Privacy Statement​

1. About this statement
Humbli Pty Ltd (“Humbli”, “we”, “us”, “our”) is committed to protecting the privacy of individuals. This Privacy Statement explains how we handle personal information and comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

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Importantly, our services do not require or involve the collection of personal information. In providing our services to our clients, we do not request or collect personal information about individuals. We may, in limited and incidental circumstances, receive personal information, and this Statement explains how we handle it in those circumstances.

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A copy of the APPs is available from the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

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2. About Humbli
Humbli is a business-to-business provider of financial difficulty intelligence and customer-care solutions. We work with financial institutions, regulators and governments to help improve how financial difficulty, including hardship and vulnerability, is understood, managed and supported. The information and data we handle is generally commercial in nature and does not identify individuals.

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3. Personal and sensitive information
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Sensitive information is a special category of personal information (for example, health information, or information about racial or ethnic origin, religious beliefs or criminal record) that has additional protections under the Privacy Act. It is unlikely that we will collect sensitive information; if we do, we will only collect it with your consent, unless an exception under the Privacy Act applies.

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4. When we may collect personal information
Because our services do not involve collecting personal information, the circumstances in which we may receive it are limited and incidental. They may include, but are not limited to:

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• The names and business contact details of individuals who enquire through our website or interact with us in the course of business dealings;

• Applications for employment with Humbli, including the information contained in an application;

• Where we are the recipient of personal information due to a mistake or oversight by one of our clients; and

• Contact details collected at Humbli events.

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We only collect personal information by lawful and fair means and, where reasonable and practicable, directly from the individual concerned.

 

5. How we use personal information
Where we hold personal information, we use it for the purpose for which it was provided, for example to respond to an enquiry, manage a business relationship, consider a job application, or comply with our legal obligations. We will only use or disclose it for another purpose where you would reasonably expect us to, where you have consented, or where otherwise permitted under the Privacy Act.

 

5.1 Automated decision-making
We do not use personal information to make, or to substantially assist in making, automated decisions that could reasonably be expected to significantly affect an individual’s rights or interests. If we introduce any such automated decision-making in future, we will update this Statement to describe the personal information used and the kinds of decisions made, consistent with the Privacy Act.

 

5.2 Direct marketing
We do not currently undertake direct marketing. If we do so in future, we will comply with the APPs, including by providing a simple means to opt out of receiving direct marketing communications.

 

6. Anonymity and pseudonymity
Where it is lawful and practicable to do so, you have the option of dealing with us anonymously or by using a pseudonym. This may not be practicable where we need identifying information to respond to you or to meet a legal obligation.

 

7. Who we may disclose personal information to
We do not sell personal information, and we do not disclose an individual’s personal information except in accordance with this Statement. Where relevant, we may disclose personal information to:

 

• Service providers who help us operate our business (for example IT and cloud providers), who are required to keep it confidential;

• Our professional advisers, such as legal advisers, accountants and auditors;

• Referees, as part of an employment application;

• A purchaser in connection with a sale of our business or assets; and

• Regulators, government agencies and law enforcement bodies where required or authorised by law.

 

8. Overseas disclosure
We may store personal information with service providers located outside Australia (for example, cloud and data-storage providers). Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure the recipient handles it in a manner consistent with the APPs, except where an exception under the Privacy Act applies.

 

9. How we protect personal information
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include access controls, multi-factor authentication, encryption, and confidentiality obligations on our people. When personal information is no longer needed and we are not required by law to retain it, we take reasonable steps to destroy or de-identify it.

 

10. Accessing and correcting your personal information
You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, please contact us using the details below. We may need to verify your identity before providing access. We do not charge a fee for making a request and we will not impose excessive charges. We will respond within a reasonable period. In some circumstances we may be unable to provide access or make a correction (for example, where doing so would affect another person’s privacy or where we are prevented by law); if so, we will tell you why and how you can complain.

 

11. Data breaches
If we become aware of a data breach, we assess whether it is an eligible data breach that is likely to result in serious harm. Where it is, we notify the OAIC and affected individuals as soon as practicable, in accordance with the Notifiable Data Breaches scheme under the Privacy Act.

 

12. Complaints and how to contact us
If you have a question or complaint about your privacy or this Statement, please contact our Privacy Officer at info@humbli-insights.com. We will acknowledge your complaint and work with you to resolve it. If you are not satisfied with our response, you may contact the OAIC:

 

• Website: www.oaic.gov.au

• Email: enquiries@oaic.gov.au

• Phone: 1300 363 992

• Post: GPO Box 5218, Sydney NSW 2001

 

13. Changes to this statement
This Statement sets out our current approach to managing our privacy obligations and replaces all previous Humbli privacy statements. We may update it from time to time by publishing the updated version on our website, and we encourage you to review it periodically.

 

14. Definitions
In this Statement, the following terms have the meanings set out below: