Bamboo investments App

Privacy Policy

Privacy Policy

Bamboo 61 Pty Ltd (“Bamboo”, “we”, “our”, “us”) are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) in Australia.

This Privacy Policy describes our policies and practices in relation to how we collect, store, use and disclose your personal information. It also explains how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

Collection of your personal information

‘Personal information’ means any information about you, from which your identity is apparent or can be uncovered.

To use our mobile application, you must create an account. When you create ana ccount, we will ask you for your name, email address, mobile phone number and a password. We use third party service providers to connect to your bank account(s) and to establish a direct debit facility. You will need to provide your bank account details to our third party service provider.

We never see or store your bank account details. Our website can be viewed without providing personal information, other than your IP address.

How we collect your personal information

Generally, we collect your personal information directly from you, when you set up an account with us, and when you use our mobile application and/or website. We may also collect information from other service providers (including marketing, software and IT providers) who help us to provide our services.

How we use your personal information

The main purpose for which we collect, hold, use and disclose your personal information is to provide asset acquisition and management services through our mobile application and to operate our website.

Other purposes include to:

  • Provide our services, manage your ongoing requirements and our ongoing relationship with you;
  • Undertake research that will assist us to improve our mobile application and website, and develop our services;
  • Perform internal functions such as administration, accounting and information technology system requirements;
  • Comply with legal and regulatory requirements and prevent fraud or crime; and
  • Refer you to other businesses whose services may be of interest to you.

We may also send you offers, updates, articles, newsletters or other information about our services and other products and services that we believe will be of interest to you. You may opt out of this at any time by getting in contact with us.

We will communicate with you by email or sms, unless you tell us that you do not wish to receive communications in that manner.

Electronic Fund Transfers (EFTs) and Account Balances

Bamboo partners with financial services software company Sila Inc. (Sila) and banking services provider Evolve Bank & Trust (Evolve), member FDIC, to offer you electronic fund transfers (EFTs). When you create a Bamboo account, link a bank account, or initiate an EFT, you are authorizing us to share your identity and banking information with Sila and Evolve to support your account. You are also agreeing to the terms of Sila’s privacy policy, Evolve’s privacy policy, and Evolve’s communications consent and disclosure (the “Partner Terms”). It is your responsibility to make sure the data you provide us is accurate and complete, which is necessary for our partners to process EFTs on your behalf. The Partner Terms may be modified from time to time, and the governing versions are incorporated by reference into this Privacy Policy. Any term not defined in this section but defined in the Partner Terms assumes the meaning as defined in the Partner Terms. IT IS YOUR RESPONSIBILITY TO READ AND UNDERSTAND THE PARTNER TERMS BECAUSE THEY CONTAIN TERMS AND CONDITIONS CONCERNING YOUR BAMBOO ACCOUNT, INCLUDING BUT NOT LIMITED TO USE OF YOUR PERSONAL INFORMATION.

Disclosure of your personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors in so far as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Bamboo, https://getbamboo.io/, its customers, related entities, or third parties.

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia and Switzerland.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality.

We would seek to only disclose information in good faith and where required by any of the above circumstances.

By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

Sharing your personal information

We may disclose your personal information to:

  • Our agents and contractors who supply services to us e.g. software providers, IT services and hosting, data storage providers, marketing, administration services, compliance consultants and auditors
  • Other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event
  • Regulatory bodies, government agencies or law enforcement bodies
  • Anyone who refers you to us or who you refer to us, and
  • Others, if we are permitted to or required to do so by law.

We do not sell, trade, licence or rent your personal information.

Disclosing your personal information overseas

If we disclose your information to any businesses who are located overseas, we will ensure that either they are subject to equivalent or better privacy regulatory regimes as Australia, or that they have agreed to provide equivalent or better protection of your personal information as is required in Australia.

California Privacy Rights

If you are a resident of the State of California, under the California Consumer Privacy Act (CCPA), you have the right to request information on how to exercise your disclosure choice options from companies conducting business in California. Specifically:

  • Exercising the Right to Know. You may request, up to twice in a 12-month period, the following about the personal information collected on you in the past 12 months:

    • the categories and specific pieces of personal information we have collected;
    • the categories of sources from which we collected the personal information;
    • the business or commercial purpose for which we collected it;
    • the categories of third parties with whom we shared the personal information; and
    • the categories of personal information about you that we disclosed for a business purpose.
  • Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.

  • Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place.

  • Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, you may contact Bamboo either via email to privacy@getbamboo.io or contact us via postal mail, proper postage prepaid, at:

Bamboo

Attn: Your California Privacy Rights

701 Brazos Street Austin, TX 78701

Please indicate your preference as to how you would like us to respond to your request (i.e., email or postal mail). All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or postcard and clearly stated on the actual request. For all requests, please include your name, street address (if you would like a response via postal mail), city, state, and zip code. We may need to verify your identity before responding to your request, such as verifying that the email address or contact information from which you send the request matches your email address or contact information that we have on file. Authentication based on a government-issued and valid identification document may be required. We will not accept requests via telephone or fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

How our website and mobile application manage your personal information

Website and mobile application When you use our website and mobile application, we use applications such as Google Analytics and Amazon Web Services to collect information including, but not limited to your IP address, browser type, version and language, operating system, pages viewed, page access times and referring website address. This information is used internally to gauge visitor traffic, usage trends, site speed, to deliver personalised content to you and to make informed decisions regarding marketing and performance optimization.

Emails We and our service providers use email analytics to show us how recipients interact with our emails, e.g. whether you have read or clicked on the communications.

Third party links Our website and mobile application may contain links to sites operated by other parties. Those parties, their agents or other companies working for them may use technology that automatically collects your IP address or such as cookies or JavaScript to personalise the content of, and to measure the performance of their links. We do not have control over these technologies or the data that these parties obtain. Accordingly, this Privacy Policy does not cover the information practices of these third parties.

We will not identify users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through analytic tools.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in this notice. If our information practices change at some time in the future, we will only use data collected from the time of the policy change forward for these new purposes.

How do we store and protect your personal information?

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements. This will be for as long as you are a customer of ours and may be for 10 years after that to comply with legal requirements and to ensure clarification of any questions after the end of our relationship.

We hold the information we collect from you in physical and electronic records, which may be stored at our premises or those of our service providers, or in secure data centres or in the cloud.

We strive to ensure that your information is safe by using a range of physical and electronic security measures to protect it from misuse, interference, loss, unauthorised access, modification or disclosure.

Changes to this Privacy Policy

Please be aware that we may change this policy in the future. We may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website.

Accessing your personal information

You have a right to:

  • Request access your personal information and to ask us to correct or erase it, subject to exceptions allowed by law
  • Ask us to restrict the way we manage your personal information (for example if you dispute the correctness of the information)
  • Request that we transfer your data to another entity, and
  • Object to us managing your personal information at any time (e.g., you can withdraw any consent you have given us to manage your personal information). This does not invalidate the legality of our management of your personal information before your consent is withdrawn).

For security reasons, we may require you to put your request in writing. We reserve the right to charge a fee for each request to search for and provide access to your information.

We will correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.

In some limited cases, we may need to refuse you access to your information or a request for correction. If this is the case, we will advise you as soon as possible after your request and let you know the reasons for our refusal.

Making a complaint

If you have any concerns about our compliance with the privacy laws or this Privacy Policy, please write to us at privacy@getbamboo.io. We will aim to respond with a decision within 30 days of your complaint.

If your complaint reasonably requires us to contact some other person, we may need to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and, if we do, what that information is.

If your complaint is not resolved, you may refer your complaint to an independent complaints body. Relevant details are listed below.

Australia
Office of the Australian Information Commissioner
Website: https://www.oic.wa.gov.au/en-au/
Email: enquiries@oaic.gov.au
Tel: 1300 363 992

Contacting Us

We welcome your comments regarding this Privacy Policy. If you have any questions about this Privacy Policy and would like further information, please contact our Privacy Officer by email at privacy@getbamboo.io.

Bamboo 61 Pty Ltd
ABN 86 626 100 981
G/45 St Georges Terrace, Perth
6000, Australia

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