID, you can also choose to hide your email address from us and Apple will instead provide us with a random email address which will be linked to your Finder account.

Please note: you can request us to update the email address linked to your Finder account by contacting our support team. You can unlink your Google login details in your "Linked Accounts" page of your Google Account. You can unlink your Apple login details using the "Sign in with Apple" or "Apps Using Apple ID" settings of your Apple ID account settings.

6.4.2 Account verification:

We may collect information to enable us to process verification of your account information and so we can authenticate who you are.

6.4.3 Using our services, or buying or selling:

Information you provide when you communicate with us, or information you provide including transaction information and payment information, which may include bank details. We also may collect information if you make a complaint, have a dispute and if we investigate conduct related to use of our services.

6.4.4 When you contact us:

This includes information gathered through webforms, email, or other means of communication between you and us, and where relevant between you and the other party to a transaction.

6.4.5 Indirect information:

We may collect information from someone authorised by you, and you may authorise to collect information on your behalf from a third party, for example, a credit score or credit header file or similar collated information.

6.4.6 Using your account:

This can include items you have purchased (as a buyer) or sold (as a seller), search history, communications, and other information which you may give us to help with identifying which products you may be interested in.

6.4.7 Browsing our Online Platform:

We may collect information from your browser, and device, including IP address, geographical location, search terms, device description, device operating system, browsing times and dates, user ID, location information, page view statistics, website traffic information, referral url, web log information.

6.4.8 Direct Marketing:

We may use the personal information we collect for direct marketing. This includes receiving emails and sms messages from us. If you do not wish to receive direct marketing, please contact us in writing with your request. Please note that we may not be able to continue to provide our Services to you if you opt out of direct marketing.

6.4.9 Cookies:

We may collect information using cookies and similar technologies, relevant to viewed pages, followed links, and other browsing behavior. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

6.4.10 Other sources:

We may get information from 3rd parties which are used to verify your identity, publicly available information, information from other users, and credit related information which is lawfully available to us.

We may get information from 3rd parties which are used to verify your identity, publicly available information, information from other users, and credit related information which is lawfully available to us.

We may also get anonymised and aggregated insights and reports that include information about demographics, preferences and interests, to help us understand the effectiveness of an advertising campaign or the composition of the audience that viewed certain advertisements or content on our Site (for example, a measurement report that tells us an advertisement was seen by "70,000 females between the ages 24-30 in New South Wales". We get such information through the Nielsen proprietary digital measurement software embedded in our Site. Nielsen's measurement software allows users of our Site to contribute to market research engaged in by Nielsen, such as through its Digital Content Ratings service. To learn more about the information that Nielsen measurement software may collect and your choices with regard to it (including how to opt-out), please see the Nielsen Digital Measurement Privacy Policy at https://www.nielsen.com/legal/privacy-principles/digital-measurement-privacy-statement\.

6.4.11 General:

We collect personal information which is reasonably necessary for the functions or activities of our business. We will only collect information by lawful and fair means and not in an unreasonably intrusive way.

6.5 Anonymity and pseudonymity

Where possible, and if you so choose, we will interact with you anonymously. However, if we do not have relevant personal information, we may not be able to provide our services to you.

6.6 Third Parties

Our Online Platform may contain hyperlinks to websites owned and operated by third parties, and advertisements by independent third party sellers. These third party sellers, and third party websites may have their own privacy policies and are also likely to use cookies, and we, therefore, urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

6.7 What we use, retain and disclose

Our use of your personal information will always have a lawful basis, either because you have consented to our use of your personal information or because it is reasonably necessary to provide our services and undertake our activities.

We use your personal information for the following purposes:

• we provide a personalised service, including using our services, using our platform interface;
• answering your general queries about financial products, credit products and related matters;
• correspondence with you or as directed by you, or on your behalf;
• carrying out advertising, marketing and educative training or promotional activities;
• to understand the effectiveness of an advertising campaign or the composition of the audience that viewed certain advertisements or content on our Site;
• to facilitate marketing from third parties;
• to detect and investigate fraud and other unlawful activities;
• to contact you;
• to improve our services;
• to provide technical and customer services;
• to provide feedback to you;
• to provide subscription services which you have consented to receiving including emails and newsletters;
• carrying out competitions;
• helping you identify products or services which may be appropriate for you;
• referring you to product and service providers;
• in connection with a corporate transaction such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy;
• where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so that we can offer a more relevant, tailored experience and where appropriate
• we provide your personal information to third parties for purposes related to providing our services, including for regulatory requirements, processing transactions and identification.

We may also use your information to provide you with offers, location based services, and to directly contact you using email, sms, telephone and postal mail for purposes including customer services related matters which includes technical issues, disputes, general assistance, collecting and refunding payments, and surveys. We may also use personal information to enforce agreements.

We may use information which we hold about you to show you relevant advertising on third-party sites (e.g. Facebook, Google). This could involve showing you an advertising message where we know you have a Finder account and have used Finder services. If you don't want to be shown targeted advertising messages from Finder, or its affiliated entities, some third party sites allow you to request not to see messages from specific advertisers on that site in future.

We store personal information for as long as we require it for our business purposes and legal compliance. We store personal information to stop criminal activity, to collect any overdue fees, to resolve disputes, to deal with technical problems, enforce our agreements, and for other purposes under Australian laws. We have security measures in place to protect your personal information.

Your personal information may be shared with third parties and other companies in the Finder Group in order to provide services to you, to identify you, to obtain your credit score if consented to, to enable us to undertake marketing and advertising related activities, for research purposes, to detect or investigate unlawful activities, to meet our legal and compliance policy requirements, and for transaction processing.

We may transfer your personal information to overseas recipients, including other businesses in our group, which may result in your personal data being transferred between, and stored on, servers in Europe, Australia and other countries.

We may also access, hold and use aggregated information about the people that use our services. Aggregated information won't identify you or any other individual but simply provides us with non-personally identifiable data that we'll use to improve our services, understand our users' needs and develop tailored content. We may disclose this aggregate information to third parties for purposes including research and publishing statistics related to our business. Although you would have provided us with the information we aggregate for these purposes, it won't identify you or enable you to be personally identified.

If we do not need your personal information for any or the purposes set out in this policy, or as required by law, we will take reasonable steps to de-identify or destroy the information.

By registering an account with us, or by using our Site or Services, you consent to us collecting, holding and using your personal information in this way.

6.7.1 About Google Analytics:

On our Site, we use the analysis tracking tool Google Analytics. Google Analytics is a tracking tool that serves to analyse the data traffic on our website.

To make Google Analytics work, a tracking code is built into the code of our Site. Using this tracking code, Google then assigns its own unique ID ("Google ID") associated with your browser cookie to you. This way, Google Analytics recognises you as a new user. The next time you visit our Site, you will be recognised as a "returning" user. All data collected by Google is stored together with this Google ID to make it possible for Google to evaluate pseudonymous user profiles.

Click here to learn more about Google Analytics and how Google handles your data due to our use of Google Analytics.

Why do we use Google Analytics on our website?

With the help of the reports we receive from Google Analytics through identifiers like cookies and the Google ID that Google assigns to you, we can better tailor our Site and Services to your preferences, based on your interactions with our Site.

To be more specific, the types of Google Analytics data and reports we may receive about your behaviour, and what they tell us include:

• Browser and Device Info: Technical information about the device and web browser of Site users. For example, when you view a product on our Site via a smartphone and only buy the product later via a laptop, this helps us make sure our Site works well on different devices. It also informs our cross-device remarketing campaigns. (Remarketing is when we show Site users our offer on other websites).

• Session Info: Data about visits and how users interact with our Site, including which path they take. For example, how long users stay on our Site and the actions (including search history and links clicked) that they perform whilst on it. This also includes:

• Real-time Reports which, for example, tell us what is happening on our Site at any moment in time, such as how many users are currently browsing a particular page on our Site; and

• Conversion Reports: which explain to us the process a users on our Site follows to perform a desired action based on a marketing message. For example, when you go from a mere Site users to a member (due to creating a Finder account) or newsletter subscriber. We use these reports to learn more about how our marketing activities are received by you. This helps us increase our conversion rate.

• Advertising reports: These help us to analyse and improve our online advertising.

• Acquisition reports: These give us helpful information on how we can get more people interested in our Service.

Ads Personalisation through Google Signals

Google Signals is a feature within Google Analytics that provides additional insights on an anonymised and aggregated basis only, into user behaviour and demographics, when users have ads personalisation turned on.

You can control personalised ads on Google by visiting "My Ad Centre". You can configure what ads you are shown (if you enable this feature), or choose to turn it off and disable it entirely if you previously opted-in.

Through Google Signals, we receive anonymised and aggregated data for the purposes of:

• Enhanced Cross-Device Reporting: Google Signals allows us to see how users interact with our website or app across different devices (e.g., smartphones, tablets, desktops) when they are signed in to their Google accounts. This helps us understand the user's journey and which devices they use in the conversion process.
• Demographics and Interests: With Google Signals, we can access aggregated and anonymised demographic and interest data about our users. This includes age, gender, and interests like sports, travel, or technology. This information can be valuable for tailoring our marketing campaigns to specific audience segments.
• Remarketing: We can create more effective remarketing campaigns by using Google Signals data. It enables us to re-engage with users who have interacted with our website or app, potentially increasing conversions.
• Cross-Device Conversions: Google Signals helps us to understand how users move between devices before they convert. This insight can be valuable in optimising our marketing strategy to accommodate multi-device user behaviours.
• Enhanced Conversions: With Google Signals, we can measure conversions more accurately, giving us a clearer picture of the effectiveness of our marketing efforts.
• Benchmarking: We can compare our website's or app's performance to others in our industry. This benchmarking data can help us to identify areas where our business may need improvement.
• Insights for Tailored Advertising: Google Signals provides insights into how different user segments interact with our content. This information can be used to create more personalised and effective ad campaigns based on the anonymised and aggregated data we receive.

6.8 Security

Your information is protected by security measures, including data encryption, access controls including physical controls and information access controls, firewalls. If you believe your account has been compromised, please contact customer services at help@finder.com.

6.9 Your rights and choices

6.9.1 Accessing and correcting your personal information

We aim to ensure personal information is accurate, up-to-date and complete. Please ensure that you provide us with accurate information.
You have the right to ask for access to personal information that we hold about you, and ask that we correct that personal information and we must respond within 30 days. Following your access request, we must give you access to your personal information and we must take steps to correct it if we consider it is incorrect, unless we are prevented from doing so under a relevant law.
We will require you to verify your identity before we give you access to your information or correct it. If we refuse to give you access, or correct it, we must notify you in writing of the reasons. If we have disclosed your information to a third party, and it has since been corrected, you can request us to tell them about the correction. If we refuse to correct the information, you can request that we associate it with a statement that you believe the information is incorrect and why.

6.9.2 Opt out of Nielsen Measurement

You can opt out of market research by Nielsen measurement by following the instructions set out in Nielsen's Digital Measurement Privacy Statement: https://www.nielsen.com/us/en/legal/privacy-statement/digital-measurement.

6.10 How to make a complaint

If you decide to make a complaint to us about how your personal information has been handled, you should write to us by email or post setting out the circumstances of your complaint, and how you wish for it to be resolved.
Following receipt of your complaint, we will consider your complaint, and decide what action to take. If we decide that the complaint should be investigated, it will be handled by a more senior person than the person who the complaint is about. We will respond to you within 30 days.
If you need additional information about the Australian Privacy Principles, the Privacy Law or our obligations you can also access the website of The Office of the Australian Information Commissioner (http://www.oaic.gov.au/).

6.11 How to contact us

If you want to arrange access to your information or have questions about privacy or the use of this site, please email privacy@finder.com or write to us at:
Privacy Team
Finder Group
Level 10, 99 York St,
Sydney, NSW, Australia 2000

Date: 14 December 2023