Privacy Notice and Policy

Meaning of words

In this policy, the following applies:

We”, “us” and “our” means Team Thrive Pty Ltd ACN: 637 676 496 (Thriday).

you” and “your” means the person that the terms of this document apply to.

  1. Privacy notice

Find out how we collect and handle personal information about you, and how to contact us if you have questions or would like to make a privacy complaint.

Collecting personal information about you

Generally, we collect personal information directly from you. We do so when you when you open an open an account, or perform a transaction with us.

We collect, use, hold and disclose personal information about you so that we (or our business partners as set out below) can:

  • establish your identity as required by the Anti-Money Laundering and Counter Terrorism Financing Act
  • assess your eligibility as a customer
  • process applications for products and services
  • operate our (and our business partners) products and services that you use
  • manage our risks and help identify and investigate inappropriate and illegal activity, such as fraud
  • comply with our legal obligations to assist law enforcement agencies or regulators
  • inform you about products or services that we think may be of interest to you, including those of our business partners.

What happens if you do not provide us with sufficient personal information about you?

If you do not provide us with the personal information we need, we may not be able to provide you with the products or services you are seeking.  We will let you know if this is the case and you will need to decide whether our products and services are right for you.

To whom do we disclose personal information?

We have business partners that we transmit your personal information to in order to provide you our products and services.  

Our main business partners we transmit your personal information to if you use our products and services are:

  • Regional Australia Bank Ltd ABN 21 087 650 360 AFSL & Australian Credit Licence 241167  
  • POP Business Pty Ltd ABN 52 629 385 486

The type of entities and people we (or our business partners as mentioned above) disclose your personal information to include:

  • organisations which provide or confirm information to verify your identity (our business partners complete this verification)
  • contractors for things like card production and delivery
  • brokers, agents and advisers acting for you if you have consented to them receiving information
  • persons and organisations who assist us in monitoring recorded calls for the purposes of quality assurance, training and acknowledgement, including our business partners
  • lenders’ and valuers if we offer lending products in the future
  • our auditors, insurers and re-insurers
  • government and law enforcement agencies or regulators
  • credit reporting bodies and other credit providers
  • organisations that help identify and investigate inappropriate or illegal activity, such as fraud.

Electronic verification of identity

As noted above, our partners are required under the Anti-Money Laundering and Counter-Terrorism Financing Act to collect and verify information relating to your identity. Subject to your consent, we will disclose your name, address, date of birth and Australian business number in order to access identification information electronically held by credit reporting bodies, the government’s Documentation Verification Service (DVS) and other public records.

To access such information, our business partners may use a service provider. The service provider, may, for verification purposes on our or our partners behalf:

  • request that a credit reporting body provide us with an assessment as to whether your personal information matches that held in their credit information files. (In preparing this assessment, the credit reporting body may use the personal information of other individuals);
  • disclose your personal information to the DVS;
  • search other public records.

If we are unable to verify your identity using the above methods, you will be provided with a notice to that effect. You may then be asked to provide further evidence of your identity. If we are unable to verify your identity to our satisfaction, we will not be able to provide you with the services or products you seek.

Our Privacy Policy

Our Privacy Policy is set out below.  It contains information about:

  • how we collect, use, hold and disclose your personal information
  • how you can access personal information about you
  • how you can seek correction of that personal information
  • how you may complain if you think we may have breached your privacy
  • how we will deal with your complaint and
  • how we manage credit information.

Sending information overseas

Depending on our commercial arrangements, we may disclose personal information about you to business partners with operations overseas or who store personal information overseas.

Our business partners may send and store your personal information in servers operated by service providers including Amazon Web Services and Microsoft Azure in the United States of America.  

When partnering with another business that your personal information may be sent to, we ensure that the entity complies with privacy and information security requirements that are commiserate with those that apply in Australia and our own Privacy Policy.

By becoming a customer and using our services, you consent to your personal information being sent and stored in the United States of America and the European Union and acknowledge that the business partner will not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

Find out how we collect and handle personal information about you, and how to contact us if you have questions or would like to make a privacy complaint.

  1. Privacy Policy

Context

This privacy policy (Privacy Policy) is to be read in conjunction with the Privacy Notice above and explains how we handle personal information.  It is relevant to current customers and other individuals with whom we deal in the course of our business — such as prospective members and customers, account signatories, holders of powers of attorney, legal personal representatives and the like.

Meaning of words

In this Privacy Policy, the following applies:

We”, “us”, “our” and “Thriday” means Team Thrive Pty Ltd ACN: 637 676 496.

you” and “your” includes our customers (being an individual or other entity) as well the other individuals referred to above with whom we deal in the course of our business.  

1. Our commitment

We value your trust in us. It is important for us to keep personal information about you secure and confidential.  That’s why protecting your information and being clear about what we do with it is a vital part of our relationship with you.

To achieve this, we comply with the Privacy Act 1988 (which includes the Australian Privacy Principles and Part IIIA) (Privacy Act).

Please note that during the course of our dealings with you, we may provide more information about how we handle personal information about you. If that further information provides that we may do this in a way that is different from this Privacy Policy, then the terms of that further information will prevail.

2. About us

We are an Australian owned financial technology company and operate under the brand “Thriday”.  It is our goal to create services for small to medium size business to help them thrive in their business.  

We have business partners that we transmit your personal information to in order to provide you our products and services.  

Our main business partners we transmit your personal information to if you use our products and services are:

  • Regional Australia Bank Ltd ABN 21 087 650 360 AFSL & Australian Credit Licence 241167
  • POP Business Pty Ltd ABN 52 629 385 486

3. Information we collect

Information we collect from you

Generally, we collect personal information about you directly from you and our business partners. We do so when you become a customer, open an account, or perform a transaction with us (and/or our business partners).  

The kind of information we collect will vary according to whether, for example, you wish to open a transaction account, use an accounting or bookkeeping software service or act as a signatory.  

When you subscribe to our products and services, we and our business partners collect your personal information – including your name, email, phone number, Australian business number, customers, transactions, such as payments to and from your transaction account and the details of those payments, including source and destination.  We collect this information via our business partners such as, but not limited to:

  • authorised deposit taking institutions (banks);
  • card payment providers;
  • accounting partners.


Our business partners have “KYC” and “KYB” obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006. “KYC” stands for “Know Your Customer” and “KYB” stands for “Know Your Business” which means we are required to pass certain information to our partners so that they can verify that you are who you say you are and so they can comply with their obligations to monitor account and transaction activity.  Our partners use additional third parties that specialise in cross checking your information and provide results to our partners and in turn, us.

When you subscribe to our products and services, we usually ask for, at least, your full name, date of birth, residential address, contact details and Australian business number.  If you are subscribing as a corporate or other entity, we will ask for details of that entity, including beneficial ownership and the names and personal details of office holders.  In all cases, we will also ask for evidence of your identity.  In all cases, we may collect further information at any time on our own behalf or on behalf of our partners so that they meet their obligations under the KYC requirements of the anti-money laundering and counter-terrorism legislation.

When you use our website or mobile applications we may collect information about your location or activity. Some of this website information we collect using cookies. Please refer to our Website Terms and Conditions for more information about cookies.

Information we collect from third parties

We may also collect information about you from third parties such as databases managed by Federal and State governments.

Sensitive information

We may need to collect sensitive information, where necessary for insurance or hardship applications.  

What happens if you do not provide us with sufficient personal information about you?

If you do not provide us with the personal information we need, we may not be able to provide (or continue to provide) you with the products or services you are seeking or using. This means that we may close your accounts and terminate our relationship with you.  

4. How do we use your information?

We collect, use, hold and disclose personal information so that we or our partners can:

  • establish your identity as required by the Anti-Money Laundering and Counter Terrorism Financing Act 2006
  • assess your eligibility to become a customer
  • process applications for products and services
  • operate products and services that you use
  • design our products and services
  • manage our relationship with you
  • submit information to government agencies on your behalf when directed by you to do so  
  • manage our risks and help identify and investigate inappropriate or illegal activity, such as fraud
  • contact you
  • improve our products and services and your experience with us
  • comply with our legal obligations to assist law enforcement agencies or regulators
  • inform you about products or services that we think may be of interest to you, including those of our business partners

5. To whom do we disclose personal information?

Third parties

As mentioned above, we have business partners that we transmit your personal information to in order to provide you our products and services.  

The type of entities and people we (or our business partners as mentioned below) disclose your personal information to include:

  • organisations which provide or confirm information to verify your identity (our business partners complete this verification)
  • contractors for things like card production and delivery
  • contractors who assist us with direct marketing and market research
  • persons and organisations who assist us in monitoring recorded calls for the purposes of quality assurance, training and acknowledgement
  • persons acting on your behalf, for example brokers, agents, advisers, guardians, financial managers and persons holding power of attorney
  • persons involved in arrangements that provide funding to us, including trustees and managers of loan programs
  • ratings agencies
  • other financial institutions, for example so that we can process a claim for mistaken payment    
  • our auditors, insurers and re-insurers
  • lenders’ and valuers if we or our partners offer lending products in the future
  • government and law enforcement agencies or regulators
  • credit reporting bodies and other credit providers is we or our partners offer lending products in the future
  • organisations that help identify and investigate inappropriate or illegal activity, such as fraud.

Sending information overseas

Depending on our commercial arrangements, we may disclose personal information about you to business partners with operations overseas or who store personal information overseas.

Our business partners may send and store your personal information in servers operated by service providers including Amazon Web Services and Microsoft Azure in the United States of America and the European Union.  

When partnering with another business that your personal information may be sent to, we ensure that the entity complies with privacy and information security requirements that are commiserate with those that apply in Australia and our own Privacy Policy.

By becoming a customer and using our services, you consent to your personal information being sent and stored in the United States of America and European Union, and acknowledge that the business partner will not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

Electronic verification of identity

As noted above, our partners are required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to collect and verify information relating to your identity.  

Subject to your consent, we will disclose your name, address, date of birth, Australian business number and other information in order to access identification information electronically held by credit reporting bodies, the government’s Documentation Verification Service (DVS) and other public records.

To access such information, the partner may use a service provider.  The service provider may, for verification purposes on our partners behalf:

  • request that a credit reporting body provide us with an assessment as to whether your personal information matches that held in their credit information files. (In preparing this assessment, the credit reporting body may use the personal information of other individuals);
  • disclose your personal information to the DVS;
  • search other public records.

If we or our partners are unable to verify your identity using the above methods, you will be provided with a notice to that effect. You may then be asked to provide further evidence of your identity. If we or our partners are unable to verify your identity, we will not be able to admit you to provide you with the services or products you seek.

6. Keeping your information secure

We hold personal information in our system and our partners’ systems, either as electronic, voice or paper files.

As we have a commitment to ensure all personal information is held securely, we have in place security systems to protect information from unauthorised access. We also limit access to our authorised personnel.

Where personal information is no longer needed for any of our or our partners functions or activities, subject to any legal requirements for holding data for a period of time, we ensure that the information is securely destroyed or de-identified.

We seek our partners to do the same with personal information we have transmitted to them that they hold.

7. Accessing and correcting personal information (including credit information) about you

Accessing personal information about you

You can request access to your personal information by writing to wecare@thriday.com.au  

and providing details of your request.  

Is a fee charged?

We may charge you a fee for providing access to personal information about you. That covers our time spent in locating and putting the information together.

Updating and correcting information

It’s important that we have your correct details, such as your current address and telephone number. Please ensure that your details with us are always current.

You can also ask us to correct any information we hold if it is inaccurate. If we have passed that information on to third parties, then you can ask us to contact those other parties.

If your request for access and correction involves credit-related information provided to us by others (e.g. credit reporting bodies or other credit providers), we will need to contact them.

We’ll try to have the information corrected within 30 days. If we can’t meet that, we’ll let you know the reason for the delay and try to agree a timeframe with you to extend the period.

We’ll contact you when the process is complete.

What if we cannot agree that the information should be corrected?

If we do not agree with you that information should be corrected, we’ll advise in writing with our reasons. You can ask us to include a statement with the relevant information, indicating your view that the information is inaccurate, misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.

8. Making a privacy complaint

How do I complain about a privacy matter?

To lodge a complaint, please contact us using the details set out at the end of this Privacy Policy. We will deal with the matter via our internal complaints processes.

External review

If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA).  AFCA provides fair and independent financial services complaint resolution that is free to consumers.

You can contact AFCA as follows

Website: www.afca.org.au
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
Mail: Australian Financial Complaints Authority GPO Box 3, Melbourne VIC 3001

You may also contact the Office of the Australian Information Commissioner at:

Website: www.oaic.gov.au
Phone: 1300 363 992
Mail: Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001

9. Amending this Privacy Policy

We may amend this Privacy Policy at any time. The new version will be published on our website.

10. How to contact us or find out more

For all privacy-related queries, requests for access and correction, complaints, or any other requests, or to request a printed version of this Privacy Policy, use any of the methods set out below. You can also contact us to change your marketing preferences.

Email: wecare@thriday.com.au