Update December 2023
This Privacy Policy (Policy) applies to Future Group Australian Holdings Pty Ltd and its related bodies corporate (Future Group, we, us, and our) including promotional and administration activities for Future Super, smartMonday, Verve, GuildSuper and Child Care Super. It outlines how we manage your personal information and safeguard your privacy.
At Future Group, we understand your concerns about privacy and the security of your personal information. Your privacy is important to us, and we are bound by the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles ('APPs'). We are committed to protecting the personal information that we hold about you.
To ensure compliance with the Privacy Act and as part of our commitment to ensuring the security of your private and confidential information, we have established and implemented this Policy.
Future Group will:
Future Group provides:
Personal information is information or an opinion that allows others to identify you. This includes your name, gender, contact details, as well as your health and financial information.
We will only collect personal information that is reasonably necessary to offer and administer our services and products, or to provide information about a service or product or any other information that you have requested from us. We will collect personal information only by lawful and fair means.
We may also collect personal information to:
If you are not a customer but interact with Future Group, we may collect information to identify and interact with you.
If you are a contractor or prospective staff member, we may collect information to allow us to carry out our recruitment functions, to correspond with you, to fulfil the terms of any contractual relationship and/or to ensure that you can perform your duties.
Personal information The type of information we collect will depend on the type of product or service you request. Examples of personal information we collect includes:
Sensitive information For some of our products and services, we may also need to collect sensitive information about you where the information is necessary for one or more of our functions or activities and you consent to the collection, or it is required or authorized by law. This may include:
Sensitive information will only be used for the purpose for which it was provided.
If you provide us with information about other individuals (such as employees, dependents, etc.) you must obtain their consent for us to use their information in accordance with our Privacy Policy prior to your disclosure to us or otherwise let us know if this is not the case.
You do not have to give us your personal information. However, if you choose not to, we may not be able to provide you with our products or services or more information about them. We might not be able to process your transactions or allow you to access our online services.
If you do not provide the information we request, you would like to remain anonymous or you want to use a pseudonym, we might not be able to provide the appropriate type or level of service or product.
Unless impracticable or unreasonable to do so, we will collect information directly from you. This might be when you contact us by telephone, email, letter or online in order to complete a product or service application, or any other kind of administrative form. Our emails may contain automatic features that collect personal information. You can engage with us through social media or our website, or through our mobile phone app.
If we are permitted by law to do so, we may collect information about you from third parties. We may collect this information from third parties such as our affiliates, Authorised Representatives, or other third parties such as employers, insurance companies, financial institutions, medical professionals, law enforcement, dispute resolution, statutory and regulatory bodies, marketing lists and industry databases, publicly available sources or other government bodies.
If you ask us, we will take reasonable steps to let you know how we have sourced your personal information, unless it is obvious from the circumstances that you would know or would reasonably expect us to have the information (such as where we are dealing with your advisers).
In most cases, we will obtain your consent to handle your personal information either at the time you engage us to provide you with a product or service, or as soon as practicable. Consent can be either express or implied. Where consent is requested, we will properly inform you what you are consenting to.
We may use your personal information to contact you to promote and market our products and services. You may modify or withdraw your consent, or opt-out of receiving direct marketing at any time by contacting the Privacy Officer (privacy@futuregroup.com.au).
If you receive electronic communications, such as an e-newsletter, you may unsubscribe at any time by following the instructions included in the communication.
If you previously chose to receive push notifications on your mobile device, you can manage your preferences either through your device or the application settings. Alternatively, you may uninstall the application by using the uninstall process available on your mobile device.
To prevent the use of cookies and the associated advertising, you need to adjust the settings on your browser to refuse all cookies.
Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.
Where we receive information that we have not requested (“unsolicited information”), we will determine whether we could have legally collected the information, and whether it is reasonably necessary for our functions or activities. If it is, we will handle the information in the same way that we handle information we have requested. If not, we will take steps to destroy or de-identify the information.
We will generally only use and disclose your personal information for the purpose that it was collected for, any related purpose that you would reasonably expect us to use or disclose it for, for the purpose of analytics, or as permitted under this Privacy Policy or under any law. Future Group otherwise has a duty to maintain the confidentiality of its clients’ information unless disclosure is permitted with your consent or compelled under any law.
Your information may be used for the following purposes to:
We may conduct data analysis and data analytics on customer information we hold. Generally, this information is based on aggregated data that doesn’t contain information that identifies individuals.
We may disclose your information to our affiliates or third party service providers to assist us in providing, managing and administering our services and products, such as:
We will only use and disclose your sensitive information for the purpose it was collected, for any other directly related purpose that you would reasonably expect us to use it for, or in accordance with a law or regulation. With your consent, we may use or disclose your information for additional purposes from time to time.
In addition to our affiliates, we may also disclose personal information to third parties such as our contractors, agents and service providers when we outsource certain functions, including market research, marketing, claims handling and recruitment. This would also include our third party storage providers whom we may use from time to time to store information physically or electronically.
Some of our contractors, agents and service providers are located outside of Australia, meaning your personal information may be disclosed to a recipient in other countries. We limit the use and disclosure of personal information to the purpose for which it was provided.
In addition, anonymised web traffic information is disclosed to third party analytics platforms when you visit our websites (who may store the information across multiple countries) and when you communicate with us through our social media applications, where the provider and its partners may collect and hold your personal information overseas.
We will not disclose your personal information to overseas recipients unless and until we have taken reasonable steps to ensure that the overseas recipient will handle your personal information in a manner consistent with the APPs, or you have consented to the transfer of the information.
We take reasonable precautions to protect and secure your personal information from misuse, interference, loss, unauthorised access, modification or unauthorised disclosure.
Your personal information is held by us electronically on secure systems provided by cloud service providers. It may also be held in hardcopy form, for example, in paper files which are archived in a secure facility. Personal information held electronically is secured by passwords, encryption and firewalls in line with Australian information security standards. We undertake audits and monitoring of staff access to our systems.
Your personal information is only retained for as long as necessary to fulfil the purpose/s for which it was collected, unless we are required to retain the information for a certain period of time under an Australian law or court or tribunal order. Once no longer required, we take such steps as are reasonable in the circumstances to destroy or permanently de-identify your personal information.
We ask that you help us keep your personal information accurate, up to date, and complete. You should contact us to update your personal information or advise us if the personal information we hold is not accurate, up to date, or complete. You may ask to see the personal information we hold about you and have it corrected if necessary. We will need to verify your identity before giving you access.
You can access or update your personal information as follows:
If we do not provide you with access or refuse to update your information, we will provide you with the reason for refusal and complaint options available to you.
If we incur a cost in giving you access to your personal information, we may need to charge you for the associated cost(s).
There may be exceptional circumstances where we cannot provide you with access to your personal information because of reasons outlined in the Australian Privacy Principles, or where we consider your request to be frivolous or vexatious. In these cases, we will advise you in writing why we cannot provide you with the information and information about how to make a complaint about the refusal.
If you have any questions, would like further information about our privacy and information handling practices, would like to discuss opt-outs, believe that your privacy has been breached, or you have a privacy complaint, please contact the Privacy Officer:
Attn: Privacy Officer Future Group (or one of its relevant bodies, e.g. Future Super, smartMonday, Verve, GuildSuper, or Child Care Super) Level 3, 31 Alfred Street Sydney NSW 2000
privacy@futuregroup.com.au
1300 658 422
1300 262 241
1300 799 482
1300 361 477
1800 060 215
We are committed to respecting your privacy, and we will respond to you as soon as reasonably possible. You can also refer to our Complaints Policy for information on how we manage and respond to complaints.
If you are not satisfied with the resolution of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner by one of the options below:
GPO Box 5218 Sydney NSW 2001
enquiries@oaic.gov.au
1300 363 992
Office of the Australian Information Commissioner
The internet is not a secure environment. If you use the internet to send us personal information, you do so at your own risk.
We make use of “cookies” technology on our websites. We use cookies to distinguish you from other users of our websites, improve the functionality of our websites, and to learn more about the way that users interact with our content.
You can disable the use of cookies through your internet browser preferences. Please note, if you choose to block all cookies, you may not be able to access all or a part of our websites and may be unable to engage in some activities.
We may also use tracking technologies called web beacons to collect information about your visit to our sites. Like cookies, this technology enables us to track pages and content accessed and viewed by users on Future Group sites. Also, when we send HTML-formatted (as opposed to plain text) emails to our users, this technology may be embedded in such emails. Using web beacons allows us to determine whether emails have been opened or links were accessed, and identify aggregate trends, individual usage, and generate statistics about how our site is used.
You can avoid web beacons by choosing to open emails in plain text. You can manage these settings through your email application.
Our websites use the Google AdWords remarketing service and similar services from other providers to advertise on third party websites (including Google) to previous visitors to our sites. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network or other sites. Third-party vendors, including Google, may distribute ads based on someone’s past visits to the Future Super websites.
Of course, any data collected will be used in accordance with our own privacy policy, Google’s privacy policy, or the privacy policy of other remarketing services used by Future Super.
You may be able to access external websites by clicking on links provided on Future Group websites. These websites aren’t subject to our privacy standards and procedures. Once you leave our websites, our privacy policy no longer applies. You’ll need to review those websites directly to view a copy of their privacy policies and to ensure your personal information is protected.
While we may use social networking platforms for communications, we won’t ask you to supply personal information publicly over these platforms. Sometimes, we’ll invite you to send your details to us via private messaging, for example, to answer a question you have raised about your superannuation account.
Any personal information that you contribute to the publicly accessible sections of social media applications can be read, collected, and used by other users of the application. We have no control over these other users and cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with our privacy standards.
As the supplier of the Program, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us. In the course of doing business with you, the collection of personal information in some instances is necessary or unavoidable. We are committed to protecting the privacy of all personal information that we collect and ensuring that your personal information is handled correctly.
All personal information collected by us will be treated in accordance with the Australian Privacy Principles (“APPs”) as contained in the Privacy Act 1988 (Cth). The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.
This policy details the type of personal information we collect from our customers, how we manages personal information about you, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices.
“Personal information” is information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or now. Information where we have removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.
The kinds of personal information that we may collect and hold from you or about you include: contact information, such as your name, postal address, e-mail address and telephone number; date of birth and gender; account information such as username, password and transaction history; information concerning your interests, buying habits and product preferences; and any other personal information submitted to us by you. We do not collect sensitive information (such as relating to your ethnic origin, religious or philosophical beliefs, membership of a political or trade association, sexual preferences or health), and would not do so without your consent.
When you browse our website or contact us electronically, we may record geographical tagging, cookies and statistical data. This may include your IP address, date and time of your visit, operating system, language preferences, device characteristics, pages visited, information downloaded and type of browser used to access the website.
We use this information to help us to make decisions about maintaining and improving our website and online services.
While our website may contain links to other websites with the exception of our related entities, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these third parties.
We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so. For example, we collect personal information from you or about you from information you submit to us when:
you apply for or request a product or service; when you participate in our call centre marketing campaigns, competitions or surveys; when you respond to our advertising and direct mail; you provide information to us via email or telephone; and when you have other dealings with us. However, in some circumstances, it is necessary for us to collect personal information through third parties or from a source of publicly available information.
If we receive personal information that we have not requested (unsolicited information) and we determine that we could not have collected that information under the APPs if we had requested it, then we will destroy or de-identify the information if it is lawful and reasonable to do so.
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide our services to you. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions For example, we may use the information obtained from you: to process your application for service and to establish and manage your account or facility, and carry out transactions you wish to make; to provide requested services to you, and bill you for our services and collect overdue payments; for our research and development of new products and services; for training, quality control and verification purposes (including monitoring and recording your telephone conversations with us from time to time); respond to and communicate with you about your requests, questions and comments; protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and comply with and enforce applicable legal requirements, relevant industry standards and our policies. If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to answer your enquiry, complete the transaction you have entered into, or provide our services to you to the best of our ability.
Your personal information is held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorized access, modification and disclosure.
We store personal information in a combination of secure Australian based computer storage facilities and paper based files and other records. We use industry accepted and compliant technology and security so that we are satisfied that your information is transmitted safely to us through the internet or other electronic means.
We also employ the following measures in order to safeguard your personal information: data held and stored on paper is stored in lockable offices and in secure premises; data held and stored electronically is protected by internal and external firewalls, limited access via file passwords, and files designated read-only or no access; data held and stored “in the cloud” is protected by internal and external firewalls, limited access via file passwords and files designated read-only or no access. We also require our IT contractors and other third parties to implement privacy safeguards; where we disclose personal information to third parties (including contractors and affiliated businesses located locally and overseas), our contractual arrangements with them include specific privacy requirements; and our staff receive regular training on privacy procedures.
We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose. We use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed: paper records are shredded or destroyed securely; and electronic records are deleted from all locations, to the best of our ability, or encrypted and/or placed beyond use
We respect the privacy of personal information and will take reasonable steps to keep it strictly confidential.
We will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected. Where such a disclosure is necessary, we will require that the third party undertake to treat the personal information in accordance with the APPs.
Generally, we may disclose personal information about you in the following circumstances: where we have contracted an external organisation to provide us with support services. This may include but is not limited to processing applications or orders, marketing support, deliveries, market research and debt collection. These service providers may be within or outside Australia; to comply with our legal obligations (we notify you any time we are required to produce information in this way unless we are prohibited by court order or law or there is suspicion of fraud and/or criminal activity); where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter; or Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is: necessary to protect or enforce our legal rights or interests or to defend any claims; necessary to prevent or lessen a serious threat to a person’s health or safety; required or authorised by law; or permitted by another exception in the Privacy Act. Where we wish to use or disclose your personal information for other purposes, we will obtain your consent. We impose strict requirements of security and confidentiality on all third parties as to how they handle personal information. We provide our outside contractors both locally and internationally, and retail affiliates only with information they need to perform their services - they are not permitted to use the information for any purpose except to provide the service to us. The Privacy Act also strictly controls the information we exchange with credit reporting agencies.
This Privacy Policy also applies in relation to our collection and use of credit information of individuals, in connection with commercial credit provided by us. The types of credit information that we collect and use for the purpose of collecting payments and/or making payments include: names, addresses and other contact details of accountholders (both prospective and current); bank account details; driver’s licence details; and financial information. We do not disclose credit information to credit reporting bodies.
We have procedures in place for dealing with and responding to requests for access to, and correction of, the personal information held about you. In most cases, we expect that we will be able to comply with your request. However, if we do not agree to provide you access or to correct the information as requested, we will give you written reasons why. For example, a request to access personal information may be rejected if: the request is frivolous or vexatious; providing access would have an unreasonable impact on the privacy of another person; providing access would pose a serious and imminent threat to the life or health of any person; providing access would prejudice our legal rights; or there are other legal grounds to deny the request. To assist us to keep our records up-to-date, please notify us of any changes to your personal information.
We have procedures in place for dealing with complaints and concerns about our practices in relation to the Privacy Act and the APPs. We will respond to your complaint in accordance with the relevant provisions of the APPs.
We may update our policies and this Privacy Policy Statement from time to time. The latest version is published within your Program Site.
If you have any questions about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please email us at privacy@ewallet.com.au