Privacy Policy

1. About Beforepay

If you do not give, or withdraw or opt-out of your consent to the above, we will be unable to offer, or to continue to provide, our products or services to you.

‘Addendum 1 Additional information for individuals in the UK/EEA details the legal basis for the collection and use of personal information for individuals based on the UK/EEA.

5. How do we collect personal information?

We may collect your personal information either directly from you, or indirectly from third parties or our clients. We may collect this information when you:

• create an account with Beforepay via our mobile application or website and access or use our financial products and services, including our budgeting and expense tools;
• use our websites to understand our products, contacting us or accessing our blog articles;
• use the services offered by one or more of our clients that use our AI-powered credit decisioning and lending solutions and share your personal information with us;
• register to receive emails about our products, services and events.

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.

6. Identity Verification and Use of the Document Verification Service (DVS)

We may use the Australian Government’s Document Verification Service (DVS) to verify your identity using identification information you provide (such as driver licence, passport or other government-issued identification).

6.1 Your consent

By agreeing to identity verification, you provide your express consent to Beforepay to:

• collect, use and disclose your identification information for the purpose of verifying your
  identity;
• submit your identification information to the DVS;
• receive and use the results of that verification; and
• use third-party systems and service providers, such as FrankieOne or independent
  contractors, involved in the DVS process.

6.2 Consequences of declining consent

If you do not consent to identity verification using the DVS:

• we may be unable to verify your identity;
• you may not be able to create an account or access Beforepay products and services;
  and
• we may not be able to continue providing services to you where identity verification is
  required by law.

6.3 Further information about the DVS

The DVS is operated by the Australian Government. You can find more information about:

• how the DVS works; and
• how your information is handled

on the Australian Government’s website: https://www.idmatch.gov.au/
‍
You can also contact us using the details in this Privacy Policy, if you would like more
information about how we use the DVS.

6.4 Your rights and complaints regarding DVS information

You have the right to:

• request access to your personal information;
  
• request correction of inaccurate information; and
• make a complaint about how your personal information has been handled.

Information about how to make a complaint is set out in Section 17 of this Policy.

7. Automated decision-making

Data collected About You:

• We may use automated decision-making tools and models to assess whether your application meets our eligibility criteria, including information collected during your application process, such as your personal identifiers, financial transaction information, sensitive information, information about your circumstances, and behavioural information.

Creditworthiness Score:

• We may calculate an internal creditworthiness score for you, based on our automated mathematical-statistical modelling and risk criteria to assess the creditworthiness of our customers. This automated decision-making process occurs at a point in time, and may consider the data collected above, as well as how you have historically used our products, your repayments history and any prior defaults on payment (if applicable).

Automated Decision-Making:

• When you apply for a Beforepay product or service, we may decide, based on our risk appetite at that moment in time, our responsible lending obligations and based on the data collected as described above, if you are eligible for the product.
• The specific circumstances related to your application or your personal or financial situation may lead to an automated decision that you are not eligible for a Beforepay product or service.

If you do not give, or withdraw or opt-out of your consent to our automated decision making processes, we will be unable to offer or to continue to provide our products or services to you.

8. Why do we collect your personal information

Beforepay only collects your personal information to provide our products and services to you, including to enable us to verify your identity and details so we can provide our service to you, where it is otherwise reasonably necessary for our business activities (including those business activities described in this Privacy Policy), for any required regulatory or legal disclosure, any other purpose you have consented to and any other purpose permitted under the Privacy Act and APPs.

We may enter into arrangements with related body corporates and/or third parties to enrich data and produce insights for our partners or for the general public. Any insights are aggregated, anonymised information. No personally identifiable information is shared.

If you do not provide your information to us, your application for a product or service may be denied, and we may not be able to respond to your requests, personalise your experience with us, or let you know about other products or services that might better meet your needs.

9. How do we use your personal information?

Beforepay only uses your personal information for the purpose for which it has been provided, where it is otherwise reasonably necessary for our business activities, any other purpose you have consented to and any other purpose permitted under the Privacy Act and APPs. This may include using your personal information for the following purposes:

• to enable you to access and use our products and services;
• to be used for identity verification purposes, which may involve the use of third-party systems;
• to operate, protect, improve and optimise our website, app, 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; and
• to comply with our legal and regulatory obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
• to consider you for a position with Beforepay for which you have applied;
• to acquire goods or services from you or from your employer;
• to create aggregated, anonymized insights for our partners or for the general public, without sharing any personally identifiable information;
• to merge, contribute to, and enrich datasets of Beforepay, third parties, or partners to create insights and services;
• for other purposes for which you have consented;
• as required or permitted by relevant laws and regulations; and
• for statistical and analytical purposes to enhance the products and services offered by Beforepay, partners, and/or third parties, including comparative data.

By agreeing to our Privacy Policy, you agree that we may use your personal information for the purposes for which we collect it and for related purposes which would be reasonably expected of you.

10. Do we use your personal information for direct marketing?

From time to time, we and/or our carefully selected business partners may send you direct marketing communications and information about our products and services that we think may be of interest and value to you.

This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth), Privacy Act and APPs. By providing us with your personal information, you consent to us and our business partners using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS and telephone.

If you do not wish to receive direct marketing communications from us, you may opt-out by contacting us using the details at the bottom of this page or by using the opt-out facilities provided in the relevant communication (e.g., an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• your agents;
• existing or potential third party suppliers and service providers, including providers for the operation of our websites and/or our business or in connection with providing our products and services to you, provided that any potential third parties suppliers and service providers agree that they will keep the information confidential and comply with privacy laws in relation to any data provided by Beforepay;
• professional advisers, dealers and agents;
• payment systems operators (e.g. merchants receiving card payments);
• anyone to whom our assets or businesses (or any part of them) are transferred;
• Beforepay related body corporates and/or third parties we have entered into a commercial relationship with to share data in order to produce insights as part of our business activities, provided that the related body corporate and/or third parties agree that they will keep the information confidential and comply with privacy laws in relation to any data provided by Beforepay;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
• our employees and related bodies corporate;

We may also disclose your personal information to a trusted third party who also holds other information about you, for example where our third party providers provide data aggregation services or identity verification services for which you are a customer. 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.

We will only disclose your personal information with third parties as described in this Privacy Policy or as otherwise notified to you at the time of collection or with your consent.

11. Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to our partners and third party service providers located in the Philippines, Sri Lanka, India, Serbia, Ukraine, Germany, Canada, Bangladesh, US and the UK. When we disclose your personal information overseas, we will take all reasonable steps to ensure that your personal information is held, managed and accessed in accordance with appropriate standards for the handling of personal information.

12. Cookies and third party analytics services

We use ‘cookies’ or other similar tracking technologies on our website to help us improve our products and services and enhance your user experience. When you access our website or use our products and services, we and/or our third party service providers place small files on your computer, mobile or other device that store information about your internet browsing activity. We use cookies to ascertain which web pages are visited and how often, to make our website more user friendly, to give you a better experience when you return to our website and to target advertising to you that we think you may be interested in.

You can disable cookies through your internet browser unless they are required to prevent fraud or ensure the security of our website. If you decline our cookies, our website and products and services may not work as intended for you.

In addition to using cookies or other similar tracking technologies, we may also use third party analytics services to measure and analyse the effectiveness of our marketing campaigns, assess risk, optimise experiences, and understand usage.

We handle any personal information collected by cookies, other similar tracking technologies or third party analytics services in the same way that we handle all other personal information in accordance with this Privacy Policy.

*Addendum 1: Additional information for individuals in the UK/EU’ to this Policy details the types of cookies we may collect from individuals based in the UK/EU.

13. Security, sharing, and storage of personal information

We are regularly audited to confirm we remain compliant with our security certifications, including ISO270001. As part of these audits, our security is validated by external auditors.

We may hold your personal information in cloud or other types of networked or electronic storage with trusted third party services providers. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be accessed.

We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. We use a number of physical, administrative, personnel and technical measures to protect your personal information.

Measures we take to protect your personal information include:

• using appropriate information technology and processes;
• restricting access to your personal information to our employees and those who perform services for us who need your personal information to do what we have engaged them to do;
• using computer and network security systems with appropriate firewalls, encryption technology and passwords for the protection of electronic files; and
• securely destroying or “de-identifying” personal information if we no longer require it subject to our legal obligations to keep some information for certain prescribed periods.

We do our best to protect the security of your personal information.

14. Data retention

We will keep your personal information for as long as we have a relationship with you and for 7 years or otherwise as required for our business operations or by applicable laws.

We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and for proper record keeping.

We may also retain a record of any stated objection by you to receiving marketing for the purpose of ensuring we can continue to respect your wishes and not contact you further.

15. Links

Our website, apps, and platforms 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 or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage you to read them before using those websites.

16. Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the details at the bottom of this page. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, incomplete or out-of-date please contact us and we will take reasonable steps to ensure that it is corrected and/or updated. We will generally rely on you to assist us in informing us if the personal information we hold about you is inaccurate, incomplete or out-of-date.

17. Making a complaint and correcting your information

If you think we have breached the Privacy Act or the APPs, or you wish to make a complaint about how we have handled your personal information, you can contact us using the details at the bottom of this page.

If you believe we have not resolved your complaint satisfactorily, you can lodge a complaint through:

• The Office of the Australian Information Commissioner (OAIC), if your complaint is about privacy; or
• The Australian Financial Complaints Authority (AFCA), if your complaint relates to the regulated consumer credit provided by BPG Credit Pty Ltd only (for example, a Personal Loan Agreement). AFCA does not review complaints about our Pay Advance product, but we will work with you directly to resolve any issues fairly and transparently.

Office of the Australian Information Commissioner (OAIC)
Visit: www.oaic.gov.au
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Mail: GPO Box 5218, Sydney NSW 2001

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

18. Referral program

Beforepay allows users to invite friends and family to sign up for its products and services. Sometimes we offer a promotional value for every friend or family member who signs up through your referral link or code. To help you do this, we may request you to grant us access to your mobile device address book. You can then direct us to send referral messages to contacts you select in your address book.

By sending a referral, you also consent to Beforepay sending your public profile image to the contacts you select to receive a referral link. By choosing to invite a friend you represent that you have received the friend’s consent to provide their email address and/or phone number with us.

Beforepay will use that information to send an email inviting him or her to visit the site and will store that information to track the success of the referral program and may send marketing emails. You can also send an SMS with a referral link or code to your contacts. If you use this option, you understand that Beforepay does not control the timing, content, or recipients of these SMS messages.

Users may not send, publish, or share any false, misleading, or deceptive communications in connection with participation in the Referral Program. Users may not send any referral emails, SMS messages, or other communications to persons under the age of 18.

If you are referred to Beforepay through one of our referral programs, or if someone attempts to refer you, we may contact you using the details provided to us, whether you have already signed up for Beforepay or not.

19. For more information

If you have any questions or would like us to use your data in a more limited way than described in this Privacy Policy, please contact us at privacy@beforepay.com.au.

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Beforepay Group Limited (formerly Cheq Limited)
Email: privacy@beforepay.com.au
‍Mail: Suite 1.09, 77 Castlereagh Street, Sydney NSW 2000

Addendum 1: Additional information for individuals in the UK/EU

1. Legal basis for collection and use of your personal information as a Data Controller

‍For UK or European Economic Area (EEA) residents, we describe our legal justifications (commonly referred to as “legal basis”) for the collection and use of your personal information.

• Based on our contract with our clients:

We may collect your personal information to provide our services to our clients, and to meet our responsibilities under the applicable contracts that we have in place with our clients. Generally, if we cannot obtain the necessary personal information from you in this context, we may not be able to provide our client with our products and services.

• Based on your prior consent (where permitted or required by law):
• We may also use your personal information to resolve any issues that our clients may have with our products or services.

We may use your personal information in the context of marketing and sales to propose similar offers or inform you about upcoming products and send newsletters. From time to time, we and/or our carefully selected business partners may send you direct marketing communications and information about our products and services that we think may be of interest and value to you. By providing us with your personal information, you consent to us and our business partners using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS and telephone.

• If you share your contact details with us, e.g by completing the “Contact Us” form on our website or sharing them with a Beforepay representative at an event, we will process your personal information to register your details and contact you based on your request, which is in our legitimate interest.
• When you interact with our websites or use our products and services, we collect and use ‘cookies’ or other similar tracking technologies on our website to help us improve our services and enhance your experience. The cookies management and consent process is described in Section 4 below.
• If you interact with us on our social media pages, we will process your personal information as joint controllers with the social media provider and to respond to your request and record the interaction. This is our legitimate interest, to ensure that we respond to your demands and feedback and improve our product and service offerings.

Promoting the security of our services

• We use your Personal Data to monitor the use of our websites and services, verifying accounts and user activity, investigating suspicious activity, and enforcing our information security policies. We carry out these activities pursuing our legitimate interest in promoting the security of the services, websites, systems, applications and premises, and in protecting our rights and the rights of others.

To comply with our legal obligations and for legal and administrative purposes

• To comply with our legal and regulatory obligations and for legal and administrative purposes such as, verifying and processing payment, screening against fraud, money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, and for understanding, exercising, enforcing or protecting our legal rights and those of others.

2. UK or EEA Privacy Rights

Subject to applicable law, you have the right to:

• Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed,
• Request that inaccurate personal information is corrected,
• Request us to restrict the processing of personal information where the processing is inappropriate,
• Object to the processing of personal information,
• Request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means, and
• File complaints with data protection authorities in your respective country if you believe your data rights have been violated.
• Request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements,
• Not to be subject to a decision based solely on automated processing which significantly affect you, unless you have explicitly given consent, or the automated processing is necessary under your contract with us,

3. Cookies

Types of cookies used by Beforepay:

• Strictly Necessary Cookies
  Strictly Necessary Cookies are required to enable the basic features of our websites, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
• Functional Cookies
  Functional Cookies enable us to analyse the use of the website in order to measure and improve performance. Functional Cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.
• Analytics Cookies
  Analytical Cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
• Performance Cookies
  Performance Cookies are used to understand and analyse the key performance indexes of the website which helps in delivering a better user experience for the visitors.
• Advertisement Cookies
  Advertisement Cookies are used to provide visitors with customised advertisements based on the pages you visited previously and to analyse the effectiveness of the ad campaigns
• Uncategorised Cookies
  Other Uncategorised Cookies are those that are being analysed and have not been classified into a category as yet.
• Other Tracking Technologies
  When you use third-party web-based software, websites or mobile apps, the technology may involve certain built-in tracking technologies. This can include:
• Tracking Pixels
  Our website uses Google, LinkedIn and Facebook Pixel Tags which we may include an image in our communications with you. This may allow us to understand when you read electronic communications we send you, deliver more accurate and relevant content, and improve our communications to you. When using this technology, we may receive aggregated or anonymised information.

• In certain cases, we may collect Personal Information from you, for example:
• • Location data (such as city, region and where you opened your email);
  • Your IP address;
  • Browser and device information: for example, your mobile or desktop operating system (OS), type of email software, device, and user agent; or
  • The date and time you open our electronic communications.

You can disable cookies through your internet browser unless they are required to prevent fraud or ensure the security of our website. If you decline our cookies, our website and products and services may not work as intended for you. We handle any personal information collected by cookies, other similar tracking technologies or third party analytics services, in the same way that we handle all other personal information in accordance with this Privacy Policy.

Addendum 2: Additional information for individuals residing in California

Under Californian law, residents of the American state of California have specific rights regarding their personal information. If you are a California resident, this section applies to you, in addition to the rest of the Privacy Policy. It provides more detail on how we collect, use and share the personal information of California residents in operating our business, and their rights with respect to that personal information.

For the purposes of this section, Personal Information has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), as further amended by the California Privacy Rights Act (“CPRA”).

However, this section does not apply to:

• Information exempted from the scope of the CCPA/CPR,
• Personal Information processed by advertising vendors on our website through the use of cookies.
• Personal Information we collect, use, and share on behalf of our customers as a “service provider” under the CCPA for the purposes of providing our Services to them; or

1. Collection of Information

• We may use automated decision-making tools to determine your creditworthiness or eligibility for a Beforepay product or service.
• Our automated decision-making process may automatically reject your application for a product or service. If this happens, you will have an opportunity to provide further information and challenge the decision through a manual review. In any case, if you feel that an automated process may have impacted you, please contact our Customer Support.
• Beforepay and third parties may collect information from you automatically as you access or apply for a product or service. This may include use of cookies and other technologies to keep track of your interactions with the product or service, to serve you with ads on other online services, and to offer you a more personalized and relevant experience.
• The information Beforepay receives via the product or service may be combined with information Beforepay receives from third parties and sources outside of the product or service.
• Beforepay obtains your consent (e.g., opt-in, opt-out), however, before knowingly sharing Personally Identifiable Information with third parties (other than Beforepay affiliates) for their own direct marketing purposes.
• Beforepay may share your non-Personally Identifiable Information, aggregate and/or de-identified information about you except as prohibited by applicable law.
• Beforepay may ask you to provide Personal Information (e.g., name, address, e-mail, phone number, etc.), including sensitive personal information (e.g., financial transaction information, government identifiers, behavioural information, etc.), which may be required for us to determine your creditworthiness or eligibility for a Beforepay product or service.

In particular, we do not:

• sell any personal information from individuals located in California;
• share any such personal information with third parties for their own commercial benefits; or
• discriminate against you in any manner.

2. California Privacy Rights

In addition to the above mentioned rights, under California law you have the right to (subject to legal restrictions):

• be provided with a timely notice, at or before the point of data collection, about the categories of personal information to be collected from you, and the purposes for which the personal information is collected or used, and whether that information is sold or shared;
• request that we delete all of your personal information collected from you;
• opt-out of the “sharing” of your personal information for cross-context behavioural advertising;
• all personal information that is collected from you be treated in accordance with this policy, including the use of different categories of your personal data that has been collected from you, and the disclosure of your personal information.
• request access to/disclosure of the personal information (that is, disclosure of our collection and use of your personal information) over the past 12 months from the date we receive the request;

3. Exercising Your rights as a California Resident

We use services that employ cookies and other technologies to collect personal information (including identifiers and internet activity information) about your use of our websites and other online services over time, which helps us to deliver targeted ads. In addition, we may share your contact details with our advertising vendors for the placement of targeted ads. Our use of some of these services may constitute the “sale” or “sharing” of personal information as defined under the CCPA to/with third party advertisers. You may opt-out of such sales or sharing at any time.

4. Children’s Privacy

The service is intended for a general audience and not directed to children less than 13 years of age. We do not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.