Privacy Policy – Archived 11.11.22
Learn how 91 treats personal data across the websites we operate and services we provide.
Contents
The fine print.
2. What Personal Information do we Collect
3. How Personal Information is Collected
4. Purpose of Collecting, Holding, Using and Disclosing Personal Information
6. Disclosure of Personal Information
7. Cookies and Statistical Analysis
8. Storage & Security of Personal Information
9. Do we Send Personal Information Overseas?
11. Access to, Deletion of and Correction of your Personal Information
NOTE:
- This policy was superseded on 11.11.2022. For current version, please click here.
The fine print.
1. General Information
In this privacy policy, “us”, “we”, “our” or “91” means 91 Holdings Pty Ltd and our related bodies corporate including 91 Pty Ltd, 91 PEO Pty Ltd, 91 Financial Services Pty Ltd and EI R&D Pty Ltd, Webscale Pty Ltd, KeyPay Ltd UK and PensionSync Ltd UK.
At 91, we are committed to safeguarding the privacy of our users’ personal information. This privacy policy applies to all personal information provided to us and all personal information stored on the 91 website at www.employmenthero.com (“EH Website“), web application, mobile applications and 91 functionality, services and content (collectively known as “EH Platform“) owned or operated by us as set out in this privacy policy.
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 collection notices provided to you from time to time.
We may change our privacy policy from time to time by publishing changes to it on the EH Website (which you can visit here). We encourage you to check the EH Website periodically to ensure that you are aware of our current privacy policy.
If the change to our privacy policy is significant and you have an account with us, we will let you know through your account or by email.
2. What Personal Information do we Collect
When used in this policy, the term “personal information” means any information, opinion or data that we collect about an individual where that individual is identified or where that individual is reasonably identifiable. It also includes “personal information”, “personal data” or similar terms as defined in any applicable privacy or data protection laws.
The types of personal information we may collect and hold will vary depending on your dealings with us. This information includes, but is not limited to, the following:
- names and addresses;
- details regarding gender and marital status;
- dates of birth and phone numbers;
- email details;
- remuneration details;
- superannuation details;
- tax information;
- profession, occupation or job title;
- job qualifications and history;
- computer IP addresses; and
- any additional information relating to you that you provide to us directly through our websites or indirectly through use of the Services.
If we are providing you with additional products and services, the types of personal information we may collect may include, without limitation:
- group certificates, payslips, and other income or earnings information;
- proof of identity documentation, such as passports, drivers licenses and birth certificates;
- financial information, including but not limited to, home loans, credit cards, vehicle loans and personal loans;
- utility bills including internet services;
- health and life insurance policy statements;
- information relevant to your lifestyle options including but not limited to, health and fitness information, entertainment services and mobile services;
- information relevant to your financial needs and objectives;
- information relevant to your assets and liabilities, income and expenses;
- information relevant to your investment preferences and attitude or tolerance to risk; and
- any other information provided for the purposes of providing additional products and services.
By providing this information to use, or consenting to a third party (such as your employer) providing that information to us, you consent to our collection and use of that information as set out in this privacy policy.
3. How Personal Information is Collected
We generally collect your personal information directly from you. We do this in ways including:
- by way of dealing with you in person;
- over the telephone;
- through electronic communications including emails;
- through the EH Platform (including details entered upon registration for use of the EH Platform or use of any of the services available through the EH Platform); and
- through customer feedback or survey forms.
We may also collect your personal information from a third party where you have consented to the personal information being provided by the third party (for example, where an employer provides information about employees to the EH Platform for the purpose of using our services, or where personal information is collected by our third party service providers who are permitted to disclose that information to us). We may also collect information from you through our related bodies corporate.
From time to time, you may provide us, and we may collect from you, personal information of a third party (for example, information about employees if you are entering data on behalf on an employer). Where you provide the personal information of a third party, it is your responsibility to ensure that those persons are aware of this privacy policy, understand it and agree to accept it.
4. Purpose of Collecting, Holding, Using and Disclosing Personal Information
The primary purpose for which we collect, hold, use and disclose information about you is to enable us to perform our business activities, functions and services and to provide customer service effectively. We collect, hold, use and disclose your personal information for the following purposes:
- to provide our services and support to you;
- to personalise and customise your experience with our products and services;
- to manage and enhance the EH Platform and our products and services;
- to provide you with information about our existing and new products and services (including for direct marketing purposes as described in section 5 below);
- to share contact details including mobile phone numbers with your employer and co-workers, where your employer has activated this feature and you have not opted out;
- to verify your identity;
- to investigate any complaints about, or made by, you;
- to investigate any suspected breach of any of our terms and conditions or unlawful activity engaged in by you;
- for any purpose we disclose to you at the time of collection; and
- as required or permitted by any law.
In addition, we may use personal information for the following purpose where you request or authorise us:
- to allow third parties to provide additional products and services to you;
If you do not provide us with the personal information described in this policy:
- we may not be able to provide you with information about products and services that you requested;
- we may not be able to provide you with the EH Platform or products or services you requested; and
- we may not be unable to tailor the content of the EH Platform to your preferences and your experience of the EH Platform may therefore not be useful.
Personal information collected for marketing purposes may be communicated to a third party where you have consented to the personal information being provided to the third party (for example by agreeing to provide information for directed marketing, including but not limited to, discounts, offers and promotions).
5. Direct Marketing
We may use personal information for direct marketing reasons, including updating you on our latest products, services and news. These communications may be sent in various forms, including mail, SMS, email or through your account with us, in accordance with applicable marketing laws.
You can opt out of receiving this direct marketing at any time by using any of our unsubscribe mechanisms or by contacting privacy@employmenthero.com.
6. Disclosure of Personal Information
We may disclose your personal information to:
- our employees, related bodies corporate, contractors or external service providers for the purposes of the operation of the EH Platform or our business, fulfilling requests by you, and otherwise providing products and services to you;
- our existing or potential agents, business partners or joint venture entities or partners to enable us to perform our business activities and provide products and services to you;
- specific third parties authorised by you to receive information held by us;
- relevant authorities and institutions including the tax authorities, payroll providers, banks, financial institutions and superannuation providers in connection with the provision of our services or if required by law; and
- the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator if required by law or we consider it necessary for the protection of our systems or for the prevention or detection of illegal activity.
7. Cookies and Statistical Analysis
We use cookies. When you use the EH Platform or any of our services, certain information may be recorded for statistical purposes. Such information enables us to improve our products and services. The information that may be recorded includes information regarding your:
- server address;
- domain name;
- date and time of visit;
- previous websites visited; and
- browser type and operating system; and location data.
More information about the types of cookies we use, why, and how you can control them please read our cookie notice.
8. Storage & Security of Personal Information
To provide the EH Platform and our products and services, 91 contracts with third party suppliers who store data on secure data centres . Further details on our third party storage provider’s location and security
While we take all reasonable steps to ensure the security of our system, we cannot provide any guarantee regarding security of the personal information and other data transmitted to the EH Platform or services and we will not be held responsible for events arising from unauthorised access of your personal information.
9. Do we Send Personal Information Overseas?
Personal information will be mainly hosted on third party servers in the countries as described in section 8 above. However, 91’s related bodies corporate and third party service providers include those based in Australia, United Kingdom, New Zealand, Vietnam and the Philippines. As part of our processes, personal may be accessed or temporarily hosted in those countries.
Where we disclose data overseas, we take measures to ensure your information is treated in accordance with at least the standards that apply in the country whose privacy or data protection laws apply to that personal information (other than when compelled to make disclosure under local laws).
10. Links
The EH Platform may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website. Third party websites are responsible for informing you about their own privacy practices and policies. We encourage you review the privacy policies on any third party websites you visit so that you understand their privacy practices.
Our use of information received from Google APIs will adhere to the , including the Limited Use requirements.
11. Access to, Deletion of and Correction of your Personal Information
If you wish to access, verify or correct any of the personal information you have submitted to us, you may do so by using the available facilities on the EH Platform or by contacting us via privacy@employmenthero.com. We will provide you with access to the information which we hold about you and allow corrections to be made to this information unless an exception under the relevant privacy or data protection laws apply.
Contact us at privacy@employmenthero.com to request deletion of your user account and/or data. As soon as practicable after your request, we will take reasonable steps to delete your information from our systems and will provide your request to any relevant sub-processors. These steps will not include deleting any information stored in our system backups.
Our security procedures mean that we may request proof of identity before we provide you with access to personal information.
12. Complaints and Contact
We recognise that privacy is important and we are committed to protecting your personal information and ensuring it is only used in accordance with our privacy policy. Should you have any questions or you would like to raise a concern or complaint about how we have handled your personal information or our compliance with applicable privacy or data protection laws, please email us at privacy@employmenthero.com.
Once we receive a complaint, whether it is in writing or by verbal means, we will endeavour to commence an investigation as soon as practicable. The investigator will endeavour to determine the nature of the issue and how it occurred. We may contact you during the process to seek any further clarification if necessary. We will also contact you to inform you of the outcome of the investigation and where a breach of this privacy policy or the relevant privacy or data protection laws is found we will discuss your concerns and outline options regarding how they can be resolved.
We will aim to ensure that all questions and concerns are resolved in a timely and appropriate manner.
If you are not satisfied with the outcome of your complaint, or require further information on privacy, you are entitled to contact the relevant privacy or data protection regulator in your jurisdiction.
