Privacy Policy

www.cashflowsmoothing.com.au is operated by Sinch Operations Pty Ltd (ABN 66 637 126 697) (“Sinch”) who is referred to in this Privacy Policy as “we”, “us”, “our” and similar grammatical forms.

By using the Sinch website, and by sending Invoices to Sinch, you are accepting the terms of this Privacy Policy, and you are consenting to our collection, use, disclosure, retention, and protection of your personal information as described in this Privacy Policy.

We respect and appreciate that your privacy is important to you. Sinch will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.

 

1. When do we collect information?

We ordinarily collect personal information about you for the following purposes:

  1. assessing and processing existing or future application(s) for credit as part of a Cashflow Smoothing Plan, managing your Sinch Account or other products, responding to your questions, and performing our obligations in relation to credit provided to you;
  2. complying with laws, including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (for identity verification purposes), taxation laws, and other legislation which requires us to collect your personal information.
  3. completing credit checks on you through various third-parties;
  4. either us, a biller or any other service provider appointed by us contacting you about your Sinch Account or your Agreement or regarding repeat purchase promotions, campaigns or for any other special offer/s or promotions;
  5. protecting us and our assets (including against fraud) and selling our assets (including by assigning any debts); and

If you do not provide your personal information to us, we may not be able to approve your application for a Sinch Account or allow you to use our Services and/or we may not be able to deal with future requests or queries from you in connection with this Agreement.

We may collect personal information from you such as your name, address, phone number, email address or other personally identifiable information about you (personal information). We may also collect business information from you such as the registered company name, ABN/ACN, registered company address, business phone number, business email address or other identifiable information about your company (business information).

We collect five categories of information when you use our website:

  1. the personal information you voluntarily provide — that is, we collect personal information with your informed consent;

  2. the business information you voluntarily provide — that is, we collect business information with your informed consent;

  3. the information our software extracts from Invoices sent Sinch;

  4. anonymous non-personal information about how you use our website; and

  5. “cookie” based information that makes your use of our website easier by recording your preferences so that when you return to our website the “cookie” re-loads that information into your web browser.

For example, we will collect personal information from you when you register on our websites, subscribe to our newsletter, respond to a promotional offer, competition or survey or fill out a form related to any customer service feature operating on our websites.

We use electronic software to automatically extract information from Invoices you send to Sinch which we use to provide our services.

We may collect your personal and/or business information from third parties where it is unreasonable or impracticable to collect it directly from you. These third parties include billers, other credit providers, any of your referees, banks, landlords, accountants, lawyers and financial advisers, service providers to us (including introducers, private investigators, professional advisers), professional organisations, internet sources, public and subscriber only databases, and government authorities.

When you become a Sinch customer you will need to provide certain details so that we can establish and manage your Sinch Account.

Once we launch the Sinch portal, and should we provide the functionality to log-in through social media, when you log-in to our website using your Facebook or Twitter log-in (or use any other log-in connected to any other social media platform) you are allowing that social media platform to share your personal information with us (that is, your personal information related to your log-in with that social media platform, which may include your email address and other personal information).

 

2. Why do we need to collect personal information?

We collect personal information to provide our Service to you. The personal and business information collected on our websites will be used to provide the services you have requested, such as setting up and managing your Cashflow Smoothing Plan, direct debiting your Instalments and enabling us to pay business expenses (in the form of Invoices) on your behalf which you send to your us. Your personal and business information may also be used in relation to any survey, promotional offer or any competition you may enter on our websites.

We may disclose information about you, your Sinch Account, or your Cashflow Smoothing Agreement to any third party involved in an actual or proposed assignment, novation or dealing by us, and that disclosure may be in a form that may enable that third party to identify you.

 

3. What information do we collect?

The type of information we collect from you will depend on which services you use. The personal and business information we may collect includes your name, postal address, email address, telephone numbers and contact details and information for identification purposes. If you provide us with details of your business bank account/s (to be used as a method of payment), passport or Medicare card then we will collect those details.

We also collect information from Invoices sent to Sinch, including but not limited to, due dates, amounts, any applicable discounts, and other information which we may use to provide our services.

General information about visits to our websites is collected by our computer servers, with small files (“cookies”) that our websites transfer to your computer’s hard drive through your Web browser (if you allow the delivery of “cookies”). The “cookies” are used to follow the pattern of movements of users by letting us know which pages on our websites are visited, in what order and how often and the previous website visited and to process Invoice payments. The anonymous non-personal information that we collect and analyse is not personal information as described in the Privacy Act.

 

4. Why do we use “cookies” and other web use tracking technologies?

When you access our website, a small file containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your computer. The purpose of sending these files with a unique ID number is so that our website can recognise your computer when you next visit our website. The “cookies” that are shared with your computer can’t be used to discover any personal information such as your name, address, or email address. They merely identify your computer to our websites when you visit us.

We can also log the internet protocol address (IP address) of visitors to our website so that we can work out the countries in which the computers are located.

We collect information using “cookies” and other tracking technologies for the following reasons:

  • to help us monitor the performance of our website so that we can improve the operation of the website and the services we offer;

  • to provide personalised services to each user of our website to make their navigation through our website easier and more rewarding to the user; and

  • when we have permission from the user, to market the services we provide by sending emails that are personalised to what we understand are the interests of the user.

Even if you have given us permission to send you emails, you can, at any time, decide not to receive further emails and will be able to “unsubscribe” from that service.

If you are unhappy about having a cookie sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, some of our services may not function properly.

 

5. How do we store your information?

We use different technologies and procedures to help protect personal information from unauthorized access, loss, alteration, disclosure or use. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal and business information is held in data centres. We also use data encryption when personal and business information is transferred to and from our service providers. Our commitment to data security means:

  • we have procedures to limit access to personal information within our organisation;
  • we use security measures and technologies within our organisation to protect your personal and business information; and
  • we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where bank account information is being transferred.
     

Web traffic information we collect, such as data collected by Google Analytics may be stored overseas. Other information we store on third-party applications may also be stored overseas.

 

6. What use do we make of your personal information?

We will communicate with you in relation to any matters relating to your Cashflow Smoothing Plan and Sinch Account digitally such as through our website and emails.

We may also release your personal and business information when we believe release is appropriate to comply with the law, enforce our subscription agreements, website policies and terms & conditions, or to protect the rights, property, or safety of us or others.

We may disclose your personal and business information (including your credit information and credit eligibility information where permitted by applicable laws) for the purposes described above to any of our related bodies corporate, our assignees or potential assignees, billers, our service providers (including Gobbill), other credit providers, your assignees or proposed assignees, debt collection agencies, our banks and financial advisers, our lawyers, accountants and other professional advisers, any suppliers or contractors to us who may need to have access to your personal and/or business information for the purpose of providing services to us or you, any person specifically authorised by you in writing, and any person as permitted or required by law.

 

7. Marketing products and services to you

We may send you information and updates about any other product, service, or information that we provide to our customers; in addition, we may send you occasional company news and information about other products and services or special promotional offers of our affiliated or partner companies.

If at any time you would like to stop receiving future commercial messages from us, we include detailed unsubscribe instructions at the bottom of each email. You can opt out of us using or disclosing your personal information for direct marketing purposes at any time by contacting us by email [email protected]

If you wish to stop receiving messages from us specifically relating to the management of your Cashflow Smoothing Plan/s, you will need to first close your account with us.

 

8. How can I access and correct the personal information that you collect?

You have the right to request access to and correct the personal information that we hold about you (including credit information and credit eligibility information). Our Privacy Policy contains details about how you can make such requests, as well as information about how you can make a complaint and how we will deal with such a complaint.

In accordance with APP 12, you are allowed to have access to, and correct, the personal information we hold about you.

To access this information, you need to email us using the contact details below. In accordance with APP 13 you may ask us to take reasonable steps to correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

If you believe that your personal information has been misused, you can make an appointment with us to discuss the matter. We take your privacy seriously and therefore we require you to see us in person unless it is unreasonably difficult for you to do so. Please bring photo identification (such as drivers’ licence or passport) with you to the meeting so that we can confirm your identification. To make an appointment for a meeting please contact us at: email: [email protected]

If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC):

Telephone: 1300 363 992
Email: [email protected]

Website (OAIC complaints page): http://www.oaic.gov.au/privacy/privacy-complaints

 

9. Third party links

Our websites may include links to websites operated by third parties. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our websites and welcome any comment about linked websites.

 

10. Web Terms and conditions

Please also visit the terms and conditions governing access to our website at www.cashflowsmoothing.com.au which sets out the conditions of use and limitations of liability governing the use of our website.

 

11. Your consent

By using our website and entering into a Cashflow Smoothing Agreement with us, you consent to this Privacy Policy.

 

12. Changes to our Privacy Policy

If we decide to change this Privacy Policy, we will post those changes on this page, and update the Privacy Policy modification date below.

 

This Privacy Policy was last modified on 31 March 2023