Our Privacy Policy applies to Douugh and Douugh Academy  ('us' 'we' or 'our'). It sets out how we collect, use, store and disclose your personal information as we are required under the Privacy Act 1988 (Cth) ('Privacy Act').

When you provide personal information to us, we will collect, use and disclose your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

This Privacy Policy applies when you create an account with Douugh via our mobile application or website and access or use our products and services, including our investing, spending, budgeting and expense tools and short-term credit product. By creating an account with Douugh, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.

This notice applies across all websites that we own and operate and all services we provide, including mobile apps, and any other apps or services we may offer (for example, events or training), as well as in relation to all offers and third-party relationships.

We may need to update this notice from time to time. Where a change is significant, we’ll make sure we let you know – usually by sending you an email.

This Privacy Policy replaces all previous versions, and our latest version is available from our website.

We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store, share and disclose your personal information.

If you have any questions about this document please email us at help.au@douugh.com

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.

Any information that may be required in order to facilitate your dealings with us. This typically includes the following;

We may your personal information either directly from you, or indirectly from third parties.register on our website or app and use our products and services;

• communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; or

• interact with our sites, services, content and advertising.

If you do not provide the information requested by us, we may not be able to provide you with our products and services.

There may be occasions when information is collected from third parties for example through our business partners, third party identity verification services providers or from publicly or commercially available sources for the purposes of complying with applicable laws and regulations, for example, anti-money laundering laws.

We may also collect personal information if you enter a promotion we run or if you apply for employment with us either directly or through a recruitment or employment agency.

We may also collect the personal information of our third party service providers and their staff during the course of our business activities. This information may include your name, contact details and position. We will collect this information directly from you, or from the applicable third party service provider.

By law, we can only collect information that is reasonably necessary to provide our services.

Our reason for collecting necessary information may be:

• We, and/or our partners, need it in order to provide our services.

• To meet our legal or regulatory responsibilities.

• To adhere to our contracts and agreements, in order to provide our services.

Where you’ve agreed to us by providing your information, you indicate you’re happy for us to use your personal information where lawful and necessary.

We may collect, hold, use and disclose your personal information for the following purposes:

• to enable you to access and use our website and services (as set out in our Terms & Conditions).

• to operate, protect, improve and optimise our website and services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;

• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

• to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

• to consider your employment application.

• We may disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it, and us, to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

By agreeing to this Privacy Policy you confirm that we and/or our carefully selected business partners may send you direct marketing communications and information about your account, our service and products. This may take the form of emails, SMS, in-app notifications, mail or other forms of communication. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

We may disclose personal information for the purposes described in this privacy policy to:

• Our employees and related bodies corporate;

• Our existing or potential third party suppliers and service providers in connection with providing you products or services or those existing or potential suppliers and providers improving the products and services provided to you. This may include (without limitation) payment systems operators (e.g. merchants receiving card payments or funds transfer), foreign exchange providers, brokers and dealers, and partners who facilitate the deposit and custody of funds;

• Other existing or potential third party suppliers and service providers (including providers for the operation or optimisation of our websites and/or our business or in connection with providing you, or improving our, products and services);

• Our existing or potential agents, professional advisers, business partners or partners;

• Our sponsors or promoters of any competition that we conduct via our services;

• Anyone to whom our assets or businesses (or any part of them) may be transferred;

• Specific third parties authorised by you to receive information held by us; 

  • Specifically we will provide this information to INMO Capital Pty Ltd who are required to collect your Personal Information so that together we can establish and administer the Card and Pay Now, Pay Later products provided to you.

  • Note. Your Personal Information will be used to complete a ‘soft credit’ check which is a requirement to provide Card and Pay Now, Pay Later products to you. A soft credit check will be an inquiry into your credit report initiated either INMO Capital Pty Ltd. It is primarily used to screen for pre approval financing offers or for a background check. A soft inquiry does not affect your credit score, which is a numerical representation of your creditworthiness that creditors use to determine if they should extend credit to you.

• Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law (including for the purposes of AML/CTF collection and verification).

To provide you with the services, we may disclose personal information internationally to any of our partners, including but not limited to our US Broker-Dealer (DriveWealth, LLC, “DriveWealth”) located in the United States of America and to any regulatory bodies as required by law or our foreign exchange partners. By opening an account with DriveWealth, you consent to them using your personal information in accordance with their privacy policy.

Due to the international nature of our services, we use partners and providers that may be based overseas and we may be required to share your information with them. When you provide your personal information to us, you consent to the disclosure of your information outside of your country of residence and acknowledge that we cannot guarantee that such partners or providers will handle your personal information in compliance with the laws and practices of your local market. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with such principles and legislation that we adhere to.

The data we collect from you may be transferred to and stored somewhere outside of your local jurisdiction if we have specific agreements and/or due diligence in place. In certain circumstances it may also be processed by staff outside of Australia and those who work for us or a select third party.

Cookies are text files that are placed on websites on the internet. Each cookie includes the name of the website and a unique ID. We use cookies on this website.

Cookies track things like how long a visitor spends on our website and what visitors do on our website (which pages they visit and which buttons they click on, for example). Cookies collect this information and share it with us, the website owner.

Cookies help us understand who uses our website and how we can improve it. For instance, we can understand which pages of our website are most popular with certain kinds of visitors. This allows us to understand what visitors like about our website and how we can make it more attractive for other visitors.

How do we use cookies?

As we set out above, we use cookies on the Douugh website. Cookies help us to understand how our users interact with our website.

Most of the cookies we use on our website are 'persistent' cookies. This means that they remain on your device until you erase them or they expire. The rest of these cookies are 'session' based, which are more temporary in duration. This means they will be erased when you close your internet browser.

We use these kinds of cookies on douugh.com:

• Cookies to help keep you and Douugh safe (you can't turn these off)

• Cookies to give you a better experience (you can turn these off)

• Cookies to help show you more relevant ads (you can turn these off)

We use the following types of cookies:

• Necessary cookies

Necessary cookies are placed on our website by default. You can turn off these cookies on your device if you don't want us to use necessary cookies, but it might impact your ability to browse our website. We need necessary cookies to help us to run our website and to help us detect any problems with it. For example, we use a cookie that tells us how busy the server is based on the number of visitors and that tells us if any users experience problems so that we can resolve the problems as soon as possible.

We also use cookies to remember our users while they are browsing our website, its pages, links and subdomains. For example, we use necessary cookies to help recognise you and provide you with content as you browse the website. We may also use a cookie that tracks your cookie privacy preferences so that we do not place analytics and advertising cookies, which we'll talk about below, if you don't want us to. This particular type of cookie will remain on your device even after you've stopped browsing the website so we can make sure we comply with our legal and regulatory obligations.

• Analytics and advertising cookies

These allow us to recognise and count the number of visitors to our website, and see how visitors browse our website, so we can understand how our website content is performing and improve it where necessary. We use third-party cookies for this purpose, and we've explained below the specific cookies we use.

Advertising and analytics cookies also allow us to see what pages, links and sub-domains visitors have visited so we can provide more relevant ads. We may share this information with other organisations, such as Google, Facebook and LinkedIn, for the same purpose.

Please see the section below for more detail about which advertising and analytics cookies we use and why.

Please refer to our Cookies Policy found here for more details. 

We may hold your personal information in either electronic or hard copy form. We store any electronic information on secure servers through Amazon Web Services.

We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we encrypt all data and have it stored in secured facilities. However, we cannot guarantee the security of your personal information.

As your personal information is available inside the Douugh app or website, we require you to set a strong password when creating an account and either set up multi-factor authentication or use a one-time password sent to your email upon each login. We request that you do not share your password with anyone and it remains confidential.

By law, we need to store information about you for 7 years.

Ordinarily, we will not hold your personal information for more than this period after our relationship with you has ceased, unless required by law or due to an ongoing claim.

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over your rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Under all circumstances, you have the following rights:

• Access: You have the right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; and details about how and why it is being used.

• Correct and update your information: If any of the information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request any necessary amendments be made.

• Opt-out of direct marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.

• Make a complaint: If you have any complaints or concerns about our handling of your personal information please do get in touch with us and we will do our best to resolve these. You can contact us at help.au@douugh.com. Please see our consolidated “Making a complaint” section below for more detailed information.

If you would like to exercise any of these rights, you can log into your account or email us at help.au@douugh.com. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

If you think we have breached any of the Australian Privacy Principles, as it applies to you, or you wish to make a complaint about the way we have handled your personal information, you can contact us at help.au@douugh.com.

Please include your name, email address and/or telephone number and clearly describe your complaint. For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

If you think that we have failed to resolve the complaint satisfactorily, you can telephone the Office of the Australian Information Commissioner on hotline 1300 363 992.

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us at help.au@douugh.com.